Lead and  Copper Rule  Minor  Revisions:

                                  Fact  Sheet


EPA815-F-99-010, December 1999

EPA has made minor changes to the Lead and Copper Rule. These minor revisions (also known as the
Lead and Copper Rule Minor Revisions or LCRMR) streamline requirements, promote consistent
national implementation, and in many cases, reduce burden for water systems. The LCRMR do not
change the action levels of 0.015 mg/L for lead and 1.3 mg/L for copper, or Maximum Contaminant
Level Goals established by the 1991 Lead and Copper Rule ("the rule"), which are 0 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.


As part of the LCRMR rulemaking process, the Agency collected additional data pertaining to the
exclusion of transient non-community water systems from the requirements of the rule. EPA
concluded that it is still appropriate to continue this exclusion because the Agency believes there are
de minimus (minimal) non-carcinogenic adverse health effects resulting from exposure to lead in
drinking water at such systems. This fact sheet provides a discussion of the major changes to the rule
resulting from the LCRMR.


Who Is Affected by the LCRMR?

All water system operators and managers of community water systems (CWSs) and non-transient
non-community water systems (NTNCWSs) are potentially affected, as well as the state staff who are
responsible for implementing the Lead and Copper Rule in their state.


What Are the Changes to the Lead and Copper  Rule?

The changes fall into seven broad categories as follows.

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Demonstration of Optimal Corrosion Control

           Clarify that systems must optimize corrosion control and continue to maintain and
            operate any corrosion control that is already in place.
           Add the requirement for systems that are deemed to be optimized because there is little
            or no corrosion occurring in their distribution system to:

              monitor for lead and copper tap samples once every 3 years, and meet the copper
              action level.

           Change the way in which compliance with state-designated optimal water quality
            parameters (WQP) is determined.
Lead Service Line Replacement Requirements

           Require systems subject to lead service line replacement requirements to replace the
            portion of the lead service line that they own.
           Require systems that replace only part of a lead service line that they own to notify
            residents of the potential for temporary increases in lead levels and measures they can
            take to reduce lead levels.
Public Education Requirements

           Allow NTNCWSs and special-case CWSs to use alternative language which is more
            appropriate for their systems.
           Provide more flexibility in the mode of delivery for public education, especially for
            NTNCWSs and those CWSs serving 3,300 or fewer people.
Monitoring Requirements

           Allow systems with low lead and copper tap levels to conduct tap water monitoring and
            WQP tap monitoring once every 3 years without first conducting interim rounds of more
            frequent monitoring.
           Allow NTNCWSs and certain CWSs that do not have enough taps where the water has
            stood motionless for at least 6 hours to collect samples from taps with the longest
            standing times.
           Permit more flexibility in the time of year when systems can conduct reduced
            monitoring.
           Permit some ground water systems to limit biweekly entry point monitoring to
            representative locations.
           Allow states to grant monitoring waivers to small systems with plumbing free of lead-
            and copper-containing materials.
           Allow systems to reduce the frequency of source water monitoring if they have low levels
            of source water lead and copper.
           Clarify and provide more flexibility in sampling site requirements.
           Revise the resampling triggers for composite  lead and copper source water samples.
           Permit states to invalidate tap samples under certain circumstances.
           Require systems, on reduced lead and copper tap monitoring,  to report to the State
            changes in treatment or an addition of a new water source.

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Analytical Methods
           Update the analytical methods for lead and copper to conform with changes in the
            standard methods for other inorganic chemicals.
Reporting and Record Keeping Requirements

           Revise and streamline state reporting requirements.
           Remove system reporting requirements that are redundant or no longer necessary, and
            add other reporting requirements that reflect the LCRMR.
           Revise record keeping requirements for States to reflect the LCRMR.
Special Primacy Considerations

           Add special state primacy considerations for determining optimal WQP compliance when
            multiple samples are collected per day, to verify the completion of partial lead service
            line replacement activities, and designating alternative reduced lead and copper
            monitoring periods for CWSs.


When Do These Changes Take Effect?

The Federal effective date for these revisions is April 11, 2000. However, systems should check with
their state primacy agencies because not all provisions may apply in their state.

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