1. Lead and Copper Rule: Short-Term Revisions and Clarifications
April 2008

2. Introduction How the Presentation is Organized
Lead and Copper Rule (LCR)
Introduction
Overview
Lead and Copper Tap Monitoring Requirement Review
90th Percentile Calculation Review
LCR Short-Term Revisions and Clarifications (STR)
STR Regulatory Changes
Primacy Package
This presentation begins with a review of the current Lead and Copper Rule.
Introduces terminology and acronyms used in the presentation.
Provides an overview of key provisions of the rule.
Provides a review of lead and copper tap monitoring requirements, and
Provides a review of how to calculate the 90th percentile level.
The remainder of the presentation will focus on the LCR STR.
We will provide an overview of this rule.
Discuss the requirements that have been revised by the STR.
Discuss the information that must be included in the primacy revision package and a schedule for providing that information.
April 2008

3. Introduction Terminology for Primacy Agency
State means Primacy Agency
40 CFR §141.2 definition for State
Possible Primacy Agencies
State
Tribal government
EPA region
Throughout the rule and in this presentation we use the term “State” in general to mean the primacy agency.
141.2 definition of State - the agency of the State or Tribal government which has jurisdiction over public water systems. During any period when a State or Tribal government does not have primary enforcement responsibility pursuant to section 1413 of the Act, the term “State” means the Regional Administrator, U.S. Environmental Protection Agency.
April 2008

4. Introduction Acronyms
AL: Action Level
ALE: Action Level Exceedance
CCT: Corrosion Control Treatment
CWS: Community Water System
LCR: Lead and Copper Rule
LCR STR: Lead and Copper Short-Term Revisions and Clarifications
LSLR: Lead Service Line Replacement
MCL: Maximum Contaminant Level
MCLG: Maximum Contaminant Level Goal
M/R Monitoring and Reporting (Violation)
NTNCWS: Non-transient Non-community Water System
PWS: Public Water System
SOWT: Source Water Treatment
WQP: Water Quality Parameter
April 2008

5. Lead and Copper Rule
Overview

6. Lead and Copper Rule Overview
First published on June 7, 1991.
Established MCLGs for lead and copper.
Establishes AL vs. MCL.
90th percentile sample result is compared to AL.
ALE is trigger and not violation.
ALE requires treatment techniques and additional monitoring.
MCLG Action Level
Lead mg/L mg/L
Copper mg/L mg/L
The original LCR was first published on June 7, This rule was revised by technical amendments published on July 15, 1991 (56 FR 32113), June 29, 1992 (57 FR 28786) and June 30, 1994 (59 FR 33860). EPA published the minor revisions to the rule (LCRMR) on January 12, 2000.
The purpose of the LCR is to protect public health by minimizing lead and copper levels in drinking water, primarily by reducing water corrosivity. Lead and copper primarily enter drinking water through the corrosion of distribution and household plumbing materials
The LCR establishes non-enforceable health goals called Maximum Contaminant Level Goals (MCLGs) for lead and copper. These concentrations represent levels at which no known or anticipated health effects would occur.
There is no maximum contaminant level (MCL) for the LCR. Instead, the rule establishes action levels for lead of (15 ppb or mg/L) and copper action level of 1.3 mg/L. The action levels are a screen for optimal corrosion control for small and medium size systems. Small and medium systems meeting this screen do not need to perform corrosion control studies or have to monitor optimal water quality parameters.
To determine whether an action level has been exceeded, the value at the 90th percentile of all lead or copper samples collected is compared against its respective action level. We will go through some examples on how to calculate the 90th percentile level a little later in this training.
An exceedance of an action level is not a violation. Instead, it is the primary factor in determining whether a system needs to undertake additional monitoring and treatment technique requirements.
April 2008

7. Lead and Copper Rule Overview
Three system size categories.
Size is factor for sample number and applicability/timing of some requirements.
Large: > 50,000 people
Medium: 3,301 to 50,000 people
Small: 3,300 or fewer people
The LCR divides systems into three broad size categories.
Large systems serve more than 50,000 people.
Medium systems serve 3,301 to 50,000 people.
Small systems serve 3,300 or fewer people.
System size is a factor in determining the number of samples that must be collected, as well as the applicability and timing of some of the requirements.
April 2008

8. Lead and Copper Rule Overview CWS or NTNCWS Collects Lead
and Copper Tap Samples
90th Percentile
Is at or Below
Both Action Levels*
90th Percentile
Exceeds the Lead
Action Level (15 μg/L)
90th Percentile
Exceeds the Copper
Action Level (1.3 mg/L)
Systems serving < 50,000 people and (b)(3) systems with 90th percentile lead and copper tap levels that are at are below the action level are required to conduct periodic monitoring only.
A (b)(3) system is one that has demonstrated that it has minimal levels of corrosion entering the distribution system based on lead and copper source and tap water samples in accordance with §141.81(b)(3) of the regulation.
Non-(b)(3) large systems must install CCT, regardless of whether they have an ALE.
(b)(2) systems (i.e., had CCT in place prior to 12/7/92) must conduct WQP monitoring.
If the a system exceeds the lead AL, then it must conduct PE within 60 days, begin CCT steps which includes WQP monitoring, conduct source water monitoring and install Source water treatment if needed, begin lead service line replacement and a rate of 7% of lead service lines per year and conduct periodic lead and copper tap monitoring.
However If the a system exceeds the copper AL, it must complete all the aforementioned activates except it is not required to conduct PE if conduct lead service line replacement
Conduct periodic lead and copper tap monitoring
Begin LSLR replace 7%
of LSLs
per year
Conduct public education
due within 60 days
Begin CCT
steps includes WQP monitoring **
Conduct source water monitoring (Install SOWT, if needed)
Conduct periodic lead and copper tap monitoring
* Includes systems serving ≤ 50,000 people and (b)(3) systems
** Includes non-(b)(3) systems serving > 50,000 people, irrespective of their 90th percentile levels; (b)(2) systems must collect WQPs.
April 2008

9. Review of Lead and Copper Tap Monitoring Requirements
Lead and Copper Rule
Review of Lead and Copper Tap Monitoring Requirements

10. Review of Monitoring Requirements Site Selection - CWS
Three sampling site tiers: Tier 1, Tier 2, and Tier 3.
Tier 1 sample sites are considered high risk sites.
Tier 1 sampling pool consists of single* family structures that:
Contain copper pipes with lead solder installed
after 1982 (but before State’s lead ban) or;
Contain lead pipes and/or;
Are served by a lead service line.
There are Three sampling site tiers: Tier 1, Tier 2, and Tier 3.
The LCR establishes tiering system for prioritizing sample sites, tier 1 represents the sites expected to yield the highest lead sample results, followed by tier 2 and tier 3.
Tier 1 sample sites are considered high risk sites.
Tier 1 sampling pool consists of single* family structures that:
Contain copper pipes with lead solder installed
after 1982 (but before State’s lead ban) or;
Contain lead pipes and/or;
Are served by lead service line.
All States were required to ban the use of lead solder in all public water systems and all homes and buildings connected to such systems by June 1988 (most States adopted the ban in 1987 or 1988).
Although typically a Tier 1 sampling pool is comprised of single family homes, when multiple-family residences comprise at least 20 percent of the structures served by the water system, the system may include these types of structures in its sampling pool.
* May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served.
April 2008

11. Review of Monitoring Requirements Site Selection - CWS
Tier 2 sampling pool consists of buildings including multiple family residences that:
Contain copper pipes with lead solder
installed after 1982 (but before State’s
lead ban) or;
Contain lead pipes and/or;
Are served by a lead service line.
Tier 3 sampling pool consists of single family structures that:
Contain copper pipes with lead solder installed before 1983.
Systems without a sufficient number of Tier 1 sites should select Tier 2 sites to complete the sampling pool if not enough Tier 1 and 2 sites are available the system may complete the sampling pool with Tier 3 sites.
Tier 2 sampling pool consists of buildings including multiple family residences that:
Contain copper pipes with lead solder
installed after 1982 (but before State’s
lead ban) or;
Contain lead pipes and/or;
Are served by lead service line.
Tier 3 sampling pool consists of single family structures that:
Contain copper pipes with lead solder installed before 1983.
A CWS with insufficient tier 1, tier 2, and tier 3 sampling sites must complete its sampling pool with representative sites throughout the distribution system.
A representative site is a site in which the plumbing materials at that site is commonly found at other sites served by the water system.
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available.
April 2008

12. Review of Monitoring Requirements Site Selection - NTNCWS
Two sampling site tiers: Tier 1 and Tier 2.
Tier 1 sampling pool consists of sample sites that:
Contain copper pipes with lead solder installed
after 1982 (but before State’s lead ban) or;
Contain lead pipes and/or;
Are served by lead service line.
Tier 2 sampling pool consists of sample sites that:
Contain copper pipes with lead solder installed before 1983.
Systems without a sufficient number of Tier 1 sites should select Tier 2 sites to complete the sampling pool.
A NTNCWS with insufficient tier 1 and tier 2 sampling sites must complete its sampling pool with representative sites throughout the distribution system.
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available.
April 2008

13. Review of Monitoring Requirements Sample Collection Method
First-draw.
6-hour standing time.
One-liter volume.
System or residents can collect.
As discussed earlier, lead and copper in drinking water is primarily due to the corrosion of distribution and household plumbing materials, therefore, tap water samples are collected at kitchen or bathroom sink taps of residences and other buildings vs. entry points to the distribution system.
STR clarify that sampling “sites’’ refer to “taps that can be used for human consumption,’’ such as kitchen and bathroom taps as opposed to outlets such as hose bibs or taps at utility sinks.
All lead and copper tap must be first-draw samples -- the water should have stood (not been used) for at least six hours prior to collecting the one-liter sample. For the 1991 rule, the minimum 6-hour stagnation time was a compromise between ease of sample collection and waiting for equilibrium solubility.
A first-draw sample from a nonresidential building should be collected at an interior tap used for consumption.
NTNCWSs or “special CWSs” (such as a prison or hospital) that do not have enough inside taps where the water stands unused for at least six hours, can request approval from the State to use inside taps that are the most likely to have remained unused for the longest period of time.
If samples are collected by residents, then instructions should be provided and a chain of custody maintained.
April 2008

14. Review of Monitoring Requirements Minimum Number of Tap Samples
System Population
Number of Sampling Sites (on Routine Monitoring)
Number of Sampling Sites (on Reduced Monitoring)
>100,000
100 50
10,001 to 100,00 60 30
3,301 to 10,000 40 20
501 to 3,300 10
101 to 500 5
≤100
Water systems must collect at least one lead and copper tap sample from the number of sites listed in the table corresponding to the system’s population and monitoring frequency.
Reduced monitoring sites must follow tiering requirements. For example, if a system has 100 sites, of which 75 are Tier 1 and 25 are Tier 2, it must collect all 50 reduced sites from Tier 1 sites if they are available.
Otherwise, rule does not specify which sites should be chosen for reduced monitoring (e.g., ones with highest lead results).
However, the States may specify sampling locations when a system is on reduced monitoring.
April 2008

15. Review of 90th Percentile Calculations
Lead and Copper Rule
Review of 90th
Percentile Calculations

16. Review of 90th Percentile Calculations More than 5 Samples
Step 1: Place lead or copper results in ascending order.
Step 2: Assign each sample a number, 1 for lowest value.
Step 3: Multiply the total number of samples by 0.9.
Example: 20 samples x 0.9 = 18th sample.*
Step 4: Compare 90th percentile level
to AL (in above example, 18th sample).
If your system has more than 5 samples to calculate the 90th percentile level:
List the lead and copper results in ascending order from the sample with lowest concentration to the highest concentration.
Assign each sample a number with the number 1 assigned to the sample result with the lowest value and ascending by single integers.
The sample with the highest concentration should total the number of samples taken.
Next multiply the total number of samples taken by 0.9 and that number corresponds to the sample number that is the 90th percentile concentration.
If the result from your calculation is not a whole number then you will have to round off or use interpolation to determine what sample value you should use for your 90th percentile. For example if a system received results for 105 samples, and then multiplied .9 by 105 they would get 94.5 sample is the 90th percentile. However there are no samples labeled in half integers, so 94.5th sample would be rounded to the 95th sample would equal the 90th percentile. The same procedure is used to determine the copper 90th percentile level.
* When more than minimum number of samples are collected, may need rounding or interpolation to determine 90th percentile sample.
April 2008

17. Review of 90th Percentile Calculations More than 5 Samples: Example Question
Assume 10 samples are collected with lead results as follows:
Site A: mg/L
Site B: mg/L
Site C: mg/L
Site D: mg/L
Site E: mg/L What is the 90th Percentile Value?
Site F: mg/L
Site G: mg/L
Site H: mg/L
Site I: mg/L
Site J: mg/L
This example shows how to determine the 90th percentile level when a system is required to collect more than 5 samples.
In this example, 10 samples are taken with mg/L being the lowest and mg/L being the highest.
April 2008

18. Review of 90th Percentile Calculations More than 5 Samples: Example Answer
Step 1: Order results from lowest to highest:
1. Site A: Site E: 0.014
2. Site C: Site H: 0.014
3. Site F: Site I: 0.014
4. Site J: Site B: 0.015
5. Site D: Site G: 0.040
Step 2: Multiply number of samples by 0.9 to determine which represents 90th percentile level
10 x 0.9 = 9th sample (or mg/L)
Step 3: Compare to lead action level  No Exceedance
In this example, the 90th percentile value is the 9th highest sample. The lead level of this sample is mg/L and is at the lead action level of mg/L. Therefore, the system has not exceeded the lead action level.
The same procedure is used to determine the copper 90th percentile level.
April 2008

19. Review of 90th Percentile Calculations 5 Samples
Step 1: Place results in ascending order.
Step 2: Average 4th and 5th highest sample results.
Step 3: Compare 90th percentile level to action level.
For water systems serving fewer than 100 people that collect 5 samples per monitoring period, the 90th percentile is calculated by averaging the 4th and 5th highest concentration samples.
Step 1: Place results in ascending order.
Step 2: Average 4th and 5th highest sample results.
Step 3: Compare 90th percentile level to action level.
April 2008

20. Review of 90th Percentile Calculations 5 Samples: Example Question
Assume 5 samples are collected with lead results as follows:
Site A: mg/L
Site B: mg/L
Site C: mg/L What is the 90th Percentile Value?
Site D: mg/L
Site E: mg/L
This example shows how to determine the 90th percentile level when a system is required to collect 5 samples.
April 2008

21. Review of 90th Percentile Calculations 5 Samples: Example Answer
Step 1: Order results from lowest to highest:
1. Site A: mg/L
2. Site D: mg/L
3. Site E: mg/L
4. Site B: mg/L
5. Site C: mg/L
Step 2: Average 4th & 5th samples highest samples to get 90th percentile value = mg/L
0.011 mg/L mg/L = mg/L 2
For systems collecting 5 samples, the 90th percentile level is computed by averaging the 4th and 5th value. This is the only time that the 90th percentile level is determined using the average.
In this example, the 90th percentile level = mg/L, as shown in the equation below.
0.011 mg/L mg/L = mg/L 2
This rounds up to mg/L
This system has exceeded the lead action level because its 90th percentile level is higher than the lead action level of mg/L.
Step 3: Compare average to lead action level  Exceedance
April 2008

22. Review of 90th Percentile Calculations Fewer than 5 Samples
Procedure has changed under STR.
Some systems may collect < five samples.
Sample with highest result is 90th percentile level.
No M/R violation.
Assume 3 lead samples: mg/L, mg/L, and mg/L.
90th percentile = mg/L
As discussed in next section, under the STR, States can allow some systems to collect fewer than five samples.
In these cases, sample result with highest concentration is the 90th percentile level.
There are three samples taken: 20 ppb, 8 ppb and 5 ppb, the highest concentration is 20 ppb which exceeds the lead AL of 15 ppb.
Also, if State allows fewer than five samples to be collected, system is not in violation of its M/R requirements.
April 2008

23. Memo addressed taps with aerators:
Review of Monitoring Requirements Management of Aerators during Sample Collection
Memo addressed taps with aerators:
Regularly clean aerators.
Do not remove/clean prior to or during sampling.*
Could fail to identify typical lead contribution.
If initial result > AL, recommend 2nd sample (without aerator or with clean aerator).
Use both results in 90th percentile calculation.
Over the years, EPA has received several implementation questions related to monitoring, sampling, and calculating the 90th percentile for the LCR. These next two memos will be addressing some of the questions that have arose for the aforementioned topics.
EPA issued a memo on October 20, 2006, Management of Aerators during Sample Collection to Comply with the Lead and Copper Rule.
The Memo was issued because some EPA guidance has included recommendations for removing aerators prior to sampling for lead:
Pocket Sampling Guide for Operators of Small Systems
EPA’s Interactive Sampling Guide for Drinking Water Systems Operators.
Although aerators are not intended to remove inorganic contaminants, aerators may trap particulate matter within the faucet.
The 2006 memo states that while EPA recommends homeowners regularly clean their aerators to remove particulate matter, EPA does not recommend removing or cleaning aerators prior to or during the collection of tap samples for determining 90th percentile for lead.
If customers are only encouraged to remove and clean aerators prior to sampling for lead, the customer may fail to take additional actions needed to reduce exposure to lead in drinking water.
If results (with an aerator) is > AL, EPA recommends another sample be collected (without an aerator or with a clean aerator) to determine whether particulate matter is a lead source.
Both results must be used in 90th percentile calculations. The first sample cannot be invalidated based on the presence of lead-bearing matter in the aerator.
Homeowner sampling instructions have been modified in the revised Monitoring and Reporting Guidance for Public Water Systems.
* Does not apply to tap samples collected for WQP analysis.
April 2008

24. Review of Monitoring Requirements Collecting Samples and Calculating Compliance
Memo addressed 7 aspects of tap sample collection and management:
Include all valid sample results in 90th percentile calculation:
Meet sample selection criteria
Collected within compliance monitoring period*
Do not include in 90th percentile calculation:
Customer-requested sample unless meet site selection criteria
Samples collected outside compliance monitoring period*
Calculate 90th percentile even if < minimum sample number (M/R violation).
In a 2004 memo, EPA clarified elements of the LCR associated with the collection and management of lead and copper samples and the calculation of the lead 90th percentile for compliance. In this memo EPA addressed 7 aspects of the requirements for collecting samples and calculating compliance:
1. What Sample Must Be Used in 90th Percentile Calculation. All sample results from a system’s sampling pool collected during the monitoring period must be included in the 90th percentile calculation (even if this includes more samples than the required minimum number needed for compliance). EXAMPLE: if a system sends out kits to 150 homes to ensure that it will get the required 100 samples at least and the system received sample results for 140 households, the system would have to use all 140 samples in calculating the 90th percentile. If utility takes confirmation sample, they must use original and confirmation sample in 90th percentile calculation (can’t take the average).
2. Customer-requested samples that are not collected as part of the system’s regular compliance sampling pool may or may not meet the sample site criteria. Including results from samples that do not meet the criteria could inappropriately reduce the 90th percentile value. Therefore, customer-requested samples should not be used to calculate the 90th percentile, except in cases where the system is able to determine that the site selection criteria for compliance sampling are satisfied. Even though customer-requested samples are not used for the 90th percentile calculation, the sample results must still be provided to the State.
3. Samples Outside Compliance Period. Only samples collected within the compliance monitoring period can be used. The Exception is an invalidated sample that is collected outside this period but within 20 days after State invalidates sample. If a State invalidates a sample, and the system must collect a replacement sample to have a sufficient number of samples to calculate compliance, the system must collect a replacement sample as soon as possible, but no later than 20 days after the date the State invalidates the sample or by the end of the applicable monitoring period, whichever occurs later. The replacement sample should be taken from same location if possible and cannot be used for the subsequent monitoring period.
4. If Minimum Number is Not Collected. States must calculate the 90th percentile even if the minimum number of samples are not collected. The LCR states that the 90th percentile is calculated based on “all samples taken during a monitoring period”. A system which fails to collect the minimum number required samples gets a M/R violation and thus is required to conduct Tier 3 Public Notification and report the violation in its CCR. The system will return to compliance when it completes these tasks and has completed appropriate monitoring and reporting for two consecutive 6 month monitoring periods (or one round of monitoring for a system on reduced monitoring). As discussed later in presentation, STR allows for some systems to take fewer than 5 samples – no M/R violation.
* Would include replacement sample(s) collected within 20 days of invalidation (even if collected after monitoring period end).
April 2008

25. Review of Monitoring Requirements Collecting Samples and Calculating Compliance (cont.)
Defines proper sample:
First-draw,
1-liter,
From inside tap used for consumption (kitchen or bathroom sink), and
Minimum 6-hours standing time.
System can collect sample or review collection information before analysis.
States can invalidate sample if:
Improper sample analysis, or
Site selection criteria not met, or
Sample container was damaged in transit, or
Sample subjected to tampering.
5. A proper sample is defined as a first draw one liter sample that is taken from an interior tap used for consumption (i.e. kitchen or bathroom sink) after the water has been standing in plumbing for at least six hours. Again the LCR requires samples to be collected by the system or by residents that have been properly instructed by the water system on how to take the sample. The rule does not allow water systems to challenge sample results based on alleged homeowners errors in sample collection.
6. How can utilities avoid problems with sample collection. Once a sample is analyzed, the results may not be challenged by the water system. To avoid potential sample collection problems, the system may wish to do the sampling itself or review the sample collection information before sending it to the lab. For example if a sample bottle is half full then it should not be analyzed by the lab or if chain of custody indicates the sample was taken from an outside tap then the sample should not be analyzed.
7. Sample Invalidation criteria. A State can invalidate a sample for one of the following reasons:
The lab determines that improper sample analysis caused erroneous results.
State determines the sample was taken from a site that did not meet site selection criteria. This is interpreted to mean a site is not part of the compliance sampling pool, that has not been identified as Tier 1 or other high risk site, or that it has been altered in such a way that it no longer meets the criteria of a high risk site (e.g., new plumbing or addition of a water softener).
The sample container was damaged in transit.
There is substantial reason to believe the sample was tampered with.
Invalidated samples are not counted for compliance.
April 2008

26. Lead and Copper Short-Term Revisions and Clarifications
Overview
Regulatory Changes
Primacy Package
April 2008

27. Short-Term Revisions Overview Scope of Revisions
Published in Federal Register, October 10, 2007 p.57782
Addresses implementation issues with existing rule:
Monitoring revisions (sample number, timing clarifications).
Additional requirements for providing public information.
Advanced notification of treatment changes and source
additions.
Reevaluation of “tested-out” lead service lines.
Targeted changes based on input from National LCR Review.
Key elements of treatment technique requirements are unchanged.
Long-term revision process likely to start soon.
Key elements of the treatment technique requirements remain the same:
lead and copper action levels,
optimal corrosion control treatment and,
how systems comply with the treatment technique.
April 2008

28. Short-Term Revisions Overview Guidance Documents
Six draft guidance documents to assist with implementation:
Two public information fact sheets
Separate CWS and NTNCWS consumer
information guidance
State Implementation Guidance
Water System Monitoring and Reporting Guidance.
Final expected Spring 2008.
Available at:
On Training CD !
The STR contain significant changes to the PE requirements.  The following draft documents were developed to assist water systems with implementation of the new PE requirements.
Draft Implementing the Lead Public Education Provisions of the Lead and Copper Rule: A Guide for Community Water Systems. For CWSs, includes who must receive PE materials and the time frame for distribution of the PE materials as well as suggestions on how to have a more effective public education program. Similar document is available for NTNCWSs.
Draft Lead and Copper Rule Public Education & Other Public Information Requirements for Community Water Systems Fact Sheet. Summarizes PE and other public information notification requirements for a CWS under the STR.  It provides CWS with concise information on what they need to do after a lead ALE as well as the consumer notification requirements that are not dependent on a lead ALE.  Similar fact sheet is available for NTNCWSs.
Implementing the Lead Public Education Provision of the LCR, A Guide for Community Water Systems
Implementing the Lead Public Education Provision of the LCR, A Guide for Non-Transient Non-Community Water Systems
Draft Lead and Copper Rule 2007 Short Term Revisions and Clarifications State Implementation Guidance. Explains the new requirements under the STR. Includes three appendices:
Appendix A: Primacy Revisions Crosswalk [to help States prepare primacy revision package – distinguishes between provisions that are more stringent and must be adopted.]
Appendix B: 2007 Short-Term Revisions Compared to LCR
Appendix C: Fact sheet and quick reference guide. [QRG also available as a separate document.]
Lead and Copper Rule Monitoring and Reporting Guidance. Updates Feb guidance to include the STR. Includes worksheets and instructions to assist in identifying sampling sites, sample collection, and the documentation and justification of decisions. “Suggested Directions for Homeowner Tap Sample Collection Procedures” have been revised to include sampling instructions for taps with aerators.
April 2008

29. Short-Term Revisions Overview Compliance Dates
180 days after promulgation (April 7, 2008) unless State has not adopted rule.
Date applies to:
EPA regions (WY, DC, Tribal).
States that incorporate by reference using Federal publication date (e.g., MN)
Otherwise, earlier of:
State’s adoption of rule after April 7, 2008.
December 10, 2009.
April 2008

30. In 62-550.800 F.A.C. The Term “State” shall mean “Department”
Lead and Copper Short Term Revisions and Clarifications Regulatory Changes
Monitoring Revisions
In F.A.C. The Term “State” shall mean “Department”

31. STR Regulatory Revisions Monitoring Revisions
Three Areas Revised:
Minimum number of samples required.
Monitoring and compliance period definitions.
Reduced monitoring criteria.
The STR monitoring revisions affect:
Minimum number of samples required for systems with fewer than five taps.
Clarify monitoring and compliance periods and timing of actions following an ALE.
Revise the criteria for reduced lead and copper tap monitoring.
April 2008

32. STR Monitoring Revisions Minimum Number of Samples Required
Systems Affected
Systems with fewer than 5 taps for human consumption.
Regulatory Revision
Collect multiple samples from same location on different days to meet 5 sample minimum.
States may allow 1 sample per tap for human consumption if < 5 such taps.
If < 5 samples, highest result is 90th percentile level.
The minimum number of samples requirement in the LCR-STR affect small systems serving 100 or fewer people with less than five taps for human consumption (primarily NTNCWSs).
Regulatory Revision
The regulatory revision retains the 5 sample minimum and clarifies that multiple samples may need to be collected from the same location on different days.
Also allow States discretion to reduce monitoring to one sample per tap for human consumption where there are fewer than 5 such taps. However, since this new provision is not more stringent States do not have to adopt this new provision.
For systems taking fewer than 5 samples, the highest concentration is compared against the action levels to determine compliance with AL.
April 2008

33. STR Monitoring Revisions Compliance and Monitoring Period Definitions (Changes)
Systems Affected
Systems with ALE or qualifying for reduced monitoring.
Rule Revisions
Provide monitoring and compliance period definitions.
Define ALE as date on which monitoring period ends.
Clarify timing of actions following ALE.
Clarify timing of monitoring.
Clarify reduced Pb/Cu tap monitoring period is 4 months.
Require reporting to State by October 10 for reduced lead and copper monitoring.
The LCR STR clarifies that systems are deemed to be exceeding the AL on the date the monitoring period ends.
If on 6-month monitoring, the end of monitoring period is June 30 or December 31.
If on reduced monitoring, end of the monitoring period is September 30 or last day of State-specified alternate period.
Previously timing of actions after an ALE were not clearly defined under reduced monitoring.
The LCR STR clarification makes tracking the dates and timelines related to corrosion control treatment steps and dates for public education delivery much simpler.
Previously reduced monitoring periods typically ended on Sept. 30 (June – Sept.) whereas the compliance period would end Dec. 31.
STR clarifies the timing of monitoring activities for systems that qualify for reduced lead and copper tap, WQP, and/or source monitoring or no longer meet the reduced monitoring criteria.
STR also clarify that systems on reduced lead and copper tap or WQP tap monitoring must provide monitoring-related information within 10 days after the end of the monitoring period or October 10th in most cases.
April 2008

34. Months from monitoring period end with ALE
STR Monitoring Revisions Compliance and Monitoring Period Definitions (State Actions)
Clarifies timeframe for State actions triggered by ALE.
State Decision
Months from monitoring period end with ALE
Need for corrosion control study 12
Optimal CCT for medium systems (no study required) 18
Optimal CCT for small systems
(no study required) 24
Within 12 months from the end of the monitoring period in which the system exceeds the lead or copper AL, the State may require the system to perform corrosion control studies. If the State does not require corrosion control studies the State shall specify optimal corrosion control treatment:
For medium systems: 18 months from the end of the monitoring period.
For small systems: 24 months from the end of the monitoring period.
If the State has requires the system to conduct a CC study:
System has 18 months to complete the study from the date the State required it.
State must designate CCT within 6 months from the study completion.
Remember if a system is on reduced monitoring when the exceedance occurs, the end of the monitoring period is September 30 (unless the State has designated an alternate monitoring period).
April 2008

35. STR Monitoring Revisions Compliance and Monitoring Period Definitions (System Actions)
Clarifies timeframe for system actions triggered by ALE.
System Actions
From monitoring period end with ALE
Public education (lead ALE only)
60 days*
CCT recommendation
6 months
Initial source water monitoring and SOWT recommendation
180 days
1st year of LSLR (lead ALE only)
1 day**
Materials evaluation w/ initial LSL number
12 months**
Provide documentation that LSLR requirements were met
12 months** and every 12 months thereafter.
*State may grant extension in writing.
**Corresponds to 1st monitoring period with lead ALE after treatment.
Within 60 days from end of monitoring period with lead ALE, system must deliver PE.
60-day PE time frame applies to systems that are not already conducting PE.
State may extend the 60-day deadline if the approval is granted in writing before the end of the 60-day period. [Approval should not be granted if the PWS has not already initiated PE.]
Within 180 days from end of monitoring period in which the PWS first exceeds the lead or copper AL, it must:
Collect a source water sample from each entry point, and
Make a SOWT recommendation to the State. [System can recommend that no SOWT is needed.]
PWS must begin LSLR, the day after the monitoring period in which it exceeds the lead AL after installing CCT and/or SOWT (whichever occurs later). If the PWS was on reduced monitoring, the 1st day would be Oct. 1 of the calendar year in which the exceedance occurred.
STR clarifies that within 12 months after the end of a monitoring period in which a system exceeds the lead AL, it must submit written documentation to the State of the material evaluation that identifies the initial number of LSLs in the distribution system. Also clarifies that initial number of LSLs = those lines in the distribution system when the PWS was triggered into LSLR.
STR specifies that PWS must submit documentation that it has met its replacement requirements no later than 12 months after the end of a monitoring period in which it exceeds the lead AL and every 12 months thereafter.
April 2008

36. STR Monitoring Revisions Compliance and Monitoring Period Definitions (Three-Year Compliance Period)
Triennial monitoring must occur once every 3-year compliance period.
Monitoring period is June – Sept. of same calendar year.
Cannot exceed 3 years between sampling events (see example).
2009
2010
2011
June–September
Monitoring period
2012
2013
2014
Three-year compliance period
Systems that are on reduced lead and copper tap monitoring must collect their samples during June - September of the same calendar year.
LCRMR allowed States to establish an alternate monitoring period (not to exceed 4 consecutive months in the same CY) in which water systems may conduct reduced lead and copper tap monitoring if the State believes that another time period better represents a time of normal operation where the highest lead levels are likely to occur. For example, a State may decide to set an alternate schedule for a NTNCWS that is closed during the summer months.
The diagram illustrates that if triennial monitoring must be conducted every 3 years. Therefore, if monitoring is conducted in the 2nd year of a 3-year compliance period (2010), the next sampling event would be due in the 2nd year (2013) of the next 3-year compliance period.
The STR includes similar clarifications regarding triennial monitoring for source water and WQP monitoring (i.e., that sampling must occur every three years).
April 2008

37. 1st 9-year compliance period 2nd 9-year compliance period
STR Monitoring Revisions Compliance and Monitoring Period Definitions (Nine-Year Compliance Period)
Nine-year monitoring must occur once every nine-year compliance period.
Monitoring period is June through September of same calendar year.
Cannot exceed nine years between sampling events (see example).
June–September
Monitoring period
2001
2002
2003
2004
2005
2007
2006
2008
2009
2010
2011
2012
2013
2014
2016
2015
2017
2018
1st 9-year compliance period
2nd 9-year compliance period
STR clarify that small water systems that are on 9-year monitoring must collect their samples once every 9 years.
As stated in the previous slide, samples must be collected during June – Sept. of the same CY or during the designated State-alternate period.
As shown in the example, if samples are collected during 2005 (the 5th year of the 9-year period), the next set of samples must be collected no later than 2014 (the 5th year of the next 9-year period).
The STR includes similar clarifications regarding 9-year source water monitoring (i.e., that sampling must occur at least every 9 years).
April 2008 37

38. Annual Monitoring Begins
STR Monitoring Revisions Compliance and Monitoring Period Definitions (Other Monitoring Clarifications)
The STR clarify that:
Annual reduced lead and copper tap monitoring starts in CY after 2nd 6-month period.
1st annual source period begins during CY State sets MPLs or determines SOWT not needed.
If 2nd 6-month is:
Annual Monitoring Begins
January – June
June 1 of next CY
July - December
Reduced lead and copper tap monitoring will begin during the calendar year (CY) immediately following the 2nd consecutive 6-month monitoring period in which the PWS qualifies for reduced monitoring (for med/small system – meets both ALs; or for any size, meets OWQPs and lead AL).
This timing applies to systems that qualify for annual monitoring the first time or are re-qualifying for it.
Keep in mind:
As previously discussed, STR requires sample results that are collected during a reduced monitoring period to be reported to the State by October 10. Therefore, samples should not be collected at the end of September.
The first year of annual source water monitoring will begin during the year in which the State sets MPLs or decides that no source water treatment is needed. This applies to systems using surface water or a combined source. Ground water systems monitor triennially.
April 2008 38

39. The STR clarify WQP begin dates:
STR Monitoring Revisions Compliance and Monitoring Period Definitions (Other Monitoring Clarifications – cont.)
The STR clarify WQP begin dates:
After State sets OWQPs begins:
Jan 1 or July 1 for PWSs on standard monitoring.
June 1 for small/medium on reduced monitoring.*
Annual WQP monitoring begins during CY after end of the 3rd consecutive year of 6-month periods of meeting OWQPs.
Triennial monitoring begins no later than 3 years after 3rd consecutive year of meeting OWQPs.
After the State sets OWQPs, the first WQP monitoring period is:
Jan 1 or July 1, whichever comes first, for systems on standard monitoring; and
June 1 for small/medium systems that were on reduced lead and copper tap monitoring when the ALE occurred. [Note that this differs from the 6-month compliance periods under the LCRMR that were Jan – June or July - December. The 6-month compliance period will be June 1 – November 30.]
Annual WQP monitoring begins during the calendar year immediately following the end of the 6th consecutive 6-month monitoring period in which the PWS met its OWQP specifications.
Triennial WQP tap monitoring begins no later than the 3rd CY following the end of the 3rd consecutive annual monitoring period in which it met its OWQP specifications.
* 6-month OWQP compliance period will be June 1 – November 30.
April 2008 39

40. STR Monitoring Revisions Criteria for Reduced Monitoring
Systems Affected
Systems qualifying for reduced monitoring based on OWQPs (primarily > 50,000).
Rule Revision
Cannot qualify for or remain on reduced monitoring if exceed lead AL.
Previously, could qualify based on meeting OWQPs.
Clarifies standard monitoring resumes Jan. 1 of CY following lead ALE or OWQP excursion.
Previously systems meeting optimal water quality parameters (OWQP) could go on reduced monitoring for lead and copper. Under LCR STR, systems must meet their OWQP specifications and the lead AL to go on reduced monitoring.
Systems on reduced monitoring for lead and copper that are currently exceeding the lead AL will go back on 6-month tap monitoring schedule.
STR clarifies that standard 6-month tap monitoring will begin Jan. 1 of CY following the monitoring period in which the lead ALE or WQP excursion occurred.
April 2008

41. Requirements to Inform the Public
Lead and Copper Short-Term Revisions and Clarifications Regulatory Changes
Requirements to Inform the Public

42. STR Regulatory Revisions Requirements to Inform the Public
Three New or Revised Requirements:
Consumer Notification of Lead Tap Water Results.
Consumer Confidence Report Lead Informational Statement.
Public Education following Lead ALE.
The following slides review the revisions under the LCR STR that affect system requirements to inform the public.
April 2008

43. STR Public Information Lead Consumer Notice
On Training CD !
Systems Affected
All CWSs and NTNCWSs.
Rule Revision
Provide notice of lead tap water monitoring results.
Provide irrespective of whether sample exceeds lead AL.
Provide to all served by sampling site -- not just ones with water bills.
Provide as soon as practical but within 30 days after receives results.
Provide by mail or other State-approved methods.
Lead sample results must be provided to all persons served at the sampling site not just those that receive a water bill. (For example, if the landlord receives the water bill, the water system will still have to provide sampling results to the renters at the sampling location.)
Must provide notice even if lead levels do not exceed 15 ppb.
Provide notice within 30 days of systems receiving results.
Must be provided by mail or other methods (e.g. posting for NTNCWS).
April 2008

44. STR Public Information Lead Consumer Notice (cont.)
Notice must include:
Results of lead tap water monitoring.
Explanation of lead health effects.
Steps consumers can take to reduce exposure.
Facility contact information.
MCLG and AL for lead and their definitions.*
In addition to the test results, the notice must include:
an explanation of the health effects of lead,
steps consumers can take to reduce exposure to lead in drinking water,
contact information for the water utility,
the MCLG and the action level for lead, and the definitions for these two terms from § (c) of the CCR Rule.
The PE guidances contain templates letters systems may use. Templates are available for different scenarios.
* Must use CCR Rule language.
April 2008

45. STR Public Information Lead Consumer Notice (cont.)
On Training CD !
Within 3 months after monitoring period end, send State:
Sample of lead consumer notice, and
Certification that notification meets delivery requirements.
Sample certification available in revised M/R and State implementation guidances.*
Within 3 months after the end of each lead and copper tap monitoring period, the system must:
Send the State a sample copy of the lead consumer notice, and
Certify to the State that the notification meets the delivery requirements of section (i.e., the requirements that were discussed on the previous slide).
A sample of the lead consumer notice certification form is provided as Appendix E to the revised LCR Monitoring and Reporting Guidance for Public Water Systems. *
April 2008

46. STR Public Information Lead Consumer Notice (cont.)
New consumer notice M/R violation.
Brings number of violations types to 11.
Separate violation from public education.
Begin date = 3 months and 1 day after monitoring period end.
End date = defaulted by SDWIS/ODS to 12/31/2025.
Lead Consumer Notification Violation
Violation Type Code
Contaminant Code
Violation Name
Definition 66
5000
Lead Consumer Notice
Failure to meet any of the following:
Provide notice of lead results to individuals served by taps used for lead and copper tap monitoring in accordance with §141.85(d)(1);
Meet the timing requirements for providing the notice in accordance with §141.85(d)(2);
Meet the content requirements in §141.85(d)(3);
Meet the delivery requirements in §141.85(d)(4); and
Meet the State reporting requirements in §141.90(f)(3).
The Short-Term Revisions have minimally impacted State reporting requirements. To address these Revisions, EPA has added one new violation type (to bring the total to 11) and revised the violation definitions for three violation types. EPA has not revised any of the milestone reporting requirements.
It is important to keep in mind that although the requirements for consumer notification are included under §141.85, they are considered separate from public education requirements. All systems regardless of whether they have a lead action level exceedance must conduct this notification. A violation of these requirements constitutes a separate violation from those systems that do not meet the public education requirements. In addition, a lead consumer notice violation is a reporting violation (and requires no PN); whereas a public education violation is a treatment technique (TT) violation and requires Tier 2 PN.
Begin date is 3 months and 1 day after the end of the monitoring period (i.e., is the day after the certification is due). As is true of most LCR violations, SDWIS/ODS defaults the end date to 12/31/2025.
The table lists the definition of a lead consumer notice violation. Essentially, it is failure to meet the:
content, delivery, and/or timing requirements for this notice, and/or
requirements to send a copy of the notice/certification to the State.
April 2008

47. STR Revisions Lead Consumer Notice (cont.) Example
PWS monitors June – Sept 2009.
Receives results on 7/15/09. All results are < 15 ppb.
System must provide:
Consumer notice by 8/14/2009 (30 days after learns results).
Sample notice/certification to State by 12/31/2009 (3 mos after monitoring period end).
System actually provides:
Notice on 1/10/2010.
Certification on 4/01/2010.
State reports:
One 66 violation on 2/15/2010.
Begin date = 1/1/2010 (3 mos and 1 day after monitoring period end).
End date = 12/31/2025*
Compliance achieved = 4/01/2010
Although the system is in violation because it is late in delivering the consumer notice and providing a sample notice and the certification to the State, only one violation is reported.
In this example, the violation is reported to SDWIS/ODS on 2/15/2010.
The begin date is 1/1/2010 (3 months after the monitoring period).
SDWIS/ODS defaults to an arbitrary end date of December 31, 2025 for this violation.
The date will automatically be replaced when the State reports the date that the system has “returned to compliance.’’
This action is reported as an SOX (State) or less commonly by EPA as EOX (federal) action type. The period of violation would be ended when either the SOX/EOX actions are reported and linked to the violation.
In this example, the system returned to compliance on April 1, 2010, when it submitted its notice and certification to the State.
Note: If the system returns to compliance before the violation is required to be reported, do not use the end date of 12/31/ So if in this example the system had submitted its sample notice and certification to the State on 2/1/ 2010 instead of 4/1/2010, the end date 2/1/2010 should be used in lieu of 12/31/2025.
* SDWIS/ODS defaults to 12/31/2025. State reports end date when system returns to compliance
April 2008

48. STR Public Information Consumer Confidence Report Requirement
Systems Affected
All CWSs
Rule Revision
All CCRs must include:
Sources of lead in drinking water.
Health effects from lead exposure.
Ways to reduce lead in drinking water.
Recommended flushing times.
Places to go for more information including lead testing.
Required regardless of lead sample levels.
The LCR STR revised the requirements of the CCR Rule. Previously an informational statement was only required if >5% of tap samples were above the lead AL.
Now EPA is requiring all CWS to provide information in every CCR on lead in drinking water irrespective of whether the system detected lead in any of its samples.
CWS must still report the 90th percentile value and the number of sample sites exceeding the lead AL.
All systems where EPA is the Primacy Agency, systems in States that adopt by reference automatically or adopt the rule during 2008 should comply with the new reporting requirements in the CCR due July 2009 (i.e., the 2008 CCR).
Some PWSs must include in 2008 CCR (due July 1, 2009).
April 2008

49. STR Public Information Consumer Confidence Report Requirement (cont.)
On Training CD !
Must include following mandatory language, or
Write own statement in consultation with State.
If present, elevated levels of lead can cause serious health problems, especially for pregnant women and young children. Lead in drinking water is primarily from materials and components associated with service lines and home plumbing. [Name of Utility] is responsible for providing high quality drinking water, but cannot control the variety of materials used in plumbing components. When your water has been sitting for several hours, you can minimize the potential for lead exposure by flushing your tap for 30 seconds to 2 minutes before using water for drinking or cooking. If you are concerned about lead in your water, you may wish to have your water tested. Information on lead in drinking water, testing methods, and steps you can take to minimize exposure is available from the safe Drinking Water Hotline or at
A water system must use the following mandatory language (except text in brackets is system-specific) or can modify the language in consultation with the State.
For example, the system may elect to modify the flushing information if it conflicts with its public education language.
The mandatory language is as follows:
If present, elevated levels of lead can cause serious health problems, especially for pregnant women and young children. Lead in drinking water is primarily from materials and components associated with service lines and home plumbing. [Name of Utility] is responsible for providing high quality drinking water, but cannot control the variety of materials used in plumbing components. When your water has been sitting for several hours, you can minimize the potential for lead exposure by flushing your tap for 30 seconds to 2 minutes before using water for drinking or cooking. If you are concerned about lead in your water, you may wish to have your water tested. Information on lead in drinking water, testing methods, and steps you can take to minimize exposure is available from the safe Drinking Water Hotline or at
April 2008

50. STR Public Information Public Education Requirements
Systems Affected
All systems exceeding lead AL.
Rule Revision
Shortened mandatory language consisting of:
Opening statement,
New health effects language provide greater specificity on lead health effects, and
Sources of further information.
Flushing recommendations can be tailored.
Unless waived, State must review and approve materials.
Additional delivery requirements to target sensitive populations.
STR significantly modified content of the written public education materials
CWSs and NTNCWSs must deliver the same mandatory language that consists of an opening statement, health effects language, and sources of further information
The health effects language has been revised to provide greater specificity on the health problems that can result from exposure to lead (e.g., the original health effects language indicated that lead can cause damage to the brain, while the new language specifies that this damage is associated with lower IQ in children).
The revised rule also requires these water systems to include information regarding sources of lead, steps consumers can take to reduce their lead exposure, any known reasons for elevated lead levels, and steps that the water system is taking to reduce lead levels.
Unlike the prior requirements, water systems have the flexibility to tailor these topics to fit their community and/or situation. For example, previous public education language required water systems to instruct consumers to flush their faucet for seconds or one minute (if the home has a lead service line) before drinking the water. This rule allows systems to tailor flushing directions to their specific situations.
Water systems must submit public education language for State review and approval at the option of the State.
New set of delivery requirements was added to help reach at-risk populations (e.g., pregnant women, infants, and young children).
April 2008

51. STR Public Information Public Education – Content Requirements
Required content for CWSs & NTNCWSs:
Information Statement *
Health Effects of Lead *
Sources of Lead
Steps to Reduce Exposure
What Happened? What is Being Done?
For More Information *
Information must be in appropriate languages.
On Training CD !
Info statement: IMPORTANT INFORMATION ABOUT LEAD IN YOUR DRINKING WATER. [INSERT NAME OF WATER SYSTEM] found elevated levels of lead in drinking water in some homes/buildings. Lead can cause serious health problems, especially for pregnant women and young children. Please read this information closely to see what you can do to reduce lead in your drinking water.
Health Effects: Health effects of lead. Lead can cause serious health problems if too much enters your body from drinking water or other sources. It can cause damage to the brain and kidneys, and can interfere with the production of red blood cells that carry oxygen to all parts of your body. The greatest risk of lead exposure is to infants, young children, and pregnant women. Scientists have linked the effects of lead on the brain with lowered IQ in children. Adults with kidney problems and high blood pressure can be affected by low levels of lead more than healthy adults. Lead is stored in the bones, and it can be released later in life. During pregnancy, the child receives lead from the mother’s bones, which may affect brain development.
Sources: Explain what lead is and possible sources of lead in drinking water and how lead enters drinking water. Include information on home/building plumbing materials and service lines that may contain lead. Discuss other important sources of lead exposure in addition to drinking water (e.g., paint).
Steps: (A) Encourage running the water to flush out the lead. (B) Explain concerns with using hot water from the tap and specifically caution against the use of hot water for preparing baby formula. (C) Explain that boiling water does not reduce lead levels. (D) Discuss other options consumers can take to reduce exposure to lead in drinking water, such as alternative sources or treatment of water. (E) Suggest that parents have children’s blood tested for lead.
For more Info: For more information, call us at [INSERT YOUR NUMBER] [(IF APPLICABLE), or visit our Web site at [INSERT YOUR WEB SITE HERE]]. For more information on reducing lead exposure around your home/building and the health effects of lead, visit EPA’s Web site at or contact your health care provider.
For PWSs serving a large proportion of non-English speaking consumers, as determined by the State, PE materials must contain information in the appropriate language(s) regarding the importance of the notice or contain a telephone number or address where persons served may contact the water system to obtain a translated copy of the public education materials or to request assistance in the appropriate language. – This is the same methodology used for CCR and PN.
* Must use STR mandatory language.
April 2008

52. STR Public Information Public Education – Content Requirements (cont.)
Required content for CWSs only:
Tell consumers how to get their water tested.
Discuss lead in plumbing components and difference between low lead and lead free.
“Special CWSs” can ask to forego these requirements.
CWS’s public education materials must also indicate how consumers can get their water tested, and provide a discussion of lead in plumbing materials and the difference between low-lead and lead-free materials.
“Special CWSs” can apply to State in writing to forego these additional requirements. They are defined as systems that:
Serve populations that cannot make improvements to plumbing or install point-of-use devices (e.g., CWS is a prison, hospital), and
Do not charge separately for water consumption.
State can waive the requirement for these CWSs to obtain prior approval.
April 2008

53. STR Public Information Public Education – CWS Delivery Requirements
Printed materials (pamphlets, brochures, posters) to all bill paying customers.
Materials to:
Local public health agencies
Public and private schools or school boards
Women Infants and Children (WIC) and Head Start programs
Public and private hospitals and medical clinics
Pediatricians
Family planning clinic
Local welfare agencies.
STR retain the requirements for CWSs to provide public education materials to all bill-paying customers.
STR retain the requirement for CWSs to deliver public education materials to the following organizations in their area:
Local public health agencies
Public and private schools or school boards
Women Infants and Children (WIC) and Head Start programs
Public and private hospitals and medical clinics
Pediatricians
Family planning clinic
Local welfare agencies.
but adds a requirement that water systems include an informational notice with the public education materials sent to the local public health agencies explaining the importance of sharing the information with their customers or users, even if the public health agency is not within the water system's service area.:
April 2008

54. STR Public Information Public Education – CWS Delivery Requirements (cont.)
Contact local health departments by phone/in-person.
Must make good faith effort to locate and deliver materials to following organizations in service area:
Licensed child care centers.
Public and private preschools.
Obstetricians-gynecologists and midwives.
EPA has expanded the delivery requirements in recognition of the importance of distributing information to the at-risk populations (e.g., pregnant women, infants, and young children) on the hazards of lead and how individuals can protect themselves from exposure to lead.
LHDs:
LHDs may be valuable resources for identifying additional community-based organizations that serve target populations.
Previously, CWSs were required to distribute public education materials to health departments in their area.
STR require CWSs to contact their LHDs via phone or in-person, vs. mail only to request their assistance in distributing information on lead in drinking water and how people can reduce their exposure to lead.
PWSs must contact their LHDs even if they are outside the PWS’s service area.
LHDs may provide PWS with specific list of additional community-based organizations serving target populations (may include those outside service area)
If provided, PWSs must deliver materials to all organizations on the provided lists.
Good Faith Effort: CWSs must make a “good faith effort’’ to locate and deliver materials to additional organizations (i.e., licensed childcare facilities, obstetricians-gynecologists and midwives, and preschools) and to include an informational notice with the public education materials explaining the importance of sharing the information with their customers or users.
A “good-faith effort’’ to contact at-risk customers can include requesting a contact list of childcare facilities, obstetricians-gynecologists, midwives, and preschools from LHD, even if outside PWS’s service area.
PSAs: STR remove requirement for medium/large CWSs to provide 2PSAs/yr. Instead it is one of the outreach activities from which a system can choose from.
Press releases: CWSs must distribute 2 press releases vs. 1 previously required.
Small systems: Systems serving 3,300 or fewer people can:
Limit PE material delivery informational notice to those places frequented by the most vulnerable populations without written approval from the State.
Forego issuing press releases if allowed by the State and they distribute notices to every household they serve.
Implement minimum of 1 of 9 additional outreach activities listed on the next slide.
Submit press release to newspaper, TV, and radio stations.
Small system can limit activities.
April 2008

55. STR Public Information Public Education – CWS Delivery Requirements
At least quarterly provide information on water bill.
Water bill must include following statement:
Systems serving > 100,000 must post
material on web site.
[Insert name of water system] found high levels of lead in drinking water in some homes. Lead can cause serious health problems. For more information please call [insert name of water system] or visit [insert your web site here].
With each billing cycle but no less often than quarterly, CWSs must include the following mandatory language on the water bill.
[Insert name of water system] found high levels of lead in drinking water in some homes. Lead can cause serious health problems. For more information please call [insert name of water system] or visit [insert your web site here].
CWSs may modify this message or provide the information in a separate mailing or other delivery method if allowed by the State.
Systems serving more 100,000 people must also post public education materials that meet the content requirements and keep information on their publicly-accessible Web site until the system tests at or below the action level.
April 2008

56. STR Public Information Public Education – CWS Delivery Requirements
CWSs must conduct additional outreach activities from list.
CWSs serving > 3,300 conduct 3 or more.
CWSs serving 3,300 or fewer conduct at least 1.
Public service announcement (PSA)
Paid advertisement
Display information in public areas
to customers
Public meetings
Delivery to every household
Provide materials directly to multi-family homes
Other methods approved by State
Systems must complete additional PE outreach by selecting from these options.
Public service announcement (PSA)
Paid advertisement
Display information in public areas
to customers
Public meetings
Delivery to every household
Provide materials directly to multi-family homes
Other methods approved by State
Systems should select the activities most suitable for water system consumers and most likely to reach target audiences as soon as possible.
Systems serving more than 3,300 people are required to select three additional public education activities from one or more categories on this list.
Systems serving 3,300 or fewer people must complete one activity.
April 2008

57. STR Public Information Public Education – CWS Timing Requirements
Delivery within 60 days:*
Applies if not already subject to public education.
State may grant extension.
Although the Federal rule offers a case-by-case extension option, the Department has elected not to exercise this option.
Continue as long as ALE persists:
Repeat water bill mandatory language at least quarterly.
Repeat press releases twice every 12 months.
Maintain materials on website (> 100,000 only).
Repeat other materials/activities every 12 months.
Systems must Deliver PE within 60 days from the end of the monitoring period:*
The 60 Day deadline the Applies if not already subject to public education.
State can extend 60 day deadline as long as the water system has initiated these activities and the extension is approved in writing by the State in advance of the 60-day deadline.
A system must continue delivering PE as long as ALE persists and this would include:
Repeat water bill mandatory language at least quarterly.
Repeat press releases twice every 12 months on a schedule agreed upon by the State
Maintain materials on website (> 100,000 only).
Repeat other materials/activities every 12 months.
* From end of monitoring period with lead ALE.
April 2008

58. STR Public Information Public Education – NTNCWS Delivery Requirements
STR does not change NTNCWS delivery requirements:
Distribute pamphlet/brochures to each person served.
Post informational posters in public places/common areas in each building served.
“Special CWSs” may still use NTNCWS
delivery methods.
STR does not revise delivery requirements for NTNCWSs.
The NTNCWs can
Distribute pamphlet/brochures to each person served.
Post informational posters in public places/common areas in each building served.
STR also retain the provision for “special CWSs’’, such as prisons and hospitals, to apply to the State in writing (unless prior approval is waived) to use the same delivery requirements as NTNCWSs.
April 2008

59. STR Public Information Public Education – NTNCWS Timing Requirements
Delivery within 60 days:*
Applies if not already subject to public education.
State may grant extension.
Continue every 12 months as long as ALE persists.
Although the Federal rule offers a case-by-case extension option, the Department has elected not to exercise this option.
Delivery within 60 days from end of the monitoring period in which the lead action level occurred.
60-days applies if the system is not already subject to public education.
State may extend 60 days as long as activities have started within 60 days of lead ALE and approved in writing prior to end of 60 days.
* From end of monitoring period with lead ALE.
April 2008

60. Notification of Treatment Changes and Source Additions
Lead and Copper Short-Term Revisions and Clarifications Regulatory Changes
Notification of Treatment Changes and Source Additions

61. STR Revisions Long-Term Treatment Changes and New Source Additions
Systems Affected
Systems on reduced Pb/Cu tap monitoring.
Rule Revision
Requires prior notification and approval of treatment change or source addition.
Limits notification of treatment changes to “long-term changes.”
Notification due as specified by State, or early as possible prior to change or addition.
Previously, the LCR required systems to notify the State within 60 days of making a change in treatment or adding a new source. The STR clarify EPA’s intent by stating that the notification of treatment changes apply to those that would have long-term impacts on water quality. Otherwise a system could go years before detecting a problem.
Furthermore, the STR requires notification must be done in advance of the treatment change and water systems must receive approval from the State before adding a new source or making any long-term treatment change.
April 2008

62. STR Revisions Long-Term Treatment Changes and New Source Additions (cont.)
Examples of long-term treatment changes:
Switching secondary disinfectants.
Switching coagulants.
Switching corrosion inhibitor products.
Changing dosage of existing chemicals.
Installation of membrane filters, ozonation, enhanced coagulation/softening.
Does NOT include chemical dose fluctuations associated with daily raw water quality changes.
An example of a long-term treatment change may include:
Switching secondary disinfectants (e.g. chlorine to chloramines)
Switching coagulants (alum to ferric chloride)
Switching corrosion inhibitor products (e.g. orthophosphate to blended phosphate)
Changing dosage of existing chemicals if the system is planning long-term changes to its finished water pH or residual inhibitor concentration.
Installation of membrane filters, ozonation and enhanced coagulation/enhanced softening to reduce DBPs precursors.
They do NOT include chemical dose fluctuations associated with daily raw water quality changes
More examples of the long-term treatment changes are provided in the State Implementation Guidance for the LCR STR.
April 2008

63. STR Revisions Long-Term Treatment Changes and New Source Additions (cont.)
Examples of source water additions include:
Switching source types.
Adding treated surface water to ground water only system.
Adding new well from different aquifer.
Seasonal or interannual source changes DO NOT require notification if:
Covered by previous OCCT studies and sampling, and
Covered within OCCT designation framework.
Examples of source additions include:
Shifting from ground water to surface water supply (notification and approval would not be needed if the switch is repeated on an annual basis).
Adding a treated surface water to a ground water only system.
Adding a new well from an aquifer with different water quality characteristic pertinent to corrosivity (e.g., alkalinity) than the current supply.
Regularly changing among sources on a seasonal or interannual basis that have been covered by previous LCR OCCT studies and sampling, and are covered within the OCCT designation framework, do not require notification.
April 2008 63

64. STR Revisions Long-Term Treatment Changes and New Source Additions (cont.)
Simultaneous Compliance Guidance Manual -- LT2 and Stage 2 DBP Rules
Format differs from 1999 manual.
Treatment change chapters.
Improving or optimizing existing treatment.
Addition of new carbon or microbial removal technology.
Alternate disinfection strategies.
In addition to assist the state in making its determination, EPA published “Simultaneous Compliance Guidance Manual for the Long term 2 and Stage 2 DBP Rules” on March 2007.
Available at:
April 2008

65. STR Revisions Long-Term Treatment Changes and New Source Additions (cont.)
Simultaneous Compliance Guidance Manual -- LT2 and Stage 2 DBP Rules
Identifies treatment interactions and impact on key WQPs.
Discusses operational considerations for treatment modifications.
Provides tools to gather information.
Is not cookbook -- won’t provide step-by-step
procedure to optimal “right” treatment.
Provides information to assess situation and consider options.
Provides tools for monitoring after change.
Provides tools for monitoring after change, since interactions may still be unpredictable.
April 2008

66. Reevaluation of Tested-Out Lead Service Lines
LCR STR
Reevaluation of Tested-Out Lead Service Lines

67. STR Revisions Reevaluation of Tested-Out Lead Service Lines
Systems Affected
Systems subject to lead service line replacement.
Rule Revisions
Must re-evaluate LSLs that tested < 15 ppb if re-exceed lead AL (“replaced through testing”).
Must add to inventory of LSLs to be replaced.
Previous sample may no longer be representative.
Can either re-test line or replace line.
Must consider “tested-out” line each time re-exceed.
Lead service line replacement is intended as an additional step to reduce lead exposure when corrosion control treatment is unsuccessful. The Short-Term Revisions require water systems to reconsider any lines previously determined to not require replacement (i.e., “replaced through testing’’) if they exceed the action level again in the future and resume the lead service line replacement program.
Specifically, the LCR STR requires water systems to update their inventory of lead service lines to include those that were classified as “replaced through testing.’’
The system will then divide the updated number of remaining lead service lines by the number of remaining years in the program to determine the number of lines that must be replaced per year. [Example provided on next page.]
Re-evaluation could consist of either testing the line again or physical replacement of the line because previous sample may no longer be representative of the lead service line lead concentrations.
A PWS must reconsider and retest the lines “replaced through testing’’ each time it is required to resume its lead service line program.
April 2008

68. STR Revisions Reevaluation of Tested-Out Lead Service Lines Example
2 years of replacement completed prior to resuming LSLR.
7 of the 50 LSLs were “replaced through testing.’’
15-year LSLR program.
Still has 50 LSLs in inventory because must include those lines previously considered replaced through testing.
Must replace 50 lines over 13 years (because 2 years of the 15-year LSLR program has elapsed) = about 4 lines per year.
Any retested or newly tested lines < 15 ppb are considered replaced through testing.
A PWS completed 2 years of replacement prior to resuming lead service line replacement. In that 2-year period, 7 of the 50 lead service lines in the system’s inventory were considered “replaced through testing.’’ It is on a 15-year replacement program and has still 50 lead service lines in its inventory to be considered (because it must include those previously considered “replaced through testing’’). The PWS is required to replace 50 lines over 13 years or approximately 4 lines per year. Note that any retested or newly tested lines that are at or below mg/L are considered replaced.
April 2008

69. Questions?