Lead and Copper Rule
New Requirements Begin October 1, 2011
Lead and Copper Rule Short-Term Revisions (LCR-STR) are now
required for all Group A Community and nontransient noncommunity (NTNC)
water systems. The following is a summary of changes.
Consumer Notification
Water systems must provide notification of sample results to
water users where lead and copper
samples are collected. Systems must also certify they have completed
these notices and provide a copy to the Office of Drinking Water.
The Consumer Notice for Lead and
Copper Water Sample Results (Word DOC
/ PDF) and the Consumer Notice Requirements
and Certification Form - DOH 331-462 (Word DOC
/ PDF) were developed to help water
systems meet these requirements.
New Sources and Long-term Treatment Changes
Systems must submit written documentation to us prior to the
addition of a new source or any long-term treatment change. The
documentation must include an evaluation of the potential impacts on
the corrosivity of the finished water. Our office must
review and approve any addition or change before implementation.
Changes could include:
- Addition of a new treatment process.
- Modification of an existing treatment process, such as:
- Switching secondary disinfectants (for example, chlorine to
chloramines).
- Switching coagulants (for example, alum to ferric chloride).
- Switching corrosion inhibitor products (for example,
orthophosphate to blended phosphate).
- Changing the dosage of existing chemicals if the system is
planning long-term changes to its finished water pH or residual
inhibitor concentration.
Changes in treatment may require a system to return to monitoring
once every 6 months. Water systems will be notified in writing of
any changes to their lead and copper monitoring schedule.
Clarification of Compliance and Monitoring Periods
The lead and copper compliance periods determine the frequency a
system must collect samples. These can include once every 6 months,
once a year, or every three years. Some compliance periods include a
more specific timeframe for when samples should be collected (this
is called a monitoring period.). The LCR-STR refines when compliance
and monitoring periods begin and end.
For systems monitoring annually or less frequently for lead and
copper, the monitoring period is limited to the warmest time of the
year between June and September. The LCR-STR also further defines
the timing of actions following a lead or copper action level
exceedance; the timing of monitoring activities related to reduced
monitoring schedules; and reporting requirements.
We will calculate the deadlines for completing follow-up
activities from the end of the monitoring period in which the
exceedance occurred. All samples collected to meet a 3-year
monitoring period must be collected in the same year.
Reduced Monitoring
Systems can remain on reduced monitoring (annually or once every
3 years) if they meet the lead and copper action level and
demonstrate their corrosion control treatment was effective by
meeting optimal water quality parameters. In the previous
rule, reduced monitoring didn't require meeting the action level if
the system met its optimal water quality parameters.
Public Education
Systems must provide public education within 60 days after the
monitoring period in which they exceed the lead action level. The
revisions allow us to extend the 60-day period if the system
contacts the Office of Drinking Water prior to the deadline.
The new rule refines the content of the message provided to
consumers, how the materials are delivered, and the timeframe for
delivery. Systems must also provide materials to additional
organizations to reach at-risk populations (such as WIC programs,
public and privates schools, and hospitals and clinics). Community
systems with a population of 3,300 or less may limit these
activities (40CFR141.85 (8)(b)(i, ii, iii)).
Consumer Confidence Report
The revisions require all community water systems to provide
information in their CCRs on lead in drinking water. Previously,
only water systems that detected lead above the action level in more
than five percent of the homes sampled had to include a short
informational notice about lead in their CCR. Suggested language is
available in our document,
Preparing user-friendly Consumer Confidence Reports
- (PDF, DOH 331-296), pages 7-8.
Lead Service Lines
According to our records, no water systems in Washington State
have lead service lines.
The new rule adds a requirement for utilities to reconsider
previously "tested-out" lines when resuming lead service line replacement programs. This provision only applies to systems that
have been allowed to suspend their lead service line program by testing under the
lead action level, but later exceed the lead action level again.
Resources
The following resources can help you comply with the rule
revisions.
Office of Drinking Water
U.S. Environmental Protection Agency
For More Information
If you have questions or need additional information, please
contact Denise Garrett, Lead and Copper Program Manager, at (360)
236-3099 |
