United States
Environmental Protection
Agency
Office of Water
(WH-5SO)
EPA 812-R-92-004
May 1992
LEAD AND COPPER RULE
Definitions and Federal Reporting
for Milestones, Violations and SNCs

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    Lead and Copper Rule
Definitions and Federal Reporting
                  for
 Milestones, Violations and SNCs
    Office of Ground Water and Drinking Water
      U.S. Environmental Protection Agency
             Washington, D.C.
               May 1992
              r'EAPQUARI ERS LIBRARY
              I'M'.' v;-,:»rAl PROTIC'fON AGENCY

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                          Table of Contents
FEDERAL REPORTING REQUIREMENTS	 1

Milestone Reporting	 1

 Lead and Copper Exceedances and Lead 90th Percentile Levels  	 3
    Examples	4
 Optimal Corrosion Control Study	 6
    Examples	 7
 Treatment Designation/Installation	 8
    Examples	 9
 Water Quality Parameters (WQPs)  	 10
    Examples	  	 11
 Maximum Permissible Levels (MPLs)  	 11
    Examples	 12
 Lead Service Line Replacement (LSLR)	 12
    Examples	 12

VIOLATIONS	 13

Monitoring and Reporting Violations  	 21

 Initial Lead and Copper Tap M/R	 . 21
    Examples .	 22
 Follow-up or Routine Lead and Copper Tap M/R	 23
    Examples	 24
 Initial WQP M/R	 26
    Examples	 27
 Follow-up or Routine Entry Point WQP M/R	 28
    Examples	  29
 Follow-up or Routine Tap WQP M/R	  32
    Examples	  33
 Lead and Copper Source Water M/R	  34
    Examples	  35

Treatment Technique Violations 	  37

 OCCT Study/Recommendation	  37
    Examples	  39
 OCCT Installation/Demonstration	m. .  40
    Examples	jB..  41
 Entry Point WQP Noncompliance	  42
    Examples	-	 . .  43
 Tap WQP Noncompliance 	^. .  44
    Examples	.C. .  45

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                  Table of Contents (Continued)
 SOWT Recommendation 	  46
   Examples	  46
 SOWT Installation  	  47
   Examples	  47
 MPLs Noncompliance	  48
   Examples	  49
 Lead Service Line Replacement (LSLR)	  50
   Examples	  51
 Public Education Requirements	  52
   Examples	  54
 Public Notification Requirements  	  56
 Consecutive Systems	  56

SIGNIFICANT NONCOMPLIERS	  57

Monitoring and Reporting SNC  	  59

 Lead and Copper Initial Tap M/R SNC  	  59
   Examples	  61
Treatment Technique SNCs	  65

 OCCT Installation/Demonstration SNC	  66
   Examples	  66
 SOWT Installation SNC  	  67
   Examples	  67
 Public Education SNC	  68
   Examples	  68



                          List of Exhibits

Exhibit 1 — FRDS Milestone Identification Codes	 3
Exhibit 2 — FRDS Violation Codes  	  15
Exhibit 3 — FRDS Violation Default Values	  16
Exhibit 4 — FRDS Reporting Dates for Violations by System Size
            Listed in Violation Code Sequence  	  17
Exhibit 5 — Earliest FRDS Reporting Dates for Violations by System Size
            Listed Chronologically	  IS
Exhibit 6 — Definition of Compliance Achieved by Violation Type	  19
Exhibit 7 — SNC Definition Under the Lead and Copper Rule	 58
                                  11

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Definitions and  Federal  Reporting for
      Milestones,  Violations and SNCs
  This document contains the requirements
 for State reporting to EPA and the defini-
 tions  for  violations  and   significant
 noncompliers (SNCs) under the Lead and
 Copper Rule.

 FEDERAL REPORTING
 REQUIREMENTS
  This section discusses all Federal reporting
 requirements that include milestone report-
 ing under Section 142.15 and the reporting
 to FRDS of violations and PWSs that have
 returned  to compliance. Specific guidance
 is provided that identifies how to enter these
 data into FRDS. In addition, examples are
 provided for each reporting requirement.

 Milestone Reporting
  Under Section 40 CFR 142.15 of the rule,
 States are required to report quarterly the
 name and identification number for each
 PWS in which certain milestones occur. As
 a result of comments received at State and
 Regional workshops, EPA now requires that
 these milestones be reported to FRDS. A list
 of these milestones is presented below.  .
 1. Lead and Copper Exceedances and
   Lead  90th Percentile Levels
  •  Pb and Cu action level exceedances and
     the date upon which the exceedances
     occurred (i.e., the compliance period in
     which the exceedance occurs)
  * All 90th percentile lead levels of large
    systems
  • All 90th percentile  lead  levels of
    medium and small systems, once they
    have an exceedance of the lead action
    level.
  Although Section 142.15 does not require
 Federal reporting of 90th percentile lead
values that do not exceed the action level,
Section 141.90 requires that all 90th percen-
tile values be reported by the systems to the
State. EPA is requesting all 90th percentile
lead levels be entered into FRDS for large
systems and only for those medium and small
systems that are triggered into the OCCT
requirements (i.e., have exceeded the lead
action level). All 90th percentile values are
needed for these systems to analyze rule and
treatment effectiveness.
Note: States have the option to report the
  90th percentile lead values for all systems
  if this would facilitate reporting.
2. Optimal Corrosion Control Study
  • PWSs required to  complete corrosion
    control studies
  • Date the State received the results of
    the study.
Note: To eliminate some of the State's
  reporting burden, EPA is proposing an
  amendment to the rule which would no
  longer require reporting of the corrosion
  control study milestone. However, this
  would not eliminate a system's require-
  ment to conduct a study and if the system
  fails to conduct an adequate study on time,
  the State must report a corrosion control
  study violation.
3. Treatment Designation/Installation
  •  PWSs for which the State has designat-
    ed OCCT and the date of the State
    determination
  •  PWSs  that completed installation of
    OCCT
  •  PWSs for which the State has required
    installation of Source Water Treatment
    (SOWT) and  the date of the State
    determination

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   •  PWSs that completed installation of
     SOWT.
4. Water Quality Parameters (WQPs)
   •  PWSs for which the State has designat-
     ed or approved optimal Water Quality
     Parameters (WQPs) and the date of the
     determination.

5. Maximum Permissible Levels
   (MPLs)
   •  PWSs for which the State has designat-
     ed or approved maximum permissible
     levels (MPLs) for lead and copper in
     source water.
Note: EPA is proposing an amendment
   to the rule which would no longer require
   this milestone to be reported; however,
   violations associated with this milestone
   (i.e., failure to monitor and report MPL
   information and to meet State-specified
   or  approved levels)  would remain as
   required reporting.

6. Lead Service Line Replacement
   (LSLR)
   •  PWSs required to begin replacing lead
     service lines (LSLs)
   •  PWSs for which the State has estab-
     lished a quicker LSLR schedule (i.e.,
     > 7% per year)
   •  PWSs in compliance with their replace-
     ment schedule.

Note: EPA is proposing, in an amendment
   to the rule, that States only report the
   PWSs required to begin replacing LSLs
   and the date on which systems were
   required to begin replacement. The States
   would not report PWSs on faster replace-
   ment  schedules  or  those  systems in
   compliance with their schedules.  However,
  violations of the replacement schedule (i.e.,
  failure to review/replace at least 7% of lead
   service  lines per year) would still be
   reported to FRDS.
   Based on input from the State workshops,
most States indicated a preference for report-
ing these milestones to FRDS and that
 reporting be phased in  over a two-year
 period, beginning in January 1992, to allow
 States to incorporate these new reporting
 requirements into their data systems. The
 Region should negotiate with the State for
 the first two years  as to who will have
 responsibility for ensuring that these data
 are entered into FRDS. After the initial two
 years, the State will assume responsibility
 if it has not already done so. Bear hi mind
 that not all these reporting milestones will
 be relevant for all PWSs or be in effect
 immediately. Within the first two years, only
 those milestones related to lead and copper
 exceedances, other Pb 90th percentile levels,
 and the requirement to conduct a corrosion
 control study will be in effect. Further, there
 will be quarters where the States will not
 have any milestone data to report.
 Note: As stated on page 1, EPA is
  proposing in its amendment to eliminate
  the corrosion control study milestone.
  All  milestones are  to be reported into a
 newly created FRDS database  record,
 C800 PWS-MILESTONE-EVENTS. The next
 section provides detailed  FRDS reporting
 guidance for  all milestones. In addition,
 examples on how to report these milestones
 to FRDS including data transfer file (DTF)
 specifications  are  included  after the
 discussion of each milestone. FRDS  codes
 associated with each of these milestones are
presented in Exhibit  1.



OAteMffecardOMCrfptfoit
Data
EWflMfH
Mumtwr
C801
C803
C80S
C813
C815
Data Elamant
Toaia?
C,4
fnnvdd/yy
C.4
C.40
0.7.8
Data Etonwit
; .'. ;••- Nam.
PWS-MHastona-ID
PWS-MBastowData
PWS-MUaatona-Coda
PWS-MBestOfw-Contmant
PWS-MHastona-VatiM
(in mgfl)
• C « Character data
D - Dacimal data
                                     — 2

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                                     Exhibit  1
              FRDS Milestone Identification  Codes
            Milestone
Vtlu«for
tmlm' frtmtni nl
UPHW (BWiwWw
C80BPWS-
  »KW
  CODE
on
  Pb and Cu 90th Percentile Levels
  Optimal Corrosion Control Study
  Treatment Designation/Installation
  Water Quality Parameters (WQPs)


  Maximum Permissible Levels
  (MPLs)

  Lead Service Line Replacement
  (LSLR)
  CU90     Cu action level exceedances

  PB90*     Pb action level exceedances

  CCSR     Designates systems required to conduct a study
  CCSC     Designates systems that have completed the study

  OTDE     Indicates systems in which State has designated
            or approved optimal corrosion control treatment
            (OCCT)
  STDE     Indicates systems in which State has designated
            or approved source water treatment (SOWT)
  OTIN     Indicates systems that have installed OCCT
  SUN     Indicates systems that have installed SOWT

  WQPS     Indicates systems in which State has designated
            or approved optimal WQPs

  MPLS     Indicates systems in which State has designated
            or approved MPLs for Pb and Cu in source water

  LSLR     Designates systems required to conduct LSLR
* All lead 90th percentile levels are required reporting for all large systems and those medium and smalt systems
  that are triggered into OCCT requirements. These levels will be reported into the C2100 database record (see
  page 4 for detailed discussion on the C2100 database record). All lead 90th percentfle values also will be reported
  to the C2100 database record; however, FRDS wfll post these exceedances to the C800 mtestone record. Thus.
  primacy agencies need not report this milestone. This approach is being followed to eliminate redundant reporting.
  by the primacy agency, of a lead exceedance to both the C800 and C2100 records, tf primacy agencies opt
  to report this milestone, FRDS will not post a duplicate.
  Lead and Copper
  Exceedances and Lead
  90th Percentile Levels
     States are required to report to EPA,
  quarterly, the PWSs that exceed lead or
  copper action levels. This is a critical event
            for any system regulated under this rule
            because it serves  to  trigger treatment
            technique requirements. Reporting of this
            data  will allow EPA  to  oversee State
            programs by comparing the completion of
            reported  events  to  the exceedances
            reported to FRDS.

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  Lead 90th percentile data are needed
to provide EPA with data to assist in
assessing  public exposure  to lead  in
drinking water, and the effectiveness of
this rule in reducing this contaminant.
EPA is therefore  requiring  all  large
systems, and those medium and small
systems that are triggered into OCCT
requirements (i.e., have a lead action level
exceedance) be submitted to EPA. Note
that EPA is not requiring the reporting
of copper 90th percentile levels other than
those  that exceed  the action level  of
1.3 mg/1.
  The lead 90th percentile data are to be
reported to EPA utilizing the new C2100
database record  (Parametric Data). For
large systems, all  90th percentile data
must be reported  in  this manner. For
medium and small systems,  the  90th
percentile  lead levels must begin to be
reported (as  Parametric Data records
(C2100)), with the first lead action level
exceedance,   and  forever,   thereafter
(whether any further exceedances occur
or not).
  Any 90th percentile value that exceeds
the action level  (i.e.,  >0.015 mg/1) also
should be reported using  the  C2100
database record FRDS will create and post
to the database, the  C800 milestone record
associated with this exceedance. This will
provide some relief to the States' reporting
burden because  the State will not  be
required to report an exceedance using
both  the  C2100 and C800  database
records.  However, if a State desires to
provide the Milestone record as well as
the Parametric Data record, then FRDS
will not  duplicate  the  State's  C800
Milestone record.
  As stated earlier, EPA does not need all
the  copper   90th   percentile  values.
Therefore, only the copper action level
 exceedances need to be reported. The
 exceedance will be reported to the C800
 Milestone record. There is no need for the
 State to report a C2100 Parametric Data
 record for any copper 90th percentile value.
   The C2100 Parametric-Data Database
 Record for lead 90th percentile values is
 shown as follows:
   C2101
   C2103
   C2105
   C2107
   C21U
  C.5
mm/dd/yy
mm/dd/yy
  C,4
 D.7.8
Sample-ID
Sample-Begin-Date
Sampie-End-Date
Sample-Contaminant-Code
Sampie-Analysia-Result
 MOTE: C2111 can accommodate a maximum of 7 digits
   before the decimal point and a maximum of 9 digits
   after the decimal point PEC 7.8). However, the State
   need only enter 3 significant figures for lead (e.g..
   0.016). The editing of this data element value •
   Identical to C1123 • VIOLATION-ANALYSIS-RESULT.
      EXAMPLES
EXAMPLE 1 —
  On June 30, 1992, a large system
(ZT0000001) has completed its first round
of monitoring in accordance with Sections
141.86 and 141.89. The 90th percentile
values reported by the system to the State
were 0.0143 mg/1 for lead and 1.07 for
copper.
  The State should report the lead 90th
percentile level although it does not exceed
the lead action level of 15 ppb because
EPA is requiring the reporting of AIX lead
90th percentile levels for all large systems.

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  By August 15, the State would report
the lead 90th percentile value using the
C2100 database records as follows:
  The DTF transactions for copper are:
C101
C2101
C2103

C2105

C2107

C2111
2T0000001
00001
01/01/92

06/30/92

PB90

0.014
PWS-ID
Parametric ID
First day of the
monitoring period
Last day of the
monitoring period
Sample contaminant
code tor lead
90th percentile lead level
  The DTF transactions of this record are:
13 12
1 1 1
H1ZT000000100001
H1ZT000000100001
H1ZT000000100001
B1ZT000000100001
19
1

27 32
II 1
IC2103010192
IC2105063092
IC2107PB90
IC21110.014
  The State should not report the 90th
percentile copper  level because it  was
below the action level. For copper, EPA
only  is requiring  that exceedances be
reported for all systems.
EXAMPLE 2 —
  Another large system (ZT1000000) also
successfully completes its first round of
monitoring. The 90th percentile copper and
lead levels submitted by the State are
14.7 mg/1 and 0.0167 mg/1, respectively.
  In this example, the State would report
a copper exceedance milestone because the
90th percentile exceeds the action level.
  By August 15, 1992 the State would
report the copper exceedance to the C800
database record as follows:
C101
C801
C803

C805

C815

ZT1000000
0001
06/30/92

CU90

1.5

PWS-ID
PWS-Mitestone-ID
First day of the
monitoring period
Sample contaminant
code for copper
90m percentile copper
level
13 12 19
II II
C4ZT00000010001
C4ZT00000010001
C4ZT00000010001
27 32
II 1
IC803063092
IC805CU90
IC8151.S
                                           In addition, the State would report the
                                         90th percentile lead level to the C2100
                                         database record as follows:
C101
C2101
C2103

C2105

C2107

C2111
m oooooo
00001
01/01/92

06/30/92

PB90

0.017
PWS-IO
SamptelO
First day of the monitoring
period
Last day of the monitoring
period
Sample contaminant code
for toad
90th percentile lead level
                                          The DTF transactions for lead are:
13 12 19
II II
aizTooooooiooooi
H1ZT000000100001
H1ZT000000100001
H1ZT000000100001
37 32
II 1
IC2103010192
IC2105063092
IC2107PB90
IC21110.017
  All 90th percentile  lead  values are
reported using the C2100 database record
regardless of whether it exceeds the action
level. In this example, the 90th percentile
lead level exceeds the action level and,
therefore, FRDS  will create the CSOO
database record for  lead as follows (The
User Need Not Enter this Record):
C101
C801
C803

caos

C815
ZT1 OOOOOO
0001
06/30/92

P890

0.017
PWS-ID
PWS-Milestone-ID
First day of the
monitoring period
Sample contaminant
code for lead
90th percentile lead level
                                        Note:  No violation would be reported
                                          for the system because an exceedance
                                          of an action level is not a violation and
                                   — 5 —

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  all monitoring and reporting has been
  completed correctly and on time.
EXAMPLES —
  A   medium   system   (NH5432100)
completes its first round of sampling by
December 31, 1992. The 90th percentile
level for lead is 0.014 mg/1 and 1.0 mg/1
for copper.
  The system is not required to report
either value because for medium and small
systems, the lead 90th percentile values
are only reported once the system exceeds
the action level. For copper, the system
only reports exceedances.
  The same system completes its second
round of sampling by June 30, 1993. The
90th percentile value for copper remains
at 1.0 mg/1 but the 90th percentile lead
value is 0.016 mg/1.
  The system is required  to report the
90th percentile value for lead because it
now exceeds the action level.
  By  August 15,  1993 the State would
report the lead exceedance as follows:
C101
C2101
C2103

C2105

C2107

C2111
NH5432100
00001
01/01/83

06/30/93

P890

0.016
PWS-ID
Sample ID
First day of the monitoring
period
Last day of the monitoring
period
Sample contaminant code
for lead
90th peroantile lead level
  The  DTP transaction for the  lead
exceedance are:
13 13
1 1 1
H1KH543210000001
H1NH543210000001
H1NB5432 10000001
H1MH543210000001
19
1

27 32
II t
IC2103010193
IC2105063093
IC2107PB90
IC21110.016
  FRDS  will  create  a  C800  PWS-
Milestone-Events database record for this
exceedance. In addition, the system is
 triggered into OCCT requirements and
 must now report all subsequent 90th
 percentile lead  values regardless of
 whether these values exceed the action
 level.
 EXAMPLE 4 —
  A large water system does not collect
 all the required samples by June 30,1992;
 however, it submits 90th percentile values
 for lead and copper.
  The State should not report these values
 because they are not true 90th percentile
 values. Instead, the State would submit
 the 90th percentile value for this system
 only after the required number of samples
 have been collected  and analyzed  in
 accordance with Sections  141.86 and
 141.89. In addition, the State would report
 an  Initial Lead and  Copper Tap M/R
 violation  to FRDS for this system by
 August 15, 1992. (Refer to Examples for
 Initial Lead and Copper  Tap  M/R
 violations on pages 22 and 23 to determine
 how to report this violation.)

 Optimal Corrosion
 Control Study

  The conduct of a corrosion control study
 is required for all large systems that have
 not successfully demonstrated that OCCT
 is already in place.  Medium  and small
 systems are required to perform a study
only if they exceed the 90th  percentile
lead or copper action level and the State
requires that a study be conducted. EPA
is proposing, in an amendment to the rule,
to no longer require the reporting of this
milestone because EPA can monitor
progress  through the reporting of  an
optimal corrosion control study violation.
However, the reporting of these data is
described  in  the event  this proposed
change is not adopted.

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   Currently,  the  primacy  agency  is
 required to report the following data for
 each PWS required to conduct a study:
  C101
  C801
  C803
  C805
PWS-ID
PWS-Milestone-ID
Date State determined that system
must conduct study for medium and
small systems or the date 1/1/93 for
large systems
The code CCSR to indicate a system
that is required to conduct a study.
  The State is required  to report the
following data for each PWS that has
completed a study:
..-c <" . |M DMMMtt .'*%":
,pMlNr
C101
C801
C803

C805


Dawteto*-^''* .
PWS-ID
PWS-Milestone-ID
Date State received the
study
Code CCSC identifying


results of the

a system that
has completed a corrosion control
study

      EXAMPLES
EXAMPLE 1 —
  A medium-sized system (WI0004567)
completes its first round of monitoring on
December 31, 1992, and reports a lead
90th percentile level of 25 ppb. The system
submits its recommendation for optimal
corrosion control treatment by June 30,
1993. The  State  has  12  months  to
determine whether the system should
                               conduct a study. On September 10,1993,
                               the State submits a letter to the system
                               requiring a study,
                                 By November 15, 1993 the State would
                               report:
C101
C801
C803

C805
Wl 0004567
0001
09/10/93

CCSR
PWS-ID
PWS-Milestone-ID
Date system required to
begin study
Code identifying a
system that is required
to conduct a study
                                          The DTF transactions for this record are:
13 12 19
1 I 1 1
C4WI00045670001
C4WI00045670001
27 32
II 1
IC803 091093
IC805 CCSR
                                        EXAMPLE 2 —
                                          The State receives the results of the
                                        study on March 9, 1995 (within the 18-
                                        month deadline from the date the State
                                        determines the system must conduct a
                                        study) and the study was conducted in
                                        accordance with Section 141.82 (c).
                                          By May 15, 1995, the State would report
                                        to the Region:
C101
C801
C803

C805


WI0004S67
0002
03/09/95

CCSC


PWS-ID
PWS-Milestone-ID
Date State received
study results
Code indicating system
that has completed a
corrosion control study
                                The DTF transactions for this record are:
13 12 19
1 I 1 1
C4WI00045670002
C4WI00045670002
27 32
II 1
IC803 030995
IC805 CCSC
                                      7 —

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EXAMPLES —
  A system (NY1230000) conducts a study
in accordance with Section 141.82 (c) but
submits the results on September 10,1995,
six months  later than the  required
deadline.
  By November 15,1995, the State would
report the completion of this milestone as
follows:
C101
C801
C803

C805


NY1 230000
G001
09/10/95

CCSC


PWS-ID
PWS-Milestone-lD
Date State received
study results
Code indicating system
that has completed a
study
  The DTP transactions for this record are
13       12
1 I        I

C4NY1230000C001
C4NY1230000G001
                  19
                  I
37   33
                        IC803 091095
                        IC805 CCSC
  Note: GO01 is a Group Generation Code
   tor the PWS-MHestone-ID. It tells PROS to
   create an appropriate ID in the database.
  In addition, the  State would  have
submitted a  corrosion  control  study
violation to the Region on May 15,1995
for this system because the system failed
to submit a study within 18 months (or
March 9,  1995, in this example). (Refer
to examples on pages 39 and 40 which
explains the reporting of a corrosion control
study violation).
EXAMPLE 4 —
  A medium-sized system (PA1230000)
submits the results of the study to the
State on March 9, 1995. However, the
system only evaluated the effectiveness
of one type of corrosion control treatment
instead of three. The State should not
report a milestone for having received a
study because the results were incomplete.
 Instead, during its May 15,1995, submis-
 sion, the State would report a corrosion
 control study violation for the system.
 The State only should report the milestone
 for completing an OCCT study once it
 receives a complete study from the system.

 Treatment Designation!
 Installation
  States are required to report to EPA,
 quarterly, the systems for which the State
 has designated  the  type  of Optimal
 Corrosion Control Treatment (OCCT) and
 Source Water Treatment (SOWT) and the
 date(s) the installation of the treatments)
 was (were)  completed.  The  milestone
 reporting requirements do not include the
 specific details regarding the type of OCCT
 or SOWT installed or identify  the treat-
 ment plants in which it has been installed.
 Consequently, this information will not
be available in FRDS and EPA will not
 require its reporting in the C4SO PWS-SE-
Treatment-Data record. However, under
Section 141.91, this information is required
to be retained by  water systems.
  The following must be  reported when
the State has designated the type of OCCT
or SOWT to be installed:
                 C101
                 C801
                 C803

                 C80S
         PWS-ID
         PWS-Milestone-ID
         Date State determined OCCT or
         SOWT
         The code value OTDE to indicate a
         system for which the State designated
         or approved OCCT
         The code value STDE to indicate a
         system for which the State designated
         or approved SOWT
                                   __ o  .-,

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   The following must be reported when
 the State has received proof that the
 system has installed OCCT or SOWT:
  C101
  C801
  C803

  C805
 PWS-ID
 PWS-Milestone-ID
 Date State received proof of the instal-
 lation of Ihe OCCT or SOWT
 The code value OTIN to identify a
 system that has installed OCCT
 The code value SUN to identify a
 system that has installed SOWT
      EXAMPLES
EXAMPLE 1 —
  A medium-sized system (PA123000) is
required to  install  SOWT.  The State
submits a letter dated December 1,1993,
designating the  type of SOWT to be
installed by the system.
  By February 15,1994, the State would
report to the Region:
  C101
  C801
  C803
  C805
PA1230000
0010
12/01/93
STDE
PWS-ID
PWS-Milestone-ID
Date the State deter-
mined the type of SOWT
to be installed
Code for SOWT desig-
nation
  The DTF transactions for this record are:
13 12 19
II II
C4PA12300000010
C4PA12300000010
37 32
ii 1
IC803 120193
IC805 STDE
  The same system installs SOWT within
the 24-month timeframe (i.e., 12/1/95 in
this example). On November 15, 1995 the
                                 State receives a letter from the system
                                 certifying it has installed SOWT.
                                   By February 15, 1996, the State would
                                 report to the Region:
                        C101
                        C801
                        C803
                        C805
         PA1230000
         0014
         11/15/95
         STIN
PWS-ID
PWS-Milestone-ID
Date State received
proof of the installation
of SOWT
Code for SOWT installa-
tion
                                           The DTF transactions for this record are:
                                  1 3
                                  I I
                                                    12
                                  C4PA12300000014
                                  C4PA12300000014
                                        19      27    32
                                        I      If     I

                                              ICB03  111595
                                              ICB05  STIN
EXAMPLE 2 —
  A system (MA0234000) does not install
SOWT within the 24-month timeframe
(i.e., by 12/1/95). Instead  the  system
installs SOWT and sends a letter on March
30, 1996, to the State indicating that
SOWT is installed and operating.
  The system is in violation for failure to
install and certify the treatment on-time.
The State   would  report  a  SOWT
installation violation to FRDS by February
15,1996. (Refer to examples on pages 47
and 48 which explain the reporting of a
SOWT installation violation.)
  By May 15,1996, the State would report
that the system had installed SOWT as
follows:
C101
C801
C803


C805

MA0234000
0011
03/30/96


STIN

PWS-ID
PWS-Milestone-ID
Date State received
proof of SOWT
installation
Code ter SOWT
installation
                                   — 9 —

-------
   The DTP transactions for this record are:
  13       12
  I  1       I
  C4MA02340000011
  C4MA02340000011
       19
       27
     32
             IC803 033096
             IC805 STIN
 EXAMPLE 3 —
   On June 10, 1994, the State sends a
 letter to a system (UT1034000) designating
 the type of OCCT to be installed.
   By August 15, 1994, the State would
 report:
C101
C801
C803


C805

UT1 034000
0003
06/10/94


OTDE

PWS-ID
PWS-Milestone-iD
Date the State
determined the type of
OCCT to be installed
Code for OCCT
designation
  The DTF transactions for this record are:
  1 3
12
I
19
 27
II
32
I
  C4UT10340000003
  C4UT10340000003
            IC803  061094
            IC80S  OTDE
  The system does not install OCCT
within the 24-month timeframe (i.e, by
6/10/96). Instead, the State receives a
letter from the system on November 2,
1996 that  certifies  OCCT has  been
installed.
  The system is in violation for failure to
install OCCT on  time. The State would
report an OCCT installation violation by
August 15, 1996. (Refer to examples on
pages 41 and 42 to determine how to report
an OCCT installation violation,)
             To  fulfill  the  OCCT   installation
           milestone reporting requirements, the
           State would report by February 15, 1997:
C101
C801
CS03


C805

UT1 034000
0006
11/02/96


OTIN

PWS-ID
PWS-Miiestone-ID
Date State received
proof of the installation
of OCCT
Code for OCCT
installation
                               The DTP transactions for this record are:
13 12 19
II II
C4UT10340000006
C4UT10340000006
27 32
III
IC?03 110296
IC805 OTIN 1
Water Quality Parameters
(WQPs)
  States are required to report to EPA,
quarterly, the FWSs in which the State
has designated optimal Water Quality
Parameters (WQPs) and the date  of
determination.
  The following must be reported for each
system where the State has designated
optimal WQPs values or ranges:
                              ciot
                              C801
                              C803

                              caos
                               PWS-ID
                               PWS-Milestone-ID
                               Date State designated or approved
                               optimal WOP value or ranges
                               The code value WQPS indicates a
                               system for which the State has
                               designated or approved WQPs

-------
       EXAMPLES
EXAMPLE 1 —
  A medium system (CO1004500) installs
OCCT on August 10,1996, and completes
follow-up sampling on July 8, 1997. The
State sets WQP values and submits a
letter to the system on November 19,1997
that specifies the WQP ranges.
  By February 15, 1998, the State would
report:
                                          The DTF transactions for this record are:
  C101
  C801
  C803
  C805
CO1004500
0016
11/19/97
WQPS
PWS-ID
PWS-Milestone-ID
Date State designated or
approved optimal WQP
value or ranges
Code for WQPs
  The DTF transactions for this record are:
13 12 19
II II
C4CO10045000016
C4C010045000016
27 32
II 1
IC803 111997
IC805 WQPS
EXAMPLE 2 —
  The State does not meet its deadline of
July 1,1998 for setting WQPs for a large
system (IA0004500), but instead, submits
a letter with  its determination on Octo-
ber 10,1998.  The State would not report
the deadline  date of July  1, 1998 but
instead would report the following infor-
mation to the Region by February  15,
1999:
  C101
  C801
  C803
  C805
IAOO04500
0001
10/10/98
WQPS
PWS-ID
PWS-Milestone-ID
Date the State submitted
a letter to the system
with its WQP approval or
designation
Code tor WQPs
113 12 19
II 1 1
C4IA00045000001
C4IA00045000001
27 32
II 1
IC803 101098
IC805 WQPS
Maximum Permissible
Levels (MPLs)
  States are required to report to EPA,
quarterly, the PWSs in which the State
has designated or approved  maximum
permissible levels (MPLs) for lead and
copper in source water. EPA is proposing,
in its amendment, that this milestone no
longer be  required  because  EPA can
determine those systems that are required
to install SOWT from the reporting of the
Treatment  Designation/Installation
milestone for SOWT. In addition, compli-
ance with MPLs can be assumed if the
State does not report a violation for failure
to meet these MPLs.
  In the event that this amendment is not
adopted, the  State must report the
following for each system in which it has
designated or approved MPLs for lead and
copper:
                                 C101
                                 C801
                                 C803
 C805
PWS-ID
PWS-Milestone-ID
Date State designated or approved
MPLs for lead and copper in source
water
The code value MPLS to indicate
systems for which the State has ap-
proved or designated MPLs

-------
      EXAMPLES
EXAMPLE 1 —
  The reporting of this milestone is similar
to that for WQPs. The State should report
the date it sent a letter to the  system,
specifying the MPLs for lead and copper
in source water, regardless of whether the
State meets its determination deadline.
  For  example,  assume the State is
required to set MPLs for lead and copper
in source water by June 30, 1993, but does
not  submit  a  letter  to  the  system
(AK1004500) until November i9, 1993,
with this determination.
  By February 15,1994, the State would
report:
C101
C601
C803
C805
AK1 004500
0005
11/19/93
MPLS
PWS-ID
PWS-Milestone-ID
Date State designated or
approved MPLs
Code tor MPL designation
  The DTF transactions for this record are:
13 12
1 1 1
C4AK1004SOOOOOS
C4AK10045000005
19

27 32
il I
IC803 111993
IC805 MPLS
Lead* Service Line
Replacement (LSLR)
  Currently, States must report quarterly,
the PWSs required to replace lead service
lines (LSLs), those systems on a faster
replacement schedule, and those systems
in compliance with the schedule. EPA is
proposing, in its amendment, that States
only identify those systems required to
begin replacing LSLs and the date the
system was required to start the
 replacement. EPA believes it does not need
 to know  those  systems on a quicker
 replacement schedule for proper oversight
 and that compliance with the replacement
 schedule can be  determined if the State
 does not report a LSLR violation.
   If the proposed changes to LSLR are not
 adopted, the State must also report the
 required annual rate of replacement. The
 following must be reported for each system
 where the State has determined that LSLR
 is necessary:
  C101
  C801
  C803
  C80S

  C815
PWS-tD
PWS-Milestone-ID
Date system required to initiate LSLR
The code value LSLR indicates
systems required to initiate LSLR
LSLR rate. The units must be
expressed as a decimal. The editing of
this data element value is identical to
C1123—VIOLATION—ANALYSIS-
RESULT
                                            EXAMPLES
EXAMPLE 1 —
  A system (CA0204500) installs OCCT
and collects follow-up tap samples during
the January  1,  1997  - July 1, 1997
timeframe. The 90th percentile lead level
still exceeds the lead action level. The
system is now triggered into LSLR. The
first year of LSLR begins on the date the
system exceeded the lead action level in
samples collected after the installation of
OCCT or SOWT (whichever is later); in
this example, July 1,1997. The State does
not require  the system to  be  on  an
accelerated schedule (Le., replace >1% per
year).
                                 — 12 —

-------
  By November 15,1997, the State would
report the following milestone:
C101
C801
C803

C805
CS15
CA0204500
0035
07/01/97

LSLR
0.07
PWS-ID
PWS-Milestone-ID
Date system required to
start LSLR
Code tor LSLR
LSLR Rate
  The DTP transactions for this milestone
are:
13 12
1 1 1
C4CA02045000035
C4CA0204S000035
C4CA02045000035
19
1

27 32
II 1
IC803 070197
IC805 LSLR
IC815 0.07
VIOLATIONS

  This section of the guidance provides
violation and compliance achieved defini-
tions and reporting requirements for each
violation type. Further, examples on how
to report, including DTF, are provided
after the discussion of each violation type.
  Failure to comply with the rule, includ-
ing requirements established by the State
(i.e., WQP values in finished water, lead
and copper levels in source water, and
faster LSLR  schedule) will constitute a
violation of the NPDWR for lead and
copper. To simplify reporting and analyses,
violations are categorized as either moni-
toring and reporting (M/R) or treatment
technique violations as follows:
Monitoring and Reporting Violations
  • Initial Lead and Copper Tap Water
  * Follow-up  and Routine Lead and
    Copper Tap
  • Initial WQP
  • Follow-up and Routine Entry Point
    WQP
  • Follow-up and Routine Tap WQP
  * Initial,  Follow-up, and Routine Source
    Water
 Treatment Technique Violations
   •  OCCT Study/Recommendation
   •  OCCT Installation/Demonstration
   •  WQP Entry Point Noncompliance
   •  WQP Tap Noncompliance
   •  SOWT Recommendation
   •  SOWT Installation
   •  MPL Noncompliance
   •  Lead  Service  Line  Replacement
     (LSLR)
   •  Public Education
   Exhibit 2 lists these 15 violation types
 and their corresponding FRDS codes.
  Violations for this rule are characterized
 in FRDS in the same manner as for other
 rules. That is, each violation must  have
 a unique violation ID (element CHOI), a
 code identifying the contaminant or rule
 for which the violation applies (element
 C1103),  a code describing the type of
 violation (element C1105), the date range
 (elements C1107 and C1109) and length
 of the compliance (or monitoring) period
 for which the violation occurred (element
 Cllll).
  All but one of the violations (maximum
 permissible level noncompliance of lead
 and copper in source water) will have the
 same contaminant code, 5000, representing
 violations of the Lead and Copper Rule.
As a result, for these violations (violation
 types 51-62, 64, 65) FRDS will provide the
 value of 5000 for data element C1103 (to
 allow for simple queries). Some States may
 choose to include a DTF transaction with
this  value to maintain consistency with
their reporting of other violations from
other rules. That will be acceptable as long
as the value reported for C1103 is 5000
for violation types 51-62, 64, or 65.
  Each violation is defined by a violation
type code, C1105. For this rule, there are
15 different violations that can occur. This
                                  — 13 —

-------
data element must be valued for each
violation reported.
  As in the reporting of violations for other
rules,  all violations for this rule must
identify the time frame for which the FWS
is in violation (i.e., out of compliance). In
PROS, this is characterized by the range
of dates in which a specific action or set
of actions was  (is)  to take place (e.g.,
10 samples were to be taken, treatment
was to be installed and in operation), and
is defined,  in FRDS, by  these  3 data
elements:
  Compliance period begin date (C1107)
  Compliance period end date (C1109)
  Compliance period in months (Cllll)
  In general, C1107 must be provided, as
well as either C1109 or Cllll. If Cllll
is provided,  FRDS will calculate the
associated value for C1109, and post it to
the  database. Similarly,  if C1109  is
provided, FRDS will calculate the associat-
ed value for Cllll and post it  to the
database.
  Many of the compliance periods for this
rule are of fixed length; that is, compliance
or monitoring periods are set at 6 months,
12 months, etc. For these violations, the
acceptable values for the compliance
periods will be identified in this document.
Values provided other than the acceptable
values will  result in rejection of the
entire violation. Several of the violations
can  have only a  single compliance or
monitoring period (e.g., initial lead and
copper tap sampling). For these violations,
only the begin date of the compliance
period needs to be provided; the end date
(C1109) and the compliance period length
 (Cllll) need not be provided. FRDS will
 provide default  values for  these data
 elements, consistent  with  the values
 presented in the guidance. Some States
 may choose to include a DTF transaction
 with C1109 and/or Cllll,  valued to
 maintain consistency with their reporting
 of other violations from other rules. That
 will be acceptable as long as the C1109/
 Cllll combination is reported as the value
 to which FRDS would default them. If not,
 the entire violation will be rejected. The
 violation definitions in this section clearly
 identify where the defaulting will occur.
 A summary of the data elements, for which
 FRDS  will provide default  values, is
 provided in Exhibit 3.
   Exhibit 4 is a  listing of violations in
 ascending order by FRDS violation codes
 and the earliest date in which a particular
 violation  may be  reported  to FRDS,
 generally one quarter after the violation
 occurs. These  dates are based  on a
 system's:
  a) exceeding the lead or copper action
     level during the first round of initial
     monitoring,
  b) conducting a study, and
  c)  requiring the full amount  of time
     allowed to complete a particular step.
     (e.g., 6-month compliance periods for
     initial monitoring, 24 months  for
     OCCT installation).
  Exhibit 5  presents  data similar to
Exhibit 4 but lists the various violations
in the chronological order  in which they
may be reported to FRDS.  Exhibit 6 is a
summary of the definitions of compliance
achieved for each violation type.
                                   — 14 —

-------
                          Exhibit 2
                 FRDS Violation Codes
                                                       Violation
                                                         Cod*
Initial Lead and Copper Tap M/R
Follow-up or Routine Lead and Copper Tap M/R
initial WQP M/R
Follow-up or Routine Entry Point WQP M/R
Follow-up or Routine Tap WQP M/R
Initial, Follow-up, or Routine Source Water M/R
OCCT Study/Recommendation
OCCT Installation/Demonstration
WQP Entry Point Noncompliance
WQP Tap Noncompliance
SOWT Recommendation
SOWT Installation
MPL Noncompliance
Lead Service Line Replacement
Public Education
 51
 52
 53
 54
 55
 56
 57
 58
 59
 60
 61
 62
63
64
65
                            — 15

-------
           Exhibit 3
FRDS Violation Default Values
Violation Typo
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
^ itaii EfefiMi'it

C1103
C1109
C1111
C1103
C1103
C1109
C1111
C1103
C1109
C1111
C1103
C1103
C1103
C1103
C1109
C1111
C1103
C1109
C1111
C1103
C1103
C1109
C1111
C1103
C1109
C1111
;^;'^W,&^iiftV*iat |
5000
6 months later than C1 107
6 months
5000
5000
6 months later than C1 107
6 months
5000
3 months later than C1 1 07
3 months
5000
5000
5000
5000
24 months later than C1 107
24 months
5000
3 months later than C1107
3 months
5000
5000
6 months later than C1107
6 months
5000
24 months later than C1107
24 months
NO DATA ELEMENT DEFAULTING FOR THIS VIOLATION TYPE
C1103
C1109
C1111
C1103
5000
12 months later than C1 107
12 months
5000
            — 16 —

-------
                          Exhibit 4
 FRDS Reporting Dates for Violations by System Size
           Listed in Violation Code Sequence*
*•••* v. Ij -.
' •* "« «L ' ""
•VUAkHMvI^tMl ^^kMA4k v , ""
Initial Pb/Cu Tap M/R
Follow-up Pb/Cu Tap M/R
Routine Pb/Cu Tap M/R
Initial WQP M/R
Follow-up Entry Point WQP M/R
Routine Entry Point WQP M/R
Follow-up Tap WQP M/R
Routine Tap WQP M/R
Initial Source Water M/R
Follow-up Source Water M/R
Routine Source Water M/R
groundwater
surface water
OCCT Study/Recommendation
OCCT Installation/Demonstration
WQP Entry Point Noncompliance
WQP Tap Noncompliance
SOWT Recommendation
SOWT Installation
MPL Noncompliance
groundwater
surface water
Lead Service Line Replacement
Public Education
^eaar"
51
52
52
53
54
54
55
55
56
56
56
56
57
58
59
60
61
62
63
63
64
65
£ . By«t*mS** ^ .
w^^5(
9/1/92
9/1/97
3/1/99
9/1/92
6/1/97
12/1/98
9/1/97
3/1/99
3/1/93
3/1/96
3/1/99
3/1/98
9/1/94
3/1/97
12/1/98
3/1/99
3/1/93
9/1/95
3/1/99
3/1/98
9/1/98
3/1/94
i. 1- "••
3/1/93
9/1/98
3/1/00
3/1/93
6/1/98
12/1/99
9/1/98
3/1/00
9/1/93
9/1/96
3/1/99
9/1/98
9/1/95
3/1/98
12/1/99
3/1/00
9/1/93
3/1/96
3/1/99
9/1/98
9/1/99
3/1/94
Small
3/1/94
9/1/99
3/1/01
3/1/94
6/1/99
12/1/00
9/1/99
3/1/01
9/1/94
9/1/97
3/1/99
9/1/99
9/1/96
3/1/99
12/1/00
3/1/01
9/1/94
3/1/97
3/1/99
9/1/99
9/1/00
3/1/95
* Assumes an action level exceedance during the 1 st 6-month initial tap monitoring period and that the
 system conducts an OCCT study.
                            — 17 —

-------
                          Exhibit 5
    Earliest FRDS Reporting Dates for Violations
         by System Size Listed Chronologically*

Initial Pb/Cu Tap M/R
Initial WQP M/R
Public Education
Initial Source Wat-v M/R
SOWT Recommendation
OCCT Study/Recommendation
SOWT Installation
Follow-up Source Water M/R
OCCT Installation/Demonstration
Follow-up Entry Point WQP M/R
Follow-up Pb/Cu Tap M/R
Follow-up Tap WQP M/R
Routine Source Water M/R
groundwater
MPL Noncompiiance
groundwater
Routine Entry Point WQP M/R
WQP Entry Point Noncompiiance
Lead Service Line Replacement
Routine Source Water M/R
surface water
MPL Noncompiiance
surface water
Routine Tap Pb/Cu M/R
Routine Tap WQP M/R
WQP Tap Noncompiiance
HI
51
53
65
56
61
57
62
56
58
54
52
55
56
63
54
59
64
56
63
52
55
60


9/1/92
9/1/92
3/1/94
3/1/93
3/1/93
9/1/94
9/1/95
3/1/96
3/1/97
6/1/97
9/1/97
9/1/97
3/1/99
3/1/99
12/1/98
12/1/98
9/1/98
3/1/98
3/1/98
3/1/99
3/1/99
3/1/99

3/1/93
3/1/93
3/1/94
9/1/93
9/1/93
9/1/95
3/1/96
9/1/96
3/1/98
6/1/98
9/1/98
9/1/98
3/1/99
3/1/99
12/1/99
12/1/99
9/1/99
9/1/98
9/1/98
3/1/00
3/1/00
3/1/00

3/1/94
3/1/94
3/1/95
9/1/94
9/1/94
9/1/96
3/1/97
9/1/97
3/1/99
6/1/99
9/1/99
9/1/99
3/1/99
3/1/99
12/1/00
12/1/00
9/1/00
9/1/99
9/1/99
3/1/01
3/1/01
3/1/01
* Assumes an action level exceedance during the 1st 6-month initial tap monitoring period and that the
 system conducts an OCCT study.
                            — 18 —

-------
                                    Exhibit 6
Definition of Compliance Achieved by  Violation Type
 Initial Pb and Cu
 Tap AM?**
 System meets M/R requirements, during subsequent compliance
 period(s), for each 6-month compliance period in which samples were not
 property collected [§§ 141.86(a)-(d)(1)], analyzed [§ 141.89(a)], or for
 which required information was not reported to the State [§ 141.90(a)].
 Follow-up Pb and
 Cu Tap M/R
 System meets M/R requirements, during subsequent compliance
 period(s), for each 6-month compliance period in which samples were not
 properly collected [§§ 141.86(a)-(c) and (d)(2)], analyzed [§ 141.89(a)], or
 for which required information was not reported to the State [§ 141.90(a)].
 Routine Pb and
 Cu Tap M/R
 System meets M/R requirements, during one subsequent compliance
 period, for one 6-, 12-, or 36-month compliance period (whichever was in
 effect at the time of the violation) that includes proper sample collection
 [§§ 141.86(a)-(c) and (d)(3) or (4)], analysis [§ 141.89(a)], and reporting to
 the State (§ 141.90(a)].
 Initial Tap & Entry
 Point WQP M/R
System meets M/R requirements, during subsequent compliance
period(s), for each 6-month compliance period in which samples were not
property collected [§§ U1.87(a)(1),<2) & (b)], analyzed [§ 141.89(a)], or
for which required information was not reported to the State [§ 141.90(a)].
 Follow-up Entry
 Point WQP M/R
System meets M/R requirements, during subsequent compliance
period(s), for any of the four quarters in which samples were not properly
collected [§§ 141.87(a)(1),(2) & (c)], analyzed [§ 141.89(a)], or for which
required information was not reported to the State [§ 141.90(a)].
 Routine Entry
 Point WQP M/R
System meets M/R requirements, during one subsequent quarter, that
includes proper sample collection [§§ 141.87(a)(1),(2), (d) and (e)],
analysis [§ 141.89(a)], and reporting to the State [§ 141.90(a)].	
 Follow-up Tap
 WQP M/R
System meets M/R requirements, during subsequent compliance
period(s), for each 6-month compliance period in which samples were not
properly collected [§§ 141.87(a)(1),(2) and (c)}, analyzed [§ 141.89(a)], or
for which required information was not reported to the State [§ 141,90(a)].
 Routine Tap WQP
 M/R
System meets M/R requirements, during a subsequent compliance period,
for one 6- or 12-month compliance period (whichever is in effect at the
time of the violation) that includes proper sample collection
[§§ I41.87(a)(l),(2), (d) and (e), analysis [§ 141.89(a)], and reporting to
the State [§ 141,90(a)].
 Initial Source
 Water M/R
System meets M/R requirements, during a subsequent compliance period,
for the 6-month compliance period in which samples were not properly
collected [§§ 141.88(a)(1) & (2) and (b)], analyzed [§ 141.89(a)), or for
which required information was not reported to the State [§ 141.90(b)].
 Follow-up Source
 Water M/R
System meets M/R requirements, during a subsequent compliance period,
for each^-month compliance period in which samples were not properly
collected [§§ 141.88(a)(1) & (2) and (c)-(e)], analyzed [§ 141.89(a)], or for
which required information was not reported to the State [§ 141.90(b)].

-------
                                Exhibit 6
 Definition of Compliance Achieved by Violation Type
                               (Continued)
Routine Source
Water M/R
OCCT Study/
Recommendation
OCCT Installation/
Demonstration
Entry Point WQP
Noncompliance
Tap WQP
Noncompliance
SOWT
Recommendation
SOWT Installation
Source Water MPL
Noncompliance
Lead Service Line
Replacement
Public Education
System meets M/R requirements, during a subsequent compliance period,
for one 1 -, 3, or 9-year compliance period (whichever is in effect at the
time of the violation) that includes proper sample collection
[§§ 141.88(a)(1) & (2) and (d) or (e)], analysis [I 141.89(a)j, and reporting
to the State [§ 141.90(b)].
System submits, during a subsequent compliance period, the OCCT
recommendation [§§ 141.82(a) & 141.90(c)(2)], completes and submits
the OCCT study to the State [§§ 141.82(c) & 141.90(c)(3)], and provides
any additional information to the State that is needed to make an OCCT
decision [§ 141.82(d)(2)].
System property installs and operates treatment [§ 14l.82(e)], submits
certification of proper installation and operation [§ 141.90(c)(4)j, or
demonstrates that OCCT already is in place [§§ 141.8l(b)(1)-(3) and
141.90(0(1)].
System meets State designated or approved WQP values or ranges for
one subsequent quarter [§ 141.82(g)].
System meets State designated or approved WQP values or ranges for
one subsequent 6-month compliance period [§ 14l.82(g)].
System submits SOWT recommendation to the State [§§ 141.83(a)(1) &
(b)(1)and141.90(d)(1)].
System properly installs and operates SOWT [§§ 141.83(b)(3) & (5)}
and/or submits certification of proper installation and operation
[§141.90(d)(2)].
System meets State designated or approved MPL values, during a
subsequent compliance period, for one 1-, 3-, or 9-year compliance
period (whichever is in effect at the time of the violation) [§ 141.83(b)(5)j.
System meets the 7% replacement rate (or higher if required by the
State) by any one or a combination of:
• demonstrates replaced line under its limited control {§§ 141.84{e)
and 14l.90(e) (4)]
• replaces entire line [§§ 141.84(a) & (b)]
• shows the lead service line contributes < 1 5 ppb of lead
(§ 141.84(c), and
Reports all required information to tine State [§ 141.90(e)].
System delivers one round of public education [§§ 1 41 .85(a)-(c)], and
submits a letter to the State that demonstrates measures taken to meet
these public education requirements [§ 141.90(f)].
 *  The actions needed to achieve compliance are not meant to replace other activities that are required
   to be conducted under the rule for that time frame nor are they meant to indicate that a violation did
   not occur for the system. Instead, they indicate that this violation no longer continues and should
   no longer be reported for the system. Should the system again fails to meet subsequent requirements
   of the rule, another violation must be reported.
**  The violations in italics can result in a system's becoming a SNC.
                                   — 20 —

-------
 Monitoring and
 Reporting Violations

   Monitoring  and  Reporting   (M/R)
 violations fall into 3 major categories:
 • M/R  for  lead  and  copper at  the
   customers' taps
   •  M/R for WQPs at entry points and
     taps to the distribution system
   *  M/R for lead and copper in source
     water.
   Within each of the three categories,
 initial, follow-up, and routine monitoring
 violations may be incurred. To simplify
 definitions and reporting requirements,
 EPA has combined several of the violations
 where appropriate. A total of 6 types of
 M/R violations are possible. A detailed
 discussion of each violation is provided,
 including the definition for the violation
 and instructions  on how this  violation
 should be reported to FRDS. In addition,
 examples are provided after the discussion
 of each violation,  including sample DTF
 transactions.

Initial Lead and Copper
 Tap MIR
   Initial tap sampling for lead and copper
 is required for all CWSs and NTNCWSs,
 regardless of size. Initial monitoring for
 large systems must be completed in two
 six-month compliance periods. Sampling
 during the  second six-month period  for
medium and small systems is optional if
the system exceeds the lead or copper
action  level  in  the  first  six-month
compliance period because the system is
immediately   triggered  into  OCCT
requirements. If the medium or small
system does not exceed the lead or copper
action level  during the first six-month
period, the system must sample during
a  second six-month monitoring period
 before   being   eligible   for  reduced
 monitoring.

   Initial tap sampling for lead and copper
 begins:
   Jan. 1, 1992 * large systems
   July 1, 1992 - medium systems
   July 1, 1993 - small systems

   An initial lead and copper tap  M/R
 violation must be reported for any system
 that falls to complete ANY of the Mowing
 activities,  during  either  six-month
 compliance period:
   •  Using the  appropriate  sampling
     procedures  in  accordance  with
     Sections 141.86(a) and (b)
   •  Collecting the required number of
     samples during the specified time
     frame, in accordance with Sections
     141.86(c) and (d)(l)
   •  Ensuring samples are  analyzed
     properly in accordance with Section
     141.89(a)
   •  Submitting all required monitoring
     information on-time in accordance
     with Section 141.90(a).
  A system that incurs an initial lead and
copper tap  M/R violation will  become a
significant  noncomplier (SNC) if  the
system does not return to compliance
within 3 months for  a large system,
6 months for a  medium  system,  and
12 months for a small system. A discussion
on SNCs is presented in greater detail in
the last section of this document that
begins on page 57.
Note: If applicable, systems are required
  to submit, at the start of the monitoring
  period, a justification for die use of non-
  Tier 1 sampling sites or for sampling
  <50% of lead service lines. If a system
  fails to submit these justifications and
  samples at Tier 2 or 3 sites or from
  <50% of lead service lines, the sytem
                                  — 21 —

-------
  would incur a violation at the end of
  the 6-month compliance period.
  The primacy agency must report the
following data for each Initial Lead and
Copper Tap M/R violation:
'.. v; : FRTO D«t« BenwMrt - - :
Number
C101
C1101
C1105
C1107
De»t^ik» ,
PWS-ID
Violation ID
Violation Type Code = 51
Compliance Period Begin Date & the
first day of the 6-month compliance
period
  FRDS will default the following data
elements for this violation type (these
may be optionally reported, but should be
consistent with the other data elements
for this violation).
  C1103

  C1109

  C1111
Contaminant code for lead and copper
violation = 5000
Compliance period end date =
6 months later than C1107
Compliance period in months =
6 months
  The earliest date a violation of this type
could be reported to EPA is  indicated
below by system size for both initial six-
month monitoring periods.
   * A
 Large
 Medium
 SmaH

     9/1/92
     3/1/93
     3/1/94
3/1/93
9/1/93*
9/1/94*
  Additional monitoring is optional if an exceedance of
  an action level occurs in the first 6-month monitoring
  period.
                                      EXAMPLES
                                EXAMPLE 1 —
                                 A large system (TX1230567) does not
                                complete the  first  round of  initial
                                monitoring by June 30,1992, but instead
                                completes the monitoring and submits all
                                required  information  to the  State on
                                August 29, 1992.
                                 By August 15,1992, the State will report
                                an  Initial Lead and Copper Tap  M/R
                                violation as follows:
C101
CHOI
C1103

C1105
C1107

C1109


C1111


TX1 230567
9200001
5000

51
01/01/92

06/30/92


006


PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date {Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
NOTE: C1103, C1109, and C1 111 will be
defaulted by FRDS to 5000, 063092, and 006,
respectively and, thus, need not be entered by
the State.
                                          The DTF transactions for this record are:
13 12 19
II II
D1TX12305679200001
D1TX12305679200001
27 32
II I
IC110551
IC1107010192
EXAMPLE 2 —
  A medium or small system exceeds the
lead action level during the first six-month
compliance period and does not collect any
samples during the next six months.
  The system would  not be in violation
because the second six-month monitoring
period is optional for medium and small
                                   — 22 —

-------
 systems if they  exceed an action level
 during the first monitoring period because
 they are immediately triggered into OCCT.
  Because an initial lead and copper M/R
 violation may lead to a system's becoming
 a SNC, additional examples related to the
 reporting of this violation, including how
 to report compliance achieved, can  be
 found after the discussion of an initial lead
 and copper M/R SNC on pages 61-65.

Follow-up or Routine Lead
and Copper Tap M/R

  Follow-up monitoring for lead  and copper
refers to the tap samples collected during
two consecutive six-month periods AFTER
OCCT has been installed. These results
and the results of water quality parameter
(WQP) monitoring are used by the State
to set WQP values that reflect OCCT.
  Routine monitoring is conducted:
  • During six-month periods AFTER
    WQPs have been set, or
  • By those systems not having to install
    OCCT.
The  results  are  used by the State  to
determine if the system qualifies for
reduced monitoring.
  A follow-up or routine lead and copper
tap M/R violation is defined similarly to
the initial violation. A State must report
a violation for a PWS that fails to complete
ANY of the following activities, for each
compliance period in which the violation
occurs:
  *  Using the appropriate  sampling
    procedures  in  accordance  with
    Sections 141.86(a) and (b)
  •  Collecting  the required number  of
    samples during the  required time
    frames in accordance with Sections
    141.86(c) and (d)
   • Ensuring samples  are  analyzed
     properly in accordance with Section
     U1.89(a)
   • Submitting all required monitoring
     information  on-time in accordance
     with Section 141.90(a).
 The same violation type code (i.e,, 52) will
 be used for the reporting of follow-up and
 routine tap M/R violations.
   The primacy agency must report the
 following data for  each Follow-up  or
 Routine Lead and Copper  Tap  M/R
 violation:
           sFRDSjQitisQ'Wiwj!*!
  C101
  C1101
  C1105
  C1107

  C1109
  or
  C1111

 PWS-ID
 Violation ID
 violation Type Code = 52
 Compliance Period Begin Date = the
 first day of the compliance period
 Compliance period end date:
 • 6 months later than Cl 107 tor
  foNow-up monitoring
 • 6,12 or 36 months later than
  C1107 for routine monitoring

 Compliance period in months
 • 6 months for follow-up monitoring
 • 6. 12 or 36 months for routine
  monitoring
  FRDS wffl default the following data
element:
  C1103
Contaminant code for lead and copper
violations - 5000
  Assuming the system exceeds an action
level during the first six-month monitoring
period, the earliest dates a follow-up M/R
violation or routine M/R violation could
appear in FRDS are as follows:
                                   — 23 —

-------
         FOLLOW-UP M/R
System
Size
Large
Medium
Small
System
Stze
Large
M-dium
Smail
Without OCCT Study
let Compliance
Period
N/A
3/1/97
9/1/98
2nd Compliance
Period
N/A
9/1/97
3/1/99
wtnoccr study
let Compliance
Period
9/1/97
9/1/98
9/1/99
2nd Compliance
Period
3/1/98
3/1/99
3/1/00
          ROUTINE M/R
Syttem
Size
Large
Medium
Small
Without OCCT
Study
N/A
9/1/96
3/1/00
wfthoccr
Study
3/1/99
3/1/00
3/1/01
  A system on reduced monitoring that
incurs an M/R violation would not be
required   to  return  to semiannual
monitoring nor  to collect the original
number of samples. Instead, the system
only would be required  to collect the
original  or standard  number of tap
samples if it exceeds the lead or copper
action level or to return to semiannual
monitoring if it fails to operate within the
range of values for WQPs.
      EXAMPLES
EXAMPLE 1 —
  A large system (NC0234567) completes
the requirements for the installation of
OCCT on December 31,1997. The system
does not collect any follow-up samples for
either six-month compliance period (i.e.,
 from January 1 - June 30, 1998 or July 1 -
 December 31, 1998). By August 15, 1998,
 the State would report the following:
C101
C1101
C1103

C1105
C1107

C1109

Or
C1111

NC0234567
9800001
5000

52
01/01/98

06/30/98


006

PWS-ID
Violation ID
Contaminant Code
(Defaulted by PROS)
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
                                       The DTP transactions for this violation
                                     are:
13 12 19
II II
D1NC02343679800001
D1NC0234S679800001
D1NC02345679800001
27 33
II 1
IC110552
IC1107010196
IC1111006
  By February 15,1999, the State would
report a second violation:
C101
C1101
C1103

CMOS
C1107

C1109

or
C1111

NC0234S67
9900001
5000

52
07/01/96

12/31/98


006

PWS-ID
violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
  The DTP transactions for this violation
are:
13 12 19
II 1 1
D1NC02343679900001
D1NC02345679900001
D1NC02345679900001
a? 32
il 1
IC110552
IC1107070198
IC1111006
                                — 24 —

-------
 EXAMPLE 2 —
  A   medium   system   (FL0123456)
 completes the first round of follow-up
 sampling on-time (e.g., 6/30/98). The 90th
 percentile lead and copper concentrations
 are below the action levels. The system
 does not collect a second round of samples
 during the compliance period July 1 -
 December 31, 1998.
  A medium  or  small  system  may
 discontinue the steps of the OCCT process
 whenever the system meets both action
 levels  in two consecutive monitoring
 periods. In this example, the system has
 met both action  levels  in  only one
 monitoring period and therefore has not
 qualified  to   discontinue  OCCT
 requirements.  The system  would be
required to collect  a second round  of
 samples  and therefore  would  be  in
violation on January 1, 1999 for failure
 to complete the second round of follow-up
 sampling.
  The State would report the following to
the Region by February 15, 1999:
  The DTP transactions for this violation
are:
C101
C1101
C1103

C1105
C1107

C1109

or
C1111

FL01 23456
9900001
5000

52
07/01/98

12/31/98


006

PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
13 13 19
II 1 1
D1FL01234569900001
D1FL01234569900001
D1FL01234569900001
27 32
11 1
IC110552
IC1107070198
IC1109123198
EXAMPLES —
  The State designates WQPs on July 1,
1998 but the system (GA9123456) does
not collect all required samples during its
first six-month  compliance  period for
routine monitoring of lead and copper at
the tap (i.e., July 1 - December 31, 1998).
  The State  will report  a violation by
February 15, 1999, as follows:
 C101
 C1101
 C1103

 C1105
 C1107

 C1109

 or
 C1111
QA9123456
9900001
5000

52
07/01/98

12/31/98
                                                 006
PWS-ID
Violation 10
Contaminant Code
(Defaulted by FRDS)
violation Type Code
Compliance period begin
Compliance period end
date

Compliance period in
months
                                          The DTF transactions for this violation
                                         are:
13 12 19
II t 1
D1GA91234569900001
D1GA91234569900001
D1GA91234569900001
27 32
II 1
IC110552
IC1107070196
IC1111006
                                   — 25 —

-------
EXAMPLE 4 —
  A large system (AL6123456) was eligible
for reduced monitoring on July 1,1999 but
did not collect all of its samples during the
compliance period July 1,1999 - June 30,
2000.
  The State would report a violation by
August 15, 2000, as follows:
C101
C1101
C1103

C1105
C1107

C1109

or
C1111

AL61 23456
0000001
5000

52
07/01/99

06/30/00


012

PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
  The DTF transactions for this violation
are:
13 12 19
II II
D1AL61234560000001
D1AL61234560000001
D1AL612345 60000001
27 32
II 1
IC110552
IC1107070199
IC1111012
Note:  A system on reduced monitoring
  would not be required to return to
  original monitoring for incurring an M/R
  violation. A system's reduced monitoring
  only can be affected if:
  1. The system exceeds the lead or copper
    action level. The system then would
    be required to collect and analyze the
    original or "standard"  number of
    samples; or
  2. The system fails to operate within the
    State-specified or approved ranges
    or  values  for WQPs. The system
    would  be  required to return  to
    semiannual monitoring.
 Initial WQP MIR
   Initial tap and entry point sampling for
 WQPs is conducted by all large PWSs,
 during the same sampling periods as initial
 tap  sampling for  lead and copper.  For
 medium and small PWSs, it is performed
 during each  of the initial six-month
 monitoring periods in which the lead or
 copper action  levels are exceeded.
  A violation of initial tap and entry point
 WQP M/R requirements must be reported
 for any system that fails to complete ANY
 of the  following  activities,  for  either
 compliance period in which the violation
 occurs:
   •  Using the  appropriate sampling
     procedures  in  accordance  with
     Sections 141.87(a)(l) and (b)
   •  Collecting the required number of
     samples in accordance with Section
     141.87(a)(2)
  •  Ensuring samples  are analyzed
     properly in accordance with Section
     141.89(a)
  •  Submitting all required monitoring
     information on-time in accordance
    with Section 141.90(a).
The  primacy agency must report the
following data for each Initial WQP M/R
violation:
 C101
 C1101
 C110S
 C1107
PWS-ID
Violation ID
Violation Type Code * 53
Compliance Period Begin Date » the.
first day of the compliance period

-------
   FRDS win default the following data
 elements:

Humber
C1103
C1109
C1111
" PftDS Oof* dement -

- Detariptton ,•'.,.
Contaminant code for lead and copper
violation = 5000
Compliance period end date =
6 months later than C1 1 07
Compliance period in months a
6 months
  The FRDS reporting dates for this
violation are the same as those for initial
tap monitoring for lead and copper as
follows:
System
Size
Large
Medium
Small
1st 6-month
Compliance
Period
9/1/92
3/1/93
3/1/94
2nd 6-mont/i
Compliance
Period
3/1/93
9/1/93*
9/1/94*
  A second round of samples is optional for medium and
  small systems if the action level is exceeded.
      EXAMPLES
EXAMPLE 1 —
  A large system (LA1123456) collects its
initial round of lead  and  copper tap
samples and does not exceed either action
level. However, the system does not collect
any WQPs during this six-month compli-
ance period (i.e., from January 1 - June 30,
1992).
  Unlike medium or small systems, large
systems  are  required to collect WQPs
regardless of whether they exceed the
lead or copper action level. A large system
is required to install OCCT, independent
of its 90th percentile lead and copper
values. The initial WQP data is needed
for establishing treatment  operating
parameters.
   By August 15, 1992, the State would
 report an Initial WQP M/R violation as
 follows:
                                          C101
                                          C1101
                                          C1103

                                          C1105
                                          C1107

                                          C1109
  C1111
         LA1123456
         9200001
         5000

         53
         01/01/92

         06/30/92
006
PWS-ID
Violation ID
Contaminant Code (De-
faulted by FRDS)
violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
                                          The DTP transactions for this violation
                                         are:
13 12 19
M II
D1LA11234569200001
D1LA11234569200001
27 32
II 1
IC110553
IC1107010192
  A large system is required to meet WQP
M/R  requirements for two six-month
compliance periods in order  to  have
achieved compliance for this requirement.
EXAMPLE 2 —
  A medium system completes the first
round of initial monitoring by December
31, 1992 and does not exceed the lead
or copper action level. The system  does
not collect WQP  samples during this
sampling period.
  Unlike large systems, medium and  small
systems only are required to conduct  WQP
testing  in  those compliance periods in
which they exceed the lead or copper action
level. In this example, the system has not
incurred an Initial WQP violation because
it  did not  exceed  an action level and
therefore was not required  to test for
WQPs.
                                   — 27 —

-------
EXAMPLES —
  A medium system (AX0003456) com-
pletes initial lead and copper tap sampling
by December  31, 1992 and exceeds the
copper action level. On January 1, 1993,
the system begins collecting WQPs and
the State receives these results on April
1, 1993.
  The system  is in violation because it is
required to complete the monitoring during
the same compliance period as lead and
copper tap monitoring (i.e., in this exam-
ple,  from July 1 - December 31,  1992).
Medium and small systems should com-
plete tap sampling early enough  in the
compliance period to allow them to conduct
WQP monitoring and reporting in  the
event they exceed an action level.
  By February 15,1993, the State would
report:
 C101
 C1101
 C1103

 C1105
 C1107

 C1109
 C1111
AX0003456
9300011
5000

53
07/01/92

12/31/92
006
PWS-ID
Violation ID
Contaminant Code (De-
faulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
  The DTP transactions for this violation
are:
 13       12     19
 II       1      t
 D1AX00034569300011
 D1AX00034569300011
                37
                II
           32
               IC110553
               IC1107070192
 Follow-up or Routine
 Entry Point WQP MIR
   Follow-up or routine WQP monitoring
 must occur at each entry point to the
 distribution system and at selected taps.
 The compliance periods for each of these
 varies significantly; entry point monitoring
 must  always  be  conducted  biweekly,
 whereas tap monitoring is conducted either
 semiannually or annually. In order to allow
 clear identification of the violations in
 FRDS, entry point and tap sampling M/R
 violations have been defined as separate
 violations.
   Follow-up entry point monitoring of
 WQPs   is  conducted  AFTER  the
 installation of OCCT by all large systems
 and by those medium and small systems
 during monitoring periods in which they
 exceed the lead or copper action level.
 These data are used by the State to review
 the  performance of treatment  and to
 modify the treatment or WQPs levels, as
 needed. Routine monitoring is performed
 after the State has finalized the WQPs.
   Follow-up and routine  entry point
 samples must  always  be  collected
 biweekly and reduced monitoring is not
 allowed for this type of sampling. To
 eliminate some of the reporting and
 tracking burden associated with a violation
 that could occur every 2 weeks, all entry
point violations that  occur in a given
quarter will be reported as one WQP entry
point violation.
  A single violation will be reported for
 a system that fails to complete ANY of the
following during a quarter:
   • Using the  appropriate  sampling
    procedures  in  accordance  with
    Sections 141.87(a)(l), (c)-(e)
  • Collecting the required number of
    samples in accordance with Sections
    141.87(a)(2) and (e)
                                   — 28 —

-------
   •  Ensuring  samples  are  analyzed
     properly in accordance with Section
     141.89(a)
   •  Submitting all required monitoring
     information  on-time in accordance
     with Section 141.90(a).
Therefore, if a system does not meet the
above requirements for any of the biweekly
monitoring  periods, it is  in violation.
However, for reporting purposes only, all
violations will be aggregated and a single
violation will be reported for the quarter.
  The same violation type code (i.e., 54)
is used for either the reporting of follow-
up or routine  entry point WQP M/R
violations.
  The State must report the following data
for each Follow-up  or Routine Entry
Point WQP M/R violation:
                                        FOLLOW-UP M/R
  C101
  C1101
  C1105
  C1107
PWS-ID
Violation ID
Violation Type Code = 54
Compliance Period Begin Date = the
first day of the compliance period
  FRDS wiU default the following data
elements:
 Number
  C1103

  C1109

  C1111
Contaminant code for lead and copper
violation = 5000
Compliance period end date =
3 months later than C1107
Compliance period in months =
3 months
  The earliest dates follow-up entry point
M/R violations would be reported to FRDS
are shown below for each quarter of follow-
up monitoring for systems not conducting
and conducting studies.  In addition,
reporting dates are shown for the first
quarter of routine monitoring.
Syate/n
size
Large
Medium
Small
Sywiwn
S/ze
Large
Medium
Small
without occr sway
j»t
Quarter
N/A
12/1/96
6/1/96
and
Quarter
N/A
3/1/97
9/1/96
3rd
Quarter
N/A
6/1/97
12/1/98
«ft
Quarter
N/A
9/1/97
3/1/99
wwioccr study
fat
Quarter
6/1/97
6/1/96
6/1/99
2nd
Quarter
9/1/97
9/1/96
9/1/99
3rd
Quarter
12/1/97
12/1/98
12/1/99

-------
for a quarter, the State would report one
violation for the time period January -
March and a second for liie quarter, April -
June as follows:
  For  the  violation  incurred during
January - March, the State would report
a violation by May 15, 1997, as follows:
                                     The DTF transactions for this second
                                   violation are:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109
  C1111
MS0003456
9700002
5000

54
01/01/97

U?/31/97
003
 PWS-IO
 Violation ID
 Contaminant Code
 (Defaulted by FRDS)
 Violation Type Code
 Compliance period begin
 date
 Compliance period end
 date (Defaulted by
 FRDS)
 Compliance period in
 months (Defaulted by
 FRDS)
  The DTF transactions for the  first
violation are:
13 12 19
II II
D1MS00034S 69700002
D1MS00034569700002
27 32
II 1
IC110554
IC1107010197
  For the violation incurred during April -
June, the State would report the following
by August 15, 1997:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109
 C1111
MS0003456
9700003
5000

54
04/01/97

06/30/97
003
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
13 12 19
II 1 1
D1MS00034569700003
D1MS00034569700003
27 32
II 1
IC110554 I
ICU07040197 ||
   Further, the  system is required to
sample  for an additional 5 months to
provide  12 months' worth of WQP data
on which the State can make a decision
regarding optimal WQP values or ranges.
An exception to this requirement would
be a small or medium system that is no
longer required to install OCCT because
it meets the lead and copper action levels
for two consecutive compliance periods.

EXAMPLE 2 —
  A large system (MA0003456) fails to
collect any routine entry point samples
during July and August 1998.
  A routine entry point sample would be
reported similarly to that of a follow-up
sample and would have the same violation
code. In  this example, the system would
incur  a violation  for  the  quarter,
July 1 - September 30,1998, and the State
would report a violation by November 15,
1998 as follows:
 C101
 C1101
 C1103

 C11O5
 C1107

 C1109
                                            C1111
MA0003456
9800001
5000

54
07/01/98

09/30/96
                                           003
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
                                     — 30 —

-------
   The DTP transactions far this record are
113 12 19
II II
D1MA00034569800001
D1MA00034569800001
27 32
II 1
IC110554
IC1107070198
  For large systems, routine WQP monitor-
 ing occurs for the lifetime of the system.
 Unlike initial and follow-up sampling that
 occur for a limited period of 12 months
 each, a  system  cannot make up the 2
 months  of missed samples for routine
 entry point WQP monitoring. Therefore,
 a  system will  achieve compliance  for
 routine entry point WQP monitoring if it
 successfully monitors and reports for the
 entire next quarter.
 EXAMPLES —
  A medium system (VT1003356) conducts
 routine lead and copper tap sampling and
 exceeds  the lead  action level for the
 compliance period July 1 - December 31,
 1999. The system does not collect any
 entry point WQP  samples during this
 compliance period. The system completes
 the next round of lead and copper tap
 sampling from January 1 - June 30, 2000
 and no longer exceeds the lead action level.
  Medium and small systems only are
 required to collect WQP samples in the
 same compliance period(s) in which they
 exceed an action level. In this example,
 the system should have been collecting
 biweekly samples during July 1 - Decem-
 ber 31,  1999. Because  an  entry point
 violation is reported quarterly, the State
 would report two routine entry point WQP
violations; one for the compliance period
July 1 - September 30,1999 and a second
for  the  compliance period  October 1 -
 December 31, 1999.
  For the violation occurring during the
compliance period July - September, 1999,
the State would report by November 15,
1999:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109
  C1111
 VT1003356
 OOG0001
 5000

 54
 07/01/99

 09/30/99
 003
 PWS-ID
 Violation ID
 Contaminant Code (De-
 faulted by FRDS)
 Violation Type Code
 Compliance period begin
 date
 Compliance period end
 date (Defaulted by
 FRDS)
 Compliance period in
 months {Defaulted by
 FRDS)
  The DTF transactions for this record are:
13 12 19
II 1 1
D1VT100335600G0001
D1VT100335600G0001
27 32
II 1
IC110554
IC1I07070199
  For the violation occurring during the
compliance period October - December,
1999, the State would report by February
15, 2000:
 C101
 C1101
 C1103

 C1105
 C1107

 C1109
 C1111
VT1003356
OOG0002
5000

54
10/01/99

12/31/99
003
PWS-ID
Violation ID
Contaminant Code (De-
faulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
                                    — 31 —

-------
  The DTP transactions for this second
violation are:
13 12 19
II 1 1
D1VT100335600G0002
D1VT100335600G0002
27 32
III
IC110S54
IC1107100199 j
  The system is not in violation for failure
to collect WQP samples during January 1 -
June 30, 2000, because it did not exceed
either action level. On the other hand, a
system must bear in mind that if it does
not start WQP sampling at the beginning
of the lead and  copper tap monitoring
period, but waits instead for the lead and
copper monitoring results, it risks missing
some of the required biweekly monitoring
if the lead or copper tap samples show an
exceedance of the action level. If the
system  believes  it will not exceed the
action levels (for example,  due to the
installation of OCCT or past lead  and
copper monitoring), it could chance not
collecting  entry  point  WQP samples,
knowing that it will incur an entry point
WQP violation if the 90th percentile level
exceeds the action level.
  For a medium or  small system, the
system  is considered to have returned to
compliance if either:
  •  it successfully monitors and reports
     for one quarter, or
  •  its  90th percentile monitoring results
     for lead and copper no longer show
     an  exceedance of either action level.

Follow-up or Routine
Tap WQP MIR
  In addition to  WQP  testing at entry
points, follow-up monitoring is conducted
after the installation of OCCT at taps in
the  distribution  system by  all large
systems and those medium and small
systems that exceed the lead or copper
action level. These taps are not required
to be the ones targeted for lead and copper
monitoring. Instead, the system may find
 it convenient to sample at the same sites
 used for coliform testing under the Total
 Coliform Rule.
   Routine monitoring is performed after
 the State has finalized the WQPs. The
 schedule for WQP monitoring at taps is
 lees frequent than at entry points. Samples
 are collected every six months and then
 annually if the system qualifies for reduced
 monitoring.
  A system is in violation if it fails to
 complete any of the following:
   •  Using the  appropriate sampling
     procedures   in  accordance   with
     Sections 141.87(a)(l), (c) - (e)
   •  Collecting the required number of
     samples in accordance with Sections
     141.87(a)(2) and (e)
   •  Ensuring  samples  are  analyzed
     properly in accordance with Section
     141.89(a)
   •  Submitting all required monitoring
     information on-time in accordance
     with Section 141.90(a).
To simplify reporting, a single violation
will be reported for  each 6-month or
12-month compliance period in which the
system is in violation. The same violation
type code (i.e., 55) is used for the reporting
of follow-up and routine tap WQP M/R
violations.
  The State must report the following data
for each Follow-up/Routine Tap Sampling
for WQP violation:
           iz     •••  --  - "

                 ^     - -
 Mutnber
 C101
 C1101
 C1105
 C1107

 C1109

 or
 C1111
PWS-ID
Violation ID
violation Typ« Code = 55
Compliance Period Begin Date = the
first day of the compliance period
Compliance period end date = 6 or
12 months later than C1107

Compliance period in months = 6 or
12 months
                                   — 32 —

-------
  FRDS wffl default the following data
 element:
?:"^^'^
torntwr
C1103
.^^iW^i^iig^iiii^^
Contaminant code tor lead and copper
violation = 5000
  The earliest FRDS reporting dates for
 each six-month compliance period of a
 follow-up tap WQP violation for systems
 not conducting a study and conducting a
 study are as follows:
         FOLLOW-UP M/R
System
Slzo
Large
Medium
Small
System
SUe
Large
Medium
Small
Without OCCT Study
1st Compliance
Period
N/A
3/1/97
9/1/98
2nd Compliance
Period
N/A
9/1/97
3/1/99
With OCCT Study
1tt Compliance
Period
9/1/97
9/1/98
9/1/99
2nd Compllence
Period
3/1/98
3/1/99
3/1/00
  The earliest date for reporting routine
WQP M/R violations to FRDS are shown
for systems not conducting a study and
those required to conduct a study.
          ROUTINE M/R
System
Size
Large
Medium
Small
Without OCCT
Study
N/A
9/1/98
3/1/00
With OCCT
Study
3/1/99
3/1/00
3/1/01
Note: A system can incur both entry point
  and tap WQP M/R violations in the same
  compliance period. In addition, as will
  be discussed in the description of an
 entry point and tap WQP noncompliance
 violation, these violations also can be
 incurred during the same compliance
 period as the WQP M/R violations.
                                             EXAMPLES
 EXAMPLE 1 —
  A system, (NH6003356) that is not on
 a reduced monitoring schedule  for tap
 WQP M/R, does not collect any entry point
 or tap WQP from July 1 - December 31,
 1998.
  Tap WQP M/R violations are reported
 separately   from  entry point  WQP
 violations.  Entry point violations are
 reported quarterly; therefore, the system
 would incur two entry point violations, one
 for the period July 1 - September 31,1998
 and another for the period  October 1 -
 December 31, 1998. (See examples on
follow-up or routine entry point WQP MIR
 violations on pages 29-32.)
  Routine tap WQP M/R violations have
 a compliance period  of six months (or 12
months if on reduced monitoring). In this
example, the system missed the sampling
requirements for one compliance period
(July 1 - December 31,1998) and a single
tap WQP M/R violation would be reported.
  By February 15,1999, the State would
report:
 C101
 C1101
 C1103

 C1105
 C1107

 C11O9

 or
 Cim
                                               NH6003356
                                               99Q0007
                                               5000

                                               55
                                               07/01/98

                                               12/31/98
006
          PWS-ID
          Violation ID
          Contaminant Code (De-
          faulted by FRDS)
          Violation Type Code
          Compliance period begin
          date
          Compliance period end
Compliance period in
months
                                  — 33 —

-------
  The DTF transactions for this violation
are:
13 13 19
II 1 1
D1NH600335699G0007
D1NH600335699G0007
D1NH600335699G0007
27 32
II 1
IC110555
IC1107070198
IC1109123198
EXAMPLE 2 —
  A system (TNI 103356) on  reduced
monitoring fails to  collect  WQP  tap
samples during July 1, 2003 - June 30,
2004.
  By August 15, 2004, the State woo.ld
report:
C101
C1101
C1103

C1105
C1107

C11O9

or
C1111

TN1 103356
0400001
5000

55
07/01/03

06/30/04


012

PWS-ID
Violation ID
Contaminant Code (De-
faulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
  The DTF transactions for this violation
are:
13 12 19
I 1 II
D1TN11033560400001
D1TN11033560400001
D1TN11 033560400001
27 32
II 1
IC110SS5
IC1107070103
IC1109063004
  The system would not be required to
change  from the  reduced monitoring
schedule for incurring a routine WQP M/R
violation.  The  system only would be
required to collect WQP samples semi-
annually at the original number of samples
if it no longer meets the State-specified
or approved WQP values or ranges.
 Lead and Copper
 Source Water MIR
   Any system that exceeds the lead or
 copper action level must perform source
 water monitoring within six months of the
 exceedance at  all entry  points  to the
 distribution system to determine if source
 water concentrations  of lead or  copper
 contributed to the exceedance, and thus,
 source water treatment (SOWT) is needed
   •  Initial monitoring is conducted at
     each entry point to the distribution
     system within six months after the
     action level is exceeded.
   •  Follow-up monitoring is performed
     after installation and operation of
     SOWT, at each entry point  to the
     distribution system, for two consecu-
     tive six-month monitoring periods.
   •  Routine monitoring  is performed
     after the State specifies maximum
     permissible source  water  levels
     (MPLS)  for lead and  copper or
     determines   that  SOWT  is
     unnecessary.
  Routine monitoring may be conducted
on a 1, 3, or 9-year frequency depending
on the source (ground water or surface
water) and whether the system qualifies
to sample at  a reduced monitoring
frequency.
  Initial, follow-up, or routine source water
sampling for lead and  copper violations
must be reported for each PWS that fails
to complete the following activities, for
each  compliance period in which  the
violation occurs:
  * Using the  appropriate sampling
    procedures   in  accordance  with
    Sections 141.88(a)(l) and (2)
                                  — 34 —

-------
  •  Collecting the required number of
     source water samples in accordance
     with Sections 141.88(a)(l) - (e)
  •  Ensuring samples  are  analyzed
     properly in accordance with Section
     141.89(a)
  •  Submitting  all required sampling
     information  on-time in accordance
     with Section 141.90(b).
  The same violation type code is used
(i.e., 56) for the reporting of initial, follow-
up, and routine source water sampling
violations.
  The State must  report the following
data for each Source  Water Sampling
violation:
                                The earliest FRDS reporting dates for
                              these violation are as follows:
'-'' '', ''
'UtiondMHr-
C101
C1101
C11O5
C1107

C1109


or
C1111

"\v :.D»«|pti<«"' I* -° ,
PWS-ID
Violation ID
Violation Type Code = 56
Compliance Period Begin Date = the
first day of the compliance period
Compliance period end date =
6 months or 12, 36, or 108 months
later than C1107

Compliance period in months = 6, 12,
36, or 108 months
  FRDS will default the following data
element:
 C1103
Contaminant code tor lead and copper
violation * 5000
System
Sfee
Large
Medium
Smell
System
Sb*
Large
Medium
Smell
IMffef
Monitoring
3/1 193
9/1/93
9/1/94
J
Qround
3/1/98
9/1/98
9/1/99
Follow-up Monitoring
Iff
Compliance
Period
3/1/96
9/1/96
9/1/97
2ml
Compllmnc*
**—-|j»W
f*vno0
9/1/96
3/1/97
3/1/98


Surfee*
3/1/99
3/1/99
3/1/99
                                            EXAMPLES     I
                                          	^	     i
                                      EXAMPLE 1 —
                                        A large system (PA1103666) exceeds the
                                      copper action level during its first round
                                      of initial lead and copper tap monitoring
                                      (i.e., January 1 - June 30,1992) and fails
                                      to collect source water samples within six
                                      months of exceeding an action level or by
                                      December 31, 1992 in this example.
                                        By February 15,1993, the State would
                                      report the following:
C101
C1101
C1103

C1105
C1107

C1109

or
C1111

PA1 103666
9300001
5000

56
07/01/92

12/31/92


006

PWS-ID
Violation ID
Contaminant Code
(Defaulted by PROS)
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
                                 — 35 —

-------
  The DTP transactions for this violation
are:
                                   The DTF transactions for this violation
                                 are:
13 12 19
II II
01PA11036669300001
D1PA11036669300001
D1PA11036669300001
27 32
II 1
IC110556
IC1107070192
IC1111006
  To achieve compliance, the system must
fulfill  the  monitoring and reporting
requirements hi accordance with Sections
141.88(a)(l), 141.89, and 141.90(b) for one
six-month compliance period.

EXAMPLE 2 —
  A system (MD0103666) installs SOWT
on June 30,  1995 and collects the first
round of follow-up source water samples
but does not collect the second round of
source water samples.
  All systems, required to install SOWT,
must  collect  follow-up source water
samples during two consecutive six-month
compliance periods to provide  data on
which State can set MPLs for  lead and
copper in source water. In this example,
the system is in violation for failure to
collect follow-up  samples  during the
compliance period January 1 - June 30,
1996.
  By August 15, 1996, the State would
report the following:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109

  Of
  C1111
MD0103666
9600002
5000

56
01/01/96

06/30/96
006
PWS-ID
Violation ID
Contaminant Code
(Defaulted by PROS)
Violation Type Code
Compliance period
begin date
Compliance period end
Compliance period in
montns
13 12 19
II 1 1
D1MD01036669600002
D1M001036669600002
D1MD01036669600002
27 32
II 1
IC110556
IC1107010196
IC1111006
  To achieve compliance, the system must
 collect an additional round of source water
 samples.

 EXAMPLES —
  A ground water system (DE0103666),
 on a nine-year monitoring cycle, does not
 collect any source water samples for the
 compliance period January  1,  2001 -
 December 31, 2009.
  Once a system installs  SOWT, it is
 required to collect source water samples
 for lead and/or copper, only if the system
 has failed to meet the action level for lead
 or copper in tap water samples during any
 compliance period within the entire source
 water sampling period in effect  (in this
 example from January 1, 2001 - December
 31,  2009). Assume the system exceeded
 the copper action level during the tap
 sampling compliance period, January 1,
 2003 - December 31,  2005. The copper
action level exceedance occurs during the
source water compliance period; therefore,
the system would be in violation for failure
to sample for copper in source water.
  By February 15, 2010, the State would
report:
C101
C1101
C1103

C1105
C1107

C1109

or
C1111

DE01 03666
1000001
5000

56
01/01/01

12/31/09


108

PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
                                   — 36 —

-------
  The DTF transactions for this violation
 are:
13 12 19
II 1 1
D1DE01036661000001
D1DE01036661000001
D1DE01036661000001
27 32
II 1
IC110556
IC1107010101
IC1111108
  If the system had exceeded both the lead
and copper action  level,  it  would be
required to sample for both contaminants
in source water. Failure to conduct source
water sampling in this case would not be
treated as two violations but as a single
violation.
Note:  Unlike tap monitoring for lead,
copper or WQPs, a system on source
water reduced  monitoring  is  never
required   to return  to  its  original
monitoring schedule, regardless of whether
it properly monitors and reports or meets
State-specified or approved MPLs.
EXAMPLE 4 —
  Another ground water system, on nine-
year monitoring, does not collect any
source water samples for the compliance
period, January 1, 2001 - December 31,
2009. The system is on  a three-year
schedule   for  lead  and  copper  tap
monitoring. During the compliance period,
January 1, 2009 - December 31, 2011, the
system exceeds the copper action level.
  If the system sampled during the first
year of the compliance period (i.e., 2009),
it would be in violation for failure to collect
copper source water samples. On the other
hand, if the system  completed its tap
monitoring during the second or third year
of the compliance period (i.e., 2010 or
2011), the system would be required to
 collect copper source water samples during
 the compliance period January 1, 2010 -
 December 31, 2018. Therefore, under this
 second scenario, the system would not have
 a source  water M/R violation for the
 compliance  period  January  1, 2001 -
 December 31,  2009.

 Treatment Technique
 Violations
  Treatment technique violations can be
 incurred  for   failure   to  meet  the
 requirements for OCCT, SOWT, Public
 Education,  and  LSLR.  A   total  of
 9 treatment technique  violations are
 possible as follows:
     OCCT Study/Recommendation
     OCCT Installation/Demonstration
     WPQ Entry Point Noncompliance
     WQP Tap Noncompliance
     SOWT Recommendation
     SOWT Installation
     MPL Noncompliance
     LSLR
     Public Education
  Definitions for each treatment technique
 violation and discussions of how to report
 the violation to FRDS are provided. In
 addition, examples of how to report each
 of these violations is provided at the end
 of this document, including sample DTF
 transactions.

 OCCT Study/
Recommendation
  All large systems must conduct corrosion
 control evaluations or studies, beginning
January 1,1993 (except those successfully
                                 — 37 —

-------
demonstrating that  optimal  corrosion
control exists), and at the completion of
the study (i.e., 6/30/94), make a recommen-
dation on the OCCT to be installed. At a
minimum,  medium and small systems
exceeding the lead or copper action levels
must make a recommendation,  regarding
the treatment to be installed, within six
months after the action level exceedance
(if they have not successfully demonstrated
that  optimal corrosion control already
exists). In addition, the State may require
medium  and small systems to conduct
corrosion control studies.
  An   OCCT  Study/Recommendation
violation must be reported for a system
that  fails to provide or  complete the
following:
  •  Submit an OCCT recommendation
     on time in accordance with Sections
     141.82(a) and 141.90(c)(2),
     or
  •  Submit an "acceptable'1 study on time
     in accordance with Sections 141.82(c)
     and  141.9
-------
  Assuming a medium or small system
 exceeds an action level during the first six-
 month  compliance period,  the FRDS
 reporting date for failure  to  make  a
 recommendation or conduct  a study on-
 time are:
   The DTP transactions for this record are:
Sy*t*m
Size
Large
Medium
Small
Recommendation
N/A
9/1/93*
9/1/94*
Study
9/1/94
9/1/95
9/1/96
  Assumes that the system was not required to conduct
  a study. For those systems that must conduct a study,
  the recommendation i& a required component of the
  study and would not be reported as a separate violation.
      EXAMPLES
EXAMPLE 1 —
  The State notifies a system (RIO 103644)
in a letter dated September 10,1993 that
it is required to conduct an OCCT study.
The system conducts the study in accord-
ance with Section 141.82(c) but does not
submit the  results within the required 18
months, by March 9,  1995 in this example.
The State receives the study from the PWS
on September 10, 1995. 6 months  later.
  By May 15, 1995, the State would  report
an OCCT Stady/Reoammenclation "Violation
for  the system as  follows:
C101
C1101
C1103

C1105
C1107

C1109

or
C1111

RI01 03644
9500001
5000

57
09/10/93

03/09/95


018

PWS-ID
Violation ID
Contaminant Code (De-
faulted by FRDS)
violation Type Code
Compliance period begin
date
Compliance period end
date
"-
Compliance period in
months
13 12 19
it II
D1RI01036449500001
D1RI01036449500001
D1RI010364 49500001
27 32
II 1
IC110557
IC1107091093
IC1111018
   In addition, the system's completion of
 the study currently is required to be
 reported as a milestone. (Refer to examples
 for the Corrosion Control Study milestone
 reporting on pages 7 and 8.)
 Note: A system that is required to
   conduct a study, but fails to complete
   the study or make an OCCT  recom-
   mendation, would not incur a separate
   OCCT recommendation violation because
   the  recommendation is a  required
   component of the study.

 EXAMPLE 2 —
   A medium-sized system submits the
 results of the study to the State within
 the required 18-month period or by June 9,
 1995 in this example. However the system
 evaluated the effectiveness of only one of
 the three  types of corrosion  control
 treatments required to be evaluated.
  The State should not at this time report
 a milestone for having received a study
 because the results were incomplete.
 Instead, as part of its August 15, 1995
 submission, the State would report a
 corrosion control study violation for the
 system  similar  to  the  one shown in
 Example 1. The State only should report
 the C800 milestone record once it receives
 a complete study.
 EXAMPLES —
  A medium system (WV0163644) exceeds
 the lead action level during the compliance
 period July 1 - December 31, 1992. The
 State  does not require  the  system to
 conduct a study and the system does not
 submit an OCCT recommendation to the
State by June 30, 1993 as required (i.e.,
                                  — 39

-------
within six months of exceeding an action
level).
  The system  would  incur  a violation
because it must recommend OCCT to the
State, even if it is not required to conduct
a study.
  By August 15, 1993, the State would
report:
  C101
  C1101
  C1103

  C1105
  C1107

  C11Q9

  or
  C1111
WV0163644
9300001
5000

57
01/01/93

06/30/93
006
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period
begir date
Compliance period end
date

Compliance period in
months
  The DTP transactions for this violation
are:
13 12 19
II II
D1WV01636449300001
D1WV01636449300001
D1WV0163 6449300001
27 32
il 1
IC110557
IC11070 10193
ICH09063093
OCCT Installation/
Demonstration

  Each system  requiring OCCT must
install treatment, have it operating, and
submit a certification to the State that this
treatment  is properly  installed  and
operating within 24 months. In addition,
any PWS  may  be  deemed  to have
optimized corrosion control by the State,
if the  system meets  the requirements
specified in Sections 141.81(b)(2) and (3).
  An OCCT Installation/Demonstration
violation must be reported for a system
that fails to complete the following on time:
  *  Have the State-designated treatment
     properly installed and operating in
     accordance with Section 141.82(e),
     AND
  •  Submit a  certification of proper
     installation  and   operation   in
     accordance with Section 141.90(c)(4),
     OR
  •  Demonstrate that  OCCT  already
     exists in accordance with Sections
     141.81(b)(l)-(3) and 141.90(c)(l).
  The State must report the following data
for each OCCT Installation/Demonstration
violation:
                                            C101
                                            C1101
                                            C1105
                                            C1107
                                                    P^^WP^^IJF™^^*
                                           PWS-ID
                                           Violation ID
                                           Violation Type Code = 58
                                           Compliance Period Begin Date for:
                                           • Large systems = 1/1/95
                                           • Medium and Small systems * data
                                             of State letter to system specifying
                                             OCCT to be installed.
                                   FRDS wffl default the following data
                                 elements:
                                   C1103

                                   C1109

                                   C1111
                               Contaminant code for lead and copper
                               violation = 5000
                               Compliance period end date =
                               24 months later than C1107
                               Compliance period in months =
                               24 months
                                    — 40 —

-------
  The earliest FRDS reporting dates for
 this violation are as follows:
                                  The DTF transactions for this violation
                                 are:
    Large
    Medium
    Small
        N/A
       9/1/96
       3/1/98
        3/1/97
        3/1/98
        3/1/59
  A system will become a SNC  for
incurring this violation if it has a 90th
percentile lead level of 30 ppb or above
in samples collected during the most
recent compliance period.  SNCs  are
discussed in greater detail in the last
section of this document.
      EXAMPLES
EXAMPLE 1 —
  A system (WA8976541) does not install
OCCT within the 24-month time frame,
in this example by June 29,1996. Instead,
the State receives a letter on November 19,
1996,  that  certifies  OCCT  has  been
installed. Further, the most recent 90th
percentile level was 18 ppb.
  By August 15, 1996, the State would
report an OCCT Installation violation as
follows:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109
 or
 C1111
WA8976541
9600003
5000

58
06/30/94

06/29/96
024
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period
begin data
Compliance period end
date (Defaulted by
FRDS)

Compliance period in
months (Defaulted by
FRDS)
13 12 19
II 1 1
D1WA89765419600003
D1WA897654 19600003
27 32
II 1
IC110558
ICH07063094 |
                                  The system's most recent 90th percentile
                                 lead level in tap samples was <30 ppb.
                                 Therefore, the system would not meet the
                                 definition of SNC.
                                  To  fulfill the  milestone  reporting
                                 requirement, the State would report the
                                 following by February 15, 1997:
C101
C801
C803


C805

WA8976541
0006
11/19/96


OTIN

PWS-ID
PWS-Milestone-ID
Date State received
proof of the installation
ofOCCT
Code for OCCT
installation
                                  The DTF transactions for this milestone
                                are:
13 12 19
II II
C4WA8976541 0006
C4WA89 76541 0006
27 32
11 1
IC803 111996
ZC80S OTIN
EXAMPLE 2 —
  A system installs OCCT within the 24-
month timeframe but does not report it
to the State.
  As part of the requirement for installing
OCCT, the system must certify to the State
that OCCT has been properly installed and
is operating. If however, the State learns
this information through an on-site visit
prior to the 24-month deadline, it should
not issue a violation to the system. While
on-site, the State should get the system
to certify the proper  installation  and
operation. Further, if the State learns of
the installation and operation through a
                                   — 41 —

-------
phone conversation with the system prior
to the 24-month deadline, the State may
elect not to issue a violation if the system
submits a certification within a short,
specified amount of time. Ultimately, the
State   must  obtain   some   official
correspondence  documenting   the
installation and operation of OCCT and
maintain it in its official files.
Note: Additional reporting examples for
  this violation are presented after the
  discussion of an OCCT Installation/
  Demonstration SNC on pages 66 and
  67.

Entry Point WQP
Noncompliance
  States will use data from  lead and
copper tap and WQP samples, both before
(i.e.,  initial  monitoring)   and   after
installation  of  OCCT  (i.e.,  follow-up
monitoring), to  set or approve values for
WQPs to reflect OCCT for the system.
During routine monitoring,  all systems
must maintain  WQPs at  or above
minimum values or within designated or
approved ranges. Medium or small systems
only are required to collect WQP samples
during each monitoring period in which
the lead or copper action level is exceeded.
  Follow-up or routine WQP monitoring
must occur  at entry  points to the
distribution system as well as at selected
taps. The compliance periods for each of
these varies significantly;  entry point
monitoring must always be conducted
biweekly, whereas tap  monitoring  is
conducted either semiannually or annually.
In order to allow clear identification of
WQP noncompliance in FRDS, entry point
and tap WQP noncompliance have been
defined  as separate violations.
  An entry point WQP violation must
 be reported for:
   •  Any system in which the WQP values
     of any  sample  are  below  the
     minimum value or outside the range
     established by the State in accordance
     with Section 141.82(g).
  To simplify reporting, any combination
 of exceedances during a quarter will be
 reported as a single violation for that
 quarter. The severity of the violation is
 not a factor in determining whether it is
 to be reported, nor is the severity to be
 reported. Therefore, the State would report
 a single violation for a system that fails
 to meet more than  one WQP  value for
 more than one biweekly sampling period
 in a quarter as it would for a system that
 does not meet the value for a single WQP
 during a single biweekly sampling period.
 In addition, unlike lead and copper tap
 samples that require  all  samples  be
 collected to determine if an exceedance of
 an action level has occurred, a violation
 for failure to meet entry point values can
 be incurred even if the system has not
 collected all the required  samples. For
 example, if a system collects entry point
 samples at three out of four entry points
 and  any of the WQPs fail to meet the
 State-designated or approved ranges, the
 system  would  incur an  entry  point
 noncompliance violation as well as an
 entry point M/R violation  for the same
 compliance period.
  During the State Lead and Copper Rule
 workshops, concern was raised that failure
 to meet one WQP during any biweekly
 sampling  event was  too  stringent  a
definition and did not account for unusual
events. A preferred definition was one  in
which a system would not incur a violation
unless it failed to meet the value or range
                                  — 42 —

-------
for a given WQP for a minimum of two
biweekly monitoring periods during the
quarter. The language in the rule is very
specific and states that a violation occurs
whenever  "any  sample is below  the
minimum value  or  outside the range
designated by the State." Therefore, the
violation definition remains as a single
noncompliance  event  constituting  a
violation.  Systems are allowed, under
Section 141.87(d), to take a confirmation
sample for any WQP within 3 days after
the first sample. The results must be
averaged with the first sampling result
and the average must be used to determine
whether the system is in compliance with
the State-designated value or range. The
State also has discretion to delete results
of obvious sampling  errors from this
calculation.
  Systems that collect entry point WQPs
at a greater  frequency than  biweekly
should report the average of the samples
collected over the two-week period for each
WQP.
  The State must report the following
data  for   each  Entry  Point  WQP
Noncompliance violation:
                               FRDS will default the following data
                               elements:
 C101
 C1101
 C1105
 C1107
PWS-ID
Violation ID
Violation Type Code a SB
Compliance Period Begin Date - the
first day of the quarter in which the
violation was determined.
                                 C1103

                                 C1109

                                 C1111
          Contaminant code for lead and copper
          violation = 5000
          Compliance period end date =
          3 months later than C1107
          Compliance period in months a
          3 months
                                 The earliest FRDS reporting dates for
                               this violation are as follows:
System
Size
Large
Medium
Small
Without Study
N/A
6/1/96
12/1/99
With Study
12/1/98
12/1/99
12/1/00
                                     EXAMPLES
EXAMPLE 1 —
  A system (VA9163644) onfy collects WQP
samples at three out of four entry points.
The analyses of the samples indicated that
the system did not meet the WQP ranges
for pH or alkalinity in two of the three
entry point samples.
  In this example,  the system would incur
a  violation  for  WQP  Entry  Point
Noncompliance because it did not meet
all WQP  values  or  ranges during all
biweekly sampling periods in a quarter.
Although  the system did not meet two
WQPs in two samples, the violations are
aggregated into a single violation for the
quarter.
                                  — 43 —

-------
  Assuming the  system  incurred the
violation during the quarter January 1,
1997 - March 31,  1997, the State would
report by May 15, 1997:
                                - January 14, 1997, the pH readings were
                                as follows:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109
  C1111
VA9163644
9700001
5000

59
01/01/97

03/31/97
003
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
  The DTP transactions for this violation
 are:
  13       12    19
  D1VA91636449700001
  D1VA91636449700001
                27   32
                II    I

                IC110559
                IC1107010197
Note: A system may take confirmation
  samples for any WQP sample within
  3 days of taking the original sample. The
  results will be averaged to determine
  compliance with State designated or
  approved WQP values or ranges.
  This system also failed to meet all its
WQP entry point sampling requirements
(i.e., monitored at three and not all four
entry points) and therefore would incur
a WQP entry point M/R violation for the
same quarter. (Refer to examples for entry
point WQP  M/R  violations  on pages
29-32.)
EXAMPLE 2 —
  A  large system (CA1111421)  collects
entry point samples on a daily basis. The
State has designated a range of 7.0-8.5
for the pH. During the period of January 1,
Day 1
Day 2
Day 3
Day 4
Days
Days
Day 7
7.8
7.4
7.2
7.0
7.S
7.3
7.7
Day 8
Day 9
Day 10
Day 11
Day 12
Day 13
Day 14
8.2
7.9
8.6
8.3
7.8
7.5
7.6
   The system would report the average
 over  the 14-day period or 7.7 in this
 example. The system is within the desig-
 nated range set by the State and would
 not  incur  a violation  for  entry  point
 noncompliance urJess it failed to meet
 State-designated values or ranges for the
 other WQPs.

 Tap WQP Noncompliance
   Tap sampling to determine compliance
 with State-designated or approved WQP
 values or ranges occurs every six months
 or annually if  a  system  qualifies for
 reduced monitoring.
   The  method  for determining  and
 reporting tap WQP Noncompliance is the
 same as that for entry point sampling,
 with the exception that a single violation
 will be reported on a semiannual or annual
 basis. As is true with entry point WQP
 Noncompliance, tap WQP Noncompliance
 can occur even  if the  system does not
 conduct all the required sampling. In such
 a case, a system can incur both tap WQP
 M/R   and  tap  WQP  Noncompliance
 violations. In the event that a WQP fails
 to meet State-specified ranges or values,
 the system  may collect a confirmation
 sample within 3 days. The average of the
two  samples would be used  for  the
compliance determination.

-------
  The State must report the following
data for each Tap WQP Noncompliance
violation:
  C101
  C1101
  C1105
  C1107
  C1109

  C1111
PWS-ID
Violation ID
Violation Type Code = 80
Compliance Period Begin Date a the
first day of the compliance in which the
violation was determined.
Compliance period end date = 6 or
12 months later than C1107
Compliance period in months = 6 or
12 months
FRDS will default the following data
element:
 Mumbef
  C1103
Contaminant code tor lead and copper
violation = 5000
The earliest FRDS reporting dates for this
violation are as follows:
Syttem
Size
Large
Medium
Small
Without Study
N/A
9/1/98
3/1/00
With Study
3/1/99
3/1/00
3/1/01
      EXAMPLES
EXAMPLE 1 —
  A system (TX9163633) collects some but
not all required WQP tap samples during
the compliance period and does not meet
all  the required  WQP  ranges in the
samples taken.
  The reporting of this violation is similar
to that of an entry point WQP noncompli-
ance except the compliance period for tap
WQP noncompliance is 6 months (or 12
months if the  system  is  on reduced
monitoring).
  Assuming the compliance period for this
violation is January 1 - June 30,1997, the
State would report by August 15, 1997:
C101
C1101
C1103

C1105
C1107

C1109

or
C1111

TX91 63633
9700002
5000

60
01/01/97

06/30/97


008

PWS-ID
Violation ID
Contaminant Code (De-
faulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
                                The DTP transactions for this violation
                               are:
II 3 12 19
II 1 1
D1TX91636339700002
D1TX91636339700002
D1TX91636339700002
27 32
II 1
ICH0560
ICH07010197
IC1109063097
                                In addition, the system would incur a
                              WQP  tap M/R violation  during  the
                              compliance period January 1 - June 30,
                              1997. (Refer to examples on routine tap
                              WQP M/R violations on pages 33 and 34.)
                              EXAMPLE 2 —
                                A system  (AZ3363633)  on reduced
                              monitoring fails to meet the range of one
                              of the WQP values during the compliance
                              period July 1, 2003 - June 30, 2004.
                                     45 —

-------
  By August 15, 2004, the State would
report:
  C101
  C1101
  C1103

  cnos
  C1107

  C1109

  or
  CM 11
AZ3363633
0400001
5000

60
07/01/03

06/30/04
012
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
  The DTK transactions for this violation
are:
13 12 19
II II
D1AZ33636330400001
D1AZ33636330400001
D1AZ33636330400001
27 32
II 1
IC110560
IC1107070103
XC1109063004
  In addition, because the system did not
meet the State-specified or approved WQP
range, the system would no longer qualify
to sample at a reduced frequency but
would be required to collect samples semi-
annualiy. The system would not have to
collect  the original number of samples
unless it exceeded the lead or  copper action
level.

SOWT Recommendation
  Any system exceeding the lead or copper
action level must complete source water
monitoring  and  make  a treatment
recommendation to the State within six
months after exceeding the action level
in accordance with Sections 141.83(a)(l)
and (b)(l), and 141.90(d)(l).
  A SOWT recommendation violation must
be reported for any system that fails to
submit a SOWT recommendation to the
State on-time.
  The State must report the following data
for each SOWT Recommendation violation:
'
Number
C101
C1101
C1105
C1107

-•-• rtw9 wrt* laeinent
: - Si *W> «.-. xxs •; , ' - " , ^
^>::'?
-------
   By February 15, 1993, the State would
 report:
  C101
  C1101
  C1103

  C110S
  C1107

  C1109
  C1111
AZ0063633
9300001
5000

61
07/01/92

12/31/92
006
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
  The DTF transactions for this violation
are:
13 12 19
11 I 1
D1AZ00636339300001
D1AZ00636339300001
27 32
II i
IC110561
IC1107070192
SOWT Installation
  If a State requires installation of SOWT,
the system must install the treatment
within  24  months  after the  State's
determination.
  A SOWT installation violation must be
reported, within 24 months of the State's
determination of the type of SOWT to be
installed, if a system fails to:
  • Properly install and operate SOWT
    in   accordance   with   Sections
    141.83(b)(3) and (5),
    AND
  * Submit certification to the State of
    proper SOWT installation and opera-
    tion, in accordance  with Section
    141.90(d)(2).
  Any system that has a 90th percentile
lead level of 30 ppb or greater in its most
recent tap samples will become a SNC
if it incurs a SOWT installation violation.
SNCs are discussed in more detail in the
last section of this document.
  The State must report the following data
for each SOWT Installation violation:
 C101
 C1101
 C1105
 C1107
PWS-ID
Violation ID
Violation Type Code = 62
Compliance Period Begin Date = the
date of the State's determination
                                FRDS will default the following data
                                elements:

.tfetfribw
C1103
C1109
C1111
tFOfte fk»f • £ ^
:. X " 1DM6fl|)tiQfl
Contaminant code for lead and
violation = 5000
Compliance period end date =
24 months later than C1 107
Compliance period in months =
24 months
copper
                                  The earliest FRDS reporting dates for
                                this violation are as follows:
Large
Medium
Small
9/1/95
3/1/96
3/1/97
                                     EXAMPLES
                               EXAMPLE 1 —
                                 A system (KS0003456) is required to
                               install SOWT by December 31,1995. The
                               system does not install the treatment. In
                               addition, its most recent 90th percentile
                               value for lead was 18 ppb.
                                   — 47 —

-------
  The system is in violation for failure to
install the treatment. By February 15,
1996, the State would report:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109
  C1111
KS0003456
9600001
5000

62
01/01/94

12/31/95
024
PWS-ID
Violation ID
Contaminant Code
{Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
  The DTF transactions for this violation
are:
13 12 19
II II
D1KS00034569600001
D1KS00034569600001
27 32
II 1
IC110562
IC1107010194
  Because its most  recent lead 90th
percentile value is <30 ppb, the system
would not become a SNC for this violation.
If the system continues to incur this
violation and has  collected more recent
lead tap samples  that result  in a 90th
percentile level of %30 ppb, the system
would become a SNC.
NOTE: The installation of SOWT is a
  milestone reporting requirement. The
  State must report the date it received
  proof of the installation of  SOWT,
  regardless of how untimely the system
  installs the treatment. (Refer to pages 9
  and 10 for examples on how to report
  this milestone.)
  Additional examples for this violation
are presented at the end of the discussion
of SOWT Installation SNCs on pages 67
and 68.
MPLs Noncompliance

   After SOWT is installed, the State will
evaluate data representing source water
quality before and after treatment is
installed. Based on these data, the State
will  designate  or approve maximum
permissible levels (MPLs) for lead and
copper for finished water entering the
distribution system.
   MPL Noncompliance must be reported
for a system that fails to meet either State-
designated or approved MPL in accordance
with Section 141.83(b)(5).
   A system can incur separate violations
for exceeding the lead MPL and copper
MPL. However, to simplify reporting, if
a  system exceeds the MPL for only lead
or copper in more than one source water
sample, the State would report a single
violation for that period. Therefore, if the
lead MPL is exceeded in one or more
source water samples, the State  would
report one lead MPL violation. On the
other hand, if the system exceeds the MPL
for copper, as well as for lead, the State
would report two violations.
  Compliance with MPLs is based on the
samples collected. Therefore, if a system
fails to collect source water samples at all
entry points to the distribution system and
exceeds one or both MPLs in the samples
collected, the system would incur a source
water M/R violation as well as a MPL
violation for each contaminant that  was
in exceedance of the MPL.
  A system could potentially incur three
source water  violations in the  same
compliance period:
  (1) Lead MPL violation,
  (2) Copper MPL violation,  and
  (3) Source water M/R violation.
                                   _48_

-------
   The State must report the following
 data for  each MPLs Noncompliance
 violation:
  C101
  C1101
  C1103
  C1105
  C1107
  C1109

  or
  C1111
PWS-ID
Violation ID
Contaminant code
 • Lead-   1030
 • Copper - 1022
Violation Type Code • 03
Compliance Period Begin Date 3 the
first date of the 1, 3, 9-year monitoring
period
Compliance period end date - 1, 3, or
9 years later than C1107

Compliance period in months = 12, 36,
or 108 months
  MPL Noncompliance may be reported
to FRDS as early as:
System
StZ9
Large
Medium
Small
Surface Mfefw
3/1/90
9/1/98
9/1/99
Groundwtter
3/1/99
3/1/99
3/1/99
      EXAMPLES
EXAMPLE 1 —
  A system (NV0163600) collects source
water samples at all entry points to the
distribution system. In one source water
sample, it fails to meet the MPL for lead
and in two source water samples it does
not meet the MPL for copper.
  Separate violations are reported for each
contaminant but violations of the same
contaminant are aggregated into a single
violation.  In this example, a lead MPL
violation would be reported as well as a
separate copper MPL violation. However,
only one violation would be reported for
copper although the system did not meet
the MPL for this contaminant in two
samples.
  Assuming the compliance period for this
violation was January 1 - December 31,
1997, the State would report by February
15,  1998:
  For noncompliance with the lead MPL:
C101
C1101
C1103

C1105
C1107

C1109

or
C1111

NV01 63600
9600001
1030

63
01/01/97

12/31/97


012

PWS-ID
Violation ID
Contaminant Code for
lead
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months
                                          The DTF transactions for this violation
                                        are:
13 12 19
II II
D1HV01636009800001
D1HV01636009800001
D1KV01636009800001
D1NV01636009800001
27 32
II 1
IC11031030
ICH0563
ICH07010197
IC1111012
                                          For noncompliance with the copper MPL:
C101
C1101
C1103

C1105
C1107

C1109

or
C1111

NV01 63600
9600002
1022

63
01/01/97

12/31/97


012

PWS-ID
Violation ID
Contaminant Code for
copper
Violation Type Code
Compliance period begin
date
Compliance period end
date

Compliance period in
months

-------
   The DTF transactions for this violation
 are:
13 12 19
1 I II
D1NV0163 6009800002
D1HV01636009B00002
D1NV01636009800002
D1MV01636009800002
27 32
II 1
IC11031022
IC110563
IC1107010197
IC1111012
 Note: Once a system is on reduced
  monitoring for source water, it does not
  go off reduced monitoring regardless of
  whether  it incurs an  M/R  or MPL
  noncompliance violation.

 EXAMPLE 2 —
  A system on annual monitoring does not
 collect all the required samples during
 January 1 - December 31,1997. In those
 samples it  does  collect, it  exceeds  the
 copper MPL.
  A MPL violation can be incurred if the
 system exceeds either MPL in any sample
 collected.  Therefore,  the State  would
 report a  MPL violation for copper, as
 shown in Example  1,  even though the
 system failed to collect all the  required
 samples.  In addition, the system would
 incur a source water M/R violation for the
 January 1 - December 31, 1997 timeframe.
 (Refer to examples for Source Water MIR
 violations on pages 35-37.)

Lead Service Line
Replacement (LSLR)
  Systems that fail to meet the lead action
 level after installing OCCT and/or SOWT
 must replace lead service lines (LSLs) at
 the  rate of 7% annually.  In addition,
 systems   must  replace  LSLs at  an
 accelerated rate (i.e., > 7% per year) where
the State finds this feasible. A system may
count any LSL, with  lead concentrations
 of <0.015 mg/1 in all samples, as  being
replaced.
  Under Section 141.90(e)(l), the PWS
must provide the following information
to the State within 12 months after the
 exceedance of the lead action level for the
 first year of LSL replacement only:
   • Certification of a materials evaluation
     to identify LSLs
   • A LSLR  schedule  for  replacing
     annually at least 7% of the initial
     number of LSLs
   In addition, in accordance with Section
 141.90(e)(2), the system must report in
 writing to the State within 12 months after
 the exceedance of the lead action level and
 annually thereafter that:
   • 7% of the LSLs have been replaced
     (or greater if required by the State),
     and/or
   • sampling  demonstrates   a  lead
     concentration < 0.015 mg/1 exists in
     all LSL samples for an individual line
     not replaced.
   Further, the  system must submit an
 annual letter to the State, in accordance
 with Section 141.90(eX3) that contains the
 following:
   •  The number  of LSLs that were
     scheduled to be replaced for the year,
   •  The location of each LSL  that was
     replaced that year, and
   •  If measured, water lead concentration
     and the location of each LSL sampled,
     sampling method, and the sampling
     date.
  Lastly, if a system wishes to refute
partial or full ownership of a LSL, it must
submit a letter identifying that the system
has  limited control  over LSLs to be
replaced, within three months of the
exceedance  (Sections  141.84(e)  and
141.90(e)(4).
  A LSLR violation must be reported for
each system that fails to  complete the
following activities, for each compliance
period in which  the violation occurs:
  • Replace the required number of LSLs
    by the annual deadline, in accordance
    with Sections 141.84(a)  and (b),
    and/or
                                  — 50 —

-------
   •  Demonstrate   the  LSL(s)   lead
     concentration is <0.015 mg/1 in all
     lead samples, in  accordance  with
     Section 141.84(c), and
   •  Report the required LSL information
     on-time, in accordance with Section
     141.90(e).
  The State must report the following
data for each LSLR violation:
  fftwlMr
  C101
  C1101
  C1105
  C1107
PWS-ID
Violation ID
Violation Type Code = «4
Compliance Period Begin Date = first
day alter Pb action level is exceeded
in samples taken alter OCCT and/or
SOWT has been installed (whichever
is later)
FRDS will default the following data
elements:
  C1103

  C1109

  C1111
Contaminant code for lead and copper
violation = 5000
Compliance period end date * 1 year
iater than C1107
Compliance period in months =
12 months
  The  FRDS  reporting  dates  for this
violation are as follows:
System
Size
Large
Medium
Small
Without Study
N/A
3/1/96
9/1/99
With Study
9/1/96
9/1/99
9/1/00
                                      EXAMPLES
EXAMPLE 1 —
  A system (CA0223600) exceeds the lead
action level on  June  30,  1997  after
installing OCCT.   The system is  now
required to begin LSLR, starting June 30,
1997. By June 30, 1998, the system has
not submitted any of the required LSLR
information to the State.  On July 1, 1998,
the State contacts the system to determine
the LSLR status and finds out that the
system only has replaced 5% of its LSLs.
  The system is in violation because it
failed  to  replace  or  show  that LSLs
contributed  <15 ppb in at least 7% of its
LSLs and because it did not submit any
of the required information to the State.
Note: A system that must begin LSLR is
  a milestone reporting  requirement.
  (Refer to pages 12 and 13 for examples
  on how to  report this milestone.)
  The State  would report a single LSLR
violation by  August 15, 1998:
 C101
 en 01
 C1103

 C11O5
 C1107

 C1109
                                          C1111
CA0223600
9800001
5000

64
06/30/97

06/30/98
                                       012
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
                                   — 51 —

-------
  The DTP transactions for this violation
are:
113 12 19
11 II
D1CA02236009800001
D1CA02236009800001
27 32
II 1
IC110564
IC1107063097
EXAMPLE 2 —
  A system claims to have replaced 7%
of its LSLs but has only replaced limited
portions of the lines. The system never
submitted a letter to the State, refuting
control of the entire line.
  In ti.is example, the  system is in
violation because it has failed to replace
7% of its LSLs. The system is required to
replace the entire LSL, unless it submits
proof of its limited control of a LSL to the
State within  three months of exceeding
the lead action level and the State is in
agreement that the system has limited
control.
EXAMPLES —
  A system  replaces 7%  of its LSLs,
however, the State had  required the
system to replace 10% of its lines.
  Similar to noncompliance with State-
designated or approved WQP ranges or
MPLs,  noncompliance with  the LSLR
schedule set  by the State is a Federal
violation and  must be reported to FRDS.

EXAMPLE 4 —
  A system does not replace any LSLs
during July  1, 1998 -  June 30, 1999.
During that same time period, the system
does not exceed the lead action level for
the  second    consecutive  six-month
compliance period.
  A system may  discontinue replacing
LSLs whenever it no longer exceeds the
lead  action level  for two consecutive
monitoring periods. In this example, the
system would not be in violation of the
LSLR requirements. A system should be
 aware that by not replacing any lines prior
 to knowing the 90th percentile values for
 lead, it is taking a chance that it will be
 able to replace enough LSLs in time to
 prevent incurring a LSLR violation.

 EXAMPLES —
  A system replaces 5% of its lines and
 reports to the State the results of LSL
 monitoring indicating that 2% of its lines
 contribute <15 ppb lead.
  The PWSs may count  LSLs  that
 contribute <15 ppb toward its  annual
 replacement rate. In this example, this
 system would be considered to have met
 its annual 7 percent requirement and is
 in compliance.
 EXAMPLES —
  A system is required to replace 7% of
 its LSLs. The first year it replaces 15%
 of its lines and the second year it replaces
 none.
  A system may find it easier to replace
 all the LSLs in a given area and may
 result in the systems replacing > 7% of
 its lines. The State should inform the
 system up-front that it can replace >7%
 of its LSLs but it will be the responsibility
 of the system and not the State to keep
 track of the extra lines replaced, and that
 the State expects the system to report that
 at least 7% of the LSLs have been replaced
 each year.

Public Education
Requirements

  A system that exceeds the lead action
 level must conduct  a  public education
 program  and must demonstrate to the
 State it has properly delivered the public
 education materials. Public  education
 program elements differ for CWSs and
 NTNCWSs.
                                  — 52 —

-------
  A public education requirements viola-
tion must be reported for & system that
fails to meet any of the requirements as
follows:
  •  At a minimum, include the mandatory
     language in all written materials, as
     specified in Section 141.85(a), or
  •  Include the mandatory information
     in all public service announcements,
     in accordance with Section 141.85(b),
     or
  •  Deliver all public education materials:
     -  in all appropriate languages,
     -  at the required frequencies,
     -  as defined by Section 141.85(c),
     or
  •  Provide a letter to the State by the
     end of the calendar year that demon-
     strates that the system  properly
    delivered the public education materi-
    als,  as specified in the reporting
    requirement, under Section 141.90(0.
  A system must complete initial public
education requirements  within 60 days
of exceeding the lead action level. In
addition to the 60-day requirement, a CWS
has semiannual and annual requirements;
a NTNCWS has annual requirements.
CWSs  and NTNCWSs must continue to
deliver public education for as long as the
system exceeds the lead action level. A
CWS could conceivably be in violation for
the  60-day, semiannual,  and  annual
requirements. However, typically a  State
will not  learn about a public education
violation until the end of each calendar
year when a system is required to submit
a letter  which demonstrates that the
system properly delivered  the public
education materials.
  The  State would  determine from the
system's annual letter (or lack of one)
whether  the system met  its public
 education  requirements. If the system
 failed to meet any portion of its 60-day,
 semiannual  (if applicable)  or  annual
 requirements, the State would report a
 single public education violation for that
 calendar year (i.e., by February 15 of the
 next year). The State should not report
 separate 60-day, semiannual, and annual
 violations.
  The State  is not required to report a
 public education violation for any system
 that has achieved compliance by the end
 of  the  calendar  year.  EPA  is  more
 concerned  with those public education
 violations that have not been resolved and
 believes that requiring the State to report
 both a violation and compliance achieved
 in the same  quarter is an unnecessary
 reporting burden.
 Note: EPA is drafting an amendment to
  the rule, proposing that when a water
  system delivers its  public education
  materials,   it  notify  the   State
  immediately by sending copies of the
  materials to the State. This change in
  system   reporting  requirements,  if
  adopted, will facilitate a State's knowing
  whether  a  system has fulfilled all its
  public education requirements.
  EPA encourages States to determine,
prior to the  end of the calendar year,
whether systems with 90th percentile lead
level of 30 ppb or above are properly
conducting public education. Systems with
90th percentile lead levels of *30 ppb will
become SNCs if they have not delivered
all the required program elements  and
submitted the annual letter to the State
by December 31. If the State identifies the
violation early enough, it can inform the
system of the steps needed to achieve
compliance  before the end of the calendar
year to avoid becoming a SNC.
                                   — 53 —

-------
  A system is considered to have achieved
compliance, if by the end of the calendar
year,  it delivers one round of public
education as follows:
  •  For CWSs, informing the following,
     using the mandatory language, in all
     appropriate languages:
     - consumers via notices
     • facilities/organizations in contact
      with  sensitive  populations via
      pamphlets and brochures
     - consumers via major newspapers,
      television,  and radio, or
  •  For NTNCWSs, informing consumers,
     using   the   mandatory  language
     through:
     - posting
     - distribution of brochures, and
  •  For both CWSs  and  NTNCWSs,
     submitting a letter that identifies the
     measures taken to meet their public
     education obligations.
  A more detailed discussion of SNCs is
contained in the last section  of the
document.
  The State must report the following
data for each Public Education violation:
                                FRDS will default the following data
                                element:
 C101
 C1101
 C1105
 C1107
C11O9

or
C1111
PWS-IO
Violation ID
Violation Type Code = 96
Compliance Period Begin Date = the
first day after the compliance period in
which the lead action level was
exceeded
Compliance period end date » the last
day of the calendar year (12/31/XX)
         Compliance period in months
         12 months
                     6 or
                                 C1103
          Contaminant code tor lead and copper
          violation = SOOO
                                 If a system exceeds the lead action level
                               during the first initial monitoring period
                               and the  State  does not learn of the
                               violation until the end of the calendar year,
                               the FRDS reporting dates for this violation
                               would be as follows:
Large
Medium
Small
3/1/94
3/1/94
3/1/95
                                     EXAMPLES
EXAMPLE 1 —
  A community water system (MN0212600)
collects tap samples during the compliance
period ending December 31, 1992. The
results of the samples indicate a 90th
percentile lead level of 20 ppb. The system
is required to complete its initial public
education requirements by March 1,1993
(i.e., within 60  days) and to submit an
annual letter by December 31, 1993 that
demonstrates measures taken to comply
with the public  education requirements.
The system submits a letter to the State
by  December 31, 1993, but  the  letter
indicates  that  the  system  only has
delivered public education to its customers
and has not submitted the public education
information to major newspapers, facilities
and organizations,  and  to radio and
television  stations  that  serve  the
community.
                                   — 54 —

-------
  The CWS is in violation of the public
 education requirements  for  failure to
 deliver the public education requirements
 in accordance with Section 141.85 (c).
  By February 15, 1994, the State would
 report:
C101
C1101
C1103

C1105
C1107

CM 09

or
C1111

MN02 12600
94G0001
5000

65
01/01/93

12/31/93


012

PWS-ID
Violation 10
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period
begin date
Compliance period end
date

Compliance period in
months
  The DTF transactions for this violation
are:
13 12 19
It II
D1MH021260094G0001
D1KN021260094G0001
D1MN021260094G0001
27 32
II 1
ICU0565
IC1107010193
IC1109123193
  Because the 90th percentile level is
<30 ppb, the system will not become a
SNC  for  incurring this violation.  To
achieve compliance for this violation, the
system must deliver public education to
all the appropriate entities and submit a
letter that demonstrates that fact.
EXAMPLE 2 —
  A system exceeds the copper action level
during the compliance period ending
December 31, 1992 and does not conduct
any public education.
  The system is not in violation of  the
public education requirements because
these requirements only are triggered by
an exceedance of the lead action level,  not
of the copper action level.
 EXAMPLES —
  A system exceeds the lead action level
 during the compliance period January 1 —
 June 30,  1993.   During the second
 compliance period,  July 1,  1993  —
 December 31, 1993, it no longer exceeds
 the lead action level. The system does not
 conduct any public education during the
 entire calendar year.
  Although a system may cease delivering
 public education materials whenever it
 meets the lead action level, the system is
 in violation for failure to deliver its public
 education requirements for the first period.
 To correct the violation,  the system must
 still conduct one round of public education,
 in accordance with Sections 141.85(a)-(c)
 and submit a letter to the  State that
 outlines what the system has done to meet
 its public education requirements. The
 system  will not be required to conduct
 additional public education, unless its 90th
 percentile Pb level exceeds the action level.
 EXAMPLE 4 —
  A small system conducts all the required
 public education requirements with the
 exception that it only has one radio and
 television station that serve the community
 and therefore  does not  submit a public
 service announcement to five radio and
 television stations as required by the rule.
  The State can use its discretion  in
 determining whether smaller systems have
 met their public education requirements.
 For systems serving small communities,
 these systems may not have five radio or
television  stations   that  serve   the
community. If the system has submitted
the required public service message to all
those stations serving the community, the
system should not receive a violation.
Similarly, a system may  not have all the
                                   — 55 —

-------
facilities or organizations listed in Section
141.86(c)(2)(iti). If in the State's opinion
the  system  has  sent  brochures  and
pamphlets to all those organizations that
serve  high  risk  populations  in  the
community, the system would not be in
violation, (Refer to EPA guidance on public
education for suggestions on delivery.)

Public Notification
Requirements
  A PWS that incurs any lead and copper
rule violation must  meet  the public
notification requirements contained in
Section 141.32.
  A public notification violation must be
issued to a PWS that fails to meet the
requirements of Section 141.32.
  The  State  must report the following
data for each violation:

Number
C101
C1101
C1103


C1105
C1107
C1109
or
C1111
mt ittB irttaej&^ ' "
' ?~J^ *\7^ S^iA w, ^^^.oS^>S^'^"'-'>- '•N
••" -^^Pi^ii^i^: ' ;
PWS-ID
Violation ID
Contamination code for lead and
copper violation = 5000 (will not be
defaulted by FRDS)
Violation Type Code * 06
Compliance Period Begin date
Compliance Period End date

Compliance period in months
Consecutive Systems
  A  consecutive system is  one which
purchases water from another public water
system. The nature of consecutive systems
varies greatly and can involve a single
consecutive system that delivers the water
without further treatment or a more
 complex arrangement involving several
 systems, some of which may further treat
 the water before delivering it to their
 customers.
   Several States and public water systems
 have proposed consolidation of lead and
 copper tap sampling, and water quality
 parameter sampling, in consecutive water
 systems. EPA's position on the consolida-
 tion of sampling requirements under the
 Lead and Copper Rule was stated  in a
 January 10,1992 memorandum, entitled
 Consecutive Systems Regulated under the
 National Primary Drinking Water Regula-
 tions for Lead and Copper. Highlights and
 excerpts from this  memorandum  are
 presented below.
  After a review of many proposals that
 were submitted by several  States  and
 water systems, EPA believes it is reason-
 able to reduce monitoring in consecutive
 systems if the systems can demonstrate
 they are interconnected in a manner that
justifies treating them as a single system,
 in accordance with Section 141.29.
  Prior to allowing consecutive systems
 to consolidate  their sampling, the State
 must submit to its EPA Regional office,
 a written explanation of how the monitor-
 ing, treatment, and reporting requirements
 will be administered and enforced in
 consecutive systems that consolidate their
 operations for lead and copper. These
 proposals should clearly identify which
 systems  will be held accountable  for
violations of any of the rule's requirements.
 Should enforcement actions ever become
 necessary,  it  is vital that  the party
responsible for monitoring, or, if needed,
subsequent treatment (including public
education and lead service line replace-
ment) be clearly identified and accept
responsibility for any rule violations.
                                  — 56 —

-------
  The  key  elements  that  should be
contained in the proposal are:
 1. Rationale for reduced monitoring
 2. Explanations of the responsibilities
    among systems involved including
    which water  system(s)  is  (are)
    responsible for:
    - collecting and reporting to the State
      the results of the lead and copper
      tap monitoring and  all WQPs
      monitoring;
    - completing   corrosion   control
      requirements under Sections 141.81
      and 141.82; and
    - lead service line replacement
 Note: EPA expects that the parent
      supply will take responsibility for
      corrosion control throughout the
      entire area served. Depending on
      contractual agreements, the size
      and configuration of the satellite
      system(s), and the distance from
      the parent  treatment  facility,
      individual corrosion control treat-
      ment may need to be installed at
      a point or points other than the
      parent plant.
 3.  How the following provisions will be
    modified:
    - determination of 90th percentile
     lead and copper concentrations in
     the consolidated system
    - WQP  monitoring to determine
     baseline values and insure that
     OCCT is properly installed and
     maintained
 4.  If applicable, how the responsibility
    for public  education, source water
    monitoring, and SOWT will differ
    from the responsibilities as assigned
    in the preamble.
 Note: In the preamble to the final rule,
    EPA has stated that responsibility
   for public education delivery resides with
   the retailer (i.e., the consecutive or
   "satellite" system) and responsibility for
   source water monitoring and treatment
   resides with the wholesaler (or "parent"
   system.
   Once  the State has approved  this
 proposal, it should use this document to
 identify the system(s) for which it should
 report a particular milestone or violation.

 SIGNIFICANT
 NONCOMPLIERS

   The development of a SNC definition
 under this rule was quite challenging due
 to the many unique aspects of the rule
 which include:
   •  A treatment technique in lieu of an
     MCL  (only  the  Surface  Water
     Treatment Rule is  similar  in this
     respect)
   •  The requirements  of the rule are
     dependent on the 90th percentile lead
     and copper levels in tap water and,
     in part, on a system's size
   •  Many deadlines for actions taken by
     the system are based on  the date a
     State makes a determination
   •  Several requirements are one-time
     occurrences
   •  Several requirements will not be in
     effect for several years.
  A SNC definition was finalized after EPA
received input from States and its EPA
Regional offices via workshops, national
meetings, and a telephone conference. The
premise for the SNC definition is the same
as all the SNC definition for all other
rules; the designation of SNC is reserved
for those systems that are considered to
pose the  most serious threats to public
health. EPA and States agreed that four

-------
of the violations (1 M/R and 3 treatment
technique violations) could be incurred
within the next few years and would
present the most significant threat. These
four violations are:
  • Lead and Copper Initial Tap M/R
  • OCCT Installation/Demonstration
  • SOWT Installation
  • Public Education
  In  addition,  EPA  discussed  the
development of SNC definitions for WQP
Noncompliance, MPL Noncompliance, and
LSLR violations. Because none of these
violations will occur for several years, EPA
decided to defer developing a SNC
                 definition for these violations for another
                 two to three years until it has  more
                 experience with the implementation of the
                 Lead and Copper Rule.
                  The remainder of this section provides
                 the rationale behind the selection of the
                 four violations for the current lead and
                 copper SNC definition, a detailed SNC
                 definition for each of these violations, and
                 definitions for achieving compliance for
                 each  violation.  In addition, Exhibit  6
                 summarizes the SNC definition under the
                 Lead and Copper Rule. Further, examples
                 of how a system would become a SNC for
                 each of these violations are presented at
                 the end of this document.
                               Exhibit 7
   SNC Definition Under the Lead and Copper Rule
       SNC Type
System* Affected
 Monitoring/Reporting
 Initial Pb/Cu Tap M/R
All System Sizes
 Treatment Technique

 OCCT Installation
 SOWT Installation
 Public Education
Only systems with
90th percentile Pb
levels of * 30 ppb
Only systems with
90th percentile Pb
levels of £ 30 ppb
Only systems with
90th percentile Pb
levels of 2 30 ppb
System that does not correct a
violation within:
• 3 months for large systems
• 6 months for medium systems
• 12 months for small systems
System with this violation & 90th
percentile Pb level of 2 30 ppb in
most recent monitoring period
System with this violation & 90th
percentile Pb level of * 30 ppb in
most recent monitoring period
System with this violation & 90th
percentile Pb level of 2 30 ppb in
most recent monitoring period
                                 — 58 —

-------
Monitoring and
Reporting SNC

Lead and Copper Initial
Tap MIR SNC
  A violation  of the requirements for
initial lead and copper tap sampling was
determined to be a significant violation
because the results from this sampling
event serve as the cornerstone to the rule.
For medium and small systems, OCCT
requirements only are  triggered by an
exceedance of the lead or copper action
level. Although OCCT requirements apply
to large systems regardless of their 90th
percentile lead and copper values, failure
to collect lead and copper  tap water
samples prevents a PWS from meeting the
first milestone in the OCCT schedule and
will inevitably make more difficult the task
of completing each successive milestone
on time. EPA believes this increases the
likelihood that a PWS will incur a series
of OCCT-related violations for that system.
Finally, initial monitoring results are
critical  for  all systems  because  they
determine whether a system is required
to conduct source water sampling and
public education.
  The SNC definition for an initial lead
and copper M/R violation is dependent on
the length of time a PWS remains "out of
compliance". EPA wants to focus attention
on those systems that present the most
significant health threats and not to make
all systems that do not complete initial
monitoring on time to immediately become
a SNC. This approach is taken to separate
those systems needing additional time to
complete monitoring from those that have
serious  problems  in their monitoring
program.
  EPA also considered other SNC defini-
tions  for  this violation  including a
definition where a system would become
a SNC if it failed to meet the requirements
for two consecutive periods. The problem
with this definition is that it would exclude
some medium and small systems because
these smaller systems are not required
to complete a second round of sampling
if they exceed the lead or copper action
level in the first six-month monitoring
period. EPA also considered the use of a
major or minor distinction but rejected this
based  on Regional  feedback  that this
method would  be  too cumbersome  to
determine and track.
  An initial lead and copper MIR SNC
is defined as failure to correct a violation
within:
  •  3  months for large systems
  •  6 months for medium systems
  •  12 months for small systems.
  A  tighter schedule is  established for
large systems for several reasons. First,
large systems have established deadlines
for each step of OCCT. If the system does
not complete both rounds of initial moni-
toring  shortly after January 1, 1993,  it
may be unable to meet the OCCT study
deadline of July 1,1994 and, in addition,
fail to  meet the deadlines of the subse-
quent OCCT requirements. Second, large
systems are the first group of systems
required  to conduct initial monitoring.
Through this staggered implementation
of the rule, EPA hopes that medium and
small systems can build on the knowledge
gained by large systems and, ultimately
that smaller systems may have  to expend
fewer resources to implement the rule.
Therefore, larger systems' meeting their
OCCT deadlines are of importance not only
to those systems but to medium  and small
systems as well.
  A system will incur a violation but will
not become a SNC if it returns to compli-
ance within the 3-, 6- or 12-month time
                                 — 59 —

-------
frame. A system is considered to have
returned to compliance (ETC) for an Initial
Lead and Copper Tap M/R violation if:
  *  The required number of samples have
     been properly collected and analyzed
     in   accordance   with   Sections
     141.86(a)-(c) and 141.89
                AND
  •  All required monitoring information
     has been reported in accordance with
     Section  141.90(a) as follows:
     - Lead and copper results including
      the location of each site and  the
      criteria for its selection
     - Certification  of  proper  sample
      collection
     - 90% lead and copper levels, and if
      applicable,
      --   certification regarding customer-
          collected samples
      —  justification   of  non-Tier 1
          sampling sites (Note: This infor-
          mation is submitted prior to the
          start of initial monitoring, but
          a violation for failure to submit
          this information would not be
         incurred until the end of the six-
         month compliance period.)
      ~ justification of sampling < 50%
         of  lead  service   line  sites
         (Note: this   information   is
         submitted prior to the start of
         initial  monitoring,   but  a
         violation for failure to submit
         this information would not be
         incurred until the end of the six-
         month compliance period.)
      - identification of sites not previ-
         ously sampled and reason for
         change.
  If a system meets the above criteria for
having  RTC, the States  or EPA must
indicate Compliance Achieved in the
follow-up action record and successfully
link this action to the violation. FRDS will
compute SNCs based on the date posted
for the  violation  and for Compliance
Achieved in the follow-up action record
(i.e., C1200).
  The following dates must appear in the
Compliance Achieved record AND be
linked to  the violation or  FRDS will
identify the system as a SNC:
* Optional. If the system is triggered into OCCT requirements during the first sampling period, a second
  round of monitoring is not required.

-------
  At the State implementation workshops,
 EPA Headquarters presented the concept
 of reporting in real-time for large systems
 for this violation only. (Note: For ah other
 FRDS  reporting, a one-quarter (i.e.,
 3 months) lag exists between the time the
 event is generally known to the State and
 the time the State reports it to FRDS. For
 large systems, the posting of the ETC
 follow-up  action record must occur in the
 same quarter in which the system has
 achieved compliance. This is referred to
 as real-time reporting.)
  EPA believes that real-time reporting
 is important for large systems in order to
 quickly identify which systems are having
 difficulty implementing the rule. Further,
 EPA believes this reporting burden to be
 minimal because of the relatively low
 number of large systems serving greater
 than 50,000 people and the even lower
 number of large systems that are expected
 to be in violation of the initial lead and
 copper tap M/R requirements. Real-time
 reporting requires States and/or Regions
 to determine at the end of a quarter, which
 of these  systems  have  returned  to
 compliance. Therefore, a  Compliance
Achieved record must be reported to
 FRDS before that quarter's SNCs are
 determined or the system will be identified
 as a SNC.
      EXAMPLES
EXAMPLE 1 —
  A large system (TX1230567) does not
complete the first round of initial
 monitoring by June 30, 1992 but instead
 completes the monitoring and submits all
 required reporting information to the State
 on August 29,1992 (i.e., within 3 months
 of incurring the violation).
   By August 15, the State will report an
 Initial Lead and Copper Tap M/R violation
 as follows:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109
  C1111
TX1230567
9200001
5000

51
01/01/92

06/30/92
006
PWS-ID
violation ID
Contaminant Code
(Defaulted by FRDS}
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
  The DTF transactions for this violation
are:
13 12 19
t 1 II
D1TX12JOS679200001
D1TX12305679200001
27 32
II !
IC110531
IC1107010192
  In addition, because this violation may
lead to a system's becoming a SNC, the
State must report that the system has
achieved compliance to prevent the system
from becoming a SNC. Further, in this
example the State is required to report
this follow-up action (i.e., compliance
achieved)  in  real time. As mentioned
previously, real-time reporting is required
only for large systems incurring an initial
Lead and Copper Tap M/R violation.
                                  — 61 —

-------
  Therefore, by September 30,1992, the
State or Region must indicate in FRDS,
that the system has achieved compliance
and link it to the violation as follows:
  C101
  C1201
  C1203

  C1205
  C1215

  Y5000
TX1230567
9200001
08/29/92

SOX
9200001
PWS-ID
Enforcement ID
Date system achieved
compliance
Follow-up enforcement
action code, SOX =
Compliance Achieved
Comment Field, optional
reporting
Y5000 serves as a
mechanism tor linking
the follow-up action to
the violation
  The DTP transactions for this record are:
11 12 19
It II
E1TX 1230567 9200001
E1TX12305679200001
E1TX12305679200001
27 32
tl 1
IC1203082992
XC1205SOI
1*50009200001
  There are several alternative methods
to link the follow-up action to the violation,
only one of which can be used at a time.
The Y5000 (Associated Violation IDs) is
displayed in the example. If the primacy
agency does not supply its own record IDs
(i.e., uses group generation codes) for the
violation   ID,   one  of  the  following
alternatives must be used:
  The first alternative would be the Z5000
method (Associated Violation Contaminant
Groups). The 25000 transaction would be
13 12 1»
II II
E1TX12305S79200001
211X12305(79200001
E1TX1230S679200001
27 32
II 1
IC12030B2992
IC1205SOX
IZS00051S000010192
providing  the  substantive  violation
information  of violation type  51, and
compliance period begin date of 01/01/92.
FRDS would then link the enforcement
to this specific violation.
                                    The  second alternative would be the
                                  X5000 (Associated Violation Range). The
                                  X5000 transaction would be:
13 12 19
II 1 !
E1TX12305C79200001
E1TX12305679200001
E1TX12305S79200001
27 32
III
IC1203082992
IC1205SOX i
1X500010192010292 |
providing the date  range  01/01/92 to
01/02/92. However, any other violation for
this PWS which has a compliance period
begin or  end date  within the  dates
provided  (01/01/92  - 01/02/92  in this
confusing example) would be linked to this
enforcement. Therefore, care must be used
with this  option. For  more  detailed
information on these enforcement-violation
linking methods, please consult the FRDS
Data Entry Instructions.

EXAMPLE 2 —
  A medium system (OK0230567) does not
complete   its  initial  monitoring  by
December 31,1992. Instead it completes
monitoring and  submits all required
information by April 15,1993 (i.e., within
6 months).
  The State would report an initial lead
and copper tap M/R violation by February
15, 1993 as follows:
                                   C101
                                   C1101
                                   C1103

                                   C1105
                                   C1107

                                   C1109
                                   C1111
                               OK0230567
                               93G0001
                               5000

                               51
                               07/01/92

                               12/31/92
                               006
                   PWS-ID
                   Violation ID
                   Contaminant Code
                   (Defaulted by FRDS)
                   Violation Type Code
                   Compliance period begin
                   date
                   Compliance period end
                   date (Defaulted by
                   FRDS)
                   Compliance period in
                   months (Defaulted by
                   FRDS)
                                    — 62 —

-------
   The DTF transactions fen- this record are:
113 12 19
1 1 1 1
D10K023056793G0001
D10K023056793G0001
27 32
II 1
IC110551
IC1107070192
   In  addition,  because  this  system
 achieved compliance within six months
 of incurring the violation, the State would
 report compliance achieved for this system
 to prevent the system from becoming a
 SNC. Real time reporting is not required
 for medium and small systems.
   Therefore, by August 15,1993, the State
 would report:
  C101
  C1201
  C1203

  C1205
  C1215

  Z5000
OK0230667
93G0001
04/15/93

SOX
515000070192
PWS-tO
Enforcement ID
Date system achieved
compliance
Follow-up enforcement
action code, SOX -
Compflance Achieved
Comment BeW, optional
reporting
Fo*ow-up action to
violation ink
The DTF transactions for this record are:
13 ia 19
II 11
E1OK02305«793G0001
E1OK02305S793G0001
B1OH02305S793G0001
27 33
II 1
IC1203041593
IC1205SOI
II S0005XS000070192
EXAMPLES —
  A large system (PR2230567) does not
complete  its first  six-month  period of
initial monitoring by June 30, 1992 but
completes the monitoring and reports all
required  information by November 19,
1992.
  As was the case in Example 1, the State
would report a violation for the system by
August 15,1992. However, the system did
not return to compliance within 3 months
                                    and therefore would meet the definition
                                    of SNC for this violation. On October 1,
                                    1992, FRDS would determine that the
                                    system was a SNC. Because reporting of
                                    follow-up actions are required Federal
                                    reporting, the State still would report that
                                    the system  had achieved compliance
                                    although it would be reported too late to
                                    prevent the system from becoming a SNC.
                                      By August 15, 1992, the State would
                                    report a violation as follows:
C101
C1101
C1103

C1105
C1107

C1109
                                              C1111
PR2230567
92G0001
5000

51
01/01/92

06/30/92
                                            006
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
                                              The DTF transactions for reporting this
                                            violation are as follows:
II 3 12 19
II 1 1
D1PR223056792G0001
D1PR223056792G0001
27 32
11 1
IC110551
IC1107010192
                                     By February 15,1993, the State would
                                   report compliance achieved and link it to
                                   the violation as follows:
                                    ciot
                                    C1201
                                    C1203

                                    C1206
                                    C1215

                                    25000
                               PR2230567
                               9300001
                               11/1 W»

                               SOX
                              515000010192
                   PWS-IO
                   Enforcement ID
                   Date system achieved
                   compliance
                   Fotow-up enforcement
                   code, SOX - compliance
                   achieved
                   Comment Field, optional
                   reporting
                   Follow-up action to
                   violation link
                                     — 63

-------
  The DTF transactions for reporting a
follow-up action or compliance achieved
in this example are as follows:
13 13 19
11 II
E1PW230S6793G0001
E1W1223054793G0001
E1PR22305S7 9 3G0001
27 12
U 1
IC1203111992
IC120SSOX
IZ5000S1S000010192
EXAMPLE 4 —
  A large system (NJ1234567) does not
collect any samples during the January
1 - June 30, 1992 timeframe. Instead, the
system conducts monitoring during the
July 1 - December 31,1992 timeframe and
submits  all     required   monitoring
information to the State by December 24,
1992.
  Large systems are required to conduct
monitoring for two six-month compliance
periods. This example can be viewed two
ways.
 a) The  system  has   satisfied  the
    requirements for the second round
    of  sampling and  therefore is in
    violation for the  first six-month
    monitoring period.
 b) The system has completed the  first
    round of sampling, albeit late  and
    must complete a second round of
    sampling.
  EPA's interpretation is that b. should
be used because the system is less likely
to become an exception. Under the first
scenario, where the system has satisfied
the requirements for the second round of
sampling but not the first,  the  system
would become a SNC on October 1, 1992.
If the system did not correct a violation
or a timely and appropriate action had not
been taken by March 31,1993, the system
would become an exception on April 1,
1993.
   Under the second scenario, the system
 would still become a SNC on October 1,
 1992 but would achieve compliance on
 December 24, 1992, thereby preventing
 the system from becoming an exception
 on April 1,  1993. However, the system
 would  incur  a  second  violation  on
 December 31, 1992 for failure to complete
 the second  round of sampling. If the
 system does not complete the required
 monitoring by March 31,1993, the system
 would again become a SNC on April  1,
 1993.  If  the  system  did  not achieve
 compliance or the State or EPA had not
 taken  a   timely   and   appropriate
 enforcement action  against the system,
 it would become an exception on  October 1,
 1993. The reporting for this example would
 be as follows:
  By August 15, 1992, the State would
 report a violation for the first six-month
 compliance period as follows:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109
 C1111
NJ1234567
9212345
5000

51
01/01/92

06/30/92
006
PWS-ID
Violation ID
Contaminant Code
(Defaulted by PROS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
  The DTF transactions for this violation
are:
 13       12     19
 It       I      I
 D1NJ12345679212345
 D1NJ12345679212345
                        27
                    32
               IC110551
               IC1107010192
                                   — 64 —

-------
   By February 15, 1993, the State would
 report that the system had returned to
 compliance as follows:
  C101
  C1201
  C1203

  C1205

  C1215

  Y5000
 NJ1234567
 9300001
 12/24/92

 SOX
9212345
 PWS-ID
 Enforcement ID
 Date system achieved
 compliance
 Compliance Achieved
 code
 Comment Field, optional
 reporting
 Follow-up action to
 violation link
  The  DTF  transactions   for   this
enforcement action are:
  1 3
  I  I
            12
          19
       27
                II
                              32
  E1NJ12345679300001       IC1203122492
  E1NJ12345679300001       IC1205SOX
  E1NJ12345679300001       IC1215
  (Applies to first round of monitoring)
  E1NJ12345679300001       IY50009212345
  In addition, by February 15, 1993, the
State would report a violation for failure
to complete the second round of sampling
by December 31, 1992 as follows:
  C101
  C1101
  C1103

  C1105
  C1107

  C1109
  C1111
NJ1234567
9300045
5000

51
07/01/92

12/31/92
006
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
  The DTF transactions for this second
violation are:
13 12 19
11 t 1
D1HJ12345679300045
D1NJ1234S679300045
27 32
It 1
IC110SS1
IC1107070192
 Treatment Technique
 SNCs
   Three treatment technique violations
 were  identified  as  having  potential
 significant health impact. These violations
 are:
   • OCCT Installation/Demonstration
   • SOWT Installation
   • Public Education
   OCCT Installation/Demonstration was
 selected because OCCT is the major
 mechanism for reducing exposure to lead
 and  copper  in  drinking water  by
 minimizing the amount of lead and copper
 that leaches from pipes in the distribution
 system and from consumers' plumbing.
   Although few systems are expected to
 need SOWT, this treatment is important
 in reducing the concentration of lead in
 drinking water where high lead and copper
 concentrations exist in source water.
   Public education also was considered
 to be  of great  significance because it
 informs the consumers of the health effects
 of lead and the simple measures that they
 can take to reduce their exposure while
 water systems are completing treatment
 requirements.
   The  SNC definition proposed at the
 workshops for these violations was similar
 to that originally proposed for the initial
 lead and copper Tap M/R violation, in that
 the system would have 3 or 6 months to
 return to compliance, depending on the
 system size. In further considering this
 definition, EPA determined that too much
 time might elapse before enforcement
 attention might be drawn to a system. This
 is especially true for public education
violations because, as the rule is currently
 written, a system is only required to report
to the State at the end of the calendar year
on measures taken  to  meet its public
education requirements. Therefore, the
                                   — 65  ""

-------
State may not be aware of the violation
until the end of each calendar year.
  EPA instead has modified the SNC
definition for  these  three  treatment
technique violations in two ways:
  1. To focus attention only on those
     systems with 90th percentile lead
     levels of &30 ppb in their most recent
     tap samples.
  2. To no longer provide a period of time
     before the system becomes a SNC but
     instead to make the system a SNC
     in the same quarter that it incurs the
     violation as shown in the chart below.
  The dates presented in  this chart
assume the system exceeds the lead action
level during the first six-month compliance
period for initial monitoring and that prior
to installing OCCT, the system conduct
an OCCT study.
  OCCT Installation
  Large
  Medium
  Small

  SOWT Installation
  Large
  Medium
  Small

  Public Education
  Large
  Medium
  Small
3/1/97
3/1/98
3/1/99
9/1/95
3/1/96
3/1/97
3/1/94
3/1/94
3/1/95
4/1/97
4/1/98
4/1/99
10/1/95
10/1/96
10/1/97
4/1/94
4/1/94
4/1/95
  Although a system that incurs one of
these treatment technique violations is
not provided 3, 6 or 12 months to correct
a violation to avoid becoming a SNC, the
question of  how  a system achieves
compliance is important for two reasons:
  1. It prevents a system from becoming
    an exception
   2. For a public education violation, the
     system will not become a SNC if it
     meets the definition of compliance
     achieved  before  the  end of the
     calendar year, when the system must
     submit  a  letter  to the  State
     identifying measures taken to meet
     the public education requirements.
     SNCs for public education  are
     based on a system's missing the
     December  31   deadline   for
     delivering all the required public
     education  components  or
     submitting a letter to the State.
     The only time a system will be
     identified as a SNC  for a public
     education violation will be on April
     1st of the following year. If a public
     education violation has not RTC by
     April 1 (via a follow-up action linked
     to the violation), the system will be
     identified as a SNC.
  The definition of return to compliance
for these three  SNCs is discussed in
greater detail below.

OCCT Installation/
Demonstration  SNC
  A  system that becomes an OCCT
Installation/Demonstration  SNC  is
considered to have returned to compliance
if it:
  •  Installs State-designated treatment,
    AND
  •  Submits proof of proper installation
     and operation, OR
  •  Demonstrates that OCCT  already
    exists.
      EXAMPLES
EXAMPLE 1 —
  A system (WY1163644) does not install
OCCT within the 24-month timeframe,
in this example by June 10,1996. Instead
                                 — 66 —

-------
 the State receives a letter from the system
 on November 2, 1997, that certifies OCCT
 has been installed.
   By August 15, 1996,  the State would
 report an OCCT Installation violation as
 follows:
C101
C1101
C1103

C1105
C1107

C1109


C1111


WY1 163644
9600001
5000

58
06/11/94

06/10/96


024


PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period
begin date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
  The DTP transactions for this violation
are:
13
1 1 1
12
19
1
37
II
32
1
  D1WY11636449600001
  D1WY11636449600001
IC110538
IC1107061194
  If the  system's most recent  90th
percentile lead level in tap samples were
30 ppb or greater, FRDS would determine
that this system was a SNC on September
1, 1996. EPA strongly suggests that the
State track the progress of systems with
90th percentile lead of % 30 ppb to help
ensure that systems are on schedule and
will not incur a violation and become a
SNC.
Note:  The date that a system installs
  OCCT   is   a  milestone  reporting
  requirement. (Refer to examples of
  the Treatment Installation/Designation
  milestone on page 10 to determine how
  to report this milestone.)
                 SO WT Installation SNC
                   A SOWT Installation SNC is considered
                 to have returned to compliance if it:
                   •  Installs State-designated treatment,
                     and
                   •  Submits proof of proper installation
                     and operation.
                                               EXAMPLES
                 EXAMPLE 1 —
                  A system (HI0063600) is required to
                 install   SOWT  and   certify  SOWT
                 installation by June 30,1995. Instead, the
                 State receives a letter from the system on
                 January 1, 1996, certifying that SOWT
                 has been properly installed and operating.
                  By August 15, 1995, the State would
                 report the following:
C101
C1101
C1103

C1105
C1107

C1109
                  C1111
HI0063600
9500001
5000

62
07/01/93

06/30/95
       024
PWS-ID
Violation ID
Contaminant Code
(Defaulted by FRDS)
Violation Type Code
Compliance period begin
date
Compliance period end
date (Defaulted by
FRDS)
Compliance period in
months (Defaulted by
FRDS)
                  The DTP transactions for this violation
                are:
13 12 19
t I i 1
D1HI00636009500001
D1HI00636009500001
27 32
II 1
ZC110562
IC1107070193
                                  — 67 —

-------
  The most recent 90th percentile lead
value  for  this system was 35 ppb.
Therefore, on October 1, 1995, the system
will become a SNC. EPA also would
recommend that States closely track the
progress of SOWT installation for systems
with 90th percentile lead of s30 ppb to
help ensure that systems are on schedule
and will not incur a violation and become
SNCs.
  Like OCCT installation, EPA will allow
a State to determine whether SOWT has
been properly installed and is operating,
through mechanisms other than receiving
a certification through the mail within the
24-month  timeframe.  The State can
determine   compliance  with  SOWT
installation requirements, through on-site
visits or  phone calls,  if the  State
documents compliance in the files and
obtains  a certification from the State
within a short period after the 24-month
deadline.
Note: The installation of SOWT is a
  milestone reporting requirement In this
  example, C803 (i.e., the date the State
  received  proof of the installation  of
  SOWT) would be 01/01/96. (For more
  details on  the reporting of SOWT
  installation,  refer to the examples for
  Treatment Designation/Installation on
  pages  9 and 10.)

Public Education SNC

  A Public Education SNC is considered
to have returned to  compliance if  it
submits a letter to the State by the end
of the calendar year that demonstrates
that the required program elements have
been completed:
     For CWSs, informing the following,
     using the mandatory language, in all
     appropriate languages:
         consumers via notices
         facilities/organizations in contact
         with sensitive populations via
         pamphlets and brochures
         consumers  via  major
         newspapers,  television,  and
         radio
     For NTNCWSs, informing consumers,
     using  the  mandatory  language,
     through:
         posting
         distribution of pamphlets and
         brochures.
      EXAMPLES
EXAMPLE 1 —
  A CWS (ME3456699) conducts lead and
copper  tap  monitoring  during  the
compliance period July 1 - December 31,
1992. The lead 90th percentile level  is
35 ppb. In addition, the system does not
conduct any  public education during
January 1 - December 31, 1993.
  By February 15,1994 the system would
report a violation as follows:
C101
C1101
C1103

C1105
C1107

C1109

Of
C1111

ME345G699
9400001
5000

65
01/01/93

12/31/93


012

PWS-IO
Violation 10
Contaminant Code
(Defaulted by PROS)
Violation Type Code
Compliance period
begin date
Compliance period end
date

Compliance period in
months

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  The DTP transactions for this violation
are:
113 12 19
II II
D1ME34566999400001
D1ME34566999400001
01ME34566999400001
27 32
II 1
IC110565
IC1107010193
IC1111012
  In addition, because this system has a
90th percentile lead level that is 230 ppb
and did not deliver public education to all
the media or to facilities/organizations,
the system meets the definition of SNC
for public education. On April 1, 1994,
FRDS would determine that this system
is a SNC.
EXAMPLE 2 —
  Another CWS  exceeds the lead action
level during the compliance period July 1 -
December  31,  1992. Its  lead  90th
percentile value is 35 ppb. The  State
contacts the system on  March 1  to
determine whether the system has met
its 60-day requirements. The system has
not conducted any public education. The
State informs the system that it must
deliver  at least  one round of public
education materials to all the required
individuals, organizations, and media as
specified in Section 141.85(c) and indicate
these actions in an  annual letter  by
December 31, 1993 or the system will
become a  SNC on April 1,  1994. On
November 21, 1993, the State receives a
letter that demonstrates that the system
has properly delivered its public education.
  Under this scenario, the system has
achieved compliance and would not become
a SNC on April 1, 1994. Further, the State
would not be  required to report  the
violation and compliance achieved to FRDS
as EPA is more concerned with unresolved
violations and believes that reporting a
violation and compliance achieved for the
same quarter is an unnecessary reporting
burden.

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