Proposed Regulations for
  Lead  in  Drinking  Water

                              August  1988
Requirements  For Water Systems Serving Fewer Than  500 People

In early August 1988, the U.S. Environmental Protection
Agency (EPA) proposed  new national  primary drinking
water regulations (NPDWRs) for controlling lead  and
copper in drinking water.  The proposed regulations are
designed to  prevent corrosion of lead and copper plumbing
materials by water and to remove lead from distributed
The  proposed NPDWRs require  water  suppliers  to
minimize lead levels in tap water. For lead that enters water
as a corrosion by-product, suppliers must  either meet
"no-action" levels for lead, copper, and pH, or install or
improve corrosion control treatment.  Effective corrosion
control treatment may include reducing the water's acidity,
increasing its alkalinity, and/or adding a corrosion inhibitor
such as zinc orthophosphate  Suppliers that exceed lead
"no-action" levels will also be required to conduct a public
education program to inform its customers of the health
risks associated with lead in drinking water.  For drinking
water leaving  the  treatment  plant and  entering the
distribution  system,  the  proposed  MCLs   establish
acceptable concentrations for lead and copper. If water
systems exceed the MCLs for lead or copper, they will be
required to bring the concentrations down to acceptable
levels by either installing a best available technology (BAT)
or by taking other steps  such as  drilling a new well or
blending water from other sources.   Water suppliers
measure compliance with the MCLs by sampling drinking
water  leaving  the  plant  and  compliance  with  the
"no-action" levels by sampling drinking water at the tap of
targeted residences.  The number of samples required is
determined by the population size served by  the water

The proposed regulations specify that systems serving fewer than
500 people must begin monitoring to determine compliance with
the MCLs no later than 27 months after publication of the final
rule  The proposed regulations also specify that systems of this
size complete the first round of momtonne   to determine
compliance with "no-action" levels within 39 months after
issuance of the final rule
       The first action that water suppliers will need to take under
       the proposed regulations will be to determine if their water
       system is in compliance with the MCLs for lead and copper.
       This will be done by collecting water samples at distribution
       system entry points after conventional treatment has been

       Sampling Requirements
       The frequency of sampling vanes with the type of water
       system, as defined below.
       System True
                            Frequency of Sampling
       Ground-water Systems

       Surface Water Systems

       Mixed Systems
                            One sample per year
                            from each well or entry
                            point to the distribution
                            One sample quarterly
                            from each entry point to
                            the distribution system
                            One sample quarterly
                            from surface water entry
                            points to the distribution
                            system, one per year from
                            ground-water entry
                            points to the distribution
In cases where there are multiple wells drawing on the same
aquifer,  States may  designate  representative  wells for
sampling. For systems with ground-water supplies, a  State
may reduce the total number of samples by allowing the use
of composite samples which combine up to  five sources.

In the first year that monitoring is required, water suppliers
may use historical  data instead of new data  to meet the
monitoring requirements specified in the proposed rule if
the data was gathered in the same manner specified in the
proposed regulation.

Sample Analysis
Next, water suppliers analyze the samples for lead and
copper. The proposed MCLs for water sampled at the entry
points to the distribution system are 0.005 mg/1 for lead and
1.3 mg/1 for copper. A system is in compliance if the lead
and copper concentrations are within these levels.
                                                 Page 1


If no violations have occurred in the most recent two years of
monitoring, States may reduce the monitonng requirements
to once every five years for systems serving less than 500
The average annual cost of monitoring for MCLs is about
$4.60 for a system serving fewer than 500 people.
A system is m noncompliance if it exceeds the MCLs for
lead or copper in one sample. States may allow systems that
exceed the MCL to take one additional sample and
determine compliance based on the average of the two
samples. If the analysis shows that MCLs are exceeded,
water suppliers will be required to install a treatment
technology to reduce the concentrations of lead and copper
in distributed water to acceptable levels. The proposed
A11 cost information provided in this summary was obtained from the
‘Appendix Material for the Regulatory Impact Analysis of Proposed
Nalional Primary Drinking Water Regulations for Lead and Copper” (June
regulations list several treatment technologies that EPA has
designated as BATs. They are: ion exchange, reverse
osmosis, hme softening, and coagulation/filtration. Other
methods, including blending or installing a new well, may
also be used to comply with the MCLs. However, in order to
be eligible for a variance from the MCLs, a system will be
required to install one of the four technologies listed above
All of the proposed technologies are currently available,
have been proven to effectively reduce the concentrations of
these contaminants to the required levels, and are
compatible with other water treatment processes used in
different regions of the U.S.. See Exhibit 1 for an outline of
the proposed requirements for compliance with MCLs for
lead and copper in systems serving fewer than 500 people.
EPA has estimated the cost of installing and operating the
best available treatment technologies for a water supply
system serving fewer than 500 people to be as follows:**
1, 1988 Draft) Costs were derived from data on page V-40
‘Costs were derwed from data on pages 11—4 through ii—8 of previously
cited source
The treatment technique extablishes “no—action” levels and
is designed to ensure that corrosion of lead plumbing
materials by water is controlled so that lead concentrations
in drinking water are minimized at consumers’ taps.
Sampling Requirements
Under the proposed regulations, water systems will sample
drinking water from targeted residences to determine
compliance with the “no—action” levels. Systems would
collect 10 samples during the first year of sampling and
repeat the process every five years. Systems serving fewer
than 500 people must complete the first round of morutonng
within 42 months after release of the final regulations
Samples will be morning first draw or other 8 to 18 hour
standing samples. Samples will be one liter in volume and
collected at the cold water kitchen taps of targeted
residences. Systems with lead service connections will be
required to take half of their water samples as morning first
draw samples and half as service line samples (i.e., samples
of water that have stood for 8 to 18 hours in the service
connection). In general, targeted residences will be
single—family houses. Systems may include multiple—family
housing such as apartments if more than 20 percent of the
homes served by the system fall in this category.
EPA proposes that samples be taken from houses
determined to be at high risk for lead or copper problems
• Residences at the ends of the distribution system (i.e.,
dead—ends or areas of low or no flow); and either
• Residences that have lead solder that is less than five
years old in their plumbing systems; or
• Residences with lead service connections and/or lead
interior plumbing.
Half of the samples collected must be from each of these
latter two categories.
Sampling Analysis
Water suppl!ers will then be required to analyze the samples
for lead, copper, and pH. The proposed regulation requires
that the following “no—action” levels be met:
1) Lead average level less than or equal to 0.010 mg/I;
2) No more than 5% of the samples contain greater than
1.3 mg/I of copper; and
3) No more than 5% of the samples have pH less than 8.0.
If the “no-action” levels are not met, the proposed
regulation requires that public water suppliers install or
improve their corrosion control treatment for lead and
copper. if the average level for lead exceeds 0.0 10 mg/I, or
more than 5% of the lead samples exceed 0.020 mg/I, water
suppliers will be required to implement a public educatLon
program to mform its customers of the health risks
associated with lead in drinking water.
The average annual cost of monitoring for “no-action” levels
is about $55.50 for a system serving fewer than 500 people.
Costs were derived from data on page V1—45 of previously cited source
Treatment Technology Total Capital Cost O&M Cost (per year)
Ion Exchange $ 49,000 — 85,000 $ 2,000 — 5,000
Reverse Osmosis $105,000 — 210,000 $12,000 — 36,000
Lime Softening $150,000 — 175,000 $ 9,000 — 21,000
Direct Filtration $102,000 — 132,000 $ 3,000 — 3,500
Coagulation/Filtration $164,000 — 192,000 $11,000 — 27,000
Page 2

Exhibit 1
MCLs Requirements for Water Systems Serving Fewer than 500 People
Monitor system to determine corn-
pliance with MCLs for lead and
copper (begin no later than 27
months and crpiers tirat round of
monitoring no later than 42 months
after final rule Is published)
Sample drInking water at distribution
entry points alter conventional treat-
Reduce monitoring tot QW J J Reduce monitoring for SW end
I systems to once every five J mixed ayslen,a to once per
I yeara I afler for one year, repeat
[ er three years
Syaterr, is In nonoonipliance
If one sample exceeds MCLe
Install treatment or take
other steps to reduce lead
[ nd copper to required ie _ j
MCLS = Max/mum contam inant levels
GW = Ground-water
SW = Surfase water
If any of the “no—action” levels are exceeded, systems will
be required to apply to the State for a treatment plan within
one year after the close of the initial monitonng period.
Public water systems may also propose a treatment plan to
the State and request approval The State will either specify
a required corrosion control treatment plan or approve the
public water system’s treatment plan. The treatment plan
will also contain a schedule for implementing the following
I) Installing and operating the corrosion control
treatment required by the State;
2) Monitoring to determine efficacy of the treatment as
3) Adjusting the treatment as necessary to minimize lead
4) If “no—action” levels continue to be exceeded after
installation of treatment, demonstrating that treatment
is optimal and lead levels are mulirnized for the system;
5) Conducting a public education program, if necessary.
EPA recommends that systems serving fewer than 500
people consider installing treatment systems such as a soda
ash feed or a limestone bed contactor to adjust pH and
alkalinity if “no—action” levels are not met. See Exhibit 2 for
an outline of the proposed requirements for compliance
with “no—action” levels in systems serving fewer than 500
EPA estimates the average annual costs of complying with
the “no—action” levels treatment requirements to be $1,700
for a system serving fewer than 500 people.*
tosiawere derived from data on pages VT—30, 3 t,55, and 69 of previously
cited source
Sample mixed systems once
quarterly from SW entry
points and once annualiy
from OW entry points
1 Analyze samples MC ls are
0005mg / I for lead, end t3
- /l tot cooper
System In oompltarce if all
samples are within MCLs
If no violations wIthin most
recent two monitoring years,
Slate may reduce monItoring
Page 3

Under the proposed rule, EPA requires public water
suppliers that exceed “no—action” levels for lead to conduct
intensive public education programs to inform their
customers of the health risks associated with lead in drinking
water. Water suppliers will be required to undertake a
public education program encouraging consumers to reduce
their exposures to lead in drinking water if:
1) The lead level exceeds 0.020 mg/I (measured as the 95th
percentile of samples taken); and
2) The lead average level exceeds 0.0 10 mg/I.
EPA recognizes that most of the lead and copper found in
drinking water at the tap is added by plumbing after the
water leaves the treatment plant. For this reason, individual
actions on the part of the pubhc are essential for reducing
exposures to lead in drinking water.
Water suppliers exceeding one of the “no—action” levels for
lead will be required to design a public education program to
meet two performance standards, one regarding program
content and a second regarding program delivery. An
effective public education program for lead in drinking
water will include uiformation about:
(1) the health reasons for concern about lead exposure,
including identification of sensitive subpopulations;
(2) sources of lead exposure, including non—drinking water
sources; and
(3) measures that can be taken to reduce lead exposure
from drinking water.
Detailed standards for required public education programs are
outlined in the proposed rule
EPA is currently conducting a community—based pilot study
to develop and evaluate alternative public education
approaches that effectively address the problems associated
with lead in drinking water. In cooperation with the pilot
community, the Agency will conduct public outreach efforts
and develop information materials to assist public water
suppliers and other community interests in designing and
implementing effective public education programs in their
EPA will also accept public comment on a variety of
alternative approaches to this proposed regulation. The
major alternatives are:
• Requiring corrosion control treatment if 95 percent of
lead samples are not below 0.020 mg/I, in addition to the
average lead level, copper level, and pH “no—action”
• Adding lead service line replacement as part of the
treatment techniques requirement to reduce lead
levels. Under this alternative, systems would be
required to remove service lines that contribute a
significant amount of lead to tap water;
• Setting up an alternative two—tiered monitoring plan to
improve the accuracy of the sampling program and, in
some cases, reduce the total number of samples
required. Under this alternative, systems serving fewer
than 500 people would take 10 samples as Stage 1 of the
two-tiered process. If no samples exceed the maximum
“no-action” level, the system would be excused from
further sampling during that monitoring period. If
more than one sample exceeds the “no-action” level.
the system would be required to collect five more
samples as Stage 2 of the process. If more than one
sample collected from Stages 1 and 2, combined,
exceeds the “no-action” level, the system would have to
undertake corrosion control treatment;
• Deleting pH “no-action” levels;
• Adding an additional “no-action” level for total
alkalinity of 30 mg/I to trigger corrosion control
treatment; and
• Deleting MCLS for distribution water leaving the
treatment plant. Removal of lead from distributed
water would be added as part of the required treatment
technique requirement. -
Individuals wishing to comment on the proposed rule should
do so in writing by October 17,1988. Send comments to:
Lead and Copper Comment Clerk
Office of Drinking Water (WH—550)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Page 4

Figure 2
Treatment Technique Requirement
Monitor 1
Determine Whether
No-Action Levels
Met (Pb, pH, Cu)
Exceed Any No-
Install Treatment
andfor Conduct Public
Education Program
Continue to Exceed
Any No-Action
Exceed Pb
Optimize Treatment,
Obtain State
Approval and Do
State May
Report Any
Changes in
Treatment to State
Exceed Pb
Average or Cu or
pH No-Action
Continue Public
Program as Long
as Pb is

Individuals with questions on how to comply with drinking water
regulations for lead and copper should contact their State Environmental
or Health Departments. Information may also be obtained from the EPA
Safe Drinking Water Hotline. The toll—free number is (800) 426—4791 and
the Washington, D.C. number is (202) 382—5533. The hotline is open from
8:30 a.m. to 4:00 p.m. EDT.
United States
Environmental Protection