-EPA
        United States
        Environmental Protection
         Agency
                                                 Office of Water
                                                 4604
EPA812-F-96-001
February 1996
        FACT SHEET
        LEAD AND COPPER RULE PROPOSED MINOR REVISIONS
BACKGROUND

Minor revisions are necessary to streamline, reduce reporting burden, and improve implementation of the National
Primary Drinking Water Regulations for Lead and Copper.  These changes do not affect the rule's basic
requirements to optimize corrosion control and, if appropriate, treat source water, deliver public education, and
replace lead service lines.  EPA also is requesting comment on several burden reduction suggestions that the
Agency is not proposing but believes are worth considering.  Finally, F.PA is collecting additional data in  response
to a legal challenge by the Natural Resources Defense Council on the exclusion of Transient Non-Community
Water Systems (TNCWSs) from coverage under the rule and is requesting public comment on the appropriateness
of the continued exclusion. The following outlines this action.

MONITORING

Reduce Monitoring Burden

'       Let systems demonstrating very low levels of lead and copper at the tap reduce the monitoring frequency
        more rapidly than currently allowed.

       Give States flexibility to waive most monitoring for "all plastic" small-sized systems.

       Permit ground water systems required to conduct bi-weekly entry point monitoring to limit such
        monitoring to representative locations.

       Allow systems subject to source water monitoring to reduce the frequency of such  monitoring if they have
        low levels of source water lead and copper.

       Allow seasonal Non-Transient Non-Community Water Systems (NPNCWSs) that do not operate during
        the summer to conduct reduced monitoring for lead and copper at the tap dtirtng the warmest month(s) of
        operation.

Other Revisions Affecting Man itoring

       Add sample invalidation provisions.

       Clarify sampling site selection requirements.

       Revise the resampling triggers for composite lead and copper source water samples.

       Decrease holding time for acidified lead and copper samples.

SYSTEMS DEMONSTRATING OPTIMAL CORROSION CONTROL

       Clarify monitoring requirements pertaining to systems that, have demonstrated that they already
        have completed activities equivalent to the rule's corrosion control treatment steps.

       Add requirements pertaining to systems that have demonstrated that little or no corrosion is
        occurring in the distribution system.

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PUBLIC EDUCATION

       Provide alternative language for use by NTNCWSs.and some Community Water Systems (CWSs).

       Allow greater flexibility in the timing and method of delivery.

       Let CWSs serving 500 or fewer people to limit the area of distribution.

LEAD SERVICE LINE REPLACEMENT

       Revise the definition of "control" as it applies to lead service line replacement.

       Remove the rebuttable presumption that the system controls the entire line.

REPORTING REQUIREMENTS

       Remove system reporting requirements that are redundant or no longer necessary.

       Add requirements for systems subject to  reduced monitoring to notify the State of any changes in
        treatment or source water.
                                         !
       Change the deadline for systems to report completion of public education tasks to the State.

       Modify State reporting requirements to eliminate redundant and unnecessary requirements and to collect
        limited additional information.

REQUEST FOR COMMENTS

       Request comment on the following burden reduction suggestions the Agency is considering and may
        include in the final rule. SHOULD THE AGENCY:

        (1) eliminate the requirement for systems to calculate 90th percentile values;

        (2) reduce the frequency of entry point water quality parameter monitoring;

        (3) allow flushing and bottled water instead of corrosion control in NTNCWSs;              ''

        (4) eliminate the requirement for systems to justify not recommending specific corrosion control
        treatment;                                                                        '

        (5) allow alternatives to tap samples to assess the effectiveness of corrosion control;

        (6) allow CWSs serving between 501 and 3,300 people to omit the public service announcement task as a
        part of public education; and

        (7) reduce the frequency of State reporting of lead and  copper information to EPA?

       Explain that EPA is collecting additional data pertaining to the exclusion of TNCWSs from coverage
        under the rule and solicit comment on the continued appropriateness of the exclusion.

ESTIMATED IMPACT OF CHANGES

       EPA estimates the proposed changes will reduce total annual costs to water systems by approximately $1.5
        million and reduce total annual State implementation costs by approximately $300.000.

FOR FURTHER INFORMATION

        Call the SAFE DRINKING WATER HOTLINE at 1-800-426-4791.

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