The Florida Department of Environmental Protection and the Florida Department of Health ensure that drinking water from public water systems meets water quality standards for lead (Pb) and copper (Cu). Public water systems are required to perform routine water quality testing to ensure that the water they are providing their customers meets state and federal standards. In Florida, lead is monitored under two separate regulations:
- The Inorganics Monitoring Rule, in 62-550.513, Florida Administrative Code, requires community water systems and non-transient, non-community water systems to monitor for lead at each point of entry to its distribution system (in other words, after the water leaves the treatment plant, but before it reaches the water system’s first customer.
- The Lead and Copper Rule (LCR), at Subpart I, Part 141 of title 40 of the federal code of regulations (40 C.F.R. sections 141.80-.91) and section 62-550.800, F.A.C., requires community water systems and non-transient, non-community water systems to collect first-draw samples from water taps in homes/buildings that may be or are at an elevated risk of lead/copper contamination (taking into account the presence of lead/copper pipes and fixtures, and the use of lead in the pipe solder used to connect lead/copper pipes). Selecting these higher-risk sites is a more effective method of targeting sampling locations that may pose a greater risk to public health, as opposed to the approach of selecting monitoring sites based solely on geographic distribution across a water system’s service area.
The purpose of the LCR is to protect public health by minimizing lead (Pb) and copper (Cu) levels in drinking water. Lead and copper are primarily introduced to drinking water through corrosion of plumbing materials that contain lead and copper.
Who must sample for lead and copper, and how are the samples analyzed?
- All community water systems and non-transient non-community water systems must sample their water in accordance with the monitoring requirements of the LCR. Water samples are collected by the owners or occupants of houses, multi-family residences or businesses that are selected by the public water system for sampling. The U.S. Environmental Protection Agency (EPA) has developed guidance for public water systems on the appropriate design of a monitoring program and the procedures for collecting samples. A public water system’s sampling plan must include houses, multi-family residences, or businesses that are most likely to contain lead or copper plumbing materials (e.g., those which are often found in older buildings and homes).
- At least 30 days prior to collection of lead and copper samples, a public water system must submit its sampling plans to the department for review and approval. A sampling plan must identify the sites to be sampled, along with a certification that the sites selected are those that present the greatest risk.
- After receiving guidance from the public water system on proper sampling procedures, the owner or occupant of the building collects one tap water sample per monitoring period.
- Water samples are then sent to a laboratory certified by the Florida Department of Health. The public water system must send the results of the laboratory’s analyses to the department within 10 days following the end of the compliance period (40 C.F.R. 141.90).
How are the levels of lead and copper calculated under the LCR?
The action levels for lead and copper (0.015 mg/L and 1.3 mg/L, respectively) are based on what is referred to as the 90th percentile assessment. The 90th percentile refers to the calculation of the results of all lead and copper samples collected during a compliance period. If the 90th percentile value of samples collected by the water system exceeds the action level, this means at least 10% of the public water system’s sample results are greater than 0.015 mg/L for lead or 1.3 mg/L for copper.
Put more simply, if a public water system collects 10 lead samples, the system puts the results of the lead analyses in order from smallest to largest. If the concentration of lead in the ninth sample is greater than 0.015 mg/L, then the system has incurred an action level exceedance.
After exceedance of an action level, a public water system must initiate a set of specific actions required by the LCR in order to address the lead or copper action level exceedance, including notifying the property owner, notifying all of its customers, educating its consumers about lead and copper and how to minimize exposure, and monitoring water quality. These steps are discussed below.
How often is the water tested for lead and copper?
A public water system must test the drinking water for lead and copper twice a year, once a year or every three years. A public water system that has not recently experienced any of the following situations may qualify to monitor annually or once every three years:
- Lead or copper action level exceedances.
- Source water changes.
- Long-term changes in treatment.
- Where water quality parameter monitoring is required and the system is subject to a reduced lead and copper tap monitoring frequency, failure to operate at or above the minimum value or within the range of values for the water quality parameters specified by the department for more than nine days in any six-month monitoring period (water quality parameters may include, but are not limited to, pH, conductivity, calcium and alkalinity). These measurements are used for various purposes including verification of the adjustment of corrosion control treatment.
A public water system that has recently experienced any of the above situations must conduct two consecutive monitoring rounds every six months before it may be eligible to sample just once a year or every three years.
How many samples are required?
The number of water samples that a public water system (PWS) must collect and analyze for lead and copper during a compliance period depends on the size of the population served by the system and the frequency with which the system must monitor water quality. Water systems that monitor water every six months must collect at least the following number of samples:
| Population Served by the PWS | Number of Sample Sites |
|---|
| greater than 100,000 | 100 |
| 50,001 to 100,000 | 60 |
| 10,001 to 50,000 | 60 |
| 3,301 to 10,000 | 40 |
| 501 to 3,300 | 20 |
| 101 to 500 | 10 |
| fewer than 101 | 5 |
Water systems that monitor water once a year or once every three years must collect at least the following number of samples:
| Population Served by the PWS | Number of Sample Sites |
|---|
| greater than 100,000 | 50 |
| 50,001 to 100,000 | 30 |
| 10,001 to 50,000 | 30 |
| 3,301 to 10,000 | 20 |
| 501 to 3,300 | 10 |
| 101 to 500 | 5 |
| fewer than 101 | 5 |
How do consumers learn about the results of lead and copper sampling?
A public water system must notify each participant who collected lead and copper tap samples of their individual lead results within 30 days of receipt of the sample results from the laboratory, regardless of whether the results exceed the action level for lead or copper.
The LCR also requires that public water systems notify the department that they have complied with their obligation to notify consumers of the results of lead and copper sampling. Public water systems submit the following form to the department no later than three months following the end of a compliance period: PWS Certification of Notification of Lead and Copper Tap Sample Results.
If water analyses indicate that the action level for lead (0.015 mg/L) has been exceeded, then the water system must notify all of its customers and take action to educate the public about sources of lead, potential health effects of lead and steps that the public can take to reduce exposure to lead. In addition, the system is required to submit to the department the Lead Public Education Program Report For PWS along with a copy of the notices that were sent to consumers.
Lead and Copper Tap Sampling Forms
The department facilitates prompt monitoring, reporting, public notice and public education by making electronic forms available to public water systems:
Links to Information about Lead and Copper Monitoring
Guidance Documents
