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Reference Guide for Public Water Systems
Lead and Copper Rule Comparison
This table compares the major differences between the current Lead and Copper Rule (LCR) and the final Lead and Copper Rule revisions (LCRR).
In general, requirements that are unchanged are not listed. For existing rule requirements visit: https://www.epa.gov/dwreginfo/lead-and-copper-rule.
For more information on the new LCR visit: https://www.epa.gov/ground-water-and-drinking-water/final-revisions-lead-and-copper-rule.
CURRENT LCR
FINAL REVISED LCRR
Action Level (AL) and Trigger Level (TL)
• 90th percentile (P90) level above lead AL of 15 |ig/L or copper AL
of 1.3 mg/L requires additional actions.
• 90th percentile (P90) level above lead AL of 15 |ig/L or copper AL
of 1.3 mg/L requires more actions than the previous rule.
• Defines lead trigger level (TL) of 10 < P90 <15 |ig/L that triggers
additional planning, monitoring, and treatment requirements.
Lead and Copper Tap Monitoring
Sample Site Selection
• Prioritizes collection of samples from sites with sources of lead in
contact with drinking water.
• Highest priority given to sites served by copper pipes with lead
solder installed after 1982 but before the state ban on lead pipes
and/or LSLs.
• Systems must collect 50% of samples from LSLs, if available.
Sample Site Selection
• Changes priorities for collection of samples with a greater focus on
LSLs.
• Prioritizes collecting samples from sites served by LSLs -all
samples must be collected from sites served by LSLs, if available.
• No distinction in prioritization of copper pipes with lead solder by
installation date.
• Improved tap sample site selection tiering criteria.
Collection Procedure
• Requires collection of the first liter sample after water has sat
stagnant for a minimum of 6 hours.
Collection Procedure
• Requires collection of the fifth-liter sample in homes with LSLs after
water has sat stagnant for a minimum of 6 hours and maintains first-
liter sampling protocol in homes without LSLs.
• Adds requirement that samples must be collected in wide-mouth
bottles.
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CURRENT LCR
Monitoring Frequency
• Samples are analyzed for both lead and copper.
• Systems must collect standard number of samples, based on
population; semi-annually unless they qualify for reduced
monitoring.
• Systems can qualify for annual or triennial monitoring at reduced
number of sites. Schedule based on number of consecutive years
meeting the following criteria:
o Serves < 50,000 people and < lead & copper ALs.
o Serves any population size, meets state-specified optimal water
quality parameters (OWQPs), and < lead AL.
• Triennial monitoring also applies to any system with lead and
copper 90th percentile levels < 0.005 mg/L and < 0.65 mg/L,
respectively, for 2 consecutive 6-month monitoring periods.
• 9-year monitoring waiver available to systems serving < 3,300.
FINAL REVISED LCRR
• Prohibits sampling instructions that include recommendations for
aerator cleaning/removal and pre-stagnation flushing prior to sample
collection.
Monitoring Frequency
• Some samples may be analyzed for only lead when lead monitoring
is conducted more frequently than copper.
• Copper follows the same criteria as the current rule.
• Lead monitoring schedule is based on P90 level for all systems as
follows:
o P90 > 15 jig/L: Semi-annually at the standard number of sites,
o P90 > 10 to 15 jig/L: Annually at the standard number of sites,
o P90 < 10 jig/L:
¦ Annually at the standard number of sites and triennially at
reduced number of sites using same criteria as previous rule
except copper 90th percentile level is not considered.
¦ Every 9 years based on current rule requirements for a 9-year
monitoring waiver.
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CURRENT LCR
FINAL REVISED LCRR
Corrosion Control Treatment (CCT) and Water Quality Parameters (WQPs)
CCT
• Systems serving > 50,000 people were required to install treatment
by January 1, 1997 with limited exception.
• Systems serving < 50,000 that exceed lead and/or copper AL are
subject to CCT requirements (e.g., CCT recommendation, study if
required by primacy agency, CCT installation). They can
discontinue CCT steps if no longer exceed both ALs for two
consecutive 6-month monitoring periods.
• Systems must operate CCT to meet any primacy agency-designated
OWQPs that define optimal CCT.
• There is no requirement for systems to re-optimize.
CCT
• Specifies CCT requirements for systems with 10 < P90 level <15
[igfL:
o No CCT: must conduct a CCT study if required by primacy
agency.
o With CCT: must follow the steps for re-optimizing CCT, as
specified in the rule.
• Systems with P90 level >15 (J,g/L:
o No CCT: must complete CCT installation regardless of their
subsequent P90 levels,
o With CCT: must re-optimize CCT.
o CWSs serving < 10,000 people and non-transient water systems
(NTNCWSs) can select an option other than CCT to address lead.
See Small System Flexibility.
CCT Options: Includes alkalinity and pH adjustment, calcium
hardness adjustment, and phosphate or silicate-based corrosion
inhibitor.
CCT Options: Removes calcium hardness as an option and specifies
any phosphate inhibitor must be orthophosphate.
Regulated WQPs:
• No CCT: pH, alkalinity, calcium, conductivity, temperature,
orthophosphate (if phosphate-based inhibitor is used), silica (if
silica-based inhibitor is used).
• With CCT: pH, alkalinity, and based on type of CCT either
orthophosphate, silica, or calcium.
Regulated WQPs:
• Eliminates WQPs related to calcium hardness (i.e., calcium,
conductivity, and temperature).
WQP Monitoring
• Systems serving > 50,000 people must conduct regular WQP
monitoring at entry points and within the distribution system.
• Systems serving < 50,000 people conduct monitoring only in those
periods > lead or copper AL.
WQP Monitoring
• Systems serving > 50,000 people must conduct regular WQP
monitoring at entry points and within the distribution system.
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CURRENT LCR
FINAL REVISED LCRR
• Contains provisions to sample at reduced number of sites in
distribution system less frequency for all systems meeting their
OWQPs.
• Systems serving < 50,000 people must continue WQP monitoring
until they no longer > lead and/or copper AL for two consecutive 6-
month monitoring periods.
• To qualify for reduced WQP distribution monitoring, P90 must be <
10 |ig/L and the system must meet its OWQPs.
Sanitary Survey Review:
• Treatment must be reviewed during sanitary surveys; no specific
requirement to assess CCT or WQPs.
Sanitary Survey Review:
• CCT and WQP data must be reviewed during sanitary surveys
against most recent CCT guidance issued by EPA.
Find-and-Fix:
No required follow-up samples or additional actions if an individual
sample exceeds 15 (J,g/L.
Find-and-Fix:
If individual tap samples >15 |ig/L.
o Find-and-fix steps:
o Collect tap sample at the same tap sample site within 30 days,
o For LSL, collect any liter or sample volume,
o If LSL is not present, collect 1 liter first draw after stagnation,
o For systems with CCT
o Conduct WQP monitoring at or near the site >15 (J,g/L.
o Perform needed corrective action.
o Document customer refusal or nonresponse after 2 attempts,
o Provide information to local public health officials.
LSL Inventory and LSLR Plan
Initial LSL Program Activities:
• Systems were required to complete a materials evaluation by the
time of initial sampling. No requirement to update materials
evaluation.
• No LSLR plan is required.
Initial LSL Program Activities:
• All systems must develop an LSL inventory or demonstrate absence
of LSLs within 3 years of final rule publication.
• LSL inventory must be updated annually or triennially, based on
their tap sampling frequency.
• All systems with known or possible LSLs must develop an LSLR
plan.
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LSLR:
• Systems with LSLs with P90 >15 |ig/L after CCT installation must
annually replace >7% of number of LSLs in their distribution
system when the lead action level is first exceeded.
• Systems must replace the LSL portion they own and offer to replace
the private portion at the owner's expense.
• Full LSLR, partial LSLR, and LSLs with lead sample results <15
|ig/L ("test-outs") count toward the 7% replacement rate.
• Systems can discontinue LSLR after 2 consecutive 6-month
monitoring periods < lead AL.
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LSLR:
• Rule specifies replacement programs based on P90 level for CWSs
serving > 3,300 people:
o If P90 >15 |ig/L: Must fully replace 3% of LSLs per year based
upon a 2 year rolling average (mandatory replacement) for at least
4 consecutive 6-month monitoring periods,
o If P90 > 10 to 15 |ig/L: Implement an LSLR program with
replacement goals in consultation with the primacy agency for 2
consecutive 1-year monitoring periods.
• Small CWSs and NTNCWSs that select LSLR as their compliance
option must complete LSLR within 15 years if P90 >15 jag/L See
Small System Flexibility.
• Annual LSLR rate is based on number of LSLs and galvanized
requiring replacement when the system first exceeds the action level
plus the current number of lead status unknown service lines.
• Only full LSLR (both customer-owned and system-owned portion)
count toward mandatory rate or goal-based rate.
• All systems replace their portion of an LSL if notified by consumer
of private side replacement within 45 days of notification of the
private replacement. If the system cannot replace the system's
portion within 45 days, it must notify the state and replace the
system's portion within 180 days.
• Following each LSLR, systems must:
o Provide pitcher filters/cartridges to each customer for 6 months
after replacement. Provide pitcher filters/cartridges within 24
hours for full and partial LSLRs.
o Collect a lead tap sample at locations served by replaced line
within 3 to 6 months after replacement.
• Requires replacement of galvanized service lines that are or ever
were downstream of an LSL.
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CURRENT LCR
FINAL REVISED LCRR
LSL-Related Outreach:
• When water system plans to replace the portion it owns, it must
offer to replace customer-owned portion at owner's expense.
• If system replaces its portion only:
o Provide notification to affected residences within 45 days prior
to replacement on possible elevated short-term lead levels and
measures to minimize exposure,
o Include offer to collect lead tap sample within 72 hours of
replacement.
o Provide test results within 3 business days after receiving results.
LSL-Related Outreach:
• Inform consumers annually that they are served by LSL or lead
status unknown service line.
• Systems subject to goal-based program must:
o Conduct targeted outreach that encourages consumers with LSLs
to participate in the LSLR program,
o Conduct an additional outreach activity if they fail to meet their
goal.
o Systems subject to mandatory LSLR include information on LSLR
program in public education (PE) materials that are provided in
response to P90 > AL.
Small System Flexibility
No provisions for systems to elect an alternative treatment approach
but sets specific requirements for CCT and LSLR.
Allows CWSs serving < 10,000 people and all NTNCWSs with P90 >
10 |ig/L to select their approach to address lead with primacy agency
approval:
• Systems can choose CCT, LSLR, provision and maintenance of
point-of-use devices; or replace all lead-bearing plumbing materials.
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CURRENT LCR
FINAL REVISED LCRR
• All CWSs must provide education material in the annual
Consumer Confidence Report (CCR).
• Systems with P90 > AL must provide PE to customers about
lead sources, health effects, measures to reduce lead exposure,
and additional information sources.
• Systems must provide lead consumer notice to individuals
served at tested taps within 30 days of learning results.
• Customers can contact the CWS to get PE materials translated
in other languages.
• CWSs must provide updated health effects language in all PE
materials and the CCR.
o Customers can contact the CWS to get PE materials translated in
other languages.
• All CWSs are required to include information on how to access the
LSL inventory and how to access the results of all tap sampling in
the CCR.
• Revises the mandatory health effects language to improve accuracy
and clarity.
• IfP90> AL:
o Current PE requirements apply.
o Systems must notify consumers of P90 > AL within 24 hours.
• In addition, CWSs must:
o Deliver notice and educational materials to consumers during
water-related work that could disturb LSLs.
o Provide information to local and state health agencies,
o Provide lead consumer notice to consumers whose individual tap
sample is > 15 |ig/L as soon as practicable but no later than 3
days.
Also see LSL-Related Outreach section of table.
Systems on a reduced tap monitoring schedule must obtain prior
primacy agency approval before changing their source or treatment.
Systems on any tap monitoring schedule must obtain prior primacy
agency approval before changing their source or treatment. These
systems must also conduct tap monitoring biannually.
• Periodic source water monitoring is required for systems with:
o Source water treatment; or
o P90 > AL and no source water treatment.
• Primacy Agencies can waive continued source water monitoring if
the:
o System has already conducted source water monitoring for a
previous P90 > AL;
o primacy agency has determined that source water treatment is not
required; and
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CURRENT LCR
FINAL REVISED LCRR
o System has not added any new water sources.
• Does not include separate testing and education program for CWSs
at schools and child care facilities.
• Schools and child cares that are classified as NTNCWSs must
sample for lead and copper.
• CWS must conduct sampling at 20% of elementary schools and 20%
of child care facilities per year and conduct sampling at secondary
schools on request for 1 testing cycle (5 years) and conduct sampling
on request of all schools and child care facilities thereafter.
• Sample results and PE must be provided to each sampled
school/child care, primacy agency and local or state health
department.
• Excludes facilities built or replaced all plumbing after January 1,
2014.
Primacy Agencies must report information to EPA that includes but is
not limited to:
• All P90 levels for systems serving > 3,300 people, and only levels >
15 |ig/L for smaller systems.
• Systems that are required to initiate LSLR and the date replacement
must begin.
• Systems for which optimal corrosion control treatment (OCCT) has
been designated.
Expands current requirements to include:
• All P90 values for all system sizes.
• The current number of LSLs and lead status unknown service lines
for every water system.
• OCCT status of all systems including primacy agency-specified
OWQPs.
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