United States Office of Water EPA815-R-99-022
Environmental Protection 4606 April 2000
Agency
&EPA Notification and
Reporting Requirements
for Partial Lead Service
Line Replacement under
the Lead and Copper
Rule
Printed on Recycled Paper
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TABLE OF CONTENTS
What is the Purpose of this Guidance Document? 1
How is this Document Organized? 1
What Special Terms Does A System or State.Need to Know to Understand this Guidance? .... 2
How Have the Notification and Reporting Requirements Changed as a Result of the LCRMR?
3
Differences in Lead Service Line Replacement Requirements '
Before and After the LCRMR 7
What Type of Information Must A System Report to the State? 9
What Key Points Should A System Remember? 10
APPENDIX A
Example Notification Language A-l
PWS Notification Requirements for Lead Service Line (LSL) Replacement A-2
Example Language for Line Replacement Offer to Private Line Owners A-3
Example Language for Notification of
Planned Partial Lead Service Line Replacement A-7
Example Language for Notification of Lead Service Line Sample Results A-9
APPENDIX B
Lead and Copper Rule Minor Revisions
that Relate to Partial Lead Service Line
Notification and Reporting Requirements B-l
Lead and Copper Rule Minor Revisions that Relate to Partial Lead Service Line Notification and
Reporting Requirements B-2
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Disclaimer
The statements in this document are intended solely as guidance. This
document is not intended, nor can it be relied upon, to create any rights
enforceable by any party in litigation with the United States. EPA may decide
to follow the guidance provided in this document, or to act at variance with the
guidance based on its analysis of the specific facts presented. This guidance
may be revised without public notice to reflect changes in EPA's approach to
implementing the authorities discussed in the Guidance or to clarify and update
text.
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How Have the Notification and
Reporting Requirements Changed as
a Result of the LCRMR? ,
The LCRMR strengthen and clarify the
notification and reporting procedures that a
system must follow after partial lead service line
replacement. The LCRMR do not change the
requirements regarding which systems must
replace lead service lines. A system is still only
required to begin replacing its lead service lines if
it exceeds the lead action level after it has
completed installing treatment that is designed to
reduce lead levels [See §141.84(a)]. No matter
what a system's size, it is subject to these
requirements.
The LCRMR require a system to replace the
portion of the line that it owns [See §141.84(d)].
This is consistent with the 1994 court ruling that
revised the original requirements under the 1991
Rule. Under the 1991 Rule, systems were
required to replace the entire line up to the
building inlet, unless they could demonstrate to the
satisfaction of the State that they controlled less
than the entire service line.
The LCRMR also specifically require a system to
maintain documentation in its files that identifies
the portion(s) of the line that the system owns [See
§141.84(b)]. In addition, the LCRMR also clarify
that a system must ask owners or their authorized
agents if they want their portion of the line
replaced [See §141.84(d)].
As was true prior to the LCRMR, the owner of
the service line is responsible for the cost of
replacing his/her portion of the line. If local or
State laws preclude a system from having to
replace any lines that it does not own, then the
system is not required to offer to replace the
privately-owned portion of the line. In those
instances, where such a restriction does not exist,
a system should make this offer in writing and
maintain records of any related correspondence.
In addition, this correspondence should be
completed well in advanced of any planned
replacement. Otherwise, the system may not be
aware of where it will be conducting partial
replacement, and the system may be unable to
meet the notification schedule described under the
section entitled, "Partial Lead Service Line
Replacement Notification Requirements".
Appendix A contains a "screening letter", to
determine which line owners are interested in
having their lines replaced. This document will
allow a system to maintain records of the initial
agreements that the system reaches with line
owners or their agents. This letter is not intended
to serve as a final contractual agreement for
those who accept a system's replacement offer.
Because formal contractual and financial
agreements are highly situation-specific and are
up to the parties involved, no sample language
for these agreements is provided in this guidance
document.
Partial Lead Service Line Replacement
Notification Requirements
In those instances where the system does not
replace the privately-owned portion of the line,
because of legal restrictions or the owner decides .
not to pay for the replacement of the privately-
owned portion, a system must fulfill the
following notification and monitoring
requirements. A system is not subject to these
requirements whenever it replaces an entire lead
service line [See §141.84(d). This would also be
true in those instances where a system only
replaces a gooseneck, pigtail, or other fittings and
these are the only lead components in its service
line.
1. A system must notify the residents of the
building(s) for which it is replacing only part
of the lead service line [See §14l.84(d)].
Under the LCRMR, a system's notification
must:
• be sent at least 45 days prior to the
partial replacement; (some States allow
less than 45 days notice in the case of
Notification and Reporting Requirements for Partial LSLR
3
'April 2000
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emergency repairs; in this instance, the
system should notify customers as soon as
possible; the system should check with the
State to clarify the specific allowances
that apply to the system);
alert users that they might have a
temporary increase of lead levels in their
drinking water;
provide users with guidance on how to
minimize their exposure to lead; and
inform users mat the system will collect a
sample for lead within 72 hours of
completing the partial replacement, and
that the system will notify them of the
outcome within 3 business days of
receiving the laboratory results [See
§141.84(d)]
Note: A system's notification to water
users can be mailed, or delivered by
other methods that are approved by the
State. For multi-family dwellings, a
system can post the information in a
conspicuous common-use location.
Unlike public education, there is no mandatory
language that a system must use to notify its
affected users. The LCRMR only specify that the
language contains the key elements listed above.
If a system chooses, it can use the sample
language provided in Appendix A.
2. A system must collect one representative
water sample from each partially-replaced
lead service line, and have it analyzed for lead
[See§141.84(d)(l)].
The sample must be:
• collected within 72 hours of completing
the partial lead service replacement; and
representative of the water in the service
line, as described in the following
section, "How to Collect a
Representative Sample" [See
3 . A system must report the results of the
analysis to the owner and the residents)
served by the line within 3 business days of
receiving the results [See §141. 84(d)(l)]. If
the notice is post-marked within 3 business
days of receiving the results, it is considered
to be "on time". A system can also distribute
the sample results by posting in a
conspicuous place (for multi-family
dwellings), or by other State-approved
methods.
A summary of the differences in requirements
prior to LCRMR and under the LCRMR are
provided in the table on the following page.
Remember: Whenever a
system replaces an ENTIRE
lead service line, the system is
not subject to the partial lead
service line notification and
reporting requirements [See
§141.84(d)].
How to Collect a Representative Sample
The procedure for collecting a representative
sample following partial replacement is the same
as if a system was testing a lead service line to
see if it needed to be replaced. The procedure for
collection is explained in §141.86(b)(3) of the
federal regulations and is provided in Appendix
B. EPA has provided further explanation below
for convenience.
The service line sample must be 1 liter in volume
and have stood in the line for at least six hours
[See § 141.86(b)(3)]. A system can collect the
sample in one of the following ways:
Notification and Reporting Requirements for Partial LSLR
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April 2000
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1. Sample from a kitchen or bathroom tap:
These samples should be taken after flushing
the water volume between the tap and the line.
A sample from a single-family home, should
be collected after the water has run and there
is a significant change in water temperature,
which is indicative of water that has been
standing in the line. The sample should be
collected from the building tap which is
closest to the portion of the lead service line
that was not replaced (i.e., the first tap in the
building, most likely a kitchen or bathroom
tap on the first floor).
2.
If the sample is collected from a multi-family
residence, then the volume of pipe between
line replacement and the tap should be
calculated. Use the "Pipe Volume" table on
page 6 to estimate the volume. EPA
recommends selecting the pipe diameter that
is one size larger than the actual pipe size,
since pipe material thickness can vary,
affecting the interior diameter and the actual
volume of water.
Sample directly from a line tap:
When collecting samples in this fashion, a
system should include the installation of the
tap and collection of the sample into its lead
service line replacement schedule.
•*" Remember: Lead service line samples should not be
included in the 90th percentile calculations.
Notification and Reporting Requirements for Partial LSLR
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Pipe Volume Table (Volumes Listed in Liters)
Pipe Length
(Feet)
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
25
30
- 35
40
60
Pipe Diameter (Inches)
3/8
0.06
0.09
0.11
0.14
0.17
0.20 '
0.23
0.26
0.28
0.31
0.34
0.37
0.40
0.43
• 0.46
0.49
0.51
0.54
0.57
0.71
0.86
1.00
r.H
1.43
1/2
0.09
0.14
0.18
0.23
0.27
0.32
0.36
0.41
0.45
0.50
0.55
0.59
0.64
0.68
0.73
0.78
0.82
0.86
0.91
1.14
1.36
1.59
1.82
2.27
5/8
0.14
0.21
0.27
0.34
0.41
0.48
, 0.55
0.62
0.69
0.75
0.82
0.89
0.96
1.03
1.10
1.16
1.23
1.30
1.37
1.71
2.06
2.40
2.74
3.43
3/4
0.19
0.29
0.38
0.48
0.57
0.67
0.76
0.86
0.95
1.05
1.14
1.24
1'.33
1.43
1.52
1.62
1.71
1.81
1.90
2.38
2.85
3.33
3.80
4.76
1
0.32
0.49
0.65
0.81
0.97
1.14
1.30
1.46
1.62
1.78
1.95
2.11
2.26
2.43
2.60
2.76
2.92
3.08
3.24
4.06
4.87
5.68
6.49
8.11
11/4
0.50
0.74
0.99
1.24
1.48
1.73
1.98
2.22
2.47
2.72
2.96
3.21
3.46
3.71
3.95
4.20
4.45
4.70
4.94
6.18
7.41
8.65
9.88
12.36
Notes: 1. Volumes can be added together for pipe lengths not listed.
2. Liters can be converted to gallons by dividing by 3.785.
3. EPA recommends selecting the pipe diameter that is one size larger than the actual pipe size, since
pipe material thickness can vary, affecting the interior diameter and the actual volume of water.
Notification and Reporting Requirements for Partial LSLR
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Differences in Lead Service Line Replacement Requirements
Before and After the LCRMR
Requirements Under the 1991LCR*
Requirements Under the LCRMR
What are a system's obligations regarding replacement of the privately-owned portion of the line?
A system had to notify the user/building owner
served by die line that it was replacing the portion
of the line that it owns.
A system had to offer to replace the privately-
owned portion of the lead service line at the
owner's expense. Note: Prior to the LCRMR, the
rule was not clear whether the offer was to be made
to the user or building owner.
A system must notify the owner of the line, or the
owner's authorized agent, that the system is
replacing die portion of the lead service line that it
owns [See § 141.84(d)].
A system must offer to replace the building owner's
portion of the line at the owner's expense [See
§141.84(d)]. If any local or State laws preclude
such a requirement, a system is not required to
either offer to replace, or to actually replace the
line. A system is also not required to replace the
privately-owned portion if the owner refuses to pay
for this portion of the replacement.
What are a system's obligations to its customers if it does not replace the entire line?
For each resident served by a partially-replaced
line, a system had to offer to collect and analyze a
first-flush tap sample, after die system had
completed die partial replacement. This sample
would have been collected at die tap of each
resident that had accepted the system's sampling
offer.
A system has to notify each resident that is served
by a partially-replaced line that, after the system
has completed the partial replacement, it will collect
a sample representative of the water in the service
line and have it analyzed for lead [See
§141.84(d)(l)]. The system is not required to offer
to collect samples for each affected resident.
Radier, die system is just required to collect a
representative service line sample [See
§141.84(4X1)]. Therefore, for a multi-family
dwelling, only one representative sample must be
collected, preferably at the first tap leading into die
building [See §141.84(d)(l)].
A system also has to notify all residents served by
the partially-replaced line that they may have a
temporary increase of lead levels in their water [See
§141.84(d)(l)]. With this, the system must provide
guidance on measures consumers can take to
minimize their exposure to lead [See
§141.84(d)(l)]
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April 2000
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Differences in Lead Service Line Replacement Requirements
Before and After the LCRMR
Requirements Under the 1991 LCR*
Requirements Under the LCRMR
When must a system provide notification of the planned partial lead service line replacement?
Prior to the LCRMR, a notification schedule was
not specified.
A system must provide notification at least 45 days
before it begins the partial replacement [See
§14l.84(d)(l)]. However, if a system's line
replacement is in conjunction with emergency
repairs, the State may allow for a shorter
timeframe.
When must a system collect the sample and provide the results?
If residents) accepted the system's offer, the
system had to collect the sample(s) and report
results to the resident(s) within 14 days following
the partial line replacement.
A system must collect the sample within 72 hours of
completing the partial replacement and report the
results within 3 business days of receiving the
results [See §141.84(d)(l)].
Who pays for the analysis?
The Rule did not specify.
The system.
Who must a system report the results to?
A system had to report the results to residents.
In general, a system must report to both the building
owner(s) and (he resident(s) that are served by the
partially-replaced line [See §14I.84(d)(l)]. Note
that both are notified because many multi-family
dwellings are not owned by the occupants (e.g.,
apartment buildings). A system also must submit
these monitoring results to the State within the first
ten days of the month following that in which the
system receives the results [See §141.90(e)(4)].
However, the LCRMR give States the option to
modify a system's reporting requirements, so the
system should check with the State to be sure of the
specific requirements.
How should a system notify users that it is replacing a portion of the line and of the sample results?
The Rule did not specify how to notify users.
A system must notify residents by mail [See
§141.84(d)(2)]. However, for multi-family
dwellings, a system can post the notification in a
conspicuous common-use area of the building.
Also, systems may be able to use other State-
approved methods of notifying residents.
"Includes 1994 court ruling that revised the definition of control to include only those portions of the line that the
system owned. .
Notification and Reporting Requirements for Partial LSLR
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What Type of Information Must A
System Report to the State?
The LCRMR require that a system report
analytical results to the State for the samples that
the system collected following partial lead service
line replacement [See §141.90(e)(4)]. The
system must submit these results to the State
within the first ten days of the month following
the month in which the system receives the
results [See §141.90(e)(4)]. For example, if a
system collected samples in September, and
received the results during September, then it
would be required to submit these to the State no
later than October 10th.
A system can submit all of the partial lead
service line monitoring results that it receives
during any one month in a single report to the
State. However, a system cannot save
monitoring results from month to month and
submit them collectively to the State in one
report, without State approval. The LCRMR
allow the State to eliminate or modify the
reporting of post-partial replacement sample
results. This also means that the State can
require the system to report additional
information. To be certain of its reporting
requirements, a system should check with the
State.
Remember: If a system does not exceed the lead action level in tap
water monitoring for 2 consecutive monitoring periods, anrfthe system
has properly submitted the results to the State, the system can stop
replacing its lead service lines.
However, if at any time after this, the system does exceed the lead action
level, it will have to resume the replacement process [See §141.84(f)].
Notification and Reporting Requirements for Partial LSLR
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April 2000
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What Key Points Should A System Remember?
B3>
A system is not subject to the partial lead service line notification and reporting
requirements whenever it replaces an ENTIRE lead service line [See §141.84(d)].
If a system does not own the entire lead service line, the system must contact the
owner(s) or their agents and offer to replace their portion of the lead service line [See
§141.84(d)].
The system does not have to pay for replacement of the privately-owned portion. It is
the line owner's responsibility.
A system is not required to replace the privately-owned portion of the line if the local
or State regulations preclude the system from doing so, or if the owner decides not to
pay for the replacement of the privately-owned portion.
A system must provide notification to affected customers at least 45 days before
beginning partial lead service line replacement, (although the system should check
with the State to see if they allow exceptions in the case of emergency repairs) [See
§141.84(dXl)]. '
A system must tell the residents of buildings with partial line replacement about the
following:
• that they may have a temporary increase in lead levels after the partial line
replacement;
• what they can do to minimize their exposure to lead; and
• that the system will collect a sample after the replacement is done [See
§141.84(d)(l)J.
A system must collect a sample that is representative of the water in the lead service
line within 72 hours of completing the partial replacement and have it analyzed for
lead[See§141.84(d)(l)].
A system must report the results to the owners and residents served by the line within 3
business days of receiving the results [See §14I.84(d)(l)].
A system must also report these results to the State, unless the State specifies
otherwise. The State may eliminate this reporting requirement or require the system to
submit other information to demonstrate that the system has met its partial lead service
line requirements [See § 141.90(e)(4)]. • • •
Notification and Reporting Requirements for Partial LSLR ' April 2000
10
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APPENDIX A
Example Notification Language
PWS Notification Requirements for Lead Service Line (LSL)
Replacement
EPA has included a combined flowchart and timeline to provide systems with a quick
reference and overview of the various notification requirements related to lead service
line replacement.
Suggested Language for Line Replacement Offer to Private Line
Owners
This is an example of language that can be used to contact owners to determine if they
want their portion of the lead service line replaced by the system during its planned line
replacement. The response to this notice is not a binding contract, but an indication of
which privately-owned portions of lead service lines may need to be replaced, and which
customers will be affected by partial replacement.
Notification of Planned Partial Lead Service Line Replacement
This is example language for the notification which a system is required to send/post to
customers at least 45 days prior to a partial line replacement. Customers that live in
homes/buildings for which the service lines are being fully replaced will not need to be
notified.
With this notification, a system is required to provide guidance on lead minimizing
measures. EPA has provided systems with a list of lead minimizing techniques that
systems can include in their packages or posting to these customers.
Notification of Lead Service Line Sample Results
EPA has provided two sets of example language for notifying customers of the results of
post-replacement lead tests based on whether the lead level is less than or equal to 0.015
mg/L or, is above this level.
Example 1: If Results are Less than or Equal to 0.015 mg/L
Example 2: If Results are Greater than 0.015 mg/L
EPA recommends that the consumer guidance for minimizing lead in drinking water
accompany the notifications, in the case where lead levels exceed 0.015 mg/L.
Notification and Reporting Requirements for Partial LSLR April 2000
A-l
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PWS Notification Requirements for Lead Service Line (LSL) Replacement
Negotiate
contracts and
financial
agreements where
necessary
Determine amount
of LSL to replace
Line replacement process begins I-
Line replacement process completed
(timeframe will vary)
Lab analyzes sample
and system receives results
I
NO FURTHER
NOTIFICATION
REQUIREMENTS
H
a
r
I
8
i
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I
R
W
Notification and Reporting Requirements for Partial LSLR
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April 2000
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Example Language for Line Replacement Offer to Private Line Ownersihe
notice below could be used as a "screening letter", to determine which line owners will be interested in having their
lines replaced. The letter below is not intended to serve as a final contractual agreement for those who accept a
system's replacement offer.
Specific dates and deadlines have been left blank. Individual judgement should be used in determining the necessary
timelines for responses and contractual agreements. If a system's line replacement project is in conjunction with
emergency repairs, note that the system should contact private line owners, as soon as possible during the course of
the emergency repairs. In such a case, the language below can be used as a template, although some changes will
need to be made.
Page I of 4
(.
NOTICE TO LEAD SERVICE LINE OWNERS
REGARDING LINE REPLACEMENT
We will begin replacing a portion of lead service lines owned by that carry
water into your home/building on . Our comprehensive treatment program did not
bring lead levels in your community below 0.015 milligrams per liter (mg/L), thus, replacing lead service
lines is now the best way to reduce lead in your drinking water. is taking
every possible step to minimize lead levels in your drinking water. We have determined, along with EPA
and the State, that it is necessary to replace some of the lead service lines that distribute water in this
community. These lines were installed before it was known that lead in drinking water poses a health
hazard.
In fulfillment of both Federal and State regulations, we are offering to replace the portion of the lead
service line that you own, while we are in the process of replacing the sections of the service line that we
own. Any portion of your line that you choose to have us replace must be paid for by you.1
On the following page, entitled: "Deciding Whether to Replace Your Lead Service Line", we have outlined
some important issues that you should consider in determining whether you will participate in our planned
line replacement. Also attached is a confirmation form. If you indicate on this form that you would like
us to replace your line, we will contact you by . If we
do not receive a response from you by , we will assume that you choose not to
participate in this line replacement project.
If you have any further questions regarding this matter contact at .
1 According to Federal regulation §141.84(d): "A water system shall replace that portion of the lead service line that it owns.
In cases where the system does not own the entire lead service line, the system shall notify the owner of the line, or the
owner's authorized agent, mat the system will replace the portion of the service line that it owns and shall offer to replace the
owner's portion of the line. A system is not required to bear the cost of replacing the privately-owned portion of the line, nor
is it required to replace the privately-owned portion where the owner chooses not to pay the cost of replacing the privately-
owned portion of the line, or where replacing the privately-owned portion would be precluded by State, local or common law.
Notification andReporting Requirements for PartialLSLR April 2000
A-3
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Page 2 of 4
DECIDING WHETHER TO REPLACE YOUR SERVICE LINE:
• As noted above, our comprehensive treatment program did not bring the lead levels in your
community below 0.015 mg/L. Replacing lead service lines is now the best alternative to
minimize lead in your drinking water. This process should bring the lead levels to below 0.015
mg/L, as long as your building does not contain high-risk plumbing materials such as, lead pipes,
lead-based solder used to join copper pipe, or brass and chrome-plated brass faucets.
• If the drinking water in your home/building was not specifically tested for lead, we recommend
that you have your water tested. The cost of the lead test is about $ . The following is a list
of some State-approved laboratories in your area that you can call to have your water tested for
lead.
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Page 3 of 4
YES, I WANT TO HAVE MY LEAD SERVICE LINES REPLACED
I, the undersigned, request that the water system replace the portion
of lead service line which I own. I understand that during the replacement process, the land above
this line will be excavated, and that there may be some temporary increases in lead in the drinking
water related to this replacement process. I understand that, although it is most likely that my
lead levels will be decreased to below 0.015 mg/L as a result of this line replacement, there is no
guarantee that levels will decrease after the replacement is complete. I understand that this
document is not a binding contract for the line replacement, and I will make myself available for
communications and signing of a contractual agreement with by no
later than .
I understand that I am responsible for the costs of replacing the portion of the line that I own.
Printed Name
Signature Date
NO, I DO NOT WISH TO HAVE MY LEAD SERVICE LINES
REPLACED
I, the undersigned, choose not to have the water system replace the portion of
lead service line which I own.
Printed Name
Signature Date
Notification and Reporting Requirements for Partial LSLR April 2000
A-5
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Page 4 of 4
HOW TO REDUCE LEAD IN YOUR DRINKING WATER
1. Flush Your Taps.
For most of you, flushing tap water is a simple and inexpensive way you can help protect your family's health.
Flushing usually uses less than one or two gallons of water and costs only a few cents per month. To flush, let
the water run from the tap before using it for drinking or cooking any time the water in a faucet has gone
unused for more than six hours. The longer water resides in your plumbing, the more lead it may contain.
Since your building most likely has a lead service line to the water main, you should run the cold water faucet
until the water has significant temperature change, and then approximately for an additional minute, before
drinking. To conserve water, fill a couple of bottles with water after flushing the tap, and when possible use
the first flush water to wash dishes or water plants.
2. Use only cold water for cooking and drinking.
Try not to cook with, or drink water from the hot water tap. Hot water can dissolve lead more quickly than
cold water. If you need hot water for consumption, heat water from the cold tap on the stove.
*
3. Remove debris from faucet strainers regularly.
Remove loose lead solder and debris that may accumulate in your faucet strainers due to the recent lead service
line replacement. You can do this by removing the faucet strainers from all taps and running the water from 3
to 5 minutes. Thereafter, periodically remove the strainers .and flush out any debris that has accumulated over
time.
4. Install a Point of Use /home treatment device.
Tap filter These home treatment devices are limited in that each unit treats only the water that flows from the
faucet to which it is connected, and all of them require periodic regular maintenance and replacement. Devices
such as reverse osmosis systems or distillers can effectively remove lead from your drinking water. Some
activated carbon filters may reduce lead levels at the tap, however, all lead reduction claims should be
investigated. One way to do this is to look for the National Sanitation Foundation (NSF) mark.
NSF tests and verifies products, such as drinking water treatment units, to determine whether they comply with
specific standards, including the claims made by the manufacturer. Those products that pass the NSF's
standards can bear the NSF mark. If you want more information about drinking water treatment devices, you
can contact NSF at (800-NSF-8010) or visit their web site at www.nsf.com.
Countertop filter Filtering systems are now widely available at most home-goods or department stores.
Again, filters that pass NSF's testing criteria will carry the NSF mark. It is important to follow the product
usage and filter replacement instructions. Leaving a filter in for longer than its recommended life can actually
cause levels of lead or other contaminants to increase, because of accumulation in the filter. In addition, there
is potential for accumulation of bacterial contamination.
5. Purchase bottled water for drinking and cooking.
6. Replace internal plumbing such as faucets.
Notification and Reporting Requirements for Partial LSLR April 2000
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Example Language for Notification of
Planned Partial Lead Service Line Replacement
A system must notify the residents of the building(s) for which the system is replacing only a portion of the lead
service line (i.e., for those buildings which the owner/agents of the connecting lead service lines declined to have their
portion of the line replaced) [See §141.84(d)(l)]. The system's notification must be sent at least 45 days prior to the
partial replacement [See §141.84(d)(l)]. However, some States allow less than a 45-day notice in the case of
emergency repairs. In this instance, the system should notify customers as soon as possible. The system should
check with the State to clarify the specific allowances that apply to the system. EPA has provided systems with
recommended language for this notification below. Along with this notification, systems are required to provide
guidance to consumers on how to minimize lead in their drinking water [See §141.84(d)(l)]. Recommended
language for this consumer guidance is also provided below.
Page I of 2
NOTICE TO WATER USERS
To bring you the safest drinking water possible, we will begin replacing service lines that carry water into
your building on .
is taking every possible step to minimize lead levels in your drinking water.
We have determined, along with EPA and the State, that it is necessary to replace some of the lead service
lines that distribute water in this community. These lines were installed before it was known that lead in
drinking water poses a health hazard.
Because ownership of the line that services your building is shared jointly between and the owner of the building, only the portion of the line owned by
will be replaced. In some instances, this may cause a temporary increase in the levels of lead in your
drinking water. As you may know, lead can pose a significant risk to your health if too much of it enters
your body. Lead builds up in the body over many years and can cause damage to the brain, red blood cells
and kidneys. The greatest risk is to young children and pregnant women. Even small amounts of lead can
slow down normal mental and physical development of growing bodies. Until the lead levels stabilize, we
recommend that you take the precautionary measures, such as those discussed on the next page, entitled,
"How to Reduce Lead in Your Drinking Water".
In addition, we will collect a sample that is representative of the lead levels in the newly replaced service
line. We will collect this sample within 72 hours of completing our line replacement and have it analyzed
for lead. We may contact you to ask you if a sample can be collected at one of your faucets. Regardless of
where we collect the sample, we will be notifying you of the results within three business days of when we
receive the results.
If you have any questions regarding this matter contact __ at • .
Please look for our notice with the results of the lead analysis soon after the lead
service line replacement is completed.
Notification and Reporting Requirements for Partial LSLR April 2000
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Page 2 of 2
HOW TO REDUCE LEAD IN YOUR DRINKING WATER
1. Flush Your Taps.
For most of you, flushing tap water is a simple and inexpensive way you can help protect your family's health.
Flushing usually uses less than one or two gallons of water and costs only a few cents per month. To flush, let
the water run from the tap before using it for drinking or cooking any time the water in a faucet has gone
unused for more than six hours. The longer water resides in your plumbing, the more lead it may contain.
Since your building most likely has a lead service line to the water main, you should run the cold water faucet
until the water has significant temperature change, and then approximately for an additional minute, before
drinking. To conserve water, fill a couple of bottles with water after flushing the tap, and when possible use
the first flush water to wash dishes or water plants.
2. Use only cold water for cooking and drinking.
Try not to cook with, or drink water from the hot water tap. Hot water can dissolve lead more quickly than
cold water. If you need hot water for consumption, heat water from the cold tap on the stove.
3. Remove debris from faucet strainers regularly.
Remove loose lead solder and debris that may accumulate in your faucet strainers due to the recent lead service
line replacement. You can do this by removing the faucet strainers from all taps and running the water from 3
to 5 minutes. Thereafter, periodically remove the strainers and flush out any debris that has accumulated over
time. .
4. Install a Point of Use / home treatment device.
Tap filter These home treatment devices are limited in that each unit treats only the water that flows from the
faucet to which it is connected, and all of them require periodic regular maintenance and replacement. Devices
such as reverse osmosis systems or distillers can effectively remove lead from your drinking water. Some
activated carbon filters may reduce lead levels at the tap, however, all lead reduction claims should be
investigated. One way to do this is to look for the National Sanitation Foundation (NSF) mark.
NSF tests and verifies products, such as drinking water treatment units, to determine whether they comply with
specific standards, including the claims made by the manufacturer. Those products that pass the NSF's
standards can bear the NSF mark. If you want more information about drinking water treatment devices, you
can contact NSF at (800-NSF-8010) or visit their web site at www.nsf.com.
Countertop filter Filtering systems are now widely available at most home-goods or department stores.
Again, filters that pass NSF's testing criteria will carry the NSF mark. It is important to follow the product
usage and filter replacement instructions. Leaving a filter in for longer than its recommended life can actually
cause levels of lead or other contaminants to increase, because of accumulation in the filter. In addition, there
is potential for accumulation of bacterial contamination.
5. Purchase bottled water for drinking and cooking.
6. Replace internal plumbing such as faucets.
Notification and Reporting Requirements for Partial LSLR • April 2000
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Example Language for Notification of Lead Service Line Sample Results
Within 72 hours of completing its line replacement project, a system is required to collect a representative service
line sample and have it tested for lead [See §141.84(d)(l)]. A system is required to send the results of these tests
to those served by the partially-replaced line within three business days of receiving the results [See
§I41.84(d)(l)]. Depending on the results, EPA recommends slightly different language for this customer
notification. Recommended language is provided below for the two possible scenarios: if results are less than or
equal to 0.015 mg/L (example 1), and if results are greater than 0.015 mg/L (example 2). In the latter case
(example 2), EPA recommends that systems provide guidance to consumers on how to minimize lead in their
drinking water.
Example 1: If Results are Less than or Equal to 0.015 mg/L
Page I ofl
NOTICE TO WATER USERS
On we completed replacing the portion of the lead service lines owned by , which carry water into your building. We collected a representative service line
sample for lead after completing our line replacement. This sample was collected from on . The laboratory analysis yielded the following
results:
Lead: xxx mg/L
This is below 0.015 mg/L. This precautionary test shows that our line replacement efforts are working to
reduce the levels of lead in your drinking water.
However, because there are other factors that could contribute to high lead levels in your drinking water, we
urge you to find out whether you need to take further action by having the drinking water in your
home tested. Contributing factors can include materials within your home plumbing system, such as lead
pipes, lead-based solder used to join copper pipe, or brass and chrome-plated brass faucets. The cost of a
lead test is about $ .
The following is a list of some State-approved laboratories in your area that you can call to have your water
tested for lead.
If you have already had the drinking water in your home tested, with results showing low levels of lead, no
further testing is likely to be necessary.
We will continue to monitor for lead levels in the drinking water delivered to our customers as required by
Federal and State law. We will notify you through our lead public education efforts if lead levels above
0.015 mg/L persist in more than 10 percent of these samples. The safety of your drinking water is our first
priority.
Notification and Reporting Requirements for Partial LSLR April 2000
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Example Language for Notification of Lead Service Line Sample Results, continued
Note again that within 72 hours of completing its line replacement project, a system is required to collect a
representative service line sample and have it tested for lead [See §141.84(d)(l)]. The system is required to send
the results of these tests to those served by the partially-replaced line within three business days of receiving the
results [See §141.84(d)(l)]. If results are greater than 0.015 mg/L, EPA recommends that systems provide
guidance to consumers on how to minimize lead in their drinking water. Recommended language for this
consumer guidance is provided below.
Example 2: If Results are Greater than 0.015 mg/L
Page I of 2
NOTICE TO WATER USERS
On we completed replacing the lead service lines owned by ,
which carry water into your building. We collected a representative service line sample for lead after
completing our line replacement. This sample was collected from
on . The laboratory analysis yielded the following results:
Lead: xxx mg/L
This amount of lead is above 0.015 mg/L. These results may indicate, that despite our best efforts to remove
lead from the water supply, lead levels in some homes or buildings may still be high.
Although this elevated level of lead is most likely to be temporary, we urge you to find out whether you need
to take action in your own home by having your drinking water tested. Testing the water is essential
because you cannot see, taste, or smell lead in drinking water, and because there are a variety of factors that
can contribute to high levels of lead in your drinking water. Contributing factors can include materials within
your home plumbing system, such as lead pipes, lead-based solder used to join copper pipe, or brass and
chrome-plated brass faucets. The cost of a lead test is about $ .
The following is a list of some State-approved laboratories in your area that you can call to have your water
tested for lead.
Note that if you have already had the drinking water in your home tested, with results showing low levels of
lead, no further testing is likely to be necessary.
The safety of your drinking water is our first priority. We will continue to monitor for lead levels in the
drinking water delivered to our customers as required by Federal and State law. We will notify you through
our lead public education efforts if lead levels above 0.015 mg/L persist in more than 10 percent of these
samples.
Remember that lead can pose a significant risk to your health if too much of it enters your body. Lead builds
up in the body over many years and can cause damage to the brain, red blood cells and kidneys. If you choose
not to have your lines replaced, you and others who drink the water in your home/building may be exposed to
higher levels of lead in your drinking water. The greatest risk is to young children (especially under age 6) and
pregnant women. Amounts of lead that won't hurt adults can slow down normal mental and physical
development in the growing bodies of children. We have summarized several steps that you can take to help
ensure that the water that you consume is safe. Please refer to the next page entitled, "How to Reduce Lead in
Your Drinking Water".
Notification and Reporting Requirements for Partial LSLR April 2000
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Page 2 of 2
HOW TO REDUCE LEAD IN YOUR DRINKING WATER
1. Flush Your Taps.
For most of you, flushing tap water is a simple and inexpensive way you can help protect your family's health.
Flushing usually uses less than one or two gallons of water and costs only a few cents per month. To flush, let
the water run from the tap before using it for drinking or cooking any time the water in a faucet has gone
unused for more than six hours. The longer water resides in your plumbing, the more lead it may contain.
Since your building most likely has a lead service line to the water main, you should run the cold water faucet
until the water has significant temperature change, and then approximately for an additional minute, before
drinking. To conserve water, fill a couple of bottles with water after flushing the tap, and when possible use
the first flush water to wash dishes or water plants.
2. Use only cold water for cooking and drinking.
Try not to cook with, or drink water from the hot water tap. Hot water can dissolve lead more quickly than
cold water. If you need hot water for consumption, heat water from the cold tap on the stove.
3. Remove debris from faucet strainers regularly.
Remove loose lead solder and debris that may accumulate in your faucet strainers due to the recent lead service
line replacement. You can do this by removing the faucet strainers from all taps and running the water from 3
to 5 minutes. Thereafter, periodically remove the strainers and flush out any debris that has accumulated over
time.
4. Install a Point of Use / home treatment device.
Tap filter These home treatment devices are limited in that each unit treats only the water that flows from the
faucet to which it is connected, and all of them require periodic regular maintenance and replacement. Devices
such as reverse osmosis systems or distillers can effectively remove lead from your drinking water. Some
activated carbon filters may reduce lead levels at the tap, however, all lead reduction claims should be
investigated. One way to do this is to look for the National Sanitation Foundation (NSF) mark.
NSF tests and verifies products, such as drinking water treatment units, to determine whether they comply with
specific standards, including the claims made by the manufacturer. Those products that pass the NSF's
standards can bear the NSF mark. If you want more information about drinking water treatment devices, you
can contact NSF at (800-NSF-8010) or visit their web site at www.nsf.com.
Countertop filter Filtering systems are now widely available at most home-goods or department stores.
Again, filters that pass NSF's testing criteria will carry the NSF mark. It is important to follow the product
usage and filter replacement instructions. Leaving a filter in for longer than its recommended life can actually
cause levels of lead or other contaminants to increase, because of accumulation in the filter. In addition, there
is potential for accumulation of bacterial contamination.
5. Purchase bottled water for drinking and cooking.
6. Replace internal plumbing such as faucets.
Notification and Reporting Requirements for Partial LSLR April 2000
A-ll
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APPENDIX B
Lead and Copper Rule Minor Revisions
that Relate to Partial Lead Service Line
Notification and Reporting Requirements
§141.84(b),
§141.84(d)
§14L86(b)(3)
§141.90(e)(4)
Notification andReporting Requirements for Partial LSLR - • April 2000
B-l
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Appendix B
Lead and Copper Rule Minor Revisions that Relate to Partial Lead Service Line
Notification and Reporting Requirements
§14L84(b): The following section requires a system to replace the portion of the lead service line that it
owns.
A water system shall replace annually at least 7 percent of the initial number of lead service lines in its
distribution system. The initial number of lead service lines is the number of lead lines in place at the time the
replacement program begins. The system shall identify the initial number of lead service lines in its
distribution system, including an identification of the portion(s) owned by the system, based on a materials
evaluation, including the evaluation required under §141.86(a) and relevant legal authorities (e.g., contracts,
local ordinances) regarding the portion owned by the system. The first year of lead service line replacement
shall begin on the date the action level was exceeded in tap sampling referenced in paragraph (a) of this
section.
§141.84(d): The following section contains language that explains: to whom a system must make the offer
to replace the privately-owned portion of the line; what information must be included in the system's
notification; and how the system must provide this notification.
A water system shall replace that portion of the lead service line that it owns. In cases where the system does
not own the entire lead service line, the system shall notify the owner of the line, or the owner's authorized
agent, that the system will replace the portion of the service line that it owns and shall offer to replace the
owner's portion of the line. A system is not required to bear the cost of replacing the privately-owned portion
of the line, nor is it required to replace the privately-owned portion where the owner chooses not to pay the
cost of replacing the privately-owned portion of the line, or where replacing the privately-owned portion would
be precluded by State, local or common law. A water system that does not replace the entire length of the
service line also shall complete the following tasks.
(1) At least 45 days prior to commencing with the partial replacement of a lead service line, the water system
shall provide notice to the residents) of all buildings served by the line explaining that they may experience a
temporary increase of lead levels in their drinking water, along with guidance on measures consumers can take
to minimize their exposure to lead. The State may allow the water system to provide notice under the previous
sentence less than 45 days prior to commencing partial lead service line replacement where such replacement is
in conjunction with emergency repairs. In addition, the water system shall inform the residents) served by the
line that the system will, at the system's expense, collect a sample from each partially-replaced lead service
line that is representative of the water in the service line for analysis of lead content, as prescribed under
§141.86(b)(3), within 72 hours after the completion of the partial replacement of the service line. The system
shall collect the sample and report the results of the analysis to the owner and the residents) served by the line
within three business days of receiving the results. Mailed notices post-marked within three business days of
receiving the results shall be considered "on time".
(2) The water system shall provide the information required by paragraph (d)(l) of this section to the
residents of individual dwellings by mail or by other methods approved by the State. In instances where multi-
family dwellings are served by the line, the water system shall have the option to post the information at a
conspicuous location.
Notification and Reporting Requirements for Partial LSLR April 2000
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Lead and Copper Rule Minor Revisions that Relate to Partial Lead Service Line
Notification and Reporting Requirements
§l4L86(b)(3): The following section was NOT amended by the LCRMR. It is included here for the
convenience of the reader, as the sampling procedure described here is referenced above in §141.84(d).
(3) Each service line sample shall be one liter in volume and have stood motionless in the lead service line for
at least six hours. Lead service line samples shall be collected in one of the following three ways:
(i) At the tap after flushing the volume of water between the tap and the lead service line. The volume of
water shall be calculated based on the interior diameter and length of the pipe between the tap and the lead
service line;
(ii) Tapping directly into the lead service line; or
(Hi) If the sampling site is a building constructed as a single-family residence, allowing the water to run
until there is a significant change in temperature which would be indicative of water that has been standing in
the lead service line.
§14L90(e)(4): The following section adds a requirement for systems to report information to the State that
demonstrates compliance with partial lead service line replacement requirements.
Any system which collects lead service line samples following partial lead service line replacement required by
§141.84 shall report the results to the State within the first ten days of the month following the month in which
the system receives the laboratory results, or as specified by the State. States, at their discretion may eliminate
this requirement to report these monitoring results. Systems shall also report any additional information as
specified by the State, and in a time and manner prescribed by the State, to verify that all partial lead service
line replacement activities have taken place.
Notification and Reporting Requirements for Partial LSLR April 2000
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