Lead and Copper Rule:
A Quick Reference Guide for Schools and Child Care Facilities that are Regulated
Under the Safe Drinking Water Act
   CHILDREN
                                                                           This document is designed for
                                                                           schools and child care facilities
                                                                           that meet the definition of a public
                                                                           water system and therefore must
                                                                           comply with the Lead and Copper
                                                                           Rule (LCR) requirements. The
                                                                           guidance contained in this
                                                                           document does not substitute for
                                                                           EPA's regulations, nor is it a
                                                                           regulation itself. This reference
                                                                           guide provides an overview of the
                                                                           requirements but does not contain
                                                                           all of the details you will find in the
                                                                           LCR. Compliance is based on the
                                                                           actual rule language. States and
                                                                           local governments can impose
                                                                           additional requirements.
OVERVIEW OF THE RULE

Schools and child care facilities that have their own water supply and are considered non-transient, non-community
water systems (NTNCWSs) are subject to the Lead and Copper Rule (LCR) requirements.

The LCR was developed to protect public health by minimizing lead and copper levels in drinking water. The most
common source of lead and copper in drinking water is corrosion of plumbing materials. Plumbing materials that can
be made with lead and copper include pipes, solder, fixtures, and faucets.

The LCR established an action level of 0.015 mg/L (15  ppb) for lead and 1.3 mg/L (1300 ppb) for copper based on the
90th percentile level of tap water samples. This means no more than 10 percent of your samples can be above either
action level. If lead or copper levels are found above the action levels, it does not signal a violation but can trigger
other requirements that include water quality parameter (WQP) monitoring, corrosion control treatment (CCT), source
water monitoring/treatment, public education, and lead service line replacement. An explanation of how to calculate
the 90th percentile level is provided on page 3 of this guide.


HEALTH RISKS  OF LEAD AND COPPER

Children are especially susceptible to lead and copper exposure because their bodies absorb these metals at higher
rates than the average adult. Children younger than six are most at risk due to their rapid rate of growth. Exposure to
high levels of lead can cause damage to the brain, red blood cells, and kidneys. Exposure to even low levels of lead
can cause low IQ, hearing impairment, reduced attention span, and poor classroom performance. Exposure to high
levels of copper can cause stomach and intestinal distress, liver or kidney damage, and complications of Wilson's
disease in genetically predisposed people.

Because children spend so much time in school and child care facilities and their bodies are developing rapidly, it is
important to provide safe drinking water to avoid health problems linked to lead or copper exposure.
   ADULTS
High lead levels in adults have been linked to increased blood-pressure. Pregnant women and their fetuses are
especially vulnerable to lead exposure since lead can significantly harm the fetus, causing lower birth weight and
slowing down normal mental and physical development.

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KEY POINTS
SOURCES OF LEAD AND COPPER IN DRINKING WATER


When lead and copper are found in tap water it is typically due to leaching from internal plumbing materials. If the
water is too corrosive, it can cause lead or copper to leach out of the plumbing materials and enter the drinking water.

The potential for leaching increases the longer the water is in contact with the plumbing components. School water
supplies tend to have extended periods of no water use (e.g., overnight, weekends, holidays, summer) that increase
the likelihood of elevated lead levels at the tap.


LEAD AND COPPER TAP SAMPLING REQUIREMENTS


  "First draw" samples must be collected.
  Samples must be collected after the water has had time to sit in the pipes for at least 6 hours.
  If either action level is exceeded, water quality parameter (WQP) and source water sampling may be required.
  The number of lead and copper or WQP samples collected depends on the daily population served by the school
   or child care facility (see Table 1).
  Lead and copper samples must be collected every 6 months, unless the system qualifies for reduced monitoring
   (see Table 2).
  Samples for subsequent rounds of monitoring must be collected from the same sites used in the initial round.
               Table 1: Lead and Copper Tap and WQP Tap Monitoring
               School or Child
               Care Facility Daily
               Population Served
                          Number of Lead and Copper
                              Tap Sample Sites
                           Number of WQP
                           Tap Sample Sites
                                         Standard
                                            Reduced
                     Standard
                Reduced
               10,001-50,000
                            60
30
10
               3,301-10,000
                            40
20
               501 -3,300
                            20
10
               101-500
                             10
               <100
               Table 2: Criteria for Reduced Lead and Copper Tap Monitoring
               Can monitor...
                   If...
               Annually            The 90th percentile is less than both action levels (ALs) for 2 consecutive 6-month monitoring
                                  periods; or

                                  Optimal water quality parameter specifications are met for 2 consecutive 6-month monitoring
                                  periods and the primacy agency approves.

               Triennially          The 90th percentile is less than both ALs for 3 consecutive years of monitoring; or
               (every 3 years)       optimal water quality parameter specifications are met for 3 consecutive years of monitoring
                                  and the primacy agency approves; or

                                  The 90th percentile lead levels are < 0.005 mg/L and 90th percentile copper levels are < 0.65
                                  mg/L; or

                                  The system is deemed to have optimized corrosion control  by meeting the copper action level
                                  and showing:
                                        for 2 consecutive 6-month periods that the difference between the lead 90th
                                         percentile tap water level and the highest lead source water sample is less than the
                                         Practical Quantitation Limit for lead; or
                                        the highest source water lead level is below the Method Detection Level and the 90th
                                         percentile tap water lead level is < the Practical Quantitation Limit for lead for 2
                                         consecutive 6-month periods.
               Once every
               9 years
                   The school or child care facility population is < 3,300, the system meets monitoring waiver
                   criteria, and a waiver is approved by the primacy agency.

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 KEY POINTS
                CALCULATING THE 90 PERCENTILE FOR LEAD AND COPPER
                If you collect 5 samples...


                If you collect 10 samples...


                If you collect 20 or more
                samples...
                           rank the results from the lowest to the highest value, and then average the two
                           highest results. This value is the 90th percentile.

                           rank the results from the lowest to the highest value, numbering each from 1 to 10.
                           The 9th value is the 90th percentile.

                           rank the results from the lowest to the highest value, numbering each from 1 up
                           to the number of samples taken. Multiply the number of samples taken by
                           0.9. The resulting number is the value that is the 90th percentile.
                                 Example calculation: 20 samples x 0.9 = 18. The 18th value in a ranked set of
                                 sample values is the 90th percentile.
COMPLIANCE REQUIREMENTS IF ACTION LEVEL IS EXCEEDED

Four compliance areas must be addressed within certain time frames following an action level exceedance:
  Public education
  Water quality parameter (WQP) monitoring
  Source water monitoring and source water treatment
  Corrosion control treatment (CCT)

Contact your primacy agency in the event of an action level exceedance to ensure you follow the required steps.
Failure to do so may result in a compliance violation.
      Public
   Education
    within 60
       Days
When the AL for lead is exceeded, a water system must issue public education print materials (no public education is
required if only the copper AL is exceeded). (See Appendix A for an example public education poster.)
  Display informational posters on lead in drinking water in a public place or common area in each of the buildings
   served by the system; and
  Distribute informational pamphlets and/or brochures on lead in  drinking water to each person served by the
   system.

You have the option of using the alternative mandatory language provided in 141.85(a)(2) or using the original
language now contained in 141.85(a)(1). You do not need State approval before using this alternative language.
                  Public Education Requirement
                                            Poster
Pamphlet
 Compliance
Letter to State
                  Within 60 days of exceedence1
                  Every 12 months for as long
                  as exceedence occurs
                  Within 10 days after the end of each period
                  in which public education was required
                  'Applies first time action level is exceeded, and applies any subsequent time that a system exceeds the lead action level when it is not already
                  providing public education.
Water Quality
   Parameter
   Sampling
 within same
   Lead and
     Copper
   monitoring
      period
Collect water quality parameter (WQP) tap samples.
  See Table 1 for number of samples required.
  WQP samples are collected at taps and at each entry point to the distribution system.
  WQPs include: pH, alkalinity, calcium, and in the initial sample, conductivity and temperature as well. If treatment
   is currently installed, other parameters may also be included depending on the treatment type.
  After follow-up monitoring, the primacy agency will set a range of optimal WQPs.

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  Entry Point to
    Distribution
       System
    Monitoring
within 6 months
System must:
  Collect samples at each entry point to the distribution system. (You may want to use the same sampling points
   designated for chemical sampling - check with your primacy agency.)
  Make a recommendation for source water treatment.
     Corrosion
       Control
     Treatment
   KEY POINTS
within 6 months:
within 18 months:
within 24 months:

within 36 months:
Recommend optimal corrosion control treatment.
Complete corrosion control treatment study if required by primacy agency.
Install corrosion control treatment after primacy agencies has determined appropriate
treatment.
Monitor WQP at entry points for 2 consecutive 6-month periods.
COMPLIANCE REQUIREMENTS IF ACTION LEVEL EXCEEDANCE CONTINUES

If the system continues to exceed the AL after installation of corrosion control treatment or source water treatment
there are two additional compliance areas:
  Lead service line monitoring
  Lead service line replacement

Contact your primacy agency for further assistance if installation of corrosion control treatment or source water
treatment does not end AL exceedances.


DEFINITIONS

90th Percentile          The highest concentration of lead or copper in tap water that is exceeded by 10  percent of
                      the sites sampled during a monitoring period. This value is compared to the lead action
                      level (AL) to determine whether an AL has been exceeded. (See "Calculating the 90th
                      Percentile" above for instructions.)

Action Level (AL)        The concentration of lead or copper in tap water which determines whether a system may be
                      required to install corrosion control treatment, collect water quality parameter samples,
                      collect source water samples, replace lead service lines, and/or deliver public education
                      about lead. The action level for lead is 0.015 mg/L or 15 ppb. The action level for  copper is
                      1.3 mg/L or 1300 ppb.
                   Corrosion Control
                   Treatment (CCT)
                      Water treatment generally in the form of chemical addition meant to reduce the corrosivity
                      of the water.
                   Entry Point to the
                   Distribution System
                   First Draw Sample
                   Method Detection
                   Limit (MDL)
                      An entry point to the distribution system is a point after any treatment is applied, but
                      before water reaches the first consumer. Because this location is often used for sampling, it
                      is ideal to have a dedicated sampling tap which is inaccessible for drinking purposes.

                      A tap water sample taken after water has been standing motionless in plumbing pipes for a
                      period of time and is collected without flushing the tap. Approximately 8 hours is an ideal
                      amount of time to let the water sit before collecting a first draw sample, a minimum of 6
                      hours is required.

                      The minimum concentration of a substance that can be measured and reported with 99
                      percent confidence that the analyte concentration is greater than zero.
                   Optimal Water Quality
                   Parameters

                   Practical Quantitation
                   Limit (POL)
                   Water Quality
                   Parameters (WQPs)
                      Ranges or minimums set by the primacy agency that indicate a system's CCT is operating
                      at a level to most effectively minimize lead and copper concentrations at user's taps.

                      The concentration that can be reliably measured within specified limits during routine
                      laboratory operating conditions using approved methods. The PQL for lead is 0.005 mg/L.
                      The PQL for copper is 0.050 mg/L.

                      A set of water qualities or characteristics used to help systems and states determine what
                      levels of CCT would work best for the system and whether this treatment is being properly
                      operated and maintained overtime. WQPs include: pH, alkalinity, calcium, conductivity, and
                      temperature. If treatment is currently installed, other parameters such as orthophosphate
                      and silica may also be included depending on the treatment type.
                                                                                                       Office of Water (4606)
                                                                                              EPA 816-F-05-030, October 2005
                                                                                                                        4

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                                                                                                           Appendix A
              'AD   in   Drinkin?   Water
   HEALTH EFFECTS
       OF LEAD
     Lead is found throughout
     the environment in lead-
     based  paint,  air, soil,
household dust, food, certain
types of pottery porcelain and
pewter, and water. Lead can pose
a significant risk to your health
if too much  of  it enters your
body.

    Lead builds up in the body
over many years and can cause
damage to the brain, red blood
cells and kidneys. The greatest
risk is to young children and
pregnant women. Amounts of
lead that won't hurt adults can
slow down normal mental and
physical development of grow-
ing bodies. In addition, a child
at play often comes  into con-
tact with sources of lead con-
tamination - like dirt and dust -
thar rarely affect an adult. It is
important ro  wash
children's hands
and toys often,
and to try to
make sure they
only put food
in their mouths.
        LEAD IN
   DRINKING WATER
     Lid in drinking water,
       although rarely the
       sole cause of lead poi-
soning, can significantly increase
a person's total lead exposure,
particularly the exposure of in-
fants who drink baby formulas
and concentrated juices that are
mixed with water. EPA estimates
that drinking water can makeup
20 percent or more of a person's
total exposure to lead.
 THE UNITED  STATES ENVIRONMENTAL PROTECTION
 AGENCY (EPA)  and (a)
 are concerned about lead in your drinking water. Some drinking water
 samples taken from this facility have lead levels above the EPA action
 level of 15 parts per billion (ppb), or 0.015 milligrams of lead per liter
 of water (mg/L). Under Federal law we are required to have a program
 in place co minimize lead in your drinking water by (b)

     This program includes:
 1)  Corrosion control treatment (treating the water to make it less
      likely that lead will dissolve into the water);
 2}  Source water treatment (removing any lead that is in the water at
     the time it leaves our treatment facility); and
 3)  A public education program.

     If you have any questions about how we are carrying out the re-
 quirements of the lead regulation please call  us at (c)

     This poster also explains the simple steps you can take to protect
 yourself by reducing your exposure to lead in drinking water.
    HOW LEAD ENTERS
        OUR WATER
      Lid is unusual among drinking
       water contaminants in that it
       seldom occurs naturally in
water supplies like rivers and lakes.
Lead enters drinking water primarily
as a result of the corrosion, or wearing
away, of materials containing lead in
the water distribution system and
household plumbing. These materials
include lead-based solder used to join
copper pipe, brass and chrome-plated
brass faucets, and in some cases,pipes
made of lead that connect houses and
buildings to water mains (service
lines). In  1986, Congress banned the
use of lead solder containing greater
than 0.2% lead, and restricted the
lead content of faucets, pipes and
other plumbing materials to 8.0%.

    When water stands in lead pipes
or plumbing systems containing lead
for several hours or more, the lead
may dissolve into your drinking wa-
ter. This means the first water drawn
                FOR MORE INFORMATION

   YOU CAN CONSULT a variety of sources for additional information:
   Your family doctor or pediatrician can perform a blood test for lead and
provide you with information about the health effects of lead. State and local
government agencies that can be contacted include:
  (d)                        at (e)                         can
provide you with information about your facility's water supply; and
  (f)                        at (g)                       or the
  (h)                        at (i)                          can
provide you with information about the health effects of lead.
                                from the tap in the morning, or
                                later in the afternoon if the water
                                has not been used all day, can con-
                                tain fairly high levels of lead.
                                 STEPS YOU CAN TAKE
                                  to Reduce Exposure to
                                  Lead in Drinking Water
1. FLUSH YOUR SYSTEM. Let
the water run from the tap before
using it for drinking or cooking
any time the water in a faucet has
gone unused for more than six
hours. The longer water resides
in plumbing the more lead it may
contain.  Flushing the tap means
running the cold water faucet for
about  15-30 seconds. Although
toilet flushing or showering
flushes water through a portion of
the plumbing system, you still
need to flush the water in each
faucet before using it for drinking
or cooking. Flushing tap water is
a simple and inexpensive measure
you can take to protect your
health.  It usually uses less than
one to two gallons of water.

2. USE ONLY COLD WATER
FOR    COOKING   AND
DRINKING. Do not cook with,
or drink water from the hot water
tap. Hot water can dissolve more
lead more quickly than cold wa-
ter.  If you need hot water, draw
water from the cold tap and then
heat it.

3.  USE  BOTTLED WATER.
The steps described above will re-
duce  the  lead
concentrations
in your drink-
ing   water.
However,  if
you are still con-
cerned, you may
wish to use bottled
water for drinking and cooking.

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