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Action level exceedance

Action level exceedance

The Department of Environment, Great Lakes, and Energy (EGLE) evaluates compliance with lead and copper action levels based on the 90th percentile of lead and copper results for each water supply's round of sampling. The lead action level is 12 ppb for samples collected on or after January 1, 2025, and the copper action level is 1.3 ppm.

The action level is a measure of corrosion control effectiveness; it is not a health-based standard. The goal for lead in drinking water is 0 ppb; there is no safe level of lead in the blood. The goal for copper in drinking water is at or below 1.3 ppm; health effects may be experienced with copper exposure above this level.

An action level exceedance (ALE) means that more than 10% of the homes tested have lead results over 12 ppb or copper results over 1.3 ppm, or both. A lead exceedance triggers additional actions including educational outreach to customers, ongoing sampling every six months, and service line replacement. 

Contact us

Contact Aislinn Deely at DeelyA@Michigan.gov or by calling 517-388-1816.

Tier 1 public notice (PN) and public education (PE) – Lead ALE only

  • Public notice template

    A template is available for the water supply to use while developing a message to distribute to the community served by the water supply. This template will be provided to the water supply by EGLE and EGLE will work with the water supplies to develop this public notice, in the event of a lead action level exceedance. The distribution of the public notice must be designed to reach all persons served by the water supply within 24 hours.

  • Public notice distribution certification

    A signed distribution certification is due to EGLE within 10 days of notifying customers. The distribution certification documents how the public notice was distributed to all persons served by the water supply within 24 hours.

  • Public education content and distribution

    Public education is a comprehensive document intended to educate persons served by the water supply about lead health effects, sources of lead, and steps to minimize exposure. Public education has very prescriptive content and distribution requirements designed to provide comprehensive information to vulnerable subpopulations within a community. Templates are available for a water supply to use while developing public education to distribute to all persons served by the water supply. EGLE will provide the appropriate template to the water supply, in the event of a lead action level exceedance.

Additional requirements after action level exceedance – Lead ALE or Copper ALE

  • Water quality parameter monitoring

    Water quality parameters are important in determining the corrosivity of the water, determining which corrosion control treatment that a system might need to install, monitoring the effectiveness of the installed treatment, and setting future treatment goals.

    If a water supply exceeds an action level, it must collect water quality parameter samples from each entry point to the distribution system and a set number of locations in the distribution system. A water supply should reference the action level exceedance letter from EGLE for more details.

    Learn more about water quality parameter sampling

  • Lead and copper monitoring

    Michigan water supplies must sample for lead and copper using a risk-based tiering criteria. If a water supply exceeds an action level, it must increase lead and copper sampling to the standard number of sites during the next two six-month lead and copper monitoring periods. A water supply should reference the action level exceedance letter from EGLE for more details.

    Learn more about lead and copper tap sampling

  • Service line replacement

    Michigan water supplies must replace lead service lines and galvanized service lines, if the service line is or was connected to lead piping, on a 5% on average basis. If a galvanized service line can not be proven to never have been connected to lead, it needs to be replaced.

    If a water supply exceeds the lead action level after installing corrosion control treatment, it must increase replacement to a minimum of 7% within one year. A water supply should reference the action level exceedance letter from EGLE for more details.

    Learn more about service line replacement

  • Source water monitoring

    Lead and copper are common metals found in the environment. They can be natural deposits in the ground and can be in contact with a water supply’s source water.

    If a water supply exceeds an action level, it must collect a lead and copper sample from each point of entry to the distribution system within six months from the beginning of the monitoring period that exceeded the action level.

    These samples do not have a stagnation requirement. Like other compliance samples collected from the point of entry to the distribution system, the water is run between 5-10 minutes before collecting the sample. A water supply should reference the action level exceedance letter from EGLE for more details.

  • Corrosion control treatment steps

    The Michigan Safe Drinking Water Act, 1976 PA 399, as amended (Act 399) has prescriptive corrosion control treatment steps for supplies that exceed an action level.

    If a water supply exceeds an action level, it must minimize lead and copper in drinking water by reducing corrosion of water pipes and household plumbing that contain lead and copper. If treatment is found to be necessary, it must be installed, and samples must be collected to ensure the lead and copper action levels are consistently met. A water supply should reference the action level exceedance letter from EGLE for more details.

  • Consumer confidence report (CCR)

    The consumer confidence report (CCR) rule requires community water supplies to annually report to their customers on the quality of the drinking water and the sources of that water, and to characterize the risks (if any) from exposure to contaminants detected in the water.

    Water supplies must include additional language if any individual samples over the action level, as well as, if you have an action level exceedance. A water supply should reference the action level exceedance letter from EGLE for more details.

    Learn more about lead and copper rule-specific requirements for the CCR