DRAFT
 &EFA
United States
Environmental Protection
Agency
Office of Water
4606
EPA 816-F-00-010
March 2000
Lead and Copper Rule Minor Revisions
Fact Sheet for Large Water System Owners and
Operators
The U.S. Environmental
Protection Agency (EPA)
has made minor changes to
the Lead and Copper Rule
(LCR), which was first
published in 1991. These
minor revisions (also known as the Lead and Copper Rule Minor Revisions or LCRMR) take effect on April 11, 2000.
They reduce many monitoring and reporting requirements, and promote consistent national implementation by clarifying
some of the original requirements that were intended by EPA. They do not change the LCR's action levels of 0.015
milligrams  per liter (mg/L) for lead and 1.3 mg/L for copper or its Maximum Contaminant Level Goals of 0 mg/L for lead
and 1.3 mg/L for copper. The revisions do not affect the LCR's basic requirements to optimize corrosion control and, if
appropriate, treat source water, educate the public, and replace lead service lines.
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 must 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.

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               V..
                          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)
        Revisions to  Requirements for Demonstrating Optimal
Corrosion  Control
            You Must Begin Complying with These Requirements on 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.
      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.
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 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.
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
   •  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
        April 11, 2000.
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
                           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 < 0.005 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 < 0.005 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)
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 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, January
                           2000, EPA 815-R-99-019.
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      Revisions to  Monitoring  and  Reporting Requirements
       You Must Begin Complying with these Requirements on 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.
                                                         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.,
                                         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 to September.
                                           LiJ-n!
                                          Oiftlb
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.
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                           Revisions That Depend on State Adoption
 You are required to collect first-draw lead and copper
 samples, regardless of whether you have enough taps that
 can supply first-draw samples.
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.
                                  Monitoring Requirements (Continued)
          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 four consecutive years.
        Procedure Under The Lead and
        Copper Rule Minor Revisions
You can reduce your lead and copper tap water
monitoring to once every 3 years after monitoring for only
two 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 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.

   •  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.
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                         Revisions That Depend on State Adoption
 If you exceed an action level but are not required to install
 source water treatment, you are not allowed to reduce
 your source water monitoring.
You may conduct source water monitoring once every 9
years if you exceed an action level, and 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.
Reporting Requirements
X§R/^ Procedure Under The Original
€^J/ Lead and Copper Rule off 1991
I
I
I

i^jij
Ci <•<•!.
XD
Procedure Under The Lead and
Copper Rule Minor Revisions
 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.
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 Must Begin Complying with These Requirements on April 11, 2000
         Procedure Under The Original
         Lead and Copper Rule of 1991
       Procedure Under The Lead and
       Copper Rule Minor Revisions
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 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 must perform public education.
 As part of your annual compliance letter, you were
 required to provide a list of newspapers, radio stations, TV
 stations, and organizations to which you provided public
 education during the year.
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.
                            Revisions That Depend on State Adoption
y^?v? Procedure Under The Original
€^7 Lead and Copper Rule of 1991
I L«j-ni
i dnii.
|-i-
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. (Your State may require you to
obtain approval.)

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
 You are required to enclose your public education
 materials in the customers' regular water bills.
If you are a CWS, you can mail public education materials
separately from your bill.
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                           Revisions That Depend  on State Adoption
 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
 •  Broadcast information via TV and radio
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.)
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        Revisions to  Lead  Service Line  Replacement
Requirements
       You Must Begin Complying with These Requirements on April  11, 2000"
          Procedure Under The Original
          Lead and Copper Rule of 1991
 There is no specific required deadline to provide
 notification of partial replacement. Partial replacement
 occurs when you do not replace the entire LSL up to the
 building inlet.
 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
 will be 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.
       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.
*The LCRMR require you to offer to replace, at the building owner's expense, the portion of the LSL owned by the building owner,
unless this is prohibited by local law.
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                            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, January 2000,
                            EPA 815-R-99-022.
   Where Can I  Obtain More Information About the LCRMR?
                             •  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, January 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.
                       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.
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                    •   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.
DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions
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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

New Jersey, New York, Puerto Rico, Virgin
Islands

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 Branch
        61 Forsyth Street, S.W.
        Atlanta, GA  30303-3415
        (404) 562-9424
        Alabama, Florida, Georgia, Kentucky,
        Mississippi, North Carolina, South Carolina,
        Tennessee
                                                           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
                                                           901 N. 5th Street
                                                           Kansas City, KS 66101
                                                           (913)551-7032
                                                          Iowa, Kansas, Missouri, Nebraska
                                                           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
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         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 10
Drinking Water Unit
1200 Sixth Avenue
Seattle, WA 98101
(206)553-1890
Alaska, Idaho, Oregon,  Washington
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