United States
                       Environmental Protection
                       Agency
Office of Water
4606
EPA 816-F-00-009
February 2001
                       Lead and  Copper Rule  Minor Revisions
                       Fact Sheet for Public Water Systems that Serve
                       More Than 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 changes brought about by the LCRMR fall 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 on
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 can be implemented in your State.
                         This fact sheet summarizes your requirements.
                         For the actual regulatory 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
 You Were Required to Comply with These Requirements Beginning April 11, 2000
         Procedure Under The Original
         Lead and Copper Rule of 1991
 The LCR does not specifically state the continuing
 monitoring requirements if you are deemed to have
 optimized corrosion control under §141.81(b)(2) (also
 known as a (b)(2) system).

 Definition: A (b)(2) system is one that has completed
 treatment steps that are equivalent to those described in
 the 1991 LCR prior to December 7, 1992.
 The LCR is unclear on the continuing monitoring
 requirements if you are deemed to have optimized
 corrosion control under §141.81(b)(3) (also known as a
 (b)(3) system).

 Definition: A (b)(3) system is one that can show that the
 difference between the 90th percentile lead level at the tap
 and the highest lead concentration in its source water is
 less than 0.005 milligrams per liter (mg/L) for two
 consecutive 6-month periods.
       Procedure Under The Lead and
       Copper Rule Minor Revisions
The LCRMR clarify that if you are a (b)(2) system, you
must:
  • •  routinely monitor for water quality parameters
      (WQPs) after your State designates optimal water
      quality parameters (OWQPs); and
  ••  continue lead and copper tap and WQP sampling.
The LCRMR clarify that if you are a (b)(3) system, but
are not required to conduct WQP monitoring, you must
continue to properly operate and maintain corrosion
control treatment at all times.

If you are a (b)(3) system, LCRMR also require you to:
  •• collect a round of lead and copper samples from the
     taps at the reduced number of sites between October
     1, 1997 and September 30, 2000 and continue
     monitoring every 3 years thereafter;
  •• not exceed the copper action level after July  12,
     2001;and
  •• begin taking corrosion control treatment steps if
     during any round of monitoring:
     • *the difference between your 90th percentile lead
       level at the tap and the lead level in your source
       water is 0.005 mg/L or higher, or
     • *you exceed the lead action level, or
     • *you exceed the copper action level on or after
       July 12, 2001.
Note: If you must begin corrosion control treatment for any of
the 3 reasons listed above, you must follow the schedule for
medium-size systems outlined in §141.81 (e) beginning with the
requirement to complete a corrosion control study. Please refer
to the table below for more detail.
Water System Corrosion Control Treatment (CCT) Schedule under §141. 81 (e)
Requirement
Conduct Corrosion Control Study
Install CCT
Conduct follow-up lead and copper tap and WQP
monitoring
Deadline
18 months after being triggered into CCT requirements
Within 24 months after State designates CCT
Within 30 months after State designates CCT
Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions
                                       Page 2 of 10

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                         Revisions That Depend on State Adoption
                                        Definition of a (b)(3) system
         Procedure Under The Original
         Lead and Copper Rule of 1991
 The State cannot deem that you are optimized under
 §141.81(b)(3) if your source water lead levels are below
 the Method Detection Limit and your 90th percentile lead
 level at the tap is • O.005 mg/L.
       Procedure Under The Lead and
       Copper Rule Minor Revisions
If your source water lead levels are below the Method
Detection Limit (of 0.005 mg/L) and your 90th percentile
lead level at the tap is • O.005 mg/L, the State may
determine that you are a (b)(3) system. You would then be
subject to the requirements for (b)(3) systems that are
discussed on page 2 of this fact sheet.
         Changes in the Procedures for Assessing Compliance with Optimal Water Quality Parameters (OWQPs)
 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 are allowed to take 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.
"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 a 6-
month period, 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 Large Water Systems: Lead and Copper Rule Minor Revisions
                                         Page 3 of 10

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       Revisions to Monitoring  and Reporting Requirements
 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.
 If you composite your source water samples, you must
 take the samples again if the composite sample's levels
 are > 0.001 mg/L for lead, or > 0.001 mg/L or > 0.020
 mg/L (depending on the analytical method) for copper.
  lad and
 bpptrRule
| Minor Rnisigns
  2000
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. You are
also subject to this requirement if you are deemed to have
optimized corrosion control under §141.81(b)(3). Your
State may require that you provide earlier notification or
undertake additional steps to ensure that optimal corrosion
control treatment is maintained.

The resampling trigger for composite samples has been
revised to '0.001 mg/L for lead and • "0.160 mg/L for
copper.
                        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
 can supply first-draw samples.
  lad and
 bpptrRule
I Dinar Rnisigns
  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 either a non-transient non-community water
system (NTNCWS), or a community water system (CWS)
that operates 24 hours a day, such as a prison or hospital,
and you do not have enough taps that can supply first-
draw lead and copper samples, your State may allow you
to collect samples from the taps that have the longest
standing times.
Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions
                                       Page 4 of 10

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                     Revisions That Depend on State Adoption
                            Monitoring Requirements (Continued)
J*j%$ Procedure Under The Original
^•,-/ Lead and Copper Rule of 1991
You are required to conduct 3 consecutive years of
monitoring before reducing your monitoring frequency to
once every 3 years (triennial).
Sample invalidation is not allowed.







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




Before being allowed to conduct triennial WQP tap
monitoring, you must be in compliance with your OWQPs
for 6 consecutive years.
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.


| ££ Procedure Under The Lead and
jJrLL Copper Rule Minor Revisions
You can reduce the frequency with which you conduct
lead and copper tap water monitoring to 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 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 subject to
tampering.
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 limit biweekly WQP entry point monitoring to
representative locations if:
•• you are a ground water system; and
•• you can demonstrate to the State that these sites are
representative of water quality conditions in your
system.
You may proceed to triennial WQP tap monitoring more
rapidly than before if you are also eligible for accelerated
reduced lead and copper tap water monitoring and you are
in compliance with your OWQPs for 2 consecutive
monitoring periods.
You may conduct source water monitoring once every 9
years 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
•• your State has determined that source water
treatment is unnecessary.

Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions
Page 5 of 10

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                        Revisions That Depend on State Adoption
                                      Reporting Requirements
Procedure Under The Original
Lead and Copper Rule of 1991
 You are always required to calculate and report your 90th
 percentile lead and copper levels to your State.
 You are required to certify that you followed proper
 sampling procedures or that homeowners collected
 samples after receiving proper instructions.

 You are 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).

 You are required to request in writing your State's
 permission to monitor for lead and copper on a reduced
 schedule after you meet your OWQPs.
                                                    lad and
                                                    Copper Rule
                                                   pinorRnisions
                                                     2000
       Procedure Under The Lead and
       Copper Rule Minor Revisions
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 by the State-specified date, and

  •• your State gave you the results of the 90th percentile
     calculation before the end of the monitoring period.

You are no longer required to submit these certifications.
You are no longer required to provide these justifications.
You are no longer required to provide a written request
for reduced lead and copper tap monitoring, but you still
must receive written approval from your State before you
can begin reduced monitoring.
       Revisions to Public Education  Requirements
 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.
 As part of your annual compliance letter, you are required
 to provide a list of newspapers, radio stations, TV
 stations, and organizations to which you provided public
 education during the year.
       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.

Your State may allow you to forego resubmitting the list
of organizations and facilities to which you provided
public education materials if you certify that this list is no
different than the previous distribution list you provided
to the State.
Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions
                                       Page 6 of 10

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                          Revisions That Depend on State Adoption
y*M^ Procedure Under The Original
C-tg/ Lead and Copper Rule of 1991
U 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 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 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.)
                               Distribution of Public Education Materials
 If you are a CWS, you must enclose your public education
 materials in your customers' regular water bills.

 If you are an 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 an NTNCWS, you may 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 may follow the NTNCWS public education
delivery requirements. (Your State may require you to
obtain approval.)
Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions
                                          Page 7 of 10

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       Revisions to  Lead Service Line Replacement
       Requirements
 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 the State
 that demonstrates that you met your partial LSL
 requirements.
 The 1991 rule does not specify how to notify users that
 you are replacing a portion of a line and of the sample
 results.
  tad and
. Copp.rRul,
| Minor Revisions
   2000
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 to the building owner(s) and the
resident(s) served by the partially replaced line.

You must submit these monitoring results to the State
within the first 10 days of the month following that in
which you receive the results. The LCRMR give States
the option to modify reporting requirements, however, so
you need to check with your State to be sure of your
specific requirements.

You must notify residents by mail. For multi-family
dwellings, however, 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 Large 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: 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.
                                               (MHO
                      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 Large 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
                                   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 Large Water Systems: Lead and Copper Rule Minor Revisions
                                                                                  Page 10 of 10

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