EPA Memo Discusses Lead, Copper Rule Sample Collection

EPA is releasing a guidance memorandum to reiterate and clarify specific regulatory requirements for lead in drinking water. The guidance memorandum is intended for EPA regional and state staff who work in the drinking water program.

EPA is releasing a guidance memorandum to reiterate and clarify specific regulatory requirements for lead in drinking water. The guidance memorandum is intended for EPA regional and state staff who work in the drinking water program. The audience also includes water utilities who are subject to the regulations.

EPA has been conducting a national review of implementation of the Lead and Copper Rule (LCR) since early 2004. The review has identified several issues associated with the collection and management of monitoring samples and calculation of the 90th percentile for compliance. The memo reiterates requirements of the regulation and clarifies several areas where there has been confusion.

The agency is continuing to carry out its national review of implementation which is aimed at determining whether changes are needed to existing guidance or regulations. The national review includes evaluation of the data EPA collects under the LCR, and an analysis of how states are implementing the rule. As part of the review, national expert workshops were held on monitoring, lead service line replacement, public education, and simultaneous compliance.

To assure corrosion control treatment technique requirements are effective in protecting public health, the rule also established an Action Level (AL) of 15 ppb for lead in drinking water. Systems are required to monitor a specific number of customer taps, according to the size of the system. Results of monitoring are used to determine the concentration at the 90th percentile (e.g., if 100 samples collected, the concentration at the 90th highest sample). If the 90th percentile exceeds 15 ppb, the system must undertake a number of additional actions to control corrosion and to inform the public about steps they should take to protect their health.

EPA's review of state programs and press reports have identified inconsistencies in how utilities and states are carrying out the regulation. Although EPA is carrying out an extensive review to determine if changes are needed to guidance or regulations, it was clear that there was confusion about the existing requirements. EPA made the decision to release a memo to remind states and utilities of the requirements and to clarify several areas in which there appears to be some confusion with respect to those requirements.

A copy of the memorandum, Lead and Copper Rule - Clarification of Requirements for Collecting Samples and Calculating Compliance, may be downloaded from the Internet at http://www.epa.gov/OGWDW/lcrmr/lead_guide_fs.html

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