DRAFT
United States
Environmental Protection
Agency
Office of Water
4606
EPA 816-F-00-007
March 2000
&EPA
Lead and Copper Rule Minor Revisions
Fact Sheet for Public Water Systems that Serve
3,300 or Fewer Persons
We (the EPA) have made minor changes to the Lead and Copper Rule (LCR)
that was first published in 1991. These Lead and Copper Rule Minor Revisions
(LCRMR) take effect on April 11, 2000 The LCRMR do not change the
action levels of 0.015 milligrams per liter (mg/L) for lead and 1.3 mg/L for
copper. They also 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. In many cases, the revisions reduce your monitoring,
reporting, public education, and other requirements.
What Are the Changes to the Lead and Copper Rule?
The minor revisions to the LCR can be organized into four broad categories:
O Demonstrating optimal corrosion control
@ Monitoring and reporting
© Public education
O Lead service line replacement
In this fact sheet, we have identified for each category: 1) the revisions that you must begin complying with by
April 11, 2000 and 2) the revisions that you cannot implement unless and until they are adopted by your State
and incorporated into your State's drinking water regulations. Check with your State Primacy Agency to
determine when and if provisions that depend on State adoption will take effect in your State.
This fact sheet summarizes your requirements.
For the exact detailed requirements, refer to:
Federal Register, Vol. 65, No. 8. Drinking Water Regulations;
Maximum Contaminant Level Goals and National Primary
Drinking Water Regulations for Lead and Copper; Final Rule;
(Wed., Jan 12, 2000)
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o
Revisions to Requirements for
Demonstrating Optimal
Corrosion Control
fl.-ft IW/.9W15 0rt this p9£K 9f>QlY *Q V^a ONLY if you
have nstaliwJ corrosion control treatment ttitd'or we
required to coilast water cf era/Ay parameter samples
You Must Begin Complying with
These Requirements on April 11, 2000
If you have installed corrosion control treatment but are not required to conduct water quality parameter (WQP)
monitoring, you must continue to properly operate and maintain corrosion control treatment at all times.
Revisions That Depend on State Adoption
Determining Whether You Comply with Your Optimal Water Quality Parameters (OWQPs)
Procedure Under The Original
Lead and Copper Rule of 1991
Daily values were not used to determine compliance.
You were out of compliance if at any time the results of
any WQP sample were below the minimum value or
outside the range of values designated by the State.
You could collect a confirmation sample within 3 days of
the original sample. If you collected this sample, the
results of the original sample and the confirmation
sample were averaged to determine compliance.
Procedure Under The Lead and
Copper Rule Minor Revisions
"Daily values" are now used to determine compliance.
Daily values are the sample results for each WQP and are
calculated for each WQP at each sampling location. They
are based on the sampling frequency for that WQP and
sampling point.
You are only out of compliance if you have an "excursion"
for more than a total of 9 days during a 6-month period.
An excursion is any "daily value" for a WQP that is
below the minimum value or outside the range of
OWQPs set by the State.
Compliance determinations are always based on 6-month
periods, regardless of your monitoring schedule (e.g.,
daily, biweekly, semi-annually, annually, triennially) or
whether the sample is from an entry point or tap.
Confirmation samples are no longer used. You must
report the results of all samples collected during the 6-
month period.
For more information on this new OWQP compliance
procedure, refer to:
How to Determine Compliance with Optimal Water Quality Parameters as
Revised by the Lead and Copper Rule Minor Revisions, March 2000, EPA
815-R-99-019.
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions
Page 2 of 10
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Revisions to Monitoring and
Reporting Requirements
The in
to
You Must Begin Complying with
These Requirements on April 11, 2000
Procedure Under The Original
Lead and Copper Rule of 1991
The LCR was unclear that if you did not have enough
"high-risk" sites (i.e., Tier 1, 2, or 3 sites) that you were
still required to collect the minimum number of tap
samples.
The LCR did not specify which sites to use for reduced
lead and copper tap monitoring.
The LCR did not require you to notify your State if you
changed your treatment or added a new source.
Procedure Under The Lead and
Copper Rule Minor Revisions
If you do not have enough Tier 1, 2, or 3 sites, you must
use representative sites to meet minimum sampling
requirements. A site is representative if its plumbing is
similar to that of other sites in your system.
If you are on reduced lead and copper tap monitoring (i.e.,
monitor less frequently than every 6 months), you must
collect from sites that are representative of the ones you
used during standard monitoring. (Your State entity may
specify where to collect these samples.)
If you are on reduced lead and copper tap monitoring, you
must notify your State in writing no later than 60 days after
changing treatment or adding a new source.
Revisions That Depend on State Adoption
Monitoring Requirements
Procedure Under The Original
Lead and Copper Rule of 1991
You were required to conduct reduced lead and copper
monitoring only during the months of June to September.
You were required to collect first-draw lead and copper
samples, regardless of whether you had enough taps that
could supply first-draw samples.
You were required to conduct 3 consecutive years of lead
and copper tap monitoring before reducing your monitoring
frequency to once every 3 years (triennial).
Before being allowed to conduct triennial WQP tap
monitoring, you were required to be in compliance with
your OWQPs for at least 6 consecutive years.
Procedure Under The Lead and
Copper Rule Minor Revisions
Your State may allow you to conduct reduced lead and
copper monitoring during months other than June to
September.
If you a system that operates 24 hours a day and you do not
have enough taps that can supply first-draw lead and
copper samples, you may collect samples from the taps that
have the longest standing times.
You can collect lead and copper tap water monitoring once
every 3 years after monitoring for only 2 consecutive, 6-
month monitoring periods, if your 90th percentile levels are
<0.005 mg/L for lead and <0.65 mg/L for copper. (This is
also known as accelerated reduced tap monitoring).
You can proceed to triennial WQP tap monitoring if you
also qualify for accelerated reduced lead and copper tap
water monitoring and are in compliance with your OWQPs
for 2 consecutive monitoring periods.
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions
Page 3 of 10
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Revisions That Depend on State Adoption
Monitoring Requirements (continued)
Procedure Under The Original
Lead and Copper Rule of 1991
Sample invalidation was not allowed.
No monitoring waivers were allowed.
You were required to collect WQP samples at all of your
entry points.
If you exceeded an action level but were not required to
install source water treatment, you were not allowed to
reduce the frequency with which you collected source water
samples.
Procedure Under The Lead and
Copper Rule Minor Revisions
You can ask your State to invalidate lead and copper tap
water samples if the samples meet at least one of the
criteria below and you provide documentation that supports
your request:
• There is a laboratory error.
• The sample was damaged in transit.
• The State determines that the sample was taken from
an inappropriate site.
• The State believes the sample was tampered with.
Note: If you do not have enough valid samples after the
State invalidates your sample(s), you must collect enough
replacement samples to meet the minimum sampling
requirements.
You may request a 9-year monitoring waiver for lead and/or
copper tap monitoring if:
• you serve 3,300 or fewer persons;
• your 90th percentile levels are <0.005 mg/L for lead
and/or <0.65 mg/L for copper; and
• your plumbing materials meet certain criteria that
indicate negligible risk from lead and/or copper
exposure.
You may limit biweekly WQP entry point monitoring to
representative locations if:
• you are a ground water system; and
• you can demonstrate that these sites are representative
of your system's water quality conditions.
You may conduct source water monitoring on a reduced
schedule even though you exceed an action level, if:
• your source water levels are <0.005 mg/L for lead and
<0.65 mg/L for copper; and
• your State has determined that source water treatment
is unnecessary.
For more information on monitoring waivers, refer to:
Monitoring Waivers under The Lead and Copper Rule Minor
Revisions for Systems Serving 3,300 or Fewer People, March 2000,
EPA815-R-99-021.
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions
Page 4 of 10
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Reporting Revisions That Depend on State Adoption
1. You may no longer be required to calculate and report your 90th percentile lead and copper levels if:
• your State has notified you that it will perform this calculation;
• you provided your sampling results and sampling site information to your State no later than the date specified by
your State (Note: this date will be sometime before the end of the monitoring period); and
• your State gave you the results of the 90th percentile calculation before the end of the monitoring period.
2. You are no longer required to submit certifications that you followed proper sampling procedures or that homeowners
collected samples after receiving proper instructions.
3. You are no longer required to provide justifications if your sampling pool contains Tier 2 or Tier 3 sites or an
insufficient number of sites served by lead service lines (LSLs).
4. You are no longer required to request in writing your State's permission to monitor for lead and copper on a reduced
schedule after you meet your OWQPs. (You still must receive written approval from your State before you begin
reduced monitoring.)
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions Page 5 of 10
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Revisions to Public Education
Requirements
if you
You Must Begin Complying with
These Requirements on April 11, 2000
Procedure Under The Original
Lead and Copper Rule of 1991
You were required to submit a letter to the State
demonstrating that you met your public education
requirements. This letter was due by December 31 of the
year in which you performed public education.
Procedure Under The Lead and
Copper Rule Minor Revisions
You must submit a letter to the State demonstrating that
you met your public education requirements within 10 days
after each period in which these tasks were required. This
means that if you are required to deliver public service
announcements (PSAs) every 6 months, you must submit
two letters per year.
Revisions That Depend on State Adoption
yjpj/? Procedure Under The Original
C^g/7 Lead and Copper Rule of 1991
| Lcndnnd
{ Copper Rule
H Minor Revision!
•1 2000
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Procedure Under The Lead and
Copper Rule Minor Revisions
Mandatory Public Education Language
You were required to include information about LSLs, even
if your system had no LSLs.
You were not allowed to modify language regarding the
availability of building permits and consumer access to
these records.
All CWSs and non-transient, non-community water systems
(NTNCWSs) were required to use the same language
provided by EPA.
You can delete references to LSLs in your public education
materials if you have no LSLs and you obtain approval
from your State.
If you are a community water system (CWS), you can
modify public education language regarding building permit
availability and consumer access to these records, if those
documents are not available. You must have permission
from your State to modify this language.
If you are a NTNCWS, you may use alternative mandatory
public education language that is more suited to your type
of system.
If you are a certain type of CWS, such as a prison or
hospital, whose residents cannot make their own plumbing
improvements and are not billed separately for water, you
can use the alternative mandatory public education
language provided for NTNCWSs. (Your State may require
you to obtain approval.)
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions
Page 6 of 10
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Revisions That Depend on State Adoption
Distribution of Public Education Materials
All CWSs were required to:
• enclose your public education materials in the
customers' regular water bills
• provide public service announcements to radio and TV
stations semi-annually;
• notify the public via newspapers;
• distribute pamphlets to all facilities and organizations
that provide the public with health and/or educational
services.
If you were a NTNCWS, you could only post information
and distribute pamphlets; you could not use e-mail to
distribute public education information.
All CWSs were required to:
• Insert notices in the water bill
• Submit information to newspapers
• Distribute pamphlets
• Broadcast information via TV and radio
If you are a CWS, you:
• can mail public education materials separately from
your bill;
• no longer have to provide public service
announcements to radio and TV stations;
• no longer have to notify the public via newspapers.*
• can limit distribution of pamphlets to facilities
primarily serving pregnant women and children, unless
your State requires you to make a broader
distribution.*
*Ifyou serve 501 to 3,300 persons, you first must have approval
from your State.
If you are a NTNCWS, you can use internal e-mail systems
instead of using printed materials to distribute public
education materials, as long as this achieves at least the
same coverage.
If you are a certain type of CWS, such as a prison or
hospital, whose residents cannot make their own plumbing
improvements and are not billed separately for water, you
can follow the NTNCWS public education delivery
requirements. (Your State may require you to obtain
approval.)
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions
Page 7 of 10
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o
Revisions to Lead Service Line
Replacement Requirements
Ttm rw!4!c»,«ts lit Wn'i KSCWori- qppty to you ONLY H if an
hsve LSLf 3nrf you continue to exceed the lend action
level affer in&tatting corrofiloa control and far source
You Must Begin Complying with
These Requirements on April 11, 2000
The following table shows how the LCRMR have changed your requirements if you do not own the entire LSL and you
only replace that portion of the LSL that you own (also known as partial LSL replacement). Unless prohibited by local or
State law, the LCRMR still require you to offer to replace the building owner's portion of the line at his/her expense.
Procedure Under The Original
Lead and Copper Rule of 1991
There was no specific required deadline to provide
notification of partial replacement.
For each resident served by a partially replaced line, you
had to offer to collect and analyze a first-flush tap sample.
after you completed the partial replacement. This sample
would have been collected at the tap of each resident that
had accepted your offer.
If resident(s) had accepted your offer, you were required to
collect the sample(s) and report results to the resident(s)
within 14 days following the partial line replacement.
You had to report the sample results to residents.
You were not required to report any information to the
State that demonstrated that you met your partial LSL
requirements.
The LCR did not specify how to notify users about the
partial replacement or the post-replacement sample results.
Procedure Under The Lead and
Copper Rule Minor Revisions
You must notify residents at least 45 days before partial
replacement that lead levels may increase temporarily
following the replacement and provide guidance on the
measures they can take to minimize exposure to lead. If
your line replacement is in conjunction with emergency
repairs, however, your State may allow a shorter time frame
for this notification.
You must collect at your expense one representative service
line sample for each replaced LSL within 72 hours of
removing the line. You are not required to collect samples
for each affected resident.
You must collect the sample within 72 hours of completing
the partial replacement and report the results within 3
business days of receiving the results.
You must report sample results to the building owner(s) and
the resident(s) served by the partially replaced line.
You also must submit these monitoring results to the State
within the first 10 days of the month following that in which
you receive the results. However, the LCRMR give
regulating entities the option to modify reporting
requirements, so you need to check with your State to be
sure of your specific requirements.
You must notify residents by mail. However, for multi-
family dwellings you can post the notification in a
conspicuous common-use area of the building.
For more information on partial lead service line
notification and reporting requirements, refer to:
Notification and Reporting Requirements for Partial Lead Service
Line Replacement under the Lead and Copper Rule, March 2000,
EPA815-R-99-022.
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions
Page 8 of 10
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Where Can I Obtain More Information About the LCRMR?
EPA Regions
State or EPA Regional Office
You can contact the EPA Region responsible for implementing the Safe Drinking
Water Act for your systems. A list of contacts in each EPA Regional office is
provided on the next page.
Other Guidance Documents
Lead and Copper Rule: Compliance Dates, March 2000, EPA 815-R-99-020. This
document helps you understand when you must begin complying with the new
requirements of the LCRMR. This guidance contains a discussion of each of the important
changes made to the 1991 Rule by the LCRMR by major rule section (i.e., §141.81,
§141.82, §§141.84-141.90, and §141.43), and identifies when you must begin complying
with the new requirements. It also contains an appendix which compares the rule language
of the LCR against the minor revisions.
'.{••if
You can obtain any of the guidance documents listed in this fact
sheet from the Safe Drinking Water Hotline, the Water Resource Center (202-260-7786
or e-mail at center.water resource@epa.gov), or the Office of Ground Water and Drinking
Water web page at www.epa.gov/safewater/standards.html.
Safe Drinking Water Hotline
You can call the SAFE DRINKING WATER HOTLINE at 1-800-426-4791. It is open
Monday through Friday, 9:00 a.m. to 5:30 p.m., ET, excluding Federal holidays. The Hotline can
provide you with a list of other documents that pertain to the LCR and to the minor revisions.
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions
Page 9 of 10
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EPA Regional Offices
EPA Region 1
Associate Director for Drinking Water
Policy
One Congress Street
Suite 1100
Boston, MA 02114-2023
(617)918-1571
Connecticut, Massachusetts, Maine, New Hampshire,
Rhode Island, Vermont
EPA Region 2
Water Programs Branch
290 Broadway
New York, NY 10007-1866
(212) 637-3826
EPA Region 6
Source Water
Protection Branch
1445 Ross Avenue
Dallas, TX 75202
(214) 665-7150
Arkansas, Louisiana, New Mexico,
Oklahoma,
Texas
EPA Region 7
Drinking Water Branch
90 IN. 5th Street
Kansas City, KS 66101
(913)551-7032
New Jersey, New York, Puerto Rico, Virgin Islands Iowa, Kansas, Missouri, Nebraska
EPA Region 3
Drinking Water Branch
1650 Arch Street
Philadelphia, PA 19103-2029
(800) 438-2474 (Customer Service Hotline)
Delaware, Maryland, Pennsylvania, Virginia,
West Virginia, District of Columbia
EPA Region 4
Ground Water/Drinking Water Brand
61 Forsyth Street, S.W.
Atlanta, GA 30303-3415
(404) 562-9424
Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee
EPA Region 5
Safe Drinking Water Branch
77 West Jackson Boulevard
Chicago, IL 60604
(800)621-8431
Illinois, Indiana, Michigan, Minnesota, Ohio,
Wisconsin
EPA Region 8
Municipal Systems Unit
999 18th Street
Denver, CO 80202
(303)312-7021
Colorado, Montana,
North Dakota, South Dakota, Utah, Wyoming
EPA Region 9
Drinking Water Office
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1843
Arizona, California, Hawaii,
Nevada, American Samoa, Guam,
Commonwealth of the Northern Mariana
Islands
EPA Region 10
Drinking Water Unit
1200 Sixth Avenue
Seattle, WA 98101
(206)553-1890
Alaska, Idaho, Oregon, Washington
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions
Page 10 of 10
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