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<title>Management of Aerators during Collection of Tap Samples to Comply with the Lead and Copper Rule</title>
<type>single page tiff</type>

    f                       WASHINGTON, D.C. 20460
                                                                         WSG 178
                                                     Dale Signed: October 20,
                                         cn  ?o  n&
                                                                          >f i S- I ! 'I

SUBJECT:   Management of Aerators during Collection of Tap Samples to Comply
             with the-4'ead and Chopper Rule
iM.ead and Cwnper Rule

lT«ife, Director       "  ~
FROM:      Stephen*
             Drinking Water Protection Division
             Office of Ground Water and Drinking Water

TO;         EPA Drinking Water Branch Chiefs
             Regions I-X

       The I cad and Copper Rule requires monitoring at customer taps to identify levels
of lead that may result from corrosion of lead-bearing components in the distribution
system or household plumbing. Public water systems are not allowed to use sampling
sites that include faucets that have point-of-use or point-of-cntry treatment devices
designed to remove inorganic contaminants (40 CFR § 14!.86(a)). as these faucets will
have removed the lead,

       It has come to our attention that some F.PA guidance documents have included
information that ma> have led public water systems to give customers directions that
inadvertently redisee the potential to identify lead in drinking water provided at eustumer
taps -- taps that are otherwise eligible for inclusion as a sampling site.

       Lead-bearing particular matter may end up in drinking water from physical
corrosion of leaded solder in household pipes.  Many kitchen and  bathroom taps that are
used to provide water for human consumption have an aerator as part of the faucet
assembly.  Aerators serve to introduce air into the water How. whieh makes it feel as if a
larger water flow is coming out of the tap The use of aerators is widely viewed as an
effective water conservation practice. Although not intended to remove inorganic
contaminants, screens that are part of the aerator may trap partieulate matter or debris
within the faucet,

       EPA recommends that homeowners regularly clean their aerators to remove
paniculate matter; however, neither EPA's regulations nor the Agency's Lend ami
Copper Monitoring ami Reporting Giiitltmce for Public Water Systems (E5PA-816-R-02-
009} provide public water systems with specific instructions on how to consider the
                          Internet Address (URL) » http,<'www epa gov
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aerator during the collection of tap samples. However, a Pocket Sampling Guide for
Small Systems developed through an EPA grant in 20041 and a recently released CD
based on that guide2 do include information recommending removal of the aerator prior
to sampling for lead. Additionally, the Agency released guidance last December for
schools that receive water from a public water system that included advice to remove the
aerator prior to sampling.

       We have also recently seen some public water system homeowner sample
collection instructions which recommend that homeowners remove the aerator from the
tap prior to sampling. Removal and cleaning of the aerator is advisable on a regular
basis. However, if customers are only encouraged to remove and clean aerators prior to
drawing a sample to test for lead, the public water system could fail to identify the
typically available contribution of lead from that tap, and thus fail to take additional
actions needed to reduce exposure to lead in drinking water. Therefore, public water
systems should not recommend that customers remove or clean aerators prior to or during
the collection of tap samples for lead.

       If the results from the initial  sample are above the action level, the public water
system may want to consider taking a second sample to determine whether particulate
matter is the source of lead. For this sample, the aerator would be cleaned or removed
prior to sampling so that the two samples could be compared. The system may also want
to test any debris to determine if it is lead-bearing. This would allow the public  water
system to better identify- appropriate advice to give the homeowner and the community
about measures they can take to reduce their exposure to lead. Note that the results of
both samples would be included in the set of samples used to determine the 90th
percentile (i.e., the  first could not be invalidated on the basis of presence of lead-bearing
debris in the aerator).

       As noted earlier, although EPA's regulations and Lead and Copper Rule guidance
for public  water systems have not included advice about managing aerators during
sampling,  some EPA guidance documents have included such information.  This is an
error and we are currently revising those guidance documents to advise that aerators
remain in place during initial sampling for lead from taps.

       EPA's recommendation about the consideration of aerators during water sampling
applies only to samples that are collected to identify lead and copper in drinking water. It
does not apply to tap samples that may be collected to support the public water system's
optimal water quality parameter monitoring program. The aerator should be removed,
and the faucet outlet cleaned and thoroughly flushed to remove scale particles, prior to
collection of samples that may be monitored for pH and'or dissolved oxygen.
 Pocket Sampling Guide for Operators of Small Systems, New England Water Works Association, 2004

2 EPA's Interactive Sampling Guide for Drinking Water System Operators, US EPA, EPA 816-C-06-001,

                                                Date Signed: October 20, 2006

       As an attachment to this memorandum, we are providing EPA's suggested
directions for collecting tap samples for lead in drinking water that has been amended to
specifically address aerators.  Please share this information with your state drinking water
program directors. We will also include this information in any future revisions of the
Lead and Copper Monitoring and Reporting Guidance for Public Water Systems. If you
have any questions, please contact Ron Bergman, Chief of the Protection Branch, at 202-


cc:     James Taft, Association of State Drinking Water Administrators
       Steve Via, American Water Works Association

           From Appendix E, Lead ami Copper Monitoring and Reporting Guidance for Public Water Systems,
                                    EPA-S16-R-02-009, February 2002.
                                                                                         WSG K
                                                                  Date Signed: October 20, 2006
                                    Suggested Directions for
                      Homeowner Tap Sample Collection Procedures

  These samples are being collected to determine the lead and copper levels in your tap water. This sampling
  effort is required by the U.S. Environmental Protection Agency and your State, and is being accomplished
  through the cooperation of homeowners and residents.

  Collect samples from a tap that has not been used for a minimum of 6 hours. Because of this requirement, the
  best time to collect samples is either early in the morning or in the evening upon returning front work. Be sure
  to use taps that have been in general use by your household for the past few months. The collection procedure is
  described in more detail below.

1.     Prior arrangements will be made with the customer to coordinate the sample collection event. Dates will
       be set for sample kit delivery  and pick-up by water department staff.
2.     There must be a minimum of 6 hours during which there is no water used from the tap the sample is taken
       from and any taps adjacent or close to that tap. The water department recommends that either early
       mornings or evenings upon returning home are the best sampling times to ensure that the necessary
       stagnant water conditions  exist.
3.     A kitchen or  bathroom cold-water faucet is to be used for sampling. If you have water softeners on your
       kitchen taps,  collect your sample from the bathroom tap that is not attached to a water softener, if
       possible. Do  not remove the  aerator prior to sampling. Place the opened sample bottle below the
       faucet and gently open the cold water tap. Fill the sample bottle to the line marked "1000-niL" and turn
       off the water.
4.     Tightly cap the  sample bottle  and place in the sample kit provided. Please review the sample kit label at
       this time to ensure that all information contained on the label is correct.
6.     Place the sample kit outside of the residence in the location of the kit's delivery so that department staff
       may pick up  the sample kit.

?.     Results from this monitoring effort will be provided to participating customers when reports are generated
       for the State. However, if excessive lead and/or copper levels are found, immediate notification will be
       provided (usually 10 working days from the time of sample collection).

  Call	at	if you have any questions regarding these instructions.
                             TO BE COMPLETED BY RESIDENT

       Water was last used:    Time	        Date	
       Sample was collected:  Time	        Date	
       I have read the above directions and have taken a tap sample in accordance  with  these
            Signature	Date	
 Lead and Copper Monitoring Guidance            E-6                                February 2002
                                                                                  (revised 9/2006)

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