United States
Environmental Protection
Agency
Office of Water
4606
EPA 816-F-00-010
February 2001
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 monitoring,
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:
Demonstrating optimal corrosion control
Monitoring and reporting
Public education
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)
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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 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.
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.
lad and
Copper Rule
pinorRnisions
2000
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,
EPA815-R-99-019.
Fact Sheet for Tribal Water Systems: Lead and Copper Rule Minor Revisions
Page 2 of 9
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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 (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 regulating
entity if you change your treatment or add a new source.
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 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.
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.
I Iradond
1 Copp.rR.1.
Ni Minor Revisions
I 2000
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.
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 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.
Fact Sheet for Tribal Water Systems: Lead and Copper Rule Minor Revisions
Page 3 of 9
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Changes That May Reduce Your Monitoring Requirements
Procedure Under The Original
Lead and Copper Rule of 1991
Sample invalidation is not allowed.
Monitoring waivers are not allowed.
You are required to collect WQP samples at all 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.
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.
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 O.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 O.005 mg/L for lead
and O.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,
EPA815-R-99-021.
Fact Sheet for Tribal Water Systems: Lead and Copper Rule Minor Revisions
Page 4 of 9
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Changes That May Reduce Your Reporting Requirements
1. You may no longer be required to calculate and report your 90th 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 your regulating entity
before you begin reduced monitoring.)
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.
Fact Sheet for Tribal Water Systems: Lead and Copper Rule Minor Revisions
Page 5 of 9
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Changes That May Reduce Your Public Education Requirements
y^rk? Procedure Under The Original
^/7 Lead and Copper Rule of 1991
I Uodond
1 C.pperR.1.
B Minor RMiaons
s 2000
*3
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 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.
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:
provide public service announcements to radio and
TV stations semi-annually;
notify the public via newspapers;
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:
no longer have to provide public service
announcements to radio and TV stations;
no longer have to notify the public via newspapers.*
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 Tribal Water Systems: Lead and Copper Rule Minor Revisions
Page 6 of 9
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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.
^ 7 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 your
regulating entity 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 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.
w
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 Tribal Water Systems: Lead and Copper Rule Minor Revisions
Page 7 of 9
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Where Can I Obtain More Information About the LCRMR?
EPA Regions
»EPA Regional Office
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.
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.
^^p^ffl
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.
->»
^Mf%
T&K
'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 Tribal Water Systems: Lead and Copper Rule Minor Revisions
Page 8 of 9
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PWSS Program: Regional Indian Land Coordinators
EPA
REGION
Region 1
Region 2
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
ADDRESS
EPA Region 1 , (CCT)
1 Congress St., Suite 1100
Boston, MA 02 11 4-2023
EPA Region 2
290 Broadway, 24th Floor
New York, NY 10007-1 866
EPA Region 4
61 Forsythe St, SW, 15th Fir
Atlanta, GA 30303-8960
EPA Region 5 (WD-15J)
77 W. Jackson Blvd
Chicago, IL 60604-3507
EPA Region 6 (6WQ-SD)
1445 Ross Ave, Suite 1200
Dallas, TX 75202-2733
EPA Region 7
Mailcode:(PWSSWWPD)
901 N. Fifth St.
Kansas City, KS66101
EPA Region 8 (8P-W-MS)
999 1 8th St, Suite 500
Denver, CO 80202-2466
EPA Region 9 (WTR-6)
75 Hawthorne St
San Francisco, CA 94105
PWSS Dl CONTACT
Mark Sceery
Ellie Kwong
Chris Ryan
Gerard McKenna
Fred Hunter
Mary Morgan
Denis L. Baker
Chuck Pycha
Blake Atkins
Talva Hayes
Elizabeth Murtagh-Yaw
Gary Carlson
Terry Griffith
Tsegaye Hailu
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)
PHONE #
(617)918-1505
(617)918-1592
(617)918-1567
(212)637-3838
(404) 562-9477
(312)886-6201
(616)271-7492
(312)886-0259
(214) 665-2297
(913)551-7416
(913)551-7440
(303)312-6269
(303)312-6153
(303)312-6273
(415)744-1855
(415)744-2052
(415)744-1843
(415)744-1856
(415)744-1943
(415)744-1849
FAX#
(617)918-1505
(212)637-3887
(404) 562-9439
(312)886-6171
(616)271-3576
see Mary's
(214)665-2191
(913)551-7765
(303)312-6131
(415)744-1235
Region 10 EPA Region 10 (OW-136)
1200 Sixth Avenue
Seattle, WA 98101
Craig Paulsen
(206) 553-4350 (206) 553-0165
NOTE: 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 9 of 9
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