This rule applies to all community and non-transient non-community public water supply systems in the nation. In Iowa, there are approximately 1,200 systems affected by this rule. This is a significant revision with many changes to the current rule.
As has been anticipated from the proposed rule, the final rule requires all systems to which the rule applies develop an inventory of the service lines to all customers, both privately-owned and publicly-owned sides of the service line. The material used in the service line must be denoted as part of the inventory, on both the public and private sides. These inventories must be completed and submitted to the state by January 16, 2024, three years after the rule’s publication date. On the same date, systems that have lead service lines must also submit a lead service line replacement plan. We don't yet have the mechanics of this worked out, so that information will be provided at a later date.
Most of the proposed rule requirements remained in the final rule, with several changes. Only some of the changes from the current rule are listed below:
- The 90th percentile action level for lead remains at 0.015 mg/L (15 ppb), with an added trigger level at 0.010 mg/L (10 ppb); the copper action level remains at 1.3 mg/L.
- The sampling protocol changes for sampling locations with a lead service line, to include both the first and fifth liters sampled after a 6-hour standtime.
- The sample site tiering criteria changes from 3 tiers to 5 tiers. The calculation of the 90th percentile is changed in systems that have lead service lines from the current calculation.
- Systems with lead service lines must include all such sites in the sampling plans. Galvanized iron or steel pipes are considered to be lead service lines unless it can be proven there was never a lead connector or service line upstream of the galvanized pipe.
- Schools and childcare facilities are required to be sampled by the public water supply system.
- There are changes to language of the consumer notice, public education, consumer confidence report; inclusion of other new notices and certifications; and changes to the timing of the notices.
- If a sampling site exceeds 15 ppb lead, the system must conduct a “find-and-fix” review at the site, including additional sampling, to determine the cause of the lead.
- Corrosion control requirements also have some changes.
The technical guidance documents are expected to be available at some future date. EPA has an LCRR webpage.
More information will be published in the WS listserv as it becomes available.