Lead & Copper Rule

Lead Service Line Priority Project Cover Letter

Drinking Water State Revolving Fund Project Priority List Survey

COPPER

A small amount of copper is essential for good health. The Food and Drug Administration recommends a dietary allowance of 2 milligrams (mg) of copper a day. Major food sources of copper are shellfish, nuts, grains, leafy vegetables, mushrooms, chocolate, liver, and some fruits. Exposure to high doses of copper can cause health problems. Short-term exposure to high levels of copper can cause gastrointestinal distress. Long-term exposure and severe cases of copper poisoning can cause anemia and disrupt liver and kidney functions. While some of the copper you consume rapidly enters the bloodstream, your body is very good at preventing high levels of copper from entering the bloodstream; it will excrete excess copper after several days. Individuals with Wilson’s or Menke’s disease (genetic disorders resulting in abnormal copper absorption and metabolism) are at higher risk from copper exposure than the general public.

LEAD

Lead is a toxic metal that can be harmful to human health even at low exposure levels. Lead is persistent, and it can bioaccumulate in the body over time.

Young children, infants, and fetuses are particularly vulnerable to lead because the physical and behavioral effects of lead occur at lower exposure levels in children than in adults. A dose of lead that would have little effect on an adult can have a significant effect on a child. In children, low levels of exposure have been linked to damage to the central and peripheral nervous system, learning disabilities, shorter stature, impaired hearing, and impaired formation and function of blood cells.

It is important to recognize all the ways a child can be exposed to lead. Children are exposed to lead in paint, dust, soil, air, and food, as well as drinking water. If the level of lead in a child's blood is at or above the CDC action level of 5 micrograms per deciliter, it may be due to lead exposures from a combination of sources. EPA estimates that drinking water can make up 20 percent or more of a person’s total exposure to lead. Infants who consume mostly mixed formula can receive 40 percent to 60 percent of their exposure to lead from drinking water.

Pregnant Women

Lead can accumulate in our bodies over time, where it is stored in bones along with calcium. During pregnancy, lead is released from bones as maternal calcium and is used to help form the bones of the fetus. This is particularly true if a woman does not have enough dietary calcium. Lead can also cross the placental barrier exposing the fetus to lead. This can result in serious effects to the mother and her developing fetus, including:

• Reduced growth of the fetus
• Premature birth

Find out more about lead's effects on pregnancy:

• Effects of Workplace Hazards on Female Reproductive Health (National Institute for Occupational Safety and Health)

Lead can also be transmitted through breast milk. Read more on lead exposure in pregnancy and lactating women (PDF) (302 pp, 4.3 MB, About PDF).

Adults

Lead is also harmful to adults. Adults exposed to lead can suffer from:

• Cardiovascular effects, increased blood pressure and incidence of hypertension
• Decreased kidney function
• Reproductive problems (in both men and women)

Related Information

• Learn more about lead and its health effects

Can I shower in lead-contaminated water?
Yes. Bathing and showering should be safe for you and your children, even if the water contains lead over EPA’s action level. Human skin does not absorb lead in water.

This information applies to most situations and to a large majority of the population, but individual circumstances may vary. Some situations, such as cases involving highly corrosive water, may require additional recommendations or more stringent actions. Your local water authority is a valuable resource for testing and identifying lead contamination in your tap water. Many public water authorities have websites that include data on drinking water quality, including results of lead testing. Links to such data can be found on the EPA Consumer Confidence Report website.

Lead and copper are unusual among drinking water contaminants in that they seldom occur naturally in water supplies like rivers and lakes. Lead and copper enter drinking water primarily as a result of the corrosion, or wearing away, of materials containing lead and/or copper in the water distribution system and facility/residential plumbing. These materials include lead-based solder used to join copper pipe, brass and chrome-plated brass faucets, and in some cases, pipes made of lead that connect facilities to water mains (service lines). In 1986, Congress banned the use of lead solder containing greater than 0.2% lead, and restricted the lead content of faucets, pipes and other plumbing materials to 8.0%. In 2011, the Reduction of Lead in Drinking Water Act further reduced the allowable lead content in water-bearing materials with a new definition of “lead-free” products. The new definition of “lead-free” is a weighted average of 0.25% lead calculated across the wetted surfaces of a pipe, pipe fitting, and fixture and 0.2% lead for solder and flux.

When water is stagnant in lead pipes or plumbing systems containing lead and copper for several hours or more, the lead and copper may leach into the drinking water. Facilities that are seasonal such as schools can be particular susceptible to higher lead concentrations due to their extended periods of no water use (e.g. holidays, weekends, and winter/spring/summer breaks).

• For Public Water Systems (PWS)

  PWSs should have an understanding of their water chemistry and how it will interact the distribution system plumbing.

  Customers

  Customers should learn about the water they are receiving from their local water supply utility. This can be done by reading the annual consumer confidence report (CCR) which is prepared by all community water systems. Customers can also perform the following activities which will minimize your potential exposure to lead and copper in your drinking water.

  • Use only cold water for drinking and cooking. Hot water can be more corrosive than cold water.
  • Flushing your water system after any extended period of non-use like vacations. Flushing is an easy and effective way of reducing the potential of lead and copper exposure in your drinking water. Flush each faucet or fixture that is used for drinking and food preparation for a couple minutes prior to use.
  • Routine inspection of your plumbing system for signs of corrosion. Corrosion can be caused by a number of things such as dissimilar materials (copper pipe connected to brass fitting) and electrical grounding (electrical system being ground to copper pipe).
  • Routine inspection of faucet aerators. Check your aerators on a regular basis. The aerator is located at the end of the faucet and should be able to unscrew. Particulates can collect in the aerator, reducing your flow and increasing potential for lead and copper exposure.

For detailed information for how to maintain compliance with the Lead & Copper Rule see the EPA document Lead and Copper Monitoring and Reporting Guidance for Public Water Systems.

The Lead & Copper Rule applies to Community and Non Transient/Non Community Public Water Systems. Systems must have a site sampling plan that indicates the sample locations as well as backup locations. The number of sample locations is dependent on the system’s population.

Table 1

The lead and copper regulations require you to sample at locations that may be particularly susceptible to high lead or copper concentrations. The LCR establishes a tiering system for prioritizing sampling sites. A materials evaluation is required to help classify sampling sites into tiers. You must perform a materials evaluation before you begin lead and copper tap monitoring. Table 2 below, defines the tiering system for prioritizing sampling sites.

Table 2

Once monitoring begins, you must use the same sites, unless a site is no longer accessible to you or no longer fits the requirements of a priority site (e.g., the lead service lines that served the site have been replaced ).

Monitoring frequency is determined by a number of factors and are generally in two categories (Standard and Reduced).

Standard Monitoring- Samples are collected within a 6-month window (January-June and July-December). Systems will need 2 consecutive rounds of 6-month data with results less than the action level for lead and copper. All new systems and systems that have a change in source or treatment must be on standard monitoring. Systems that have an action level exceedance will also have to go to standard monitoring.

Reduced Monitoring- If a system has 2 consecutive rounds of 6-month data with results less than the action level for lead and copper, the system would be a candidate for reduced monitoring of either annual or triennial sampling. Systems would also have the number of samples reduced. Refer to Table 1.

Action Level (AL)

In 1991, EPA published a regulation to control lead and copper in drinking water. This regulation is known as the Lead and Copper Rule (also referred to as the LCR). Since 1991 the LCR has undergone various revisions, see the Rule History section below.

The treatment technique for the rule requires systems to monitor drinking water at customer taps. If lead concentrations exceed an action level of 0.015 milligrams per Liter (mg/L) or copper concentrations exceed an action level of 1.3 mg/L in more than 10% of customer taps sampled, the system must undertake a number of additional actions to control corrosion

• Calculate the 90th Percentile Concentration

  • 90th Percentile Calculator: The following external link was created by the state of Colorado and is an easy to use tool for operators to calculate the 90th percentile for compliance with the Lead & Copper Rule. The state of Montana is currently working on our own adaptation of the tool, but in the meantime please use the above link.
  • For systems that collect 5 samples, take the average of the 2 highest concentrations.
  • For systems that collect 10 samples, take the 2nd highest sample

  Compare the 90th Percentile Concentration with the Action Levels

  • Copper – 1.3 mg/L
  • Lead – 0.015 mg/L

  If your 90th percentile concentration for both Lead and Copper meets or is lower than the AL than continue with monitoring schedule.

  If one or both exceed the AL than requirements for an Action Level Exceedance (ALE) need to be completed.

  When an ALE occurs for Lead and/or Copper following tasks are required.

  • Collection of Water Quality Parameters (WQPs) from entry point and distribution system.
    • WQPs include temperature (field), pH (field), calcium (lab), Alkalinity (lab), and conductivity (lab)
    • WQPs are to be collected in the same monitoring period that the ALE occurred
  • Collection of a source water sample from entry point for lead and copper.
    • Source water sample will help determine if concentrations are from source or not.
    • Must be collected within 6 months of end of monitoring period
  • Submit recommendations for Optimal Corrosion Control Treatment (OCCT)
  • Implementation of the OCCT recommendations within 24 months after the approval by the DEQ
  • Deliver Lead Public Education (PE) (Lead only)
    • Deliver PE to your customers to inform them of:
      • The health effects for lead
      • Measures you are taking to correct the problem
      • What they can do to minimize their exposure to lead
  • Must be distributed within 10 days of receipt of data.

  • Must be re-distributed annually for as long as you exceed the ALE

  • DEQ has templates that can be used

  An ALE is not a violation but if required tasks are not followed, a violation can be issued.

Guidance 

• How to Calculate 90th Percentile Values
• 90th Percentile Calculator (EXTERNAL LINK)
• Sampling Instructions for NTNC
• Sampling Instructions for Communities

Forms 

• Consumer Notice Certification Form of Lead Tap Water Monitoring
• Lead and Copper Consumer Notice Posting Template for Non-Community - Non-Transient Systems
• Lead and Copper Consumer Notice Letter Template for Community Systems
• Sampling Location Change

Presentations

• Lead Service Line Inventories 2022
• Lead & Copper Rule and Sampling 2022

• Montana Rural Water – LCRR & Service Line Inventory Workshops (MRWS & DEQ)

• Join us for a half-day workshop featuring MT Rural Water and DEQ on the Lead and Copper Rule Revisions, including a deep dive on the
  foundational Lead Service Line Inventory. We’ll highlight how other systems are tackling the rule as well as review some of the tools available to support your compliance journey.

  • May 1, 2023 – Billings 9am-12pm
  • May 2, 2023 – Miles City 9am-12pm
  • May 3, 2023 – Glasgow 9am-12pm
  • May 4, 2023 – Havre 9am-12pm

           Click Here to Register

• Free ASDWA Webinar Series: Implementation Tools and Best Practices for Lead Service Line Inventories and Replacements
  
  • April 13, 2023 Session 6 - Regulatory Roundtable - Click Here to Register
• May 16-17, 2023 – Spring Water School Kalispell Click Here to Register

Water Service Pipe Material Identification

Finding Lead Pipes in Your Home