DRAFT United States

Environmental Protection

Agency

Office of Water

4606

EPA 816-F-00-010

March 2000

Lead and Copper Rule Minor Revisions 

Fact Sheet for Large Water System Owners and

Operators

The U.S. Environmental

Protection Agency (EPA)

has made minor changes to

the Lead and Copper Rule

(LCR), which was first

published in 1991. These

minor revisions (also known as the Lead and Copper Rule Minor Revisions or LCRMR) take effect on April 11, 2000.

They reduce many monitoring and reporting requirements, and promote consistent national implementation by clarifying

some of the original requirements that were intended by EPA. They do not change the LCR’s action levels of 0.015

milligrams per liter (mg/L) for lead and 1.3 mg/L for copper or its Maximum Contaminant Level Goals of 0 mg/L for lead

and 1.3 mg/L for copper. The revisions do not affect the LCR’s basic requirements to optimize corrosion control and, if

appropriate, treat source water, educate the public, and replace lead service lines.

What Are the Changes to the Lead and Copper Rule?

The changes brought about by the LCRMR fall into four broad categories:

ì Demonstrating optimal corrosion control

í Monitoring and reporting

î Public education

ï Lead service line replacement

In this fact sheet, we have identified for each category 1) the revisions that you must begin complying with on 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 can be implemented in your State.
DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 2 of 14

This fact sheet summarizes your requirements. 

For the actual regulatory 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)

ìRevisions to Requirements for Demonstrating Optimal

Corrosion Control

You Must Begin Complying with These Requirements on April 11, 2000

The LCR does not specifically state the continuing

monitoring requirements if you are deemed to have

optimized corrosion control under §141.81(b)(2) (also

known as a (b)(2) system).

Definition: A (b)(2) system is one that has completed

treatment steps that are equivalent to those described in

the 1991 LCR prior to December 7, 1992.

The LCRMR clarify that if you are a (b)(2) system, you

must:

C routinely monitor for water quality parameters

(WQPs) after your State designates optimal water

quality parameters (OWQPs); and

C continue lead and copper tap and WQP sampling.
DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 3 of 14

The LCR is unclear on the continuing monitoring

requirements if you are deemed to have optimized

corrosion control under §141.81(b)(3) (also known as a

(b)(3) system). 

Definition: A (b)(3) system is one that can show that the

difference between the 90th percentile lead level at the tap

and the highest lead concentration in its source water is

less than 0.005 milligrams per liter (mg/L) for two

consecutive 6-month periods.

The LCRMR clarify that if you are a (b)(3) system, but

are not required to conduct WQP monitoring, you must

continue to properly operate and maintain corrosion control

treatment at all times.

If you are a (b)(3) system, LCRMR also require you to:

C collect a round of lead and copper samples from the

taps at the reduced number of sites between

October 1, 1997 and September 30, 2000 and

continue monitoring every 3 years thereafter.

C not exceed the copper action level after July 12,

2001

C begin taking corrosion control treatment steps if

during any round of monitoring:

Î the difference between your 90th percentile lead

level at the tap and the lead level in your source

water is 0.005 mg/L or higher, or

Ï you exceed the lead action level, or

Ð you exceed the copper action level on or after

April 11, 2000.

Note: If you must begin corrosion control treatment for any of

the 3 reasons listed above, you must follow the schedule for

medium-size systems outlined in §141.81(e) beginning with the

requirement to complete a corrosion control study. Please refer

to the table below for more detail. 

Water System Corrosion Control Treatment (CCT) Schedule under §141.81(e)

Requirement Deadline

Conduct Corrosion Control Study 18 months after being triggered into CCT

requirements

Install CCT Within 24 months after State designates CCT

Conduct follow-up lead and copper tap and WQP

monitoring

Within 30 months after State designates CCT

Revisions That Depend on State Adoption

Definition of a (b)(3) system

The State cannot deem that you are optimized under

§141.81(b)(3) if your source water lead levels are below

the Method Detection Limit and your 90th percentile lead

level at the tap is < 0.005 mg/L.

If your source water lead levels are below the Method

Detection Limit (of 0.005 mg/L) and your 90th percentile

lead level at the tap is < 0.005 mg/L, the State may

determine that you are a (b)(3) system. You would then

be subject to the requirements for (b)(3) systems that are

discussed on page 2 of this fact sheet.

Changes in the Procedures for Assessing Compliance with Optimal Water Quality Parameters (OWQPs)
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Daily values are 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 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 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 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.

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. 

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, January

2000, EPA 815-R-99-019.
DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 5 of 14

íRevisions to Monitoring and Reporting Requirements

You Must Begin Complying with these Requirements on April 11, 2000

The LCR is unclear that if you do not have enough "highrisk" sites (i.e., Tier 1, 2, or 3 sites) that you are 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 does 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.,

less frequently than every 6 months), you must collect

from sites that are representative of the ones you used

during standard monitoring. (Your State may specify

where to collect these samples.)

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

change your treatment or add 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. You are

also subject to this requirement if you are deemed to have

optimized corrosion control under §141.81(b)(3).Your

State may require that you provide earlier notification or

undertake additional steps to ensure that optimal corrosion

control treatment is maintained. 

If you composite your source water samples, you must

take the samples again if the composite sample’s levels

are >0.001 mg/L for lead, or >0.001 mg/L or >0.020 mg/L

(depending on the analytical method) for copper.

The resampling trigger for composite samples has been

revised to >0.001 mg/L for lead and >0.160 mg/L for

copper.

Revisions That Depend on State Adoption

Monitoring Requirements

You are 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.
Revisions That Depend on State Adoption

DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 6 of 14

You are required to collect first-draw lead and copper

samples, regardless of whether you have enough taps that

can supply first-draw samples.

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, your State may allow

you to collect samples from the taps that have the longest

standing times.

Monitoring Requirements (Continued)

You are required to conduct 3 consecutive years of

monitoring before reducing your monitoring frequency to

once every 3 years (triennial).

You can reduce your lead and copper tap water

monitoring to once every 3 years after monitoring for only

two 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 monitoring).

Sample invalidation is 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 subject to

tampering.

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.

You are required to take 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 to the State that these sites are

representative of water quality conditions in your

system.

Before being allowed to conduct triennial WQP tap

monitoring, you must be in compliance with your OWQPs

for four consecutive years.

You may proceed to triennial WQP tap monitoring more

rapidly than before if you are also eligible for accelerated

reduced lead and copper tap water monitoring and you are

in compliance with your OWQPs.
Revisions That Depend on State Adoption

DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 7 of 14

If you exceed an action level but are not required to install

source water treatment, you are not allowed to reduce

your source water monitoring.

You may conduct source water monitoring once every 9

years if you exceed an action level, and 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.

Reporting Requirements

You are always required to calculate and report your 90th

percentile lead and copper levels to your State.

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 by the State-specified date, and

C your State gave you the results of the 90th percentile

calculation before the end of the monitoring period.

You are required to certify that you followed proper

sampling procedures or that homeowners collected

samples after receiving proper instructions.

You are no longer required to submit these certifications.

You are 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).

You are no longer required to provide these justifications.

You are 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 are no longer required to provide a written request for

reduced lead and copper tap monitoring, but you still must

receive written approval from your State before you can

begin reduced monitoring.

î Revisions to Public Education Requirements

You Must Begin Complying with These Requirements on April 11, 2000
DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 8 of 14

You are required to submit a letter to the State

demonstrating that you met your public education

requirements. This letter is due by December 31 of the

year in which you must perform 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. 

As part of your annual compliance letter, you were

required to provide a list of newspapers, radio stations, TV

stations, and organizations to which you provided public

education during the year. 

Your State 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

the State.

Revisions That Depend on State Adoption

Mandatory Public Education Language

You are required to include information about LSLs, even

if your system has 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 are not allowed to modify language regarding the

availability of building permits and consumer access to

these records.

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 State

to modify this language.

All CWSs and NTNCWSs are 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. (Your State may require you to

obtain approval.)

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.)

Distribution of Public Education Materials

You are required to enclose your public education

materials in the customers’ regular water bills.

If you are a CWS, you can mail public education materials

separately from your bill.
Revisions That Depend on State Adoption

DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 9 of 14

If you are an NTNCWS, you can only post information

and distribute pamphlets; you cannot use e-mail to

distribute public education information.

If you are an NTNCWS, you may 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 are 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

may follow the NTNCWS public education delivery

requirements. (Your State may require you to obtain

approval.)
*The LCRMR require you to offer to replace, at the building owner’s expense, the portion of the LSL owned by the building owner,

unless this is prohibited by local law.

DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 10 of 14

ï Revisions to Lead Service Line Replacement

Requirements

You Must Begin Complying with These Requirements on April 11, 2000*

There is no specific required deadline to provide

notification of partial replacement. Partial replacement

occurs when you do not replace the entire LSL up to the

building inlet.

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

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

after you complete the partial replacement. This sample

will be collected at the tap of each resident that accepts

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) 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 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 the sample results to residents.

You are not required to report any information to the State

that demonstrates that you met your partial LSL

requirements.

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

resident(s) served by the partially replaced line.

You must submit these monitoring results to the State

within the first 10 days of the month following that in

which you receive the results. The LCRMR give States

the option to modify reporting requirements, however, so

you need to check with your State to be sure of your

specific 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.

You must notify residents by mail. For multi-family

dwellings, however, you can post the notification in a

conspicuous common-use area of the building.
DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 11 of 14

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, January 2000,

EPA 815-R-99-022.

Where Can I Obtain More Information About the LCRMR?

k State or EPA Regional Office k

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.

N Other Guidance Documents N

Lead and Copper Rule: Compliance Dates, January 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.
DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 12 of 14

G Safe Drinking Water Hotline G

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.
DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 13 of 14

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
DRAFT - Fact Sheet for Large Water Systems: Lead and Copper Rule Minor Revisions Page 14 of 14

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