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EPA guidance addresses LCR implementation

Thursday, October 27, 2016   (0 Comments)
Posted by: Mona Cavalcoli
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New guidance from the US Environmental Protection Agency updates EPA regions and state primacy agencies on certain implementation aspects of the Lead & Copper Rule.

Entitled Implementation of the Lead and Copper Rule Provisions Related to Sample Site Selection and Triennial Monitoring, the memorandum asks agencies to require documentation that a water system is:

  • Using a materials evaluation that represents current conditions in the community,
  • adequately justifying any use of Tier 2 or Tier 3 LCR sample sites, rather than Tier 1 sites for LCR first-draw tap samples, and
  • identifying and addressing the root cause of any action level exceedance.
The memorandum also:
  • Strongly recommends that water systems document periodic updates to LCR materials evaluations and document how information is obtained to update the inventory.
  • Advises states to consider a water system’s (1) corrosion control treatment and historical LCR performance and (2) technical, managerial, and financial capacity before allowing it to return to triennial monitoring.

This memorandum is the latest in a series of actions by EPA to improve implementation of the current LCR while the agency develops a revised rule. EPA plans to propose the LCR Long-Term in 2017.


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