DRAFT United States

Environmental Protection

Agency

Office of Water

4606

EPA 816-F-00-007

March 2000

Lead and Copper Rule Minor Revisions 

Fact Sheet for Public Water Systems that Serve

3,300 or Fewer Persons

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) take 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:

Ï Demonstrating optimal corrosion control

Ì Monitoring and reporting

Ó Public education

Ô Lead service line replacement

In this fact sheet, we have identified for each category: 1) the revisions that you must begin complying with by

April 11, 2000 and 2) the revisions that you cannot implement unless and until they are adopted by your State

and incorporated into your State’s drinking water regulations. Check with your State Primacy Agency to

determine when and if provisions that depend on State adoption will take effect in your State.

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)
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions Page 2 of 10

ÏRevisions to Requirements for 

Demonstrating Optimal 

 Corrosion Control

You Must Begin Complying with

These Requirements on April 11, 2000

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.

Revisions That Depend on State Adoption

Determining Whether You Comply with Your Optimal Water Quality Parameters (OWQPs)

Daily values were not used to determine compliance. “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 were out of compliance if at any time the results of

any WQP sample were below the minimum value or

outside the range of values designated by the State.

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 the State. 

Compliance determinations are always based on 6-month

periods, regardless of your monitoring schedule (e.g.,

daily, biweekly, semi-annually, annually, triennially) or

whether the sample is from an entry point or tap.

You could collect a confirmation sample within 3 days of

the original sample. If you collected this sample, the

results of the original sample and the confirmation

sample were averaged to determine compliance. 

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, March 2000, EPA

815-R-99-019.
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions Page 3 of 10

ÌRevisions to Monitoring and

Reporting Requirements

You Must Begin Complying with

These Requirements on April 11, 2000

The LCR was unclear that if you did not have enough

"high-risk" sites (i.e., Tier 1, 2, or 3 sites) that you were

still required to collect the minimum number of tap

samples.

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.

The LCR did not specify which sites to use for reduced

lead and copper tap monitoring.

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 State entity may

specify where to collect these samples.)

The LCR did not require you to notify your State if you

changed your treatment or added a new source.

If you are on reduced lead and copper tap monitoring, you

must notify your State in writing no later than 60 days after

changing treatment or adding a new source. 

Revisions That Depend on State Adoption

Monitoring Requirements

You were required to conduct reduced lead and copper

monitoring only during the months of June to September.

Your State may allow you to conduct reduced lead and

copper monitoring during months other than June to

September.

You were required to collect first-draw lead and copper

samples, regardless of whether you had enough taps that

could supply first-draw samples.

If you a system that operates 24 hours a day 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 were required to conduct 3 consecutive years of lead

and copper tap monitoring before reducing your monitoring

frequency to once every 3 years (triennial).

You can collect lead and copper tap water monitoring once

every 3 years after monitoring for only 2 consecutive, 6-

month monitoring periods, if your 90th 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).

Before being allowed to conduct triennial WQP tap

monitoring, you were required to be in compliance with

your OWQPs for at least 6 consecutive years.

You can proceed to triennial WQP tap monitoring if you

also qualify for accelerated reduced lead and copper tap

water monitoring and are in compliance with your OWQPs

for 2 consecutive monitoring periods.
Revisions That Depend on State Adoption

Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions Page 4 of 10

Monitoring Requirements (continued)

Sample invalidation was not allowed. You can ask your State 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.

• The State determines that the sample was taken from

an inappropriate site.

• The State believes the sample was tampered with.

Note: If you do not have enough valid samples after the

State invalidates your sample(s), you must collect enough

replacement samples to meet the minimum sampling

requirements.

No monitoring waivers were allowed. You may request a 9-year monitoring waiver for lead and/or

copper tap monitoring if:

C you serve 3,300 or fewer persons;

C your 90th percentile levels are #0.005 mg/L for lead

and/or #0.65 mg/L for copper; and

C your plumbing materials meet certain criteria that

indicate negligible risk from lead and/or copper

exposure.

You were required to collect WQP samples at all of your

entry points.

You may limit biweekly WQP entry point monitoring to

representative locations if:

C you are a ground water system; and

C you can demonstrate that these sites are representative

of your system's water quality conditions.

If you exceeded an action level but were not required to

install source water treatment, you were not allowed to

reduce the frequency with which you collected source water

samples.

You may conduct source water monitoring on a reduced

schedule even though you exceed an action level, if:

C your source water levels are #0.005 mg/L for lead and

#0.65 mg/L for copper; and

C your State 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, March 2000,

EPA 815-R-99-021.
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions Page 5 of 10

Reporting Revisions That Depend on State Adoption

1. You may no longer be required to calculate and report your 90th percentile lead and copper levels if:

C your State has notified you that it will perform this calculation;

C you provided your sampling results and sampling site information to your State no later than the date specified by

your State (Note: this date will be sometime before the end of the monitoring period); and

C your State 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 State’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 State before you begin

reduced monitoring.)
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions Page 6 of 10

Ó Revisions to Public Education 

 Requirements

You Must Begin Complying with

These Requirements on April 11, 2000

You were required to submit a letter to the State

demonstrating that you met your public education

requirements. This letter was due by December 31 of the

year in which you performed public education. 

You must submit a letter to the State 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.

Revisions That Depend on State Adoption

Mandatory Public Education Language

You were required to include information about LSLs, even

if your system had no LSLs.

You can delete references to LSLs in your public education

materials if you have no LSLs and you obtain approval

from your State.

You were not allowed to modify language regarding the

availability of building permits and consumer access to

these records.

If you are a community water system (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 State to modify this language.

All CWSs and non-transient, non-community water systems

(NTNCWSs) were 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 State may require

you to obtain approval.)
Revisions That Depend on State Adoption

Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions Page 7 of 10

Distribution of Public Education Materials

All CWSs were required to: 

• enclose your public education materials in the

customers’ regular water bills

• 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 CWS, you:

• can mail public education materials separately from

your bill;

• 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 State requires you to make a broader

distribution.*

*If you serve 501 to 3,300 persons, you first must have approval

from your State.

If you were a NTNCWS, you could only post information

and distribute pamphlets; you could not use e-mail to

distribute public education information.

If you are a 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.

All CWSs were required to:

C Insert notices in the water bill

C Submit information to newspapers

C Distribute pamphlets

C Broadcast information via TV and radio

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 State may require you to obtain

approval.)
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions Page 8 of 10

Ô Revisions to Lead Service Line 

Replacement Requirements

You Must Begin Complying with

These Requirements on April 11, 2000

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.

There was no specific required deadline to provide

notification of partial replacement.

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 State may allow a shorter time frame

for this notification.

For each resident served by a partially replaced line, you

had to offer to collect and analyze a first-flush tap sample,

after you completed the partial replacement. This sample

would have been collected at the tap of each resident that

had accepted your offer.

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.

If resident(s) had accepted your offer, you were required to

collect the sample(s) and report results to the resident(s)

within 14 days following the partial line replacement.

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 had to report the sample results to residents.

You were not required to report any information to the

State that demonstrated that you met your partial LSL

requirements.

You must report sample results to the building owner(s) and

the resident(s) served by the partially replaced line.

You also must submit these monitoring results to the State

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 State to be

sure of your specific requirements.

The LCR did not specify how to notify users about the

partial replacement or the post-replacement sample results.

You must notify residents by mail. However, for multifamily dwellings you can post the notification in a

conspicuous common-use area of the building.

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, March 2000,

EPA 815-R-99-022.
Fact Sheet for Small Water Systems: Lead and Copper Rule Minor Revisions Page 9 of 10

Where Can I Obtain More Information About the LCRMR?

 State or EPA Regional Office

You can contact the EPA Region responsible for implementing the Safe Drinking

Water Act for your systems. A list of contacts in each EPA Regional office is

provided on the next page.

 Other Guidance Documents

Lead and Copper Rule: Compliance Dates, March 2000, EPA 815-R-99-020. This

document helps you understand when you must begin complying with the new

requirements of the LCRMR. This guidance contains a discussion of each of the important

changes made to the 1991 Rule by the LCRMR by major rule section (i.e., §141.81,

§141.82, §§141.84-141.90, and §141.43), and identifies when you must begin complying

with the new requirements. It also contains an appendix which compares the rule language

of the LCR against the minor revisions. 

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

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 Small Water Systems: Lead and Copper Rule Minor Revisions Page 10 of 10

EPA Regional Offices

EPA Region 1

Associate Director for Drinking Water

Policy

One Congress Street

Suite 1100

Boston, MA 02114-2023

(617) 918-1571

Connecticut, Massachusetts, Maine, New Hampshire,

Rhode Island, Vermont

EPA Region 6

Source Water

Protection Branch

1445 Ross Avenue

Dallas, TX 75202

(214) 665-7150

Arkansas, Louisiana, New Mexico,

Oklahoma, 

Texas

EPA Region 2

Water Programs Branch

290 Broadway

New York, NY 10007-1866

(212) 637-3826

New Jersey, New York, Puerto Rico, Virgin Islands

EPA Region 7

Drinking Water Branch

901 N. 5th Street

Kansas City, KS 66101

(913) 551-7032

Iowa, Kansas, Missouri, Nebraska

EPA Region 3

Drinking Water Branch

1650 Arch Street

Philadelphia, PA 19103-2029

(800) 438-2474 (Customer Service Hotline)

Delaware, Maryland, Pennsylvania, Virginia, 

West Virginia, District of Columbia

EPA Region 8

Municipal Systems Unit

999 18th Street

Denver, CO 80202

(303) 312-7021

Colorado, Montana,

North Dakota, South Dakota, Utah, Wyoming

EPA Region 4

Ground Water/Drinking Water Branch

61 Forsyth Street, S.W.

Atlanta, GA 30303-3415

(404) 562-9424

Alabama, Florida, Georgia, Kentucky, Mississippi,

North Carolina, South Carolina, Tennessee

EPA Region 9

Drinking Water Office

75 Hawthorne Street

San Francisco, CA 94105

(415) 744-1843

Arizona, California, Hawaii,

Nevada, American Samoa, Guam,

Commonwealth of the Northern Mariana

Islands

EPA Region 5

Safe Drinking Water Branch

77 West Jackson Boulevard

Chicago, IL 60604

(800) 621-8431

Illinois, Indiana, Michigan, Minnesota, Ohio,

Wisconsin

EPA Region 10

Drinking Water Unit

1200 Sixth Avenue

Seattle, WA 98101

(206) 553-1890

Alaska, Idaho, Oregon, Washington