United States                   Office of Water
                      Environmental Protection Agency       4606
                                              EPA 816-F-00-008
                                              February 2001
 vvEPA
Lead and Copper Rule  Minor Revisions
Fact Sheet for Public Water Systems that Serve
3,301 to 50,000 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) took 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:
                              Demonstrating optimal corrosion control
                              Monitoring and reporting
                              Public education
                              Lead service line replacement
In this fact sheet, we have identified for each category: 1) the revisions that you were required to 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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       Revisions to Requirements for
                Demonstrating  Optimal
                         Corrosion Control
             The revisions on this page apply to you ONLY if you
             have installed corrosion control treatment and/or are
             required to colled wafer qualify parameter samples
                          You Were Required to Comply with
                    These Requirements Beginning 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 are not used to determine compliance.
 You are out of compliance if at any time the results of
 any WQP sample are below the minimum value or
 outside the range of values designated by the State.
 You can collect a confirmation sample within 3 days of
 the original sample. If you collect a confirmation sample,
 the results of the original sample and the confirmation
 sample are averaged to determine compliance.
  tad and
. Copp.rRul,
| Minor Revisions
  2000
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, February 2001,
                       EPA815-R-99-019.
Fact Sheet for Medium-Sized Water Systems: Lead and Copper Rule Minor Revisions
                                      Page 2 of 9

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       Revisions to  Monitoring and
               Reporting Requirements
                                                       The revisions in this section
                                                        may apply to your system
                            You Were Required to Comply with
                     These Requirements Beginning April 11, 2000
Procedure Under The Original
Lead and Copper Rule of 1991
 The LCR is unclear that if you do not have enough "high-
 risk" sites (i.e., Tier 1, 2, or 3 sites) that you are still
 required to collect the minimum number of tap samples.
 The LCR does not specify which sites to use for reduced
 lead and copper tap monitoring.
 The LCR does not require you to notify your State if you
 change your treatment or add 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 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 are required to conduct reduced lead and copper
monitoring only during the months of June through
September.

You are required to collect first-draw lead and copper
samples, regardless of whether you have enough taps that
could supply first-draw samples.


You are 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 must be in compliance with your OWQPs
for at least 6 consecutive years.
                                                   tad and
                                                  . Copp.rRul,
                                                  | Minor Revisions
                                                    2000
                                                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 through
                                         September.

                                         If you are 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 conduct 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 • O.005 mg/L for lead and • O.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 Medium-Sized Water Systems: Lead and Copper Rule Minor Revisions
                                                                                Page 3 of 9

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                           Revisions That Depend on State Adoption
Monitoring Requirements (continued)
y*^r/^ Procedure Under The Original
€^7 Lead and Copper Rule of 1991
Sample invalidation is not allowed.












You are required to collect WQP samples at all of your
entry points.



If you exceed an action level but are not required to install
source water treatment, you are not allowed to reduce the
frequency with which you collect source water samples.


!cd,ti, Procedure Under The Lead and
•iJTJM*. 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; and/or
• The State believes the sample was tampered with.
Not e: 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 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 • O.005 mg/L for lead
and • O.65 mg/L for copper; and
••source water treatment is not required.
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 Medium-Sized Water Systems: Lead and Copper Rule Minor Revisions
Page 4 of 9

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         Revisions to  Public Education
                  Requirements
                                                              Read     section if you have
                                                                        the     action level
                           You Were Required to Comply with
                     These Requirements Beginning April 11, 2000
         Procedure Under The Original
         Lead and Copper Rule of 1991
You are required to submit a letter to the State
demonstrating that you met your public education
requirements. This letter is 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
X*2*v^ Procedure Under The Original
€^!^ Lead and Copper Rule of 1991
1 Uodond
1 C.pperR.1.
li Minor RMiaons
| 2000
Procedure Under The Lead and
Copper Rule Minor Revisions
                            Mandatory Public Education Language
You are required to include information about LSLs, even
if your system has no LSLs.
You are 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) are 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 Medium-Sized Water Systems: Lead and Copper Rule Minor Revisions
                                       Page 5 of 9

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                         Revisions That Depend on State Adoption
                             Distribution of Public Education Materials
If you are a CWS, you must enclose public education
materials in your customers' regular water bills.

If you are a NTNCWS, you can only post information and
distribute pamphlets; you cannot use e-mail to distribute
public education information.
All CWSs are required to:

   ••Insert notices in the water bill;
   ••Submit information to newspapers;
   ••Distribute pamphlets; and
   ••Broadcast information via TV and radio.
If you are a CWS, you can mail public education materials
separately from your bill.

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 Medium-Sized Water Systems: Lead and Copper Rule Minor Revisions
                                           Page 6 of 9

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          Revisions to Lead Service Line
                    Replacement
                    Requirements
            The revisions in this section apply to you ONLY if you
            have LSLs and you continue to exceed the lead action
             level after installing corrosion control and/or source
                         water treatment
                             You Were Required to Comply with
                      These Requirements Beginning 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 is no specific required deadline to provide
notification of partial replacement.
For each resident served by a partially replaced line, you
must offer to collect and analyze a. first-flush tap sample.
after you complete the partial replacement. This sample is
collected at the tap of each resident that accepts your offer.

If resident(s) accept your offer, you must collect the
sample(s) and report results to the resident(s) within 14
days following the partial line replacement.

You must report the sample results to residents.
You are not required to report any information to your
State that demonstrates that you met your partial LSL
requirements.
The LCR does 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
States 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, April 2000, EPA
                            815-R-99-022.
Fact Sheet for Medium-Sized Water Systems: Lead and Copper Rule Minor Revisions
                                         Page 7 of 9

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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: Summary of Revisions, April 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.
                                               ••ID
                      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 wmLejM4|av/MfewatoM
                  •  »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 Medium-Sized Water Systems: Lead and Copper Rule Minor Revisions
                                                        Page 8 of 9

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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
                                   4
                                                 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 Branc
        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 Medium-Sized Water Systems: Lead and Copper Rule Minor Revisions
                                                                                    Page 9 of 9

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