Lead and Copper Rule Minor Revisions:
Fact Sheet

EPA 815-F-99-010, December 1999

Federal Register Notice
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Guidance Documents for Lead and Copper Rule Minor Revisions

EPA has made minor changes to the Lead and Copper Rule. These minor revisions (also known as the Lead and Copper Rule Minor Revisions or LCRMR) streamline requirements, promote consistent national implementation, and in many cases, reduce burden for water systems. The LCRMR do not change the action levels of 0.015 mg/L for lead and 1.3 mg/L for copper, or Maximum Contaminant Level Goals established by the 1991 Lead and Copper Rule ("the rule"), which are 0 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.

As part of the LCRMR rulemaking process, the Agency collected additional data pertaining to the exclusion of transient non-community water systems from the requirements of the rule. EPA concluded that it is still appropriate to continue this exclusion because the Agency believes there are de minimus (minimal) non-carcinogenic adverse health effects resulting from exposure to lead in drinking water at such systems. This fact sheet provides a discussion of the major changes to the rule resulting from the LCRMR.

Who Is Affected by the LCRMR?

All water system operators and managers of community water systems (CWSs) and non-transient non-community water systems (NTNCWSs) are potentially affected, as well as the state staff who are responsible for implementing the Lead and Copper Rule in their state.

What Are the Changes to the Lead and Copper Rule?

The changes fall into seven broad categories as follows.

Demonstration of Optimal Corrosion Control

Clarify that systems must optimize corrosion control and continue to maintain and operate any corrosion control that is already in place.
Add the requirement for systems that are deemed to be optimized because there is little or no corrosion occurring in their distribution system to:
- monitor for lead and copper tap samples once every 3 years, and
- meet the copper action level.
Change the way in which compliance with state-designated optimal water quality parameters (WQP) is determined.

Lead Service Line Replacement Requirements

Require systems subject to lead service line replacement requirements to replace the portion of the lead service line that they own.
Require systems that replace only part of a lead service line that they own to notify residents of the potential for temporary increases in lead levels and measures they can take to reduce lead levels.

Public Education Requirements

Allow NTNCWSs and special-case CWSs to use alternative language which is more appropriate for their systems.
Provide more flexibility in the mode of delivery for public education, especially for NTNCWSs and those CWSs serving 3,300 or fewer people.

Monitoring Requirements

Allow systems with low lead and copper tap levels to conduct tap water monitoring and WQP tap monitoring once every 3 years without first conducting interim rounds of more frequent monitoring.
Allow NTNCWSs and certain CWSs that do not have enough taps where the water has stood motionless for at least 6 hours to collect samples from taps with the longest standing times.
Permit more flexibility in the time of year when systems can conduct reduced monitoring.
Permit some ground water systems to limit biweekly entry point monitoring to representative locations.
Allow states to grant monitoring waivers to small systems with plumbing free of lead- and copper-containing materials.
Allow systems to reduce the frequency of source water monitoring if they have low levels of source water lead and copper.
Clarify and provide more flexibility in sampling site requirements.
Revise the resampling triggers for composite lead and copper source water samples.
Permit states to invalidate tap samples under certain circumstances.
Require systems, on reduced lead and copper tap monitoring, to report to the State changes in treatment or an addition of a new water source.

Analytical Methods

Update the analytical methods for lead and copper to conform with changes in the standard methods for other inorganic chemicals.

Reporting and Record Keeping Requirements

Revise and streamline state reporting requirements.
Remove system reporting requirements that are redundant or no longer necessary, and add other reporting requirements that reflect the LCRMR.
Revise record keeping requirements for States to reflect the LCRMR.

Special Primacy Considerations

Add special state primacy considerations for determining optimal WQP compliance when multiple samples are collected per day, to verify the completion of partial lead service line replacement activities, and designating alternative reduced lead and copper monitoring periods for CWSs.

When Do These Changes Take Effect?

The Federal effective date for these revisions is April 11, 2000. However, systems should check with their state primacy agencies because not all provisions may apply in their state.

Lead and Copper Rule Minor Revisions: Fact Sheet