United States	Office of Water
Environmental Protection	4606
Agency
EPA 816-F-00-010 Ł
February 2001
&EPA
Lead and Copper Rule Minor Revisions
Fact Sheet for Tribal Water System Owners and
Operators
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 momtonng, 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
Š	Monitoring and reporting
0	Public education
O	Lead service line replacement
In this fact sheet, we have identified in each category the revisions that are more stringent than the 1991 Rule We have
also identified those revisions which may reduce your monitoring and reporting requirements, as well as revisions that
simply clarify the requirements in the original Rule You were required to begin following the requirements of the
LCRMR on April 11,2000
Throughout this fact sheet, we refer to your "regulating entity " For most Tribal systems, the regulating entity is the EPA
Region currently responsible for overseeing implementation of drinking water regulations at your system(s) For some
systems owned and operated by Tribes, the regulating entity is the State, or the proper tribal regulating agency, if the
Tribe has received primacy for the drinking water program
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)

-------
o
Revisions to Requirements for Demonstrating Optimal
Corrosion Control
The following LCRMR provision clarify the requirements of the 1991 LCR
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
The LCRMR change the procedure for assessing compliance with
optimal water quality parameters (OWQPs) as follows:
Procedure Under The Original
Lead and Copper Rule of 1991
Daily values are not used to determine compliance.
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
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 your regulating
entity
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 your regulating entity
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, EPA 815-R-99-019
Fact Sheet for Tribal Water Systems Lead and Copper Rule Minor Revisions
Page 2 of 11

-------
Š
Revisions to Monitoring and Reporting Requirements
The following LCRMR provisions clarify the requirements of the 1991 LCR
Procedure Under The Original
Lead and Copper Rule of 1991
The LCR is unclear that if you do not have enough
"high-risk" sites (1 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
regulating entity if you change your treatment or add
a new source
Km ItnuMi
7000
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
(l 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
regulating entity may specify where to collect these
samples )
If you are on reduced lead and copper tap monitoring,
you must notify your regulating entity in writing no
later than 60 days after changing treatment or adding
a new source.
Changes That May Reduce Your 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.
Procedure Under The Lead and
Copper Rule Minor Revisions
Your regulating entity 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, you may
collect samples from the taps that have the longest
standing times.
Fact Sheet for Tribal Water Systems Lead and Copper Rule Minor Revisions
Page 3 of 11

-------
Changes That May Reduce Your Monitoring Requirements
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
Procedure Under The Original
Lead and Copper Rule of 1991
Sample invalidation is not allowed
You can reduce the frequency with which you
conduct lead and copper tap water monitoring to one
every 3 years after monitoring for only 2 consecutive,
6-month monitoring periods, if your 90lh 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 may proceed to triennial WQP tap monitoring if
you are also eligible for accelerated reduced lead and
copper tap water monitoring and you meet your
OWQPs for 2 consecutive monitoring periods
Ctfpafafc
Procedure Under The Lead and
Copper Rule Minor Revisions
You can ask your regulating entity 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,
•	Your regulating entity determines that the
sample was taken from an inappropriate site,
and/or
•	Your regulating entity believes the sample was
subject to tampering
Note: If you do not have enough valid samples after
your regulating entity invalidates your sample(s), you
must collect enough replacement samples to meet the
minimum sampling requirements
Fact Sheet for Tnbal Water Systems Lead and Copper Rule Minor Revisions
Page 4 of 11

-------
Changes That May Reduce Your Monitoring Requirements
Monitoring waivers are not allowed
You are required to collect WQP samples at qU 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.
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 Ł 0 005 mg/L for
lead and Ł 0 65 mg/L for copper, and
•	your regulating entity 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, April
2000, EPA 815-R-99-021
Fact Sheet for Tnbal Water Systems Lead and Copper Rule Minor Revisions
Page 5 of 11

-------
Changes That May Reduce Your Reporting Requirements
1. You may no longer be required to calculate and report your 90lh percentile lead and copper levels if:
•	your regulating entity has notified you that it will perform this calculation,
•	you provided your sampling results and sampling site information to your regulating entity no later than the
date specified by your regulating entity (Note: this date will be sometime before the end of the monitoring
period% and
•	your regulating entity 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 regulating entity's permission to monitor for lead and
copper on a reduced schedule after you meet your OWQPs (You still must receive written approval from yo'
regulating entity before you begin reduced monitoring )
Fact Sheet for Tribal Water Systems Lead and Copper Rule Minor Revisions
Page 6 of 11

-------
0
Revisions to Public Education Requirements
Change That Require Earlier Reporting of Your Public Education Performance
Procedure Under The Original
Lead and Copper Rule of 1991
You are required to submit a letter to your regulating
entity 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 your regulating entity
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 regulating entity 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 your regulating
entity
Changes That May Reduce Your Public Education Requirements
Procedure Under The Original
Lead and Copper Rule of 1991
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.
You can delete references to LSLs in your public
education materials if you have no LSLs and you
obtain approval from your regulating entity.
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 regulating entity to modify this language
Fact Sheet for Tnbal Water Systems Lead and Copper Rule Minor Revisions
Page 7 of 11

-------
Changes That May Reduce Your Public Education Requirements
All CWSs and NTNCWSs are required to use the
same language provided by EPA
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 regulating entity 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
All CWSs are required to-
1 .provide public service announcements to radio
and TV stations semi-annually;
2.	notify the public via newspapers;
3.distribute	pamphlets to all facilities; and
organizations that provide the public with health
and/or educational services.
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 CWS that serves 3,300 or fewer persons,
you"
1 .no longer have to provide public service
announcements to radio and TV stations;
2.no	longer have to notify the public via
newspapers *
3.can	limit distribution of pamphlets to facilities
primarily serving pregnant women and children,
unless your regulating entity requires you to
make a broader distribution.*
* Ifyou serve 501 to 3,300 persons, you first must have approval
from your regulating entity
If you are an 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 regulating
entity may require you to obtain approval)
Fact Sheet for Tnbal Water Systems Lead and Copper Rule Minor Revisions
Page 8 of 11

-------
o
Revisions to Lead Service Line Replacement
Requirements
Changes to Partial Lead Service Line (LSL) Replacement Requirements
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
The 1991 rule does not specify how to notify users that
you are replacing a portion of a line and of the sample
results
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
regulating entity that demonstrates that you met your
partial LSL requirements
lŤo4 mi
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 regulating entity 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 also must submit these monitoring results to your
regulating entity 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
regulating entity 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.
Fact Sheet for Tribal Water Systems Lead and Copper Rule Minor Revisions
Page 9 of 11

-------
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.
Where Can I Obtain More Information About the LCRMR?
EPA Regions	Š EPA Regional Office Š
You can contact the EPA Region responsible for implementing the Safe Drinking Water
Act for your system. A list of contacts in each EPA Regional office is provided on the
next page.

TO?
Other Guidance Documents
Lead and Copper Rule: Minor Revisions Compared to the 1991 Rule
(EPA 816-R-00-009). This document compares the regulatory language of the LCRMR against
the LCR.
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 Ž
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 Tribal Water Systems: Lead and Copper Rule Minor Revisions
Page 10 of 11

-------
PWSS Program: Regional Indian Land Coordinators
EPA	ADDRESS	PWSS Dl CONTACT	PHONE#	FAX#
REGION
Region 1
EPA Region 1, (CCT)
1 Congress St, Suite 1100
Boston, MA 02114-2023
Mark Sceery
Ellie Kwong
Chris Ryan
(617) 918-1505
(617)918-1592
(617) 918-1567
(617) 918-1505
Region 2
EPA Region 2
290 Broadway, 24th Floor
New York, NY 10007-1866
Gerard McKenna
(212) 637-3838
(212) 637-3887
Region 4
EPA Region 4
61 Forsythe St, SW. 15,h Fir
Atlanta, GA 30303-8960
Fred Hunter
(404) 562-9477
(404) 562-9439
Region 5
EPA Region 5 (WD-15J)
77 W Jackson Blvd
Chicago, IL 60604-3507
Mary Morgan
Denis L Baker
Chuck Pycha
(312) 886-6201
(616) 271-7492
(312) 886-0259
(312) 886-6171
(616) 271-3576
see Mary's
Region 6
EPA Region 6 (6WQ-SD)
1445 Ross Ave, Suite 1200
Dallas, TX 75202-2733
Blake Atkins
(214) 665-2297
(214) 665-2191
Region 7
EPA Region 7
Mailcode (PWSSWWPD)
901 N Fifth St
Kansas City, KS 66101
Talva Hayes
Elizabeth Murtagh-Yaw
(913) 551-7416
(913) 551-7440
(913) 551-7765
Region 8
EPA Region 8 (8P-W-MS)
999 18th St, Suite 500
Denver, CO 80202-2466
Gary Carlson
Terry Griffith
Tsegaye Hailu
(303) 312-6269
(303) 312-6153
(303) 312-6273
(303) 312-6131
Region 9
EPA Region 9 (WTR-6)
75 Hawthorne St
San Francisco, CA 94105
Su Cox (N & C CA)
Kevin Ryan (E AZ)
Roger Yates (NV,
Owens Valley/E CA,
Tohono O'odham Nat)
Danny Collier (Navajo)
Helen McKinley (S CA)
Karl Banks (W AZ &
Lower Colorado River)
(415) 744-1855
(415) 744-2052
(415) 744-1843
(415) 744-1856
(415) 744-1943
(415) 744-1849
(415) 744-1235
Region 10
EPA Region 10 (OW-136)
1200 Sixth Avenue
Seattle, WA 98101
Craig Paulsen
(206) 553-4350
(206) 553-0165
VOTE: Bold type indicates lead contact for EPA Region, excluding EPA Region 9.
Fact Sheet for Tribal Water Systems Lead and Copper Rule Minor Revisions
Page 11 of 11

-------