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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAY I 8 1994
THE ADMINISTRATOR
EPA Statement on Submersible Brass Pumps
Based upon data received recently, EPA advises homeowners with submersible brass pumps
to have their water tested to see if it contains levels of lead in excess of our action level of
15 parts per billion (ppb). If the test indicates lead above 15 ppb, we have prepared
information on various things the homeowner can do to reduce exposure to lead. A water
test for lead typically costs from $15 to $40, depending on the lab. While waiting for the test
results, which can take a week or two, homeowners with new pumps less than a year old,
may want to use bottled water to prevent possible additional lead exposure, since new brass
leaches lead at higher rates. This step is especially appropriate if there are children in the
home, since children are particularly sensitive to lead.
The data on submersible pumps came from the Environmental Defence Fund (EDF) who
performed laboratory studies which generally followed an NSF International test protocol.
Submersible pumps are often used in homes that are not on public water and have their own
wells. We do not have data that would tell us how long the high lead leaching continues or
how much of the lead coming from such pumps will appear at the water tap and expose the
residents. To better document the levels at which people are actually exposed, EPA,
through its own efforts and in cooperative arrangements with industry, is attempting to
determine how lead leaching from water pumps relates to exposure at the tap. However,
because the levels in this initial study are high, we are offering advice to homeowners that
emphasizes public health protection above all else.
We have prepared our hot lines (800-426-4791 for drinking water, 800-424-LEAD for lead)
to answer questions about this problem and assembled some factual material and suggestions
to the public on how to have your water tested and what actions the public can take to
reduce their potential exposure to lead. When EPA completes its studies, we will provide
the public with additional information.
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Fact Sheet
LEAD LEACHING FROM
SUBMERSIBLE WELL PUMPS
Introduction
Lead is an element that is found in air, food, paint, dust, soil, and drinking water. The Environmental
Protection Agency estimates that on average, we receive 15 to 20 percent of our total lead intake from
drinking water. Lead exposure has been associated with a wide range of risks including delays in normal
mental and physical development, impaired learning abilities in young children, and at extreme exposure
levels, irreversible damage to the brain.
This fact sheet is concerned with drinking water which may be contaminated by lead from submersible
well pumps. In laboratory tests, several models of new, previously unused submersible pumps with brass
and bronze components have been found to leach high levels of lead into the water that comes in
contact with these pumps. Unfortunately, there are no data yet that will tell us what the concentration
of lead is at the tap in homes with new pumps. This information is critical if we are to know if the high
levels found in the lab pose a health risk to family members.
Although only five specific brands were tested, the majority of submersible pumps are constructed with
brass fittings contained in a cast brass housing. EPA is concerned for residents of homes and other
buildings with submersible well pumps made with these brass fittings, because the brass alloys used in
such pumps contain lead. Some of these pumps may have the potential to leach high levels of lead into
drinking water, especially if the water is soft and corrosive.
What Is A Submersible Well Pump?
A submersible well pump for home use is typically four inches in diameter and is specially designed to
fit into a water well pipe. Lead can leach into drinking water when water sits in contact with the brass
in the pump. This could create a health risk with the water pumped into the home or other building
by the pump.
Is There A Certification Program For Well Pumps?
NSF International (NSF) is an independent certification and testing organization in the areas of
environmental and public health which develops consensus standards for various products and provides
testing and certification against those standards. Section 8.0 of the ANSI/NSF Standard 61 outlines the
requirements for various mechanical plumbing devices that contact drinking water, including submersible
well pumps. Currently, one brand of pump has been evaluated and tested in the laboratory and
certified by NSF against this standard. Others have applied for certification and are being
evaluated.

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What Is The Environmental Protection Agency Doing?
Although EPA does not regulate individual home water wells, it does regulate public water systems,
those serving 15 or more connections or those that regularly serve at least 25 individuals. It requires
public water systems to monitor for lead and install corrosion control treatment if lead is found in excess
of 15 parts per billion lead in more than 10 percent of homes tested. EPA, through its own efforts and
in cooperative arrangements with industry, is attempting to determine how lead leaching from water
pumps relates to exposure at the tap. In the meantime, EPA is encouraging consumers with such
pumps to have their water tested for lead to determine whether there may be a problem in their home.
What Should You Do?
If you are uncertain about the composition of your pump, or you know it contains brass components,
you should get your drinking water tested. Select a laboratory which is certified to test for lead by the
State and which uses EPA approved methods. Information on how to take the sample can be obtained
from EPA's Safe Drinking Water Hotline (800-426-4791). EPA's Safe Drinking Water Hotline can
provide you with the name, address, and phone number of your State lab certification officer. They,
in turn, can provide a list of State-certified laboratories.
If your submersible well pump was installed within the last year, EPA advises you to drink bottled water
while you wait for the results of the laboratory analysis, especially if there are small children in the
household. Children are especially susceptible to lead. We should try to eliminate as much of their lead
exposure as is feasible. EPA's action level for public water systems is 15 parts per billion. It is the leve'
at which Public Water Systems are required to take remedial action to reduce lead in the water.
There are a number of cartridge and reverse osmosis filtering devices that are available to remove lead
from drinking water at the tap. NSF International evaluates and certifies both bottled water and
drinking water treatment devices, the latter with regard to lead reduction performance. Lists of certified
products are available from NSF upon request. The Water Quality Association (WQA) can provide
advice on treatment units for specific uses at home. As a last resort, you may want to replace the
existing water pump with a model that does not leach significant amounts of lead. However, this option
is expensive, and still may not eliminate all the lead in your drinking water, because some of the lead
produced by the pump may have settled out in different parts of the home's piping. In addition, other
components of the home plumbing system, such as solder, brass fittings, and faucets are also potential
sources of lead.
For More Information
For more information about lead in drinking water, contact the EPA Safe Drinking Water Hotline at
800-426-4791 or the National Lead Information Center at 800-424-LEAD. For more information about
the NSF drinking water additives, bottled water, or drinking water treatment unit programs contact NSF
International at 3475 Plymouth Road P.O. Box 130140 Ann Arbor, MI 48113-0140 (313)769-5106.
WQA can be contacted at (708)505-0161, ext. 270.

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QUESTIONS AND ANSWERS ABOUT LEAD AND SUBMERSIBLE WELL PUMPS
Drinking water from wells using submersible pumps made of brass or bronze may contain
lead at levels that could pose risks to human health. This document uses a question and
answer format to address issues that may concern the affected public.
Extent of the Problem
1.	How did EPA become aware of this problem?
In laboratory tests, several models of new, previously unused submersible pumps with
brass and bronze components have been found to leach high levels of lead into the water
that comes in contact with these pumps. The findings of these tests indicate cause for
concern to users of submersible pumps and a need for further research. EPA is not
aware of data from field studies designed specifically to collect information on the extent
of lead leaching from brass and/or bronze submersible pumps or data that would indicate
what the lead levels would be at the homeowner's tap when a new pump is used in a
residential well. The Agency expects that such research will soon be conducted, and EPA
will help coordinate these efforts wherever possible. Although we do not have data on
actual human exposure at the tap, the lead levels found in the laboratory experiments are
sufficiently high for EPA to offer advise to consumers that emphasizes minimizing human
exposure above all else. The Agency is advising consumers with brass pumps to test their
water to see if they have a problem.
2.	Who may be affected?
Anyone who gets drinking water from a well with a submersible well pump that has brass
or bronze parts may be affected. Most likely this includes people who get their drinking
water from individual, household wells. People who get their drinking water from large
Public Water Systems are not likely to be affected because of dilution effects from high
flow rates and treatment at the water plant.
People with individual wells will need to test the water themselves (see Questions 13
through 18, below). The amount of lead that may be present in the water being
consumed at the tap depends on a wide range of factors and there is presently no
accurate way to predict possible exposure other than testing for the presence of lead.
3.	What is a submersible well pump?
A submersible well pump is a water pump in which the pump is submerged in the water
that is pumped. The usual well-pumping depth is 40 to 500 feet. The four-inch diameter
submersible pumps are the most commonly used pumps in private wells, as well as in very
small Public Water Systems.
4.	What factors influence how much lead can leach from submersible well pumps?
The amount of lead that may leach from a submersible well pump can vary, depending
on how much brass or bronze is used, how the brass or bronze parts are made, the age
of the pump, the corrosivity of the water and other factors. If you cannot tell for sure

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that your pump contains brass or bronze parts, the manufacturer should know; also the
pump manual or brochure may also have this information. See Question 7. As far as we
know, most submersible pumps which use brass or bronze components could leach lead
under certain conditions. The only way for you to determine if your submersible well
pump is leaching lead is to have your water tested. See Questions 13 through 18 for
more information on how to sample the water from your home.
5.	What is EPA doing about lead leaching from submersible well pumps?
EPA is continuing monitor ongoing testing lead leaching from five major models of four-
inch diameter submersible well pumps. The five models include four models made with
brass fittings, and one model made with stainless steel and plastic components. EPA is
also encouraging and coordinating research by States and pump manufacturers to study
lead levels at the tap in homes with new submersible pumps. Such field data would
provide comparison to the laboratory data already collected. EPA will evaluate the data
from these efforts and determine whether the performance standard for well pumps
established by NSF International requires modification. If so, EPA will provide technical
information and recommendations to NSF International. NSF International is an
independent certification and testing organization in the areas of environmental and
public health. NSF International develops consensus standards for various products and
provides product testing and certification against those standards.
6.	What is brass (also called bronze in some products)?
Brasses and bronzes are metal alloys containing copper and zinc. Although not a major
component of these alloys, lead is typically added to copper and zinc to improve the
machinability and water tightness of the alloy. Many pump casings and other parts of
submersible pumps currently on the market are made of lead-containing brass or bronze.
7.	How can I tell if my submersible well pump has parts made of brass or bronze?
Five specific brands of pump were included in the initial study which led EPA to be
concerned. However, as far as we know, most submersible pumps which use brass or
bronze components could leach lead under certain conditions. To find out if your
submersible well pump has components that are made of brass or bronze, you should
check with the manufacturer of the well pump. If you are unable to determine whether
a submersible pump contains brass or bronze, you should have your tap water tested to
see if lead is leaching into your water, and determine its source. See Questions 13
through 18 for more information on how to sample the water from your home.
8.	What about non-submersible pumps?
EPA has not collected data regarding whether non-submersible well pumps leach lead,
nor is EPA aware of data collected outside the Agency. The problem with lead leaching
from submersible pumps has to do with brass or bronze fittings and casings which are in
constant contact with water. Hand pumps or single stage shallow well pumps that contain
brass or bronze components that are in constant contact with the well water could also
leach lead. If you suspect that a non-submersible pump contains brass or bronze parts,
you should have your water tested. See Questions 13 through 18 for more information
on how to test your water.

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9.	Didn't the Lead Ban prohibit the amount of lead in well pumps?
The Lead Ban, passed by Congress in 1986, affects all Public Water Systems and requires
that only "lead free" pipe, solder or flux may be used in the installation or repair of (1)
Public Water Systems, or (2) any plumbing in a residential or non-residential facility
providing water for human consumption, which is connected to a Public Water System.
"Lead free" means that solders and flux may not contain more than 0.2 percent lead, and
that pipes, pipe fittings and well pumps may not contain more than 8.0 percent lead.
The Lead Ban does not apply to private wells, although manufacturers of submersible
pumps are generally following the 8.0 percent lead limit anyway. However, EPA has
found that submersible pumps are still leaching lead into water even though they have no
more than 8.0 percent lead and meet the Lead Ban's definition of "lead free".
10.	What is the definition of a Public Water System (PWS)?
Public Water System means a system for the provision to the public of piped water for
human consumption, if such a system has at least fifteen service connections or regularly
serves an average of at least twenty-five individuals daily at least 60 days out of the year.
A Public Water System is (1) any collection, treatment, storage and distribution facilities
under control of the operator of such system, and (2) any collection or pretreatment
storage facilities not under such control which are used primarily in connection with such
system. (40 CFR § 141.2)
11.	If I'm on a Public Water System, should I be concerned about lead from submersible well
pumps?
Although some Public Water Systems rely on well water and use submersible brass
pumps, wells in these systems have much greater flows than private wells and as a result,
any lead from the brass pump will be diluted. The presence of lead in public water
supply systems are most likely due to household or building plumbing components (lead
solder, brass faucets) and lead service lines, rather than from the pump.
Although Public Water Systems are required by the Lead and Copper Rule to monitor
for lead at household taps, your home may not have been included in the sampling. If
you are concerned, you can contact the water system to find out when/if monitoring
occurred and what lead levels were found in your community. The telephone number for
your Public Water System will be printed on your water bill.
12.	Are there any EPA regulations for water quality in private wells?
The Federal regulations under the Safe Drinking Water Act apply to Public Water
Systems. These regulations do not apply to private wells serving individual households.
Individual States may regulate well water quality. Most States have building codes which
affect well construction practices. Many individuals with private wells use the EPA's
regulations for Public Water Systems as guidance for the quality of their well water. Two
publications, Citizen Monitoring: Recommendations to Household Well Users (EPA 570/9-
90-006, dated April 1990) and Drinking Water From Household Wells (EPA 570/9-90-013,
dated September 1990) are available by contacting the Safe Drinking Water Hotline at
800-426-4791.

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Steps for the Consumer
13.	How can I tell if there is lead in my drinking water?
Detecting lead in drinking water requires that the water be tested. Since the EPA has
regulated lead in drinking water supplied by Public Water Systems, the Agency has
specified which methods are approved for testing lead. EPA recommends the use of a
lab that is certified to perform these specific tests on drinking water. The Safe Drinking
Water Hotline at 800-426-4791 can provide a phone number in each State that you can
call and request a list of laboratories certified to test lead in drinking water.
14.	Are there any home test kits that can be used to check lead in drinking water?
There are no home test kits that are EPA approved to test for lead. EPA recommends
a State Certified Laboratory for testing lead in drinking water. To obtain a list of
laboratories in your area, you can contact the Safe Drinking Water Hotline at 800-426-
4791 for the telephone number of your State Certification Officer who will provide you
with this list.
15.	What is the sampling protocol I should follow to test my water for lead supplied from an
individual well?
Household water supplies utilizing individual wells include various designs. Most systems
include a storage tank where water is held before it is distributed through the house.
Because lead in your drinking water may also come from lead solder and brass faucets
and fittings in the interior plumbing, it is important to determine possible contributions
of lead from indoor plumbing components. To do this, collect a 250 ml (one quarter of
a liter, or about 8.5 ounces) sample from the kitchen or bathroom faucet. The certified
lab should provide you with a proper container to collect the sample. This sample should
be collected after the water in the plumbing has sat motionless for several hours (e.g.,
first thing in the morning) without allowing the water to run first. This is called a "first-
draw sample".
To determine the highest probable amount of lead that you may be exposed to originating
from a submersible pump, a 250 ml (one quarter of a liter, or about 8.5 ounces) sample
should be collected mid-morning either: (1) at the outlet of the storage tank, if feasible,
after allowing the water to run for 30 seconds, or (2) at a tap in the house after letting
the water run for 2 minutes. This is called a "flushed sample".
16.	Didn't the Lead and Copper Rule require first-draw samples (i.e., ones that have been
taken from a tap that has not been used for at least 6 hours)? Why is this sampling
protocol different?
A one liter first-draw sample is required by the Lead and Copper Rule because the Rule
is trying to determine how much lead is leaching from plumbing inside a home (i.e., from
lead pipes, solder, flux, faucet fixtures, etc.) as well as from the distribution system. A
first draw sample is required by the Rule so that the highest levels from these sources can
be detected.

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Unlike the tap water testing protocol under the Lead and Copper Rule, EPA's
recommended protocol for submersible well pumps is devised to measure the highest
probable amount of lead that you may be exposed from the drinking water originating
from the submersible pump. We recommend that you take the water sample mid-
morning. By this time sufficient water will have passed through the system to flush out
the water that has been standing in the pipes and get the water from the well that
contains lead leached from the well pump overnight. If you want to see if your pipes are
also contributing lead to your drinking water, you should take both a first draw and a
flushed sample. We recommend 250 milliliter (ml) samples to make it easier to mail the
sample containers. For typical homes on individual wells, 250 ml samples will adequately
identify any lead contamination problems. See Question 15 for the sampling protocol.
17.	How do I evaluate my test results?
Children are especially susceptible to lead. We should try to eliminate as much of their
lead exposure as is feasible. EPA's action level for Public Water Systems is 15 parts per
billion (ppb or /j.g/1). It is the level at which Public Water Systems are required to take
remedial action to reduce lead in the water. If test results indicate that your tap water
contains lead above 15 ppb, or you want to reduce the lead level even if it is below 15
ppb, there are several steps you can take. First, determine the source of lead as best you
can. This can be done by taking a first draw sample followed by a flushed sample as
described in Question 15.
If you have a submersible well pump that contains brass or bronze and the flushed
sample has a lead level above 15 ppb, the problem could be the pump. Under these
circumstances, steps you can take to reduce your exposure to lead include installing a
home water treatment unit, using bottled water, or replacing the submersible well pump
with a pump that does not contain brass or bronze, or a bronze or brass pump which
does not leach significant amounts of lead (e.g. one that meets NSF standards). See
Question 18 for additional information.
If the lead level is above 15 ppb in the first-draw 250 ml sample, but not in the flushed
sample, the lead is likely to be coming from components of your household plumbing
(e.g., lead piping or solder, or brass faucets). If this is the case, anytime the water in a
particular faucet has not been used for several hours, flush your cold-water pipes by
running the water until it becomes as cold as it will get. (This could take as little as five
to thirty seconds if there has been recent heavy water use such as showering or toilet
flushing. Otherwise, it could take 2 minutes or longer.) The more time water has been
sitting in your household pipes, the more lead it may contain.
18.	If I test my water now, do I have to take another set of samples again?
If you sample according to the recommended protocol described above, you should have
found any lead contamination problem in your home. In fact, it appears that the older
brass is, the less lead leaches from it. So if you have a low lead reading from your pump,
there is no reason to think that the lead level will be higher in a future test. If your first
test had high lead readings, and you took corrective action such as installing a point of
use device or began a routine flushing program, a follow-up test would help you
determine the effectiveness of your actions.

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19. Will boiling water remove lead?
Boiling water does not remove lead. Consumers are sometimes directed to boil water by
their Public Water System if there is known or suspected contamination of the public
water supply by microorganisms. Boiling water kills or inactivates bacteria and viruses
that can have adverse health effects on humans. During boiling, water evaporates which
concentrates any lead that may be in the water.
20.	What can I do to protect myself and my family from exposure to lead from submersible
pumps?
You can take several steps to reduce your exposure to lead in drinking water if you
determine that you have lead in your drinking water above EPA's action level of 15 Mg/1
(equivalent to parts per billion). You can
Install a Point-of-Use treatment device that removes lead. For more information
on which types of treatment devices remove lead, contact the Water Quality
Association at 708-505-0160 or NSF International at 313-769-5106; and/or
Use bottled water for drinking and cooking. Make sure that you use a brand that
does not contain lead, however. For more information on bottled water, you can
contact the Food and Drug Administration at 301-443-4166, NSF International at
313-769-5106, or the International Bottled Water Association at 703-683-5213; or
Replace the submersible well pump with a pump that does not leach significant
amounts of lead. Stainless steel and plastic pumps have not been found to leach
lead and some brass pumps, when installed, may leach such low amounts of lead
that they do not pose a problem at the tap.
21.	Which bottled water is the best for me to drink?
Bottled water is regulated by the Food and Drug Administration (FDA), not EPA. For
information on bottled water you can contact the FDA's Consumer Affairs Office at 301-
443-4166. Information is also available from the International Bottled Water Association
(IBWA) at 703-683-5213, and NSF International which certifies bottled water at 313-769-
5106.
22. Which Home Water Treatment Units remove lead?
Generally speaking, systems using reverse osmosis remove substantial amounts of most
inorganic chemicals including lead. Several systems using filters also remove lead.
However, there are many brands and manufacturers of water filters. EPA neither
approves nor endorses home water treatment units nor does EPA conduct laboratory
tests to determine whether a unit functions as designed and/or claimed. Two reliable
sources of information about water filters are the NSF International and the Water
Quality Association which are described above.

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23. Will water softeners affect the amount of lead in drinking water?
Water softeners are devices that are attached to the plumbing at the point just after the
plumbing enters the home. This is called point-of-entry (point-of-use is when the device
is attached to a faucet inside the home). These devices soften the water by removing
minerals (primarily calcium and magnesium) that cause the water to be hard. Water
softening will also remove the lead that typically leaches from submersible well pumps
(but will not remove any lead coming from indoor plumbing components). Some water
softeners are connected to the hot water system only and therefore do not remove lead
coming from cold water taps. Preliminary tests of water softeners indicate that they will
not affect the corrosivity of the water. Unlike water softened by a water softener,
naturally occurring soft waters are mostly corrosive.
24. What is soft water?
Hard water and soft water are relative terms. Water is considered soft if it has low total
dissolved solids, low in divalent minerals (primarily calcium and magnesium). Water with
total hardness (calcium and magnesium salts and to a lesser extent iron salts are the
major causes of hardness in water) concentrations from 0 to 75 mg/1 is considered soft,
75 to 150 mg/1 is considered moderately hard, 150 to 300 mg/1 is considered hard, and
over 300 mg/1 is considered very hard. Hard water slows down the cleaning actions of
soaps and detergents and when heated will deposit a hard scale in cooking pots and in
hot water pipes.
25. What is corrosion? What is corrosive water?
Corrosion is commonly defined as an electrochemical reaction in which metal erodes or
is destroyed by contact with elements such as air, water or soil. Corrosive water is a term
used to describe the ability of certain waters to wear away metals. The important
characteristics of water that may affect its corrosiveness to metals include the following:
•	Acidity	is a measure of the water's ability to neutralize alkaline
materials. Water with acidity or low alkalinity tends to be
more corrosive than less acidic water. Water with pH less
than seven is acidic. (In some instances waters with pH
above 7 may still be corrosive).
•	Conductivity	is related to the amount of dissolved minerals in the water.
An increase in conductivity promotes the flow of electrical
current and increases the rate of corrosion.
•	Oxygen	is oxygen dissolved in water. Oxygen may either be a
corrosive agent or protect against corrosion.
•	Carbon dioxide	is carbon dioxide dissolved in water. Carbon dioxide forms
carbonic acid, which tends to attack metal surfaces. Also the
higher the levels of carbonic acid in water, the higher the
acidity of the water.

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29. What organizations can I contact for more information?
The organizations listed below can provide more information on the following subjects:
• Bottled Water:	The Food and Drug Administration regulates bottled water. To
find out about their standards call 301-443-4166. You may also
contact the International Bottled Water Association (IBWA) at
703-683-5213 or NSF International at 313-769-5106.
The International Bottled Water Association is an independent,
not-for-profit organization which can provide information about
international standards. Call them at 703-683-5213.
NSF International is an independent certification and testing
organization in the areas of environmental and public health.
NSF International may be contacted at 313-769-5106.
• Water Filters:	NSF International offers objective third-party evaluation of
water filters and will provide a list of brands which have been
certified. You can reach this foundation at 313-769-5106.
The Water Quality Association can provide advice on water
filters for specific uses at residential, commercial, industrial and
institutional settings. This independent, not-for-profit
association's phone number is 708-505-0160.
• Lead:	Additional information on lead, lead poisoning, health effects on
children, testing your home for lead paint and state contacts,
call the National Lead Information Center at 800-424-LEAD.
• Pumps:	If you get your water from a Public Water System, contact the
system that supplies your drinking water to find out if any wells
outfitted with lead-containing submersible pumps are used. The
name and phone number of the Public Water System is usually
printed on the water bill. If you are served by a municipal
system, a phone number should also be located in the
government listings of the local phone book.
If you have a household well, contact the well pump
manufacturer for information on the lead content of the
submersible well pump.
• Drinking Water For more information about EPA's drinking water regulations
and overview information and publications on drinking water
topics, you can contact EPA's Safe Drinking Water Hotline at
800-426-4791.

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