Lead and Copper in Public Water Systems

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In 2016, Ohio Legislature amended Ohio Revised Code Chapter 6109, adopting new requirements related to lead and copper for public water systems (PWSs) and certified laboratories. The new requirements charged Ohio EPA with reviewing standards for lead and copper monitoring,required more timely public notification of monitoring results, and ensured public water systems optimize corrosion control treatment. Submit the completed verification form within 5 business days of receipt of lead sample results. Submit to Ohio EPA DDAGW Central Office via email (preferred): DDAGW_lead_CN@epa.ohio.gov; fax: 614-644-2909; or mail: Ohio EPA - DDAGW, 50 West Town Street, Suite 700, Columbus, OH 43216 , Subject: Lead Consumer Notice.

The sections below include required forms, summaries of key requirements, other helpful documents and answers to frequently asked questions regarding the LCR.

Questions? Contact your district office.

General Lead and Copper Info

In 1974, the Safe Drinking Water Act was passed by Congress. This law requires EPA to determine the level of contaminants in drinking water at which no adverse health effects are likely to occur with an adequate margin of safety. Since lead contamination of drinking water often results from corrosion of the plumbing materials belonging to consumers, the EPA establishes a Treatment Technique. The Treatment Technique regulation for lead requires water systems to control the corrosivity of water.

In 2016, Ohio Legislature amended Ohio Revised Code Chapter 6109, adopting new requirements related to lead and copper for public water systems and certified laboratories. The new requirements charged Ohio EPA with reviewing standards for lead and copper monitoring, required more timely public notification of monitoring results, and ensured public water systems optimize corrosion control treatment. On May 1, 2018 new rules became effective.

Lead Service Lines and Mapping

OAC Rules 3745-81-84 and 3745-83-02 introduced new requirements that PWSs notify consumers in areas of lead service lines (LSLs) when water line work may disturb these lead lines. Ohio EPA recommends all LSLs are replaced in accordance with AWWA Standard C810-17 (follow link for purchase below). In some cases, the PWS may be required to provide filters certified to remove lead to consumers. For more information about these requirements and for LSL replacement guidance, review the following guidance documents:

Mapping

All PWSs were required to submit distribution system lead maps to Ohio EPA for the first time in 2017. Maps should be updated regularly so that systems can easily respond to disruption of service events, water main projects, and lead service line replacement projects. PWSs are required to submit an updated distribution system lead map to Ohio EPA every 5 years (next submission required in 2022). Any significant updates can be submitted to the appropriate Ohio EPA district office in the interim. Current maps can be found at the link below.

Guidance and forms for distribution system mapping can be found below:

Note: Water systems may contact Ohio EPA's Office of Compliance Assistance and Pollution Prevention at (800) 329-7518 for help with mapping questions.

Monitoring

Lead and copper enter drinking water due to the corrosion of service line and household plumbing materials; therefore, reducing water corrosivity is the primary method for reducing the health risk of lead and copper in drinking water. To measure the corrosivity of water in contact with service lines and household plumbing, federal and state rules require lead and copper routine compliance samples to be taken at residential taps within the distribution system.

Monitoring Schedule

PWSs may monitor for lead and copper on one of three schedules: every 6 months, every year (reduced annual), or every three years (reduced triennial). The number of samples PWSs are required to collect is based on population and may be reduced if the PWS is on annual or triennial monitoring.

Your current monitoring schedule can be found on our Public Water System page under the Monitoring and Reporting tab.

As of May 1, 2018, PWSs are required to apply for reduced triennial lead and copper monitoring by submitting the application below to their District Office. Systems approved for triennial monitoring are required to submit a new application after each round of monitoring. It is the obligation of the PWS to provide complete and relevant documentation with their application to increase the likelihood of qualifying for reduced triennial monitoring. Public water systems with incomplete, irrelevant, or unsubstantiated applications will be set to an annual monitoring requirement for lead and copper. Note: Ohio EPA may consider additional information about the PWS when reviewing applications.

Triennial Lead and Copper Monitoring Applications are due by November 1st annually.

Historical sample results can found on our Data Reporting page under the Data Received tab or on Drinking Water Watch.

Sample Monitoring Point IDs

Each PWS must identify unique SMP IDs for all lead and copper sample sites using the template below. The routine sampling sites used for lead and copper tap monitoring should remain the same for each monitoring period. It is the responsibility of the PWS to maintain sample site information and to provide updated sample site information to Ohio EPA including an explanation of the changes.

Sample Collection

Samples collected for compliance with the lead and copper rule must be first draw, one-liter samples. They should be collected in wide mouth bottles from kitchen or bathroom cold water taps or other taps typically used for consumption. Taps with point of use treatment or softening should not be used. Individual residents may collect samples for the PWS, detailed instructions similar to those found at the link below should be provided to the resident.

  • Tips for LCR Sampling During COVID-19 (PDF)
  • Instructions for Collection of Lead and Copper Samples by Residents (PDF)

Certified Laboratories

All lead and copper samples must be analyzed by an Ohio EPA certified drinking water laboratory.

  • To view a complete list of Ohio EPA Certified Laboratories, visit our Certified Laboratories page (lead and copper labs can be found on the Chemical list)

Lead Consumer Notice of Results

Systems are required to issue a Lead Consumer Notice (CN) for each tap sampled within 2 business days of the receipt of the laboratory result to the owner and persons served by the tap, including those that do not receive water bills. CN must be provided for both routine compliance samples and special purpose samples, regardless of result, sample type, or size. Submit to Ohio EPA DDAGW Central Office via email (preferred): DDAGW_lead_CN@epa.ohio.gov; fax: 614-644-2909; or mail: Ohio EPA - DDAGW, 50 West Town Street, Suite 700, Columbus, OH 43216 , Subject: Lead Consumer Notice.

Ninetieth Percentile Calculation

The 90th percentile calculation is used to determine if a PWS has exceeded the lead or copper action level of 0.015 mg/L for lead and 1.3 mg/L for

  • Worksheet for 90th Percentile Calculation (Excel)

Action Level Exceedance

A PWS has exceeded the action level if the 90th percentile for lead is > 0.015 mg/L or copper is > 1.3 mg/L. Lead public notification and public education is only required in the instance of a lead action level exceedance; however, a PWS may be required to implement treatment if they exceed the copper action level. Please contact your Ohio EPA district office for additional information regarding a copper action level exceedance.

Lead Public Notification (LPN)

Systems are required to issue a LPN to the entire system within 2 business days of the receipt of the laboratory results indicating there is a lead action level exceedance. Within 5 business days from the receipt of results, the PWS must submit the verification form below to their Ohio EPA District Office, verifying that the LPN was issued. Example language for an LPN is included in the Fact Sheet below.

Lead Public Education

Systems are required to issue Lead Public Education (PE) to the entire system within 30 business days of the receipt of the laboratory results indicating there is a lead action level exceedance. Within 5 business days from the issuance of PE, the PWS must submit the verification form below to their Ohio EPA District Office, verifying that the PE was issued.

  • Template for Lead Public Education after Exceedance (Community) (PDF, Word)
  • Template for Lead Public Education after Exceedance (NTNC and Certain Community) (PDF, Word)
  • Verification Form for Lead Public Education (Community) (PDF, Word)
  • Verification Form for Lead Public Education (NTNC) (PDF, Word)

Water Quality Parameters and Corrosion Control

This section includes required forms for water quality parameter monitoring, source water treatment, and corrosion control treatment recommendations.

Training

Ohio’s 2018 Revisions to the Lead and Copper Rule Webinar

More training coming to this site in 2019

Frequently Asked Questions

Who does the LCR apply to?

The LCR applies to all community and non-transient non-community public water systems.

What are the tier requirements for lead and copper?

Community Water System sampling sites

Tier 1 - Single family structures that contain copper pipes with lead solder installed between January 1, 1982 and December 31, 1988* or contain lead pipes or are served by lead service lines. Multi-family residences (MFH) with such piping can be included if MFHs are at least 20 percent of the structures served by the water system. Residences with point-of-use or point-of-entry devices, such as water softeners, are usually excluded.

Tier 2 - Buildings, including multiple-family residences, that contain copper pipes with lead solder installed between January 1, 1983 and December 31, 1988* or contain lead pipes or are served by lead service lines.

Tier 3 - Single family residences that contain copper pipes with lead solder installed before January 1, 1983.

Non-Transient Non-Community Water System sampling sites

Tier 1 - Buildings that contain copper pipes with lead solder* installed between January 1, 1983 and December 31, 1988* or contain lead pipes or are served by lead service lines.

Tier 2 - Buildings, including multiple-family residences, that contain copper pipes with lead solder installed between January 1, 1983 and December 31, 1988* or contain lead pipes or are served by lead service lines.

Tier 3 - Single family residences that contain copper pipes with lead solder installed before January 1, 1983.

*Effective May 1, 2018, the Tier 1 definitions changed from “copper pipes with lead solder installed after 1982” to “copper pipes with lead solder installed after 1982 and before 1989.” Locations previously considered Tier 1 may no longer meet the Tier 1 definition. PWSs should evaluate their sampling pool and identify additional Tier 1 locations as necessary. Lead and Copper Rule: New Tier Definitions

What are Sample Monitoring Points and how to ID them?

Sample sites are based on locations in the PWS with the highest risk for exposure. Click here for instructions on how to complete SMP IDs.

SMP ID Spreadsheets are a good tool for ensuring PWSs are sampling at qualifying locations and have information for required CN, which HB 512 requires Ohio EPA to give CN to residents if PWS fails to. It is a good idea for PWSs to have more than required number of unreduced sample sites listed on SMP ID list and send any SMP ID updates to your District Office

Can my sampling monitoring points (SMPs) change?

The intent of the LCR is to sample from the same locations from monitoring period to monitoring period. Any changes to the sample site information provided in the SMP ID Template will need to be sent to OEPA along with an explanation as to why the sample site is changing. See rule 3745-81-86(B)(4).

Are there any differences when calculating 90th percentile values with the new electronic SMP IDs?

90th Percentiles are now being calculated as results are being reported rather than at the end of the monitoring period. The results are based on the minimum number of scheduled samples until more than the minimum number of samples has been collected. Ohio EPA will act on this information to protect public health. Please use the 90th Percentile Calculator (Excel) in Excel to keep track of your results.

Why should I sample early in my monitoring period?

Revisions to Ohio’s LCR included shorter time frames for public notification, public education, and ALE response sampling. Sampling early in the monitoring period will allow time to respond to these situations and ensure rule requirements are met and associated penalties are avoided.

Can a customer collected compliance sample be invalidated?

Under the LCR, it is the PWS’s responsibility to ensure proper sampling requirements were met prior to accepting the sample from the customer and before submitting to the lab for analysis. Once a PWS accepts a customer collected sample and the data is reported to OEPA, the results cannot be invalidated. See rule 3745-81-86(F).

What is special purpose sample?

Special purpose identifies samples that are taken outside of the required monitoring period, taken from a tier site lower than the required tier, investigatory samples (repeat samples taken from same site during same monitoring period unless water system has fewer than five taps), not collected in accordance with the approved sampling methodology, or taken after lead service line replacement. Special purpose samples are subject to the 2-day CN requiring, but are not counted for determination of the 90th percentile.  See rule 3745-81-86(E).

Why are there new requirements for reduced triennial monitoring?

Three years between monitoring periods for systems that displayed possible corrosive water with the potential for lead exposure is not reasonable. Previous versions of rules allowed for reduced monitoring schedules, if certain requirements were met, but only required systems to go back to 6-month and annual monitoring after ALEs or significant treatment changes. The best way to determine lead exposure to consumers is through the collection of lead monitoring data.

What qualifies as a substantial change in water treatment?

Long term treatment changes, including changes that don’t require plan approval. The following links will show more information on substantial changes in water treatment.

USEPA Optimal Corrosion Control Treatment

What if a water system has an ALE while also operating outside of Director-established optimal WQPs?

PWS will be required to review corrosion control study and if water quality has changed, a new study will be required. Otherwise, their treatment recommendation will need to be updated, which should include the reason as to why the PWS was outside of optimal WQPs and what the system is doing to resolve this issue.

What is a Lead Consumer Notice?

Sample results and information about lead to consumer and owner of sample taps (including, if applicable, parents, guardians, or power of attorney). The consumer notice must be sent two business days following receipt of sample results, regardless of result, sample type, or sample size, Lead or copper. However, If the lead result is above 15ug/L, the notice must have additional info on health screening and blood lead level testing, send results to board of health and (NTNC only) remove fixtures with high lead levels from service. All required information is included in Ohio EPA’s CN templates. Lead consumer notice templates can be found here.

What is a Lead Public Notice?

Initial announcement to all consumers about ALE (previously PSA in PE) that need to be sent two business days following ALE determination through delivery methods such as broadcast media, social media, hand-delivery, email, posting. Lead Public Notices must include results of tap monitoring including number of samples and 90th percentile, explanation of health effects of lead, steps to reduce expose to lead from drinking water, contact info for PWS, and (Community PWSs only) include information on the availability of tap water testing. If the PWS decides to sample at additional qualifying sites before the end of the MP, an updated PN is required at the end of the monitoring period except for Community PWSs, which need to repeat twice yearly for as long as the system has an ALE. Lead consumer notice templates can be found here.

What is Lead Public education?

Additional information given to all customers following an ALE that needs to be sent thirty business days following ALE determination. PWSs need to deliver printed materials to all bill paying customers, contact at-risk consumers (i.e schools, hospitals, pediatricians), “High lead levels…” notice in all water bills, perform 3 public outreach activities, post information on PWS website (for population >100,000)

NTNC PE Requirements

  • Deliver printed materials to all persons served
  • Post informational posters
  • All required information is included in Ohio EPA’s PE templates

 

What is the basis for providing NSF certified filters to residents affected by LSL replacement?

NSF 53 filters capture particulate lead, which is generally released following partial and main lead service lines.

These filters were recommended by the US EPA Flint Technical Support Team to ensure residents have certified filters prior to LSL replacement activities and are recommended in the AWWA standard for Replacement and Flushing of Lead Service Lines. Click here to learn more.

Who is placed on the LSL replacement schedule outlined in this rule?

Only PWSs who have an ALE after installing corrosion control or source water treatment are required to replace lead service lines. These PWSs must replace at a rate of 7% per year until all service lines are removed.

Who is affected by the lead service line replacement requirements?

This rule now applies to all PWSs that have lead service lines (public or private) and this rule has new requirements for all lead service line replacements.

Requirements for lead service line replacements of Water Mains

Provide Information from 3745-81-86 (A): lead maps, lead inventory and notices to consumers of the replacement at least 45 days prior to replacement, unless as a part of an emergency repair. This should explain to consumers they may experience a temporary increase of lead levels in their drinking water, along with guidance on measures they can take to minimize their exposure to lead and offer and provide NSF/ANSI 53 certified filters to impacted consumers.

Requirements for Full and Partial lead service line replacements

Provide notice, individually mailed or posted (MFR, building, etc.), to residents or building administrators for buildings served by the line at least 45 days prior to replacement, unless as a part of an emergency repair. This should explain to consumers they may experience a temporary increase of lead levels in their drinking water, along with guidance on measures they can take to minimize their exposure to lead. If PWS is a school, nursing home or prison: parents/guardians or power of attorney should also be directly notified. If the system does not own the whole line, notify the owner of the replacement and offer to replace the owner’s portion of the LSL but PWSs do not have to pay for the replacement of the privately-owned portion of the line. Please keep records of replacements for 12 years.

Additional Requirements for Partial Lead Service Line Replacements – Partial Only

Collect (and pay for) service line sample within 72 hours of replacement. Provide notice of results to consumer in accordance with consumer notice requirements and offer and provide NSF/ANSI 53 certified filters to consumers served by the partial line.

Why should PLSLR be avoided?

A partial lead service line replacement (PLSLR) should be avoided because construction activities necessary to affect a PLSLR disturb lead laden sediment and scale that can cause significantly higher lead levels at the customer’s tap. Please consult OEPA PWS-06-001, Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines as well as AWWA C810-17, Replacement and Flushing of Lead Service Lines for more information. OEPA provides 0% interest loans for full lead service line replacement through the WSRLA program.

What are the new requirements for laboratories?

Next day reporting requirement following laboratory analysis for: Lead, copper, total microcystins in raw water, seasonal startup samples and added requirement to report results to Ohio EPA no later than 10 days following analysis for all analytes. Added requirement that for all analytes a complete analysis must be performed within 30 days of receiving the sample – Except radiologicals (60 days). Complete information for laboratory reporting can be found on the DDAGW Reporting page.

DDAGW Site Links

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