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Lead and Copper in Public Water Systems

General Information

In 1974, the Safe Drinking Water Act was passed by Congress. This law requires U.S. 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. The Lead and Copper Rule was created by U.S. EPA to control the corrosivity of water, while also protecting public health. Lead and copper enter drinking water from the corrosion of lead and copper containing plumbing materials including home interior plumbing and water service lines. Water systems are required to collect tap samples within their water distribution systems using risk-based tiering criteria, with the highest priority being sites that have plumbing materials containing lead. The rule establishes action levels for lead and copper based on a 90th percentile level of tap water samples. An exceedance of one or both action levels trigger additional actions by the water supply. All Community and Non-Transient Non-Community Public Water Systems are subject to the lead and copper rule requirements.

2016 Ohio Revised Lead and Copper Rules

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 and Copper Rule Revisions (LCRR) and Lead and Copper Rule Improvements (LCRI)

In 2019, U.S. EPA proposed lead and copper rule revisions (LCRR). These rules became effective on Dec. 16, 2021. On the same date, U.S. EPA announced the development of a new regulation, lead and copper rule improvements (LCRI). It is important to note, that while U.S. EPA is drafting the LCRI and has indicated intent to modify certain provisions of the LCRR, the service line inventory requirement is not likely to change. This means that PWSs will need to submit a complete inventory to Ohio EPA by no later than Oct. 16, 2024.

Ohio EPA recommends that all systems subject to the lead and copper rule focus their efforts on the lead service line inventories that will be required in 2024. Ohio EPA will be releasing information on how systems can prepare for the LCRI and other provisions of the LCRR in the future.

Service Line Inventories and Lead Mapping

Service Line Inventories

On Dec. 16, 2021, the U.S. EPA's lead and copper rule revisions (LCRR) became effective. As part of the LCRR requirements, community, and non-transient non-community PWSs will be required to submit lead service line inventories to the state by Oct. 16, 2024. PWSs should begin recording this information as soon as possible. Ohio EPA understands the burden these requirements place on PWSs and has made grants available to assist with documenting the minimum inventory requirements. The U.S. EPA released Guidance for Developing and Maintaining a Service Line Inventory to assist systems with complying with the LCRR inventory requirements. Ohio EPA recommends that systems review this guidance and look for additional guidance and an official Ohio EPA inventory template soon.

In preparation to meet these requirements, PWSs should be taking the opportunity to document distribution system materials during routing activities (main replacements, meter replacements, etc.) on both the public and private side of the meter. To guide PWSs in the meantime, there is a Requirements and Recommendations list available.

Service Line Inventory and Lead Mapping Financial Assistance

Please visit our Financial Assistance Webpage for more information about available funding options.

Lead Service Line Mapping

All community and non-transient non-community 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 five years. Recently, due to changes in legislation and the finalization of the LCRR, Ohio EPA extended the submission deadline from March 17, 2022, to Dec. 31, 2022 for the 2022 lead map submission requirements.

PWS with no updates to the 2017 map submittal may submit a no change verification form to Ohio EPA to meet the 2022 requirements. PWS with updated distribution information must submit an updated map. All PWS that previously submitted a no lead service line verification form must submit an updated form certifying that they have no lead service lines on both the public and private side of their distribution.

Updated maps, the no change verification form, and the 2022 no lead service line verification form (if needed) may be submitted to Ohio EPA through the following methods:

Updated guidance and forms for the 2022 distribution system mapping can be found below:

Current maps can be found at the link below.

Lead Service Line Replacements and Notification

A lead service line is a service line made of lead which connects a water main to a building inlet and any lead pigtail, gooseneck, or other fitting which is connected to such lead line. A full lead service line replacement is when both the PWS-owned portion of the LSL and the customer-owned portion of the service line are replaced, or when the entirety of the portion of the service line made of lead is replaced where no lead pipe remains. A partial lead service line replacement is when only the portion of an LSL necessary to make a repair and/or reconnection to a service line is replaced, or the replacement of just the portion of an LSL owned by a water system where lead pipe remains in any portion of the service line between the water main and the structure.

Full Lead Service Line Replacement

Generally, water systems replace the system-owned portion of LSLs as they are found, via planned water main replacements or while completing emergency repairs or replacements. However, whether an LSL is replaced as an individual project or in conjunction with other projects, utilities must meet the LSL replacement requirements of OAC Rule 3745- 81-84. Ohio EPA guidance PWS-06-001 includes additional information for notification and sampling requirements. Ohio EPA provides 0% interest loans for full lead service line replacement through the WSRLA program.

Partial Lead Service Line Replacement

Partial lead service line replacements should be avoided due to the disruption of lead laden sediment and scale that cause significantly higher lead levels at the customer’s tap. If a partial LSL replacement must be completed, there are additional notifications and sampling efforts required, as noted in the Ohio EPA guidance PWS-06-001 below.

Lead Service Line Notification

OAC Rules 3745-81-84 and 3745-83-02 introduced 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 documents:

Monitoring

Lead and Copper Monitoring

Lead and copper enter drinking water from 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 Schedules

PWSs monitor for lead and copper on one of three schedules: every six 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.

PWSs are required to apply for reduced triennial lead and copper monitoring by submitting the application below to Ohio EPA’s Central 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.

On July 26, 2022, Ohio EPA notified PWSs of several important lead and copper monitoring updates. The following determinations were made for 2023:

  • Water systems that were on annual monitoring in 2022, who applied for reduced triennial monitoring for 2023, will not be approved for reductions beyond annual.
  • Water Systems that were on triennial monitoring in 2022, who applied for triennial monitoring, and continue to meet eligibility requirements, will be approved for triennial monitoring for 2023.

Additionally, all lead and copper monitoring schedules are subject to revision in 2024, regardless of the PWSs ability to qualify for reduced triennial monitoring.

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

Historical sample results can be found 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.

Compliance 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, after at least a 6-hour stagnation period. Taps with point of use treatment or point of entry treatment, including softening, should not be used. Individual residents may collect samples for the PWS, detailed instructions like those found at the link below should be provided to the resident.

The new requirement in the LCRR to sample first draw and fifth liter samples at sites with lead service lines is currently not in effect. Look for related guidance in the future.

  • Instructions for Collection of Lead and Copper Samples by Residents (PDF)
  • Instructions for the Collection of Lead and Copper Samples by a Professional Operator of Record (PDF)
  • Sampling Reminders (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 two 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. CNs 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)

Water Quality Parameters and Corrosion Control Documents and Forms

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

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 two business days of the receipt of the laboratory results indicating there is a lead action level exceedance. Within five 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 five 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)

Source Water Treatment Recommendation

Following an action level exceedance, systems are required to monitor for lead and copper at the entry point to the distribution system and based on those results submit a source water treatment recommendation to evaluate whether treatment is needed to reduce lead and copper levels in the source water. The monitoring form and recommendation form below must be completed and returned to the water system’s Ohio EPA District Office.

  • Entry Point Lead and Copper Reporting Form (Previously Form 5108) (PDF, Excel)
  • Source Water Treatment Recommendation (PDF, Word)

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 (MFR) with such piping can be included if MFRs 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.

PWSs should routinely evaluate their sampling pool and identify additional higher tiered locations as necessary. Lead and Copper Rule: Tier Definitions

There are new tiering requirements with the new LCRR, but they are not in effect yet. Please look for additional guidance in the future.

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 the required number of standard 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 Ohio EPA 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 a 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 requirement 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.

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 within two business days following receipt of sample results, regardless of result, sample type, or sample size, or if it was for a lead or copper sample. However, if the lead result is above 15ug/L, the notice must have additional info on health screening and blood lead level testing, and the results must be sent to the board of health and (for 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 under Monitoring on this page.

What is a lead public notice?

After an ALE determination, a PWS is required to send a lead public notice (PN) to all consumers within two business days through delivery methods such as broadcast media, social media, hand-delivery, email, or posting in conspicuous areas. Lead Public Notices must include the ninetieth percentile lead level, number of samples used to compute the ninetieth percentile lead level, an explanation of the health effects of lead, a list of the steps consumers can take to reduce exposure to lead in drinking water and contact information for the water system. Community water systems must provide information on availability of tap water testing to consumers within 5 business days from the ALE. Systems may choose to include this information in their PN.

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 in Ohio EPA's Fact Sheet: Lead Consumer Notice, Lead Public Notice, and Lead Public Education Requirements.

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 U.S. 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 (available for purchase).

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.

What are the requirements for laboratories?

A complete analysis, including quality control, shall be performed no later than thirty business days after receipt of lead and copper samples. Next day reporting requirement following laboratory analysis for lead and copper, including all identifying information about where the sample was collected. Complete information for laboratory reporting can be found on the DDAGW Reporting page.

 

 

 

 

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