UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     GUIDANCE FROM HOTLINE COMPENDIUM
                                                                           WSGH41
                                                           Date Issued: December 1991
SUBJECT:   Lead Action Level Versus LCCA Guidance Level

SOURCE:    Jeff Cohen
The final Lead and Copper Rule published in the Federal Register on June 7, 1991 (56 FR
26460) establishes a lead action level of 0.015 mg/1 that triggers treatment technique
requirements in public water systems.   In 1989, EPA issued guidance in the Lead Contamination
Control Act (LCCA) of 1988 (PL 100-572) recommending that schools on public water systems
take remedial action on an individual outlet whenever the lead levels exceed 0.020 mg/1 at that
outlet.

Will EPA change the recommended guidance level for schools on public water supplies to 0.015
mg/1 to be consistent with the new regulations?  Additionally, what is the action level for
schools classified as public water system?

       Response:

       According to the preamble of the Lead and Copper Rule (page 26479), EPA is still
       recommending that 0.020 mg/1 be used to trigger action at individual outlets in schools
       using water from a public water system.  Schools that are classified as public water
       systems will have to follow the treatment and public education requirements of the Lead
       and Copper Rule if they fail to meet the action level of 0.015 mg/1 in 90% of sampled
       taps.

       The difference between these two action levels springs from the size of the sample taken.
       The EPA's "Lead in School Drinking Water" manual recommends schools collect 250
       ml first-draw samples from water fountains and outlets.  This sampling was designed to
       pinpoint specific fountains and outlets that required remediation. In contrast, the Lead
       and Copper Rule requires systems to take a one liter first-draw sample to determine
       system-wide problems.

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