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
-------
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 .-,
-------
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
C1123VIOLATIONANALYSIS-
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
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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
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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
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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
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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
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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
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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
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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 ""
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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
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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
-------
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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