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THE LEAD AND COPPER RULE
San Francisco, CA
May 24 and 25,2000
DRINKING
WATER
ACADEMY
DWA
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I ntrod action/Overview
Lead and Copper Tap/Initial WQP
Monitoring
Corrosion Control Optimization
Public Education
Source Water Monitoring &
Treatment
Replacement of Lead Service
Lines
State Reporting and
Recprdkeeping
Primacy and Implementation
Supplemental Information
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Agenda for LCR Training
U.S. Environmental Protection Agency Region 9
May 24-25, 2000
May 24,2000
Topic Schedule
Introduction (Tab 1) 8:00 - 9:15
Lead and Copper Tap/Initial Monitoring and Reporting (Tab 2) 9:15 -10:30
Break 10:30 -10:45
Lead and Copper Compliance Examples/SDWIS Reporting (Tab 2) 10:45 -12:30
Lunch 12:30-1:30
Corrosion Control Optimization (Tab 3) w/ OWQP Compliance 1:30 - 3:30
Examples (Tab 9)
Break 3:30-3:45
Corrosion Control Optimization Examples/SDWIS Reporting (Tab 3) 3:45 - 4:45
May 25,2000
Topic Schedule
Public Education (Tab 4) 8:00 - 9:00
Source Water (Tab 5) 9:00 -10:00
Break 10:00-10:15
Lead Service Line Replacement (Tab 6) 10:15-11:15
State Reporting and Recordkeeping (Tab 7) 11:15 - 11:45
Lunch 11:45-12:45
State Reporting including DTP (Continued - Tab 7) 12:45 - 3:15
Break 3:15 - 3:30
State Reporting Compliance Examples (Tab 7) 3:30 - 4:00
Primacy (Tab 8) 4:00 - 4:45
Wrap-up 4:45 - 5:00
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List of Acronyms
AL
CCSC
CCSR
CCT
Cu
CU90
CWS
DE
DIM
DTP
EPA
FR
GGC
LCR
LCRMR
LOAEL
LSL
LSLR
LSLR
M/R
MCL
MCLG
MDL
mg/L
MPL
MPLS
NSF
NTNCWS
OCCT
OTDE
OTIN
OWQP
Pb
PB90
Action Level
Corrosion Control Study Completed (Obsolete Milestone)
Corrosion Control Study Required (Obsolete Milestone)
Corrosion Control Treatment
Copper
Copper 90th Percentile Exceedance
Community Water System
Data Entry
Delete, Insert, Modify
Data Transfer File (Format)
Environmental Protection Agency
Federal Register
Group Generated Code
Lead and Copper Rule
Lead and Copper Rule Minor Revisions
Lowest Observable Adverse Effects Level
Lead Service Line
Lead Service Line Replacement
System required to begin Lead Service Line Replacement (Milestone)
Monitoring and Reporting (Violation)
Maximum Contaminant Level
Maximum Contaminant Level Goal
Method Detection Limit
Milligrams per Liter
Maximum Permissible Level
Maximum Permissible Levels Designated (Obsolete Milestone)
National Sanitation Foundation Internationals
Non-Transient Non-Community Water System
Optimal Corrosion Control Treatment
Optimal Corrosion Control Treatment Designated (Obsolete Milestone)
Optimal Corrosion Control Treatment Installed (Obsolete Milestone)
Optimal Water Quality Parameter
Lead
Lead 90th Percentile Exceedance
1
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PE
pLSLR
PQL
PSA
PWS
RTC
SDWA
SDWIS
SETS
SNC
SOWT
SIDE
STIN
TL
TNCWS
TT
u.s.c.
ug/L
V&E
WQP
WQPS
List of Acronyms
Public Education
Partial Lead Service Line Replacement
Practical Quantitation Level
Public Service Announcement
Public Water System
Return To Compliance
Safe Drinking Water Amendment
Safe Drinking Water Information System (STATE or FEDeral Version)
Significant Non-Compliance Exception Tracking System
Significant Non-Compliance or Significant Non-Complier
Source Water Treatment
Source Water Treatment Designated (Obsolete Milestone)
Source Water Treatment Installed (Obsolete Milestone)
Tap water Level
Transient Non-Community Water System
Treatment Technique (Violation)
United States Code
Micrograms per Liter
Variance & Exemption
Water Quality Parameter
Water Quality Parameter Designated by the State (Obsolete Milestone)
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5/15/00
THE LEAD AND COPPER RULE
May 2000
DRINKING
WATER
ACADEMY
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5/15/00
Introduction
Purpose of This Training
Improve consistent implementation
nationally
Present the Lead and Copper Rule Minor
Revisions (LCRMR)
Explain primacy issues
* Present SDWIS reporting
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5/15/00
Introduction
How The LCR Presentation is Organized
LCR Overview
SDWIS Reporting Overview
LCR Minor Revisions (LCRMR)
Rule Provisions
- Lead and Copper Tap/Initial WQP Monitoring
- Corrosion Control Optimization
- Public Education
- Source Water Monitoring & Treatment
- Replacement of Lead Service Lines
- State Reporting and Recordkeeping
Primacy and Implementation
After a brief introduction to the Lead and Copper Rule (LCR) and Lead and Copper Rule Minor
Revisions (LCRMR), we will provide a more in-depth discussion of each of the above topics.
For all topics, except the Primacy and Implementation section, we will:
1. Discuss the basic requirements under the LCR.
2. Summarize what's changed under the LCRMR.
As we go through this presentation, we will note those revisions with which States
and systems must begin implementation on April 11,2000. These revisions are
clarifications to the LCR or are more stringent than the LCR. They are preceded by the
symbol "O". These provisions must also be adopted by the State to retain primacy.
Those revisions without this symbol are generally less stringent than the LCR and the
State may not be able to implement them until the provisions are incorporated
into its regulations.
3. Utilize examples drawn from real world experiences noted during data verifications to
illustrate how States and systems must implement the requirements. Worksheets and
problem examples will permit you to test your understanding of the rules.
4. Discuss how State reporting to SDWIS has changed.
In the Primacy and Implementation Section, we will review primacy revision application
requirements, discuss special primacy conditions of the LCRMR, and recap those provisions
that must be adopted for a State to maintain primacy compared to those that cannot be
implemented unless adopted.
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LCR Overview
Health Effects of Lead
* Children are highly susceptible
- Impaired mental development
- IQ deficits
- Shorter attention span
- Lowered birth weight
- Altered heme synthesis and Vitamin D metabolism
Adults
- increased blood pressure
EPA set MCLG at zero
Children are highly susceptible to lead poisoning. Epidemiological evidence shows
that children who ingest lead suffer impaired mental development as shown by IQ
deficits and decreased attention spans. There is also evidence that lead can stunt growth
by altering heme synthesis and vitamin D metabolism.
Adults exposed to lead ingestion may also experience negative health effects including
increased blood pressure. At higher levels, lead can be toxic to the liver and kidney.
The EPA set the MCLG for lead at zero based on three considerations: 1) difficult to
identify clear threshold exposure levels below which there are no risks of adverse health
effects, 2) a substantial portion of the sensitive population was exceeding acceptable
blood lead levels, 3) lead was classified as a probable carcinogen (Class B2).
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5/15/00
LCR Overview
Health Effects of Copper
Stomach and intestinal distress
Complications of Wilson's Disease
Chronic exposure can cause liver
disease in genetically predisposed
individuals
EPA set MCLG at 1.3 mg/L
Copper is an essential nutrient - provided through food.
Acute exposure can cause gastrointestinal irritation (nausea, vomiting, diarrhea,
etc.).
Chronic exposure can cause liver disease in genetically predisposed individuals.
Principle source of copper in drinking water is leaching from household
plumbing.
National Academy of Sciences Review of EPA's Maximum Contaminant Level Goal
(MCLG)
Studies indicate lowest observable adverse effects level (LOAEL) for acute
exposure to copper in drinking water ranges between 2 mg/L and 4 mg/L.
Recommended leaving MCLG at current level.
Based on chronic effects in sensitive populations.
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5/15/00
LCR Overview
Published on June 7, 1991
Establishes MCLGs for lead and copper
Mandates treatment techniques vs. MCL,
triggered by tap monitoring results > AL
MCLGs Action Levels (ALs)
Lead 0 mg/L 0.015 mg/L
Copper 1.3 mg/L 1.3 mg/L
AL Exceedance is not a violation
The original Lead and Copper Rule was first published on June 7, 1991. This rule was
revised by technical amendments published on July 15,1991 (56 FR 32113), June 29,
1992 (57 FR 28786) and June 30,1994 (59 FR 33860).
The LCR establishes non-enforceable health goals called Maximum Contaminant Level
Goals (MCLGs) for lead and copper. These concentrations represent levels at which no
known or anticipated health effects would occur.
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There is no maximum contaminant level (MCL) for the LCR. Instead, a system's tap
monitoring results must be below the lead and copper action levels to avoid further
treatment. To determine whether an action level has been exceeded, the value at the
90th percentile of all lead or copper samples collected is compared against its respective
action level. We will go through some examples on how to calculate the 90th percentile
level a little later in this training.
Exceedance of an action level is not a violation. Instead, it determines whether systems
need to undertake additional monitoring and treatment technique requirements.
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5/15/00
LCR Overview
A
No
Exceedance*
Lead and Copper
Tap Monitoring
i
1
Lead Copper
Exceedance Exceedance
1
- Treatment Technique Requirements | Treatment Technique Reqts
Periodic
Monitoring
1
1 1
CCT SOWT
11 ,
P""ic LSLR CCT SOWT
Edu.
includes systems serving s 50.000 people and (b)(3) systems.
A system that serves 50,000 or fewer people that does not exceed either the lead and
copper action level, or a system that meets the criteria under §141.81 (b)(3), is required to
conduct periodic lead and copper tap monitoring. A system qualifies under § 141.81(b)(3)
(also known as a (b)(3) system), if for 2 consecutive 6-month rounds it can show that the
difference between the 90th percentile tap water lead level and the highest source water
lead concentration, is less than the Practical Quantitation Level for lead of 0.005 mg/L.
In addition to lead and copper tap monitoring, a system that exceeds the lead action level is
triggered into the following treatment technique requirements:
corrosion control treatment (CCT);
source water treatment (SOWT) steps (depending on source water levels, this
requirement may include monitoring and no treatment)
public education regarding lead; and
lead service line replacement (LSLR) when treatment fails to adequately control
lead levels (this requirement does not apply to systems that have no lead service
lines).
In addition to lead and copper tap monitoring, a system that exceeds the copper action level
is triggered into the following treatment technique requirements:
CCT; and
source water treatment (depending on source water levels, this requirement may
include monitoring and no treatment).
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Implementation Pathway for Medium-Size and Small PWSs
SAMPLE PLAN AND MATERIAL SURVEY
Initial Monitoring
Pb/Cu Taps
Existing Treatment is Optimal
Initial Monitoring
Pb/Cu Entry PoiriS
WQP Entry Points
WOP Distribution System
Public
Education
» Water
ment
Source Water
Treatment
Recommend Optimal
Corrosion Control Treatment
Existing Corrosion
Control = Optimal
State Requires Study
State Approves Treatment
Corrosion Control Study
_L
Install Treatment
Follow-Up
Monitoring
State Specifies
WQP Ranges (2)
Public Education
and LSLRP
1
Rou||ne Monitoring
MMtsWOPRwKM*
Reduced
Monitoring
Frequency
Parameters
Reduced
Monitoring
Frequency
Public
Education
LSLRP
(1) Tfte 90th pereentile tap water level I . ...
practical quantitative level (PQL) - A second round of PWCu-Tap and Pb/Cu-POE would be required for this optimization.
(2) Water Quality Parameter = WQP
Source: lead and Copper Ruk Guidance Manual, Volume 1: Monitoring.
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Implementation Pathway for Large PWSs
SAMPLE PLAN AND MATERIAL SURVEY
Initial Monitoring
Pb/Cu Tap
WOP Distribution System
WQP Entry Points
Corrosion Control
Study
Corrosion Control
Study
Recommend Optimal
Treatment
Existing
Corrosion Control
Treatment=Optimal
Recommend Optimal
Treatment
State Approves
State Approves
Install Treatment
Install Treatment
Follow-Up Monitoring
Follow-Up Monitoring
State Specifies
WOP Ranges (2)
State Specifies
WQP Ranges (2)
Public Education
and LSLRP
Routine Monitoring
Routine Monitoring
Reduced
Monitoring
Public Education
and LSLRP
(1) The 90th percetrtile tap water level (TL) minus the highest source water concentration (Point of Entry) is < or 2 the
practical quantitative level (PQL)
(2) Water Quality Parameter = WQP
Source: Lead end Copper Rule Guidance Manual, Volume 1: Monitoring.
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5/15/00
Introduction
LCRMR Summary
* Reduce burden
- frequency of monitoring
- flexibility in public education requirements
* improve implementation
- compliance with OWQP
- sample invalidation
Clarifications of 1991 rule
* Address 2 judicial remands
- transient water system exclusion
- lead service line replacement requirements
The LCRMR reduce monitoring and reporting requirements. Systems that meet certain criteria
can eliminate some monitoring requirements for lead and copper at the tap and at the source,
and for water quality parameters (WQPs).
The LCRMR provides more flexibility in the mode of delivery for public education, especially
for non-transient non-community water systems (NTNCWSs) and those community water
systems (CWSs) that serve 3,300 or fewer.
The LCRMR improve implementation with provisions that were highly desired by systems and
states. For instance the way compliance with optimal water quality parameters (OWQP) is
determined has changed. And under the minor revisions, States now have the flexibility to
invalidate samples.
Clarify what EPA intended in the original Lead and Copper Rule ("the 1991 Rule") and in
some cases add requirements that EPA originally intended to promote consistent national
implementation.
Address 2 judicial remands:
Issue 1: Whether transient non-community water system (TNCWS) should continue to
be excluded from regulation. Based on a review of existing studies, EPA believes there
are minimal non-carcinogenic adverse health effects resulting from exposure to lead in
drinking water at such systems. The rationale for this continued exclusion is discussed in
detail in the preamble to the LCRMR (65 FR 1954)
Issue 2: The Definition of "control" of lead service lines (LSLs). This issue will be
discussed in more detail in the Replacement of Lead Service Lines section and is also
discussed in the preamble to the LCRMR (65 FR 1963).
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5/15/00
Introduction
LCRMR Effective Date
Published on January 12, 2000
Effective April 11, 2000
Provisions divided into two categories
- provisions that are more stringent and systems must
begin implementing on April 11,2000 (marked with a O
throughout the presentation)
- provisions that are less stringent and require State
adoption and/or approval to implement
The LCRMR was published on January 12,2000
As we §6 through this presentation, we will note those revisions with which States and systems
must begin implementation on April 11,2000. These revisions are clarifications to the LCR or
are more stringent than the LCR. They are preceded by the symbol "O". These provisions
must also be adopted by the State to retain primacy. Those revisions without this symbol are
generally less stringent than the LCR and the State may not be able to implement them until
the provisions are incorporated into its regulations.
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5/15/00
Introduction
SDWIS Reporting Issues to Be Addressed
Effective Date
Milestone reporting
Sample reporting
Violation reporting
Enforcement/Follow-up actions and
linking
Significant Non-Compliers (SNC)
Data transfer file format (DTF)
SDWIS Reporting will be addressed in detail as we go through the different
modules of this training. Specifically, we will discuss when the new reporting
requirements become effective and the changes to milestone, sample, and
violation reporting.
i
EPA has stated in the past that all violations for the Lead and Copper Rule
reported to SDWIS should have a return to compliance associated with them.
In the compliance examples we will talk about reporting enforcement and
follow-up actions and how to link them to violations. We will also review
SNC definitions.
We will present a cursory review of DTF procedures at the end of the Lead
and Copper Tap/Initial WQP Monitoring Section, and then show you how to
report violations, sample, and milestones using selected examples from each of
the modules.
We expect and encourage discussion on these issues. We will keep a "parking
lot" list of issues or concerns that get raised. Since we have limited time to
complete the training, we may ask that you give us your comments in writing.
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Introduction
Summary of Changes to SDW1S Reporting
LCRMR
- 3 milestones (LSLR, DEEM, DONE)
- All 90th lead for medium and large
Non-rule-related changes
- 15 violation types consolidated into 10
- begin date is day after event*
- end date is 12/31/2015*
Applies to all violations except compliance with optimal water
quality parameters and WQP MIR violations.
5/15/00
LCRMR
Only 3 milestones are reported:
LSLR = System required to begin lead service line replacement.
DEEM = a milestone that indicates that the system is deemed to be optimized along with an
indicator reflecting the basis of the optimization (e.g., meets requirements under §141.81(b)(l), or
(b)(3), or State has designated optimal water quality parameters.) EPA is requesting that this
milestone be reported by 2/15/01. 1 of 3 reason codes are reported for this milestone.
DONE = a milestone that indicates that the system had completed all steps required of them:
optimization of corrosion control, installation of any source water treatment required by the State;
and replacement of lead service lines, if required. No reason codes are reported for this milestone.
LCRMR add a requirement for State to reports all 90th percentile lead values for large and medium-size
systems. There is no change from the LCR requirements for States to report 90th percentile lead values
for small systems in those monitoring periods in which the lead action level is exceeded; and 90th
percentile copper values for all size systems for those monitoring periods in which the copper action
level is exceeded. Ninetieth percentile lead and copper levels will now be reported as sample records.
Refer to next page for a summary of the changes to milestone reporting requirements.
Non-rule related changes
EPA consolidated some of the similar or like violation types under the same code; thereby reducing the
number of violation types from 15 to 10. Refer to pages 15 and 16 of this section. There you will see a
table that summarizes the violation changes. We will discuss these as we go through the training.
EPA changed the begin date to the day after the event to better characterize the violation. In addition,
EPA revised the compliance period end dates. This change will more accurately portray the length of
time a system is in violation. The change will also facilitate tracking of significant non-compliers
(SNCs), because a system may be a SNC for longer than the 12-month period for which SNCs are
determined. The change to the begin and end dates do not apply to violations for failure to comply with
optimal water quality parameters and failure to comply with water quality parameter monitoring and
reporting (M/R) requirements.
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Comparison of Required Reporting for Milestones
and 90th Percentile Levels under the LCR and LCRMR
Milestone
Code
CU90
PB90
N/A
CCSR
ccsc
OTDE
SIDE
OTIN
STIN
WQPS
MPLS
LSLR
DEEM
DONE
Description
Copper action level exceedance
Lead action level exceedance
90"* percentile lead levels thai are below the lead action level
System that is required to conduct a corrosion control study
System that has completed a corrosion control study
System in which the State has designated or approved optimal
corrosion control treatment (OCCT)
Indicates a system in which the State has designated or approved
source water treatment (SOWT)
Indicates a system that has installed OCCT
Indicates a system that has installed SOWT
Indicates s system in which the State has designated or approved
ranges for water quality parameters (WQPs)
Indicates a system in which the State has designated or approved
maximum permissible levels (MPLs) for lead and copper in source
water
Designates a system that is required to conduct Lead Service Line
Replacement
Indicates a system for which the State has:
(1) designated optimal water quality parameters under
§141.82(1), or
(2) deemed to have optimized corrosion control under
§141.81(b)(l),(b)(2),or(bX3)
Completed all applicable corrosion control, source water treatment,
and lead service line replacement requirements
Required to be reported under:
LCR?
Yes
Yes
No*
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
LCRMR?
Yes, but to be
reported as a sample
record
Required for large
& medium systems
No
No
No
No
No
No
No
No
Yes, but no longer
required to report
replacement rate
Yes
Yes
The LCR did not require States to report any 90th percentile levels below the action level (i.e., non-
exceedances). However, in the 1992 LCR reporting guidance, EPA requested that States report the 90th
percentile lead non-exceedances for all large systems, and for medium and small systems once they
exceeded the lead action level.
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Revisions to Reporting
for Lead and Copper Violations
Old Requirements
Violation
Type
Code
51
52
53
54
55
56
57
58
59
60
61
Description
Initial Lead and Copper
TapM/R
Follow-up or Routine
Lead and Copper Tap
M/R
Initial Water Quality
Parameter (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
Optimal Corrosion
Control Treatment
Study/ Recommendation
Optima] Corrosion
Control Treatment
Installation/Demonstrati
on
WQP Entry Point
Noncompliance
WQP Tap
Noncompliance
Source Water Treatment
Recommendation
Revised Requirements
Violation
Type
Code
51
52
53
56
57
58
59
57
Description
Initial Lead and Copper
Tap M/R
Follow-up or Routine Lead
and Copper Tap M/R
WQP M/R
Initial, Follow-up, or
Routine Source Water M/R
Treatment Study/
Recommendation
Treatment Installation /
Demonstration
WQP Entry Point or Tap
Treatment Technique
Noncompliance
Treatment
Recommendation
Change in Reporting
Requirement
Violation begin and end
dates'
Violation begin and end
dates1
Combined violation types 53,
54, & 55 under code 53
Violation begin and end
dates2
Violation begin and end
dates'
Combined violation types 57
& 61 under code 57
Violation begin and end
dates'
Combined violation types 58
& 62 under code 58
Violation begin and end
dates2
Combined violation types 59
& 60 under code 59
Violation begin and end
dates2
Combined violation types 57
&61 under code 57
Violation begin and end
dates'
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Revisions to Reporting
for Lead and Copper Violations
Old Requirements
Violation
Type
Code
62
63
64
65
Description
Source Water Treatment
Installation
Maximum Permissible
Level Noncompliance
Lead Service Line
Replacement (LSLR)
Public Education
Revised Requirements
Violation
Type
Code
58
63
64
65
Description
Treatment Installation/
Demonstration
Maximum Permissible
Level Noncompliance
Lead Service Line
Replacement
Public Education
Change in Reporting
Requirement
Combined violation . types
58 & 62 under code 58
Violation begin and end
dates1
Violation begin and end
dates'
Violation begin and end
dates'
Violation begin and end
dates'
1 The begin date is the day after the requirement was to occur. The end date is defaulted by SDWIS/FED to December
31, 2015. The return to compliance date or "no-action" date (proposed) replaces the defaulted December 31, 2015.
This change will better characterize the period of time in which a system is in violation.
2 The begin date is the first day of the compliance period and the end date is the last day of the compliance period.
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5/15/00
Introduction
Effective Date for SDWIS/FED
* Most requirements/provisions are effective 90
days after LCRMR published (4/11/00)
* FR lists 5/15/00 as earliest date for reporting new
requirements and codes
Option to report under old or new until 1/11/02
Reporting under new requirements mandatory 24 months after promulgation
(January 12, 2002).
States may continue to report under the old requirements until January 11,
2002.
After January 11,2002, SDWIS/FED will no longer convert or accept data
which does not meet the LCRMR reporting requirements.
Will provide a warning message in the SDWIS/FED error reports
approximately 6 months before the cutoff date as a reminder that data is being
submitted which will not be accepted after January 11,2002.
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Introduction
Effective Date for SDWIS/FED
* SDWIS/FED will convert data reported, as
necessary and appropriate, until 1/11/02
After 1/11/02, SDWIS/FED will not convert or accept
data which does not meet new requirements
Provide warning messages in Errors Reports
Converted data will be identified on SDWIS/FED
Error Reports until 1/11/02
After 1/11/02, data reported that is not consistent
with new requirements will be rejected
5/15/00
Difference in FR - Reference in Section 142.15 to January 14 instead of January 12.
SDWIS/FED has already been modified to accept the new reporting requirements
and codes.
Conversion of Violation types - Refer back to pages 15 and 16 of this section.
WQP M/R ... 54 & 55 converted to 53
WQP Noncompliance ... 60 converted to 59
OCCT/SOWT Study/Recommendation ... 61 converted to 57
OCCT/SOWT Installation/Demonstration ... 62 converted to 58
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5/15/00
Introduction
Milestones Summary
Reduction of reported Milestones (was 11;
now 3)
Two new Milestones (DEEM and DONE)
CU90 Exceedances reportable as Samples
(being converted by SDWIS/FED)
PB90 Exceedances no longer reportable as
Milestone... must be reported as Sample
Remainder of pre-LCRMR Milestones are
rejected by SDWIS/FED
Will no longer post unwanted Milestones
CU90 exceedances reported as Milestones will be converted to Samples
PB90 exceedances no longer reportable or maintained as Milestones ...
must be reported as Samples
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5/15/00
Introduction
Violation Summary
Consolidation of Violation Types ... 15 to
10
LCRMR changes non-compliance
portrayal
Begin date - day after requirement missed
End date - defaulted to December 31, 2015
until RTC reported and linked to violation
Please note that when States are switching over to the new
reporting requirements, they should not revise pre-existing
violation begin dates. This is because enforcement actions are
linked to violation begin dates. Thus modifying pre-existing
begin dates will cause these links to be broken.
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5/15/00
Introduction and Overview
Enforcement
Continued reporting required for all
formal actions, and when compliance
is achieved (RTC)
New Use for "Intentional No Action"
enforcement
Examples: 90th percentile tap monitoring
after exceedance or completion of LSLR
when no longer exceeds PB90 AL
Reporting requirements for all formal actions, including systems which have
Returned to Compliance (RTC), continue. RTC is reported as EOX or SOX
EPA has proposed reporting "Intentional No Action" (instead of the traditional
RTC) for open-ended Violations when the original requirement has been
overcome by time or circumstances making completion of the requirement
unnecessary. "Intentional No Action" reported as EO6 or SO6
This is NOT presently implemented in SDWIS/FED
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5/15/00
Introduction and Overview
Significant Non-Compliers (SNCs)
No NEW SNCs
Consolidated OCCT/SOWT Installation
and/or Demonstration into one SNC
3 discrete SNCs
- Initial Tap Monitoring (51)
- OCCT/SOWT Installation/Demonstration (58)
- Public Education (65)
SNC Definition Under the Lead and Copper Rule Minor Revisions
Initial Pb/Cu Tap M/R
Based on amount of time out of compliance
Definition: A system which has not returned to compliance, and/or a RTC
record reported to SDWIS/FED (properly linked to the
appropriate violation) within:
3 months for large systems,
6 months for medium systems
12 months for small systems
Treatment Installation /Demonstration (OCCT or SOWT)
Only systems with 90th percentile lead levels of > 0.030 mg/L
Definition: System with this violation & 90th percentile lead level of > 0.030
mg/1 in most recent monitoring period
Public Education
Only systems with 90th percentile lead levels of > 0.030 mg/L
Definition: System with this violation & 90th percentile lead level of > 0.030
mg/1 in most recent monitoring period
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5/15/00
Introduction and Overview
Significant Non-compliance SNCs
Initial Pb/Cu Tap M/R
OCCT/SOWT Installation,
or
Public Education
Has not achieved compliance,
and/or a RTC record reported to
SDW1S/FED (properly linked to
the appropriate violation) within:
3 months for large systems
9 months for medium systems
15 months for small systems
System with this violation & 90th
percentile lead level of ^0.030
mg/l in most recent monitoring
period
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5/15/00
Lead and Copper NPDWR
Requirements
Lead and Copper Tap/Initial WQP
Monitoring
Corrosion Control Optimization
Public Education
Source Water Monitoring & Treatment
Replacement of Lead Service Lines
State Reporting and Recordkeeping
Primacy and Implementation
NPDWR = National Primary Drinking Water Regulations
For each section, except Primacy and Implementation, we will present:
LCR basic requirements
Minor revisions
Compliance examples
SDWIS reporting
In the Primacy and Implementation Section, we will review primacy revision
application requirements, discuss special primacy conditions of the LCRMR,
and recap those provisions that must be adopted for a State to maintain primacy
compared to those that cannot be implemented unless adopted.
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Lead and Copper Tap Monitoring
Overview
Required for all CWSs and NTNCWSs
Systems divided into 3 size categories
Size
Small
Medium
Large
No. of People Served
< 3,300
3,301 - 50,000
> 50,000
Size impacts rule requirements
Samples collected at kitchen/bathroom taps
Sample results dictate other requirements
Lead and copper tap monitoring applies to all CWSs and NTNCWSs.
Systems are divided into 3 broad size categories (large, medium, and small). System size
is a factor in determining the number of samples that must be collected, as well as the
applicability and timing of some of the provisions.
Size
Small
Medium
Large
No. of people served
less than or equal to 3,300
3,3Q1 to 50,000
more than 50,000
Most regulations require sampling at entry points to the distribution system. Because lead
and copper in drinking water is primarily due to the corrosion of distribution and
household plumbing materials, tap water samples are collected at kitchen or bathroom
taps of residences and other buildings. This requirement significantly complicates sample
collection, requiring systems to coordinate with the people they serve.
As will be discussed in more detail in the slides that follow, tap monitoring results are the
primary driving force for determining a system's ongoing monitoring requirements and
whether it needs to undertake any of the treatment technique requirements.
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Lead and Copper Tap Monitoring
Site Selection
Sample from Highest Risk Homes
(TieM)
Copper pipes with lead solder
installed after 1982
Lead pipes
Lead service lines
Systems must sample at locations where the highest lead levels are likely to be found.
The LCR established a tiering system for prioritizing sampling sites (see boxes below).
materials evaluation is required to help classify sampling sites into tiers.
CWSs
Tier 1 sampling sites are single family structures:
with copper pipes with lead solder installed
after 1982 or contain lead pipes; and/or
that are served by a lead service line.
Note: When multiple-family residences comprise
at least 20% of the structures served by a water
system, the system may count them as Tier 1 sites.
Tier 2 sampling sites consist of buildings,
including multiple-family residences:
with copper pipes with lead solder installed
after 1982 or contain lead pipes; and/or
that are served by a lead service line.
Tier 3 sampling sites are single family structures
w/ copper pipes having lead solder installed
before 1983.
NTNCWSs
Tier 1 sampling sites consist of buildings:
with copper pipes with lead solder
installed after 1982 or contain lead
pipes; and/or
that are served by a lead service line.
Tier 2 sampling sites consist of buildings with
copper pipes with lead solder installed before
1983.
Tier 3: Not applicable.
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Lead and Copper Tap Monitoring
Site Selection
CWS: Collect Tier 1 -» Tier 2 -» Tier 3
NTNCWS: Collect Tier 1 -» Tier 2
Minimum number of required sites
identified by rule
Under the LCR, systems were required to complete their sampling pool with Tier 1 sites. If
they could not find enough Tier 1 sites, then they were to use Tier 2 sites, followed by Tier
3 sites (CWSs only). In addition, systems with LSLs in their distribution system were
required to collect at least half of their samples from sites served by LSLs. Systems whose
samples did not contain all Tier 1 sites or an insufficient number of LSLs were required to
send a letter to the State explaining why they could not identify enough of these sites.
Faucets with point-of-use devices or homes with point-of-entry treatment devices that are
designed to remove inorganic contaminants cannot be used as sampling sites.
Once monitoring begins, a system must use the same sites, unless the site is no longer
accessible to the system or no longer fits the requirements of a priority site.
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Lead and Copper Tap Monitoring
Sample Collection Method
First draw
6-hour standing time
1 liter
Residents can collect
samples
Sampling must comply with specified sampling techniques and analytical methods.
Under the LCR, all lead and copper tap samples were required to be:
1 liter in volume
collected at inside tap that was used for drinking water (residence at kitchen or
bathroom)
collected after the water had stood motionless in the plumbing for at least 6 hours
collected without flushing the tap.
One sample is collected from each sampling location.
Residents were allowed to collect the samples. In instances where this was done, the system
had to instruct the homeowner on proper sampling procedures. Systems were also required to
submit to the State with their lead and copper results, a certification that homeowners received
these instructions.
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Lead and Copper Tap
Monitoring
Minimum Number of Tap Samples
System
(Population)
>100,000
10,001 to 100,000
3,301 to 10,000
501 to 3,300
101 to SOO
MOO
No. of Sampling
Sites
(Routine)
100
60
40
20
10
5
No. of Sampling
Sites
(Reduced)
50
30
20
10
5
5
This represents the minimum number of sampling sites. Systems may collect
from additional sampling locations if they meet the sample selection criteria.
Systems must collect the routine number of sites unless they qualify for reduced
monitoring.
Note: A system serving 100 or fewer people is required to collect
a minimum number of 5 samples regardless of whether or not it is
on reduced monitoring.
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Lead and Copper Tap Monitoring
Action Levels
Lead
Copper
0
1
.015 mg/L
.3 mg/L
* Measured at 90th percentile (e.g., if 100
samples, no more than 10 may exceed
action level)
Exceedance of an AL is not a violation
Lead and copper analytical results are evaluated against an action level, not an MCL. The
90th percentile level cannot be higher than the action level. That is, no more than 10
percent of the samples can be higher than the action level. All samples that meet the
proper site selection and sample collection procedures are used to determine the 90th
percentile calculation, even if the system samples more sites than required.
If exceed lead AL, system must;
Begin corrosion control treatment steps which
includes WQP monitoring
Conduct source water monitoring and install source
water treatment if needed
Deliver public education
Replace LSL if system still exceeds lead action
level after installing treatment
If exceed copper AL. system must;
Begin corrosion control treatment steps which
included WQP monitoring
Conduct source water monitoring and install
source water treatment if needed
Public education and lead service line
replacement are not required.
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5/15/00
Lead and Copper
Tap Monitoring
How to Calculate 90th Level: > 5 Samples
Step 1: Place lead or copper results in ascending
order
Step 2: Assign each sample a number, 1 for lowest
value
Step 3: Multiply the total number of samples by 0.9
Example: 20 samples x 0.9 = 18th sample
Step 4: Compare 90th percent!le level to the action
level
Step 1: Place all lead results or copper results for one monitoring period in ascending order.
The 90th percentile values for lead and copper are determined separately.
Step 2: Assign each sample a number, with 1 being the sample with the lowest value.
Step 3: Multiply the total number of samples by 0.9 to determine the 90th percentile level.
EXAMPLE
Assume the system was required to collect 20 samples. Multiply the number of
samples by 0.9 or expressed as an equation:
20 samples x 0.9= 18th sample
In this example, the 18th sample is the 90th percentile level.
Step 4: Compare the 90th percentile level to the action level. In this example, the system or
State would compare the 18th highest sample for lead and for copper to their
respective action levels to determine whether an exceedance occurred.
Note: Some systems may collect more than the minimum requirement. In this case
the 90th percentile level is still computed by multiplying the number of samples by
0.9. When the 90th percentile sample is not a whole number (e.g., 22 samples x 0.9
- 19.8), the 90th percentile sample can be determined using rounding (20th sample)
The 90th percentile level can also be calculated using interpolation.
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Lead and Copper
Tap Monitoring
How to Calculate 90th Level: 5 Samples
Step 1: Place lead or copper results in ascending
order
Step 2: Take the average of the 4th and 5th highest
samples
Step 3: Compare 90th percentile level to the action
level
Step 1: Place all lead results or copper results for one monitoring period in
ascending order. The 90th percentile values for lead and copper are
determined separately.
Step 2: For systems collecting 5 samples, the 90th percentile level is computed
by averaging the 4th and 5th value. This is the only time that the 90th
percentile level is determined using the average.
Step 3: Compare the 90th percentile level to the action level.
Note: Systems that are required to collect a minimum of 5
samples must collect 5 samples even if 5 taps are not available.
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Lead and Copper Tap Monitoring
Initial Monitoring
Start Dates for Monitoring
Jan. 1992: Large Systems (> 50,000)
July 1992: Medium-Size Systems (3,301-50,000)
July 1993: Small Systems (< 3,300)
6-month monitoring periods (Jan - June),
(July - December)
The LCR specifies dates by which a system was required to begin monitoring. The
date was dependent on the size of the system and was specified for discrete 6-month
monitoring periods that ran from Jan to June and from July to December.
Large systems are required to conduct two, 6-month rounds of monitoring.
Small or medium systems are required to conduct one, 6-month round of monitoring.
- If the system is at or below the lead or copper action level, it is required to conduct
a second round of monitoring during the next 6 months.
- If the system is above the lead or copper action level, it is not required to conduct
lead and copper tap monitoring until it completes installing corrosion control
treatment.
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5/15/00
WQP Monitoring
Initial Monitoring
Required for all large systems
Required for small/medium systems if
exceed an AL
Sample site locations
-representative taps (e.g., coliform sites)
-entry points to the distribution system
2 samples per site
Used to assist in determining optimal CCT
For all large systems, initial WQP monitoring occurs during the same 6-month monitoring
periods as initial tap monitoring. Small and medium systems that exceed the lead and/or
copper action level must monitor before the end of each six-month initial tap monitoring
period during which the action level is exceeded.
WQPs are used to determine the corrosivity of the water in the system, and if needed to
help the State determine the type of corrosion control that a system should install and how
the system should operate this treatment. WQPs include:
pH
alkalinity
calcium
conductivity
water temperature
orthophosphate and/or silica, when inhibitors are used
WQPs monitoring occurs at:
taps to get samples that are representative of water quality throughout the
distribution system (systems can use same sites as ones used for lead and copper
tap monitoring or those used for total coliform sampling) and
entry points to the distribution system to get samples that are representative of the
source after treatment. (If 2 or more sources are combined before distribution,
sample must be representative of all sources used.)
During initial WQP monitoring, 2 samples are collected at each tap and entry point
location. Sampling should occur on different days.
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5/15/00
WQP Tap Monitoring
Minimum Number of Tap Samples
System
(Population)
>100,000
10,001 to 100,000
3,301 to 10,000
501 to 3,300
101 to 500
>100
No. of Sampling
Sites
(Routine)
25
10
3
2
1
1
No. of Samples
50
2.0
6
4
2
2
The rule specifies the minimum number of WQP tap sampling sites. 2 samples
must be collected from each sampling site. This monitoring should occur on
different days. Systems may collect from additional sampling locations.
Systems must collect the routine number of samples unless they qualify for
reduced monitoring.
We will discuss WQP monitoring that occurs after the installation of corrosion
control treatment and how a system qualifies for reduced WQP tap monitoring
in the Corrosion Control Optimization Section.
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5/15/00
Reduced Monitoring for Pb/Cu
Criteria
Systems serving
< 50,000
Any size system
that is required to
collect WQPs
Criteria Frequency
Meets both action levels Annual
for 2 consecutive 6-months
Meets both action levels Triennial
for 3 consecutive years
Meets OWQPs for 2 An n ual
consecutive 6-months
Meets OWQPs for 3 Triennial
consecutive years
Small and medium-size systems (those serving < 50,000 people) can reduce to annual
monitoring at the reduced number of sites if:
1. They are below the lead and copper action level for 2 consecutive, 6 months, or
2. They have installed corrosion control treatment and meet their optimal water quality
parameters (OWQPs) for 2 consecutive 6-month monitoring periods.
OWQPs = specific ranges or minimums that are determined by the State for each relevant
WQP that indicate that a system is operating corrosion control treatment at a level that
most effectively minimizes corrosion in the distribution system. OWQPs will be
discussed in more detail in the next section of the presentation.
Large systems (serve > 50,000 people) can only reduce to annual monitoring if they
meet their OWQPs for 2 consecutive 6-monitoring periods.
Small and medium-size systems (those serving < 50,000 people) can reduce to triennial
monitoring (once every 3 years) at the reduced number of sites if:
1. They are below the lead and copper action level for 3 consecutive years, or
2. They meet their OWQPs for 3 consecutive years (if applicable).
Under the LCR, large systems (serve > 50,000 people) can only reduce to triennial
monitoring if they meet their OWQPs for 3 consecutive years.
Note: A system that is on reduced lead and copper tap monitoring must revert to 6 month tap
monitoring at the routine number of sites, if it exceeds either action level or, if applicable,
does not meet its OWQPs. It can return to reduced monitoring if it again meets the criteria
listed above.
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5/15/00
LCR Minor Revisions
Changes to Sampling Pool
O Systems without enough tiered sites must
use representative sites
Systems without enough first-draw
sample sites
- Must collect non-first-draw samples from sites
with longest standing times
- State can waive need for prior approval
Olmplement on April 11,2000
Use Representative Sites
The LCRMR clarify that a CWS without enough Tier 1,2, or 3 sampling sites, or a NTNCWS without
enough Tier 1 or 2 sites must complete its sampling pool with representative sites. A representative site is
one in which the plumbing materials used at that site would be commonly found at other sites served by
water system.
This revision also clarifies that all systems are required to collect samples from a minimum number of sites,
even if a sufficient number of high-risk sites are not available. This means that a system with fewer than
five taps will need to collect more than one sample from a given tap on different days to meet minimum
sampling requirements. There can be variability in lead and copper levels at different taps within the same
building and even at the same tap at different points in time
Systems that cannot locate enough "tiered" sites should add to their sampling pool those sites with copper
plumbing installed subsequent to local implementation of the lead ban (typically 1988 or 1989), provided
these sites can be considered "representative".
Use of Non-First-Draw Samples
Addresses problems of NTNCWSs and some CWSs (such as prisons or hospitals) that may not have
periods of normal operation where the water has stood motionless for at least 6 hours. These systems must
collect as many first-draw samples as possible and remaining ones from sites with the standing times that
are as close to 6 hours as possible. Samples must be 1 liter in volume and collected from interior taps.
States can require the system to receive up-front approval for this sampling plan or waive the up-front
requirement. If States:
Require prior approval, the system must provide written documentation that identifies sampling
times and locations of the non-first-draw samples which the system proposes to use to complete its
sampling pool prior to sampling.
Do not require prior approval, the system must identify each site that did not meet the 6-hour
minimum standing time and the length of standing time for that particular sample, and submit this
information at the same time that it submits its lead and copper tap sample results. 14
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LCR Minor Revisions
Systems on Reduced Monitoring
LCR
Reduced sampling sites not
specified
No notification if change
source or treatment
Must request permission if
meet OWQPs
Sample collection limited to
June - Sept
No accelerated monitoring
LCRMR
O Must use representative sites
& State can specify sites
O Must notify State of change in
source or treatment
No longer need to request
permission
State may designate alternate
period
Accelerated monitoring
©Implement on April 11, 2000
Use of Representative Sites
LCRMR clarify that the reduced sampling sites must be representative of those used
during standard monitoring. States have the option of specifying where these samples
must be collected.
Change in Treatment or an Addition of a New Source
Any system that monitors less frequently than every six months must notify the State of a
change in treatment or an addition of a new source. They must provide the State with this
information within 60 days after making the change, unless the State requires earlier
notification. States also have the discretion to require additional monitoring or other
actions to ensure optimal corrosion control treatment is maintained.
Request for Reduced Monitoring
Systems subject to WQP monitoring are no longer required to request reduced monitoring
status from States. However, States must notify the system in writing when they
determine a system is eligible to begin reduced lead and copper tap monitoring. This
change applies to both annual and triennial reduced monitoring.
Systems serving 50,000 or fewer people that are below the lead and copper action levels
are automatically eligible for reduced monitoring. This has remained unchanged from the
1991 Rule.
Alternate Period/Accelerated Reduced Monitoring
The State's designation of an alternate monitoring period and accelerated monitoring are
discussed in more detail on the next two pages.
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5/15/00
LCR Minor Revisions
Reduced Monitoring (Continued)
States can approve alternate monitoring
period
Should assist seasonal NTNCWSs
Alternate period must be:
- < 4 consecutive months
- time of normal operation when highest likely
lead levels
Transition period specified
States can approve a sampling period other than June through September for systems that are on
reduced monitoring. States must keep records of these decisions.
This revision should assist seasonal NTNCWSs that do not operate during summer months
because these systems would no longer need to make special arrangements to collect samples.
The alternate period must:
be no longer than 4 consecutive months;
represent a time of normal operation, when highest levels of lead are most likely to occur
(not required for NTNCWSs if the State does not know this information).
Note: If a State plans to specify alternative periods for CWSs, it must outline
how it will determine when the highest lead levels are likely to occur, as a special
primacy consideration in its primacy package.
LCRMR specify a one-time transition period for switching to the new monitoring period:
Systems monitoring annually must collect their next round of samples no later than 21
months after the previous round.
Systems monitoring triennially must collect their next round of samples no later than 45
months after the previous round.
Small systems with monitoring waivers must collect their next round of samples before the
end of the 9-year period. (Monitoring waivers are discussed in detail later this
presentation.)
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5/15/00
LCR Minor Revisions
Accelerated Reduced Monitoring
Allowed if 90th percentile levels for two
consecutive 6-months are:
Lead
< 0.005 mg/L
Copper < 0.65mg/L
System goes directly to triennial monitoring
State approval not required
The LCRMR contain an accelerated reduced monitoring provision. It allows systems to
reduce lead and copper tap sampling to once every 3 years and to collect samples at the
reduced number of sites after only 2 consecutive 6-month periods of monitoring, if they
have the following 90th percentile lead and copper levels at the tap:
lead level of less than or equal to 0.005 mg/L; and
copper level of less than or equal to 0.65 mg/L
This provision may benefit new systems, in addition to those water systems that are in the
process of installing CCT and whose 90th percentile lead and copper levels meet the
criteria for accelerated reduced monitoring after conducting the required two rounds of
follow-up sampling subsequent to the installation of corrosion control treatment. It will
also be available for systems that are triggered into a new set of two six-month rounds of
full tap sampling due to changes in treatment or source water.
EPA decided not to allow accelerated reduced monitoring for one contaminant when the
other contaminant has a 90th percentile level above the specified threshold level. The
rationale for this decision is that there is less of a risk that there may be an undetected
problem if both lead and copper levels are below the threshold levels than if only one of
the contaminant levels is less than the threshold level and that there is more uncertainty in
the case where one of the contaminant levels is higher than the threshold level.
The LCRMR do not require systems to obtain prior State approval to monitor on this
accelerated schedule.
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5/15/00
LCR Minor Revisions
Sample Invalidation
States may invalidate tap sample if:
Improper sample analysis
Site selection criteria not met
* Sample container damaged
Sample subjected to tampering
A system may request that a State invalidate a lead or copper tap sample if it can
document that at least one of the following conditions has occurred:
The laboratory documents that the sample was analyzed improperly.
The sample was taken from an improper site.
The sample container was damaged in transit.
The sample was subject to tampering.
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5/15/00
Sample Invalidation
Documentation
System can request sample invalidation if:
- All sample results are presented to State
- Documentation is provided for samples to be
invalidated
State decision to invalidate sample:
- Must be in writing
- Cannot be made based on earlier sample
results
Invalidated samples not counted for
compliance
To request sample invalidation, a system must report the results of all the samples to the
State, and provide supporting documentation for all the samples it believes should be
invalidated.
The State must present its decision on whether or not to invalidate a sample in writing.
The State cannot invalidate a sample simply because the results of a sample are higher or
lower than that of a sample from the same location that was collected in a previous
monitoring period.
The State must maintain any records of sample invalidation requests and decisions.
Invalidated samples do not count for compliance and should not be included in the 90th
percentile calculation.
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"5/15/00
Sample Invalidation
Replacement Samples
Must be taken:
- If needed to meet minimum sampling
requirements
- Within 20 days after invalidation or by end of
monitoring period, whichever is later
- From same locations, if possible
Cannot be used for subsequent monitoring
period
Systems are only required to collect replacement sample(s) when they would have too few
samples to meet minimum sampling requirements due to the invalidation of their
sample(s).
Replacement samples are taken no later than 20 days after the date the sample was
invalidated, or by the end of the monitoring period, whichever occurs later.
Replacement samples are taken from the same locations as the invalidated samples, or if
the system cannot do this, at locations that have not already been used for sampling
during that monitoring period.
Systems cannot use these replacement samples to meet the monitoring requirements of a
subsequent monitoring period. For example, 2 replacement samples are collected in July
2001 for 2 invalidated samples that were collected during the January to June 2001
monitoring period. The system cannot include these 2 replacement samples as part of
their samples for July to December 2001.
Note: If a system is on annual monitoring and the date on which the State invalidates the
sample does not allow the system to collect a replacement sample during June -
September, the system can collect the replacement sample outside the June - September
time period, as long as it is collected no later than 20 days after the date the sample was
invalidated, or by the end of the monitoring period, whichever occurs later. For example,
the State invalidates the sample on October 15, 2000. The system has until November 4,
2000 (i.e., 20 days after the State's invalidation decision) to collect the replacement
samples.
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5/15/00
LCR Minor Revisions
Monitoring Waivers
Applies to systems serving < 3,300 people
Reduces tap monitoring to once every 9
years
Systems must meet specific materials and
monitoring criteria
States must grant approvals in writing
States can require additional activities as
waiver condition
States can grant monitoring waivers to small systems serving 3,300 or fewer people that
would allow these systems to conduct lead and/or copper tap monitoring once every 9
years. To quality, systems must meet specific materials and monitoring criteria.
Systems cannot start monitoring according to the waiver until they receive approval from
the State in writing. States can also require the system to perform additional activities, as
a condition of the waiver.
States must keep records of all decisions pertaining to waivers.
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Monitoring Waivers
Types
Types of monitoring waivers
Full waiver: both lead and copper
Partial waiver: lead or copper only
Pre-existing waiver: granted prior to 4/11/00
Types of monitoring waivers
To qualify for a full waiver (for both lead and copper), systems must certify to the State
and provide supporting documentation to the State that they meet specific materials
criteria for lead and copper in their distribution system and drinking water plumbing.
I
To qualify for a partial waiver for either lead or copper, systems only need to meet the
materials criteria for that particular contaminant for which they are requesting a waiver.
The monitoring schedule is not affected for the contaminant for which the system did not
receive a waiver.
Pre-existing waivers were granted by some States based on guidance provided to EPA
Regions in 1995. [U.S. Environmental Protection Agency. Apr. 4, 1995. Memo from
Robert J. Blanco, Director, Drinking Water Implementation Division, to O. Thomas Love,
Chief, Water Supply Branch, Region 6. All Plastic Systems Compliance with the Lead
and Copper Rule.] A pre-existing waiver is a lead and copper monitoring waiver that was
granted prior to the effective date of the LCRMR of April 11,2000.
In some cases, before granting the pre-existing waiver, States required a system to
conduct at least one round of standard tap water monitoring. Under the LCRMR, pre-
existing waivers will remain in effect as long as the water system meets the ongoing
waiver monitoring requirements and continues to meet the plumbing material eligibility
requirements.
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5/15/00
Monitoring Waivers
Materials Criteria
Applies to distribution system, service lines, drinking
water supply plumbing, including within
homes/buildings served
* Lead criteria:
- No plastic pipes w/ lead plasticizers or plastic service lines w/
lead plasticizers,
- No LSLs, lead pipes, lead soldered pipe joints, leaded brass
or bronze fittings and fixtures (unless meet lead-leaching std)
Copper criteria: no copper pipes or service lines
System must certify, with appropriate supporting documentation, that the distribution
system and service lines and all drinking water supply plumbing, including plumbing
conveying drinking water within all residences and buildings connected to the system, are
free of lead-containing and copper-containing materials.
A system is considered to be free of lead-containing materials if it contains no plastic
pipes with lead plasticizers or plastic service lines with lead plasticizers and if it is free of
lead service lines, lead pipes, lead soldered pipe joints, and leaded brass or bronze fittings
and fixtures, unless such fittings and fixtures meet the specifications of any lead-leaching
standard established pursuant to 42 U.S.C. 300g-6(e) (SDWA section 1417(e)).
Currently NSF Standard 61, Section 9 meets this criteria.
NSF standard 61, section 9 limits the amount of lead that is allowed to be released (or
leached) into drinking water from endpoint devices used to dispense drinking water such
as faucets. NSF and other organizations test products such as faucets to determine
whether they meet this standard. Those products that meet this standard carry a
certification mark.
Systems are considered free of copper-containing materials if they contain no copper
pipes or copper service lines.
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Monitoring Waivers
Monitoring Criteria
Must have completed one 6-month round of
monitoring since meeting materials criteria
Pre-existing waivers granted without monitoring
required must complete round by 9/30/2000
90th percentile levels must be
Lead criteria: < 0.005 mg/L
Copper criteria: < 0.65 mg/L
Must continue to monitor once every 9 years
New waivers
Systems must have completed at least one 6-month round of standard tap water
monitoring for lead and copper, subsequent to becoming free of lead-containing and
copper-containing materials, at sites approved by the State and from the number of sites
required for standard monitoring. 90th percentile levels must be:
< 0.005 mg/L (to qualify for a full waiver or for a partial waiver for lead).
< 0.65 mg/L for copper (to qualify for a full waiver or for a partial waiver for
copper).
Systems must continue to monitor once every 9 years.
Pre-existing waivers
If a pre-existing waiver was granted and 1) monitoring was not required as a condition of
the waiver or 2) the system conducted monitoring in which its lead and copper 90th
percentile levels were not < 0.005 mg/L and < 0.65 mg/L, respectively, the system must
complete a round of standard monitoring by 9/30/2000.
The lead and copper 90th percentile levels must meet the lead and copper
monitoring criteria listed above in order for the system to remain eligible for a
monitoring waiver.
If the system satisfies the monitoring criteria, it must continue monitoring once
every 9 years.
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Monitoring Waivers
Renewal
Recertification every 9 years, with
monitoring results
Renewed automatically if system still
meets criteria
Waiver renewals
Systems must submit a re-certification that they are lead-free and/or copper-free
every nine years, along with their lead and copper tap water results and 90th
percentile calculations. States can require this information sooner.
If system still meets criteria, waiver is renewed automatically.
EPA has developed guidance document to assist States and small water
systems understand the monitoring waiver provisions. This document is
entitled, Monitoring Waivers under The Lead and Copper Rule Minor
Revisions for Systems Serving 3,300 or Fewer People, April 2000, EPA
815-R-99-021.
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Monitoring Waivers
Other
Notification within 60 days by system
- If change in treatment or adds source
- If no longer meets materials criteria
Waiver revocation must be in writing
- If due to AL exceedance, must begin CCT steps
- If other than AL exceedance-^ triennial
monitoring
Notification within 60 days by the system
If a system has received a waiver, and later adds a new source or changes
treatment, it must notify the State in writing within 60 days after the change,
unless the State requires earlier notification. A State may add to or modify the
waiver conditions, if the State deems it necessary.
If a system becomes aware that it is no longer free of lead-containing or copper-
containing materials, it must notify the State in writing within 60 days.
Waiver revocation must be in writing
If a State revokes a waiver, it must notify the system in writing and include the
basis of its decision.
If the reason is due to an action level exceedance, the system must implement
CCT and follow the CCT deadlines specified in §141.81(e) for medium and small
systems.
If the reason is other than an action level exceedance, the system must collect
lead and copper tap samples at least triennially, using the reduced number of
sample sites.
A system may reapply for another waiver if it subsequently meets the waiver
criteria.
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LCR Minor Revisions
Sample Analysis
Holding time has been revised to be
consistent with other metals
Refers to minimum time allowed after
samples have been acidified and before
analysis
Holding time for acidified samples
The LCRMR make the minimum holding time for lead and copper samples consistent
with that for other metals. The minimum holding time refers to the length of time a
sample must remain in its original container after it has been acidified and before it can be
analyzed. The impact of this provision is a reduction in the holding time from 28 hours
to 16 hours.
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LCR Minor Revisions
System Reporting
State calculation of 90th percentile levels:
- States must notify system
- Systems must provide sampling results by
deadline
- States must provide 90th percentile calculation
to system before monitoring period end
- State can incorporate schedule into regulations
Other changes to system reporting requirements were discussed on previous slides.
These included elimination of redundant or unnecessary requirements, and new
documentation that must be provided by systems. The summary of system reporting
changes are provided in Section 9 of your notebook.
Elimination of system calculation and reporting of 90th percentile levels
States have the flexibility to eliminate the requirement that systems calculate and
report 90th percentile lead and copper values for all monitoring periods. Some States
may already verify these calculations for some systems. States can eliminate this
calculation for all or some subset of systems if:
1. States notify the system in advance that they will calculate the 90th percentile
levels and have specified when the system must provide them with tap water
results (must be prior to end of monitoring period).
2. The system provided the results of all tap water samples by the deadline specified
by the State, including each sampling site location, site selection criteria, and
identification and explanation of any changes to sampling sites.
3. States must provide the results of the calculations in writing, to the system before
the end of the monitoring period to allow them to take timely additional action if
needed (e.g., WQP monitoring).
States can incorporate directly into their regulations, the schedule that specifies when
the system must provide monitoring results/supporting documentation and when the
State will report the 90th percentile levels to the system.
The State's calculation of the 90th percentile level does not affect when monitoring or
contingent actions (e.g., WQPs, public education) must be completed. States must
maintain records pertaining to any State-calculated 90th percentile levels.
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LCR Minor Revisions
System Reporting (Continued)
Elimination of justification fetters for:
- Use of non-tier 1 sites
- Insufficient LSL sample sites
Elimination of sample certifications for:
- first-draw
- resident-collected samples
Systems are no longer required to send States justification letters when they collect
samples from other than Tier 1 sites or when fewer than 50% of their samples are from
sites with LSLs, lead pipes, or copper pipes with lead solder. Systems are also no longer
required to certify that each tap sample is first-draw or collected by residents was taken
after the water system informed the residents of the proper sampling procedures. EPA
eliminated these two requirements because it believes that continuing to require systems
to provide these letters every monitoring period imposes a burden that can no longer be
justified.
Systems should still retain in their files the information regarding the basis of their site
selection. States should review this documentation during on-site inspections.
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LCR Minor Revisions
Summary of Tap Monitoring &
Reporting Revisions
Changes to Sampling Pool
O Use of representative sites if insufficient tiered sites
- Use of non-first draw samples
Reduced monitoring
O Must use representative sites & State can specify sites
O Notification of change in treatment/new source
- No longer need to request permission for reduced Pb/Cu
after meeting OWQPs
- State may designate alternate period
- Accelerated reduced monitoring
©Implement on April 11, 2000
The LCRMR are contained in: Federal Register, Vol. 65, No. 8.
Drinking Water Regulations; Maximum Contaminant Level Goals and
National Primary Drinking Water Regulations for Lead and Copper; Final
Rule; (Wed., Jan 12, 2000)
LCRMR Revision
Use representative sites, if system has
insufficient number of tiered sites,
Use of non-first draw samples & associated
system reporting requirements
Reduced sampling sites must be
representative & State can specify location
Report change in treatment of new source
for systems on reduced monitoring
System no longer submit written request for
reduced lead and copper tap monitoring
when meeting OWQPs
Alternate period for reduced monitoring
Accelerated reduced monitoring
Where to Find It
§§141.86(a)(5)&(7)
§ 141.86(b)(5) & 141.90(a)(2)(i)-(ii)
§§141.86(c)&(d)(4)(iv)
§§141.86(d)(4)(vii)&(g)(4)(iii),
§141.90(a)(3)
§14L86(d)(4)(iv)(A)
§141.86(d)(4)(v)
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LCR Minor Revisions
Summary of Tap Monitoring &
Reporting Revisions (Continued)
Sample Invalidation
Monitoring waivers
Reduced holding time
Reporting changes
- elimination of sampling justifications
- elimination of sample collection certifications
- 90th percentile calculation by State
LCRMR Revision
Sample invalidation & associated system
reporting requirements
Monitoring waivers & associated system
reporting requirements
Reduced holding times for acidified
samples prior to analysis
State calculation of 90th percentile level
Other system reporting requirements for
lead and copper tap monitoring and WQP
monitoring
Where to Find It
§§141.86(f) & 14L90(a)(l)(ii)
§§141.86(g)&
§141.86(b)(2)
§141.90(h)
§141.90(a)
Remember: States have the option to adopt all, some, or
none of the provisions that are less stringent than the LCR.
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\
/
Lead and Copper Tap
& Initial WQP
Compliance Examples
/
\
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Applicable Reporting
Requirements
Sample Records
. PB90 - Lead 90th percentile levels
CU90 - Copper 90th percentile levels
Violations
51 - Initial lead and copper M/R
52 - Follow-up/routine lead and copper M/R
53-WQPM/R
Initial Lead and Copper M/R SNC - 51
Samples
All lead 90th percentile non-exceedances must be reported as sample records. In addition, all lead and copper
90th percentile exceedances should be reported as sample records. In the past, lead exceedances could be
reported as either a milestone or sample record. Copper exceedances were reported as milestone records.
Until January 11,2002, SDWIS/FED will convert lead or copper exceedances that are reported as milestone
records to sample records. After this date, lead or copper exceedances must be reported as sample records or
they will be rejected.
Violations (Contaminant Code = 5000)
Violation that pertain to lead and copper tap monitoring and initial WQP monitoring are:
51 violation = initial lead and copper tap monitoring and reporting (M/R) violation
52 violation = follow-up or routine lead and copper tap M/R violation
53 violation = initial WQP M/R
Compliance Portrayal:
The begin date for the 51 amd 52 violations is the day after the compliance period. The end date is defaulted to
December 31,2015 until return to compliance (RTC) is reported and linked to violation. For the 53 violation,
the begin and end date of the compliance period is the first and last day, respectively, of the designated 6-
month compliance period.
Significant Noncompliers (SNCs)
An Initial Pb/Cu Tap M/R is based on amount of time a system is out of compliance
Definition: A system which has not returned to compliance and/or which does not have a RTC record reported
to SDWIS/FED (properly linked to the appropriate violation) within:
3 months for large systems,
6 months for medium systems, and
* 12 months for small systems.
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Applicable Reporting
Requirements
Lead Results
ALL Lead 90th Percentile Results (Pb90)
required for all Large and Medium systems
Reporting of Lead 90th Percentile
Exceedances for Small systems continues
Large system serves more than 50,000 persons
Medium System serves 3,301 to 50,000 persons
Small system serves 3,300 persons or fewer
i
New requirement for ALL 90th percentile results to be reported for
Medium sized systems.
Only lead 90th percentile exceedances are required to be reported
for Small systems; however; all values will be accepted if reported.
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Applicable Reporting
Requirements
Copper Results
* Copper 90th Percentile (CU90) Exceedances
now reportable as Sample
Copper 90th Percentile (CU90) Milestone will be
converted to a Sample until January 11, 2002
Non-exceedances will not be accepted
CU90 Sample is new ... previously reported 90th percentile
exceedance as a Milestone and ONLY a Milestone ... SDWIS/FED
had no capability to accept a CU90 Sample prior to the LCRMR
implementation
Copper exceedances which are submitted as Milestones will be
converted to Sample records until January 11, 2002. After that date
they will be rejected.
SDWIS/FED does not accept copper sample or milestone records
which do not exceed the Copper action level.
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Applicable Reporting
Requirements
Initial Tap M/R (51)
Contaminant Code "5000"
Violation Type Code "51"
* Compliance Portrayal Changed
RTC Requires 2 consecutive, 6-month rounds
Affects New Systems and Pre-Existing Waivers
SNC condition
Compliance portrayal has changed for Initial Tap violations. The violation begins the first
day after the missed designated monitoring period. Previously, you would have reported one
violation for each of the two 6-month periods. Now a single violation is reported. This
change affects systems which have never monitored and new systems.
A system will return to compliance (RTC) when it meets all appropriate M/R requirements as
mentioned above, for two consecutive 6-month monitoring periods. Previously, when a
system incurred a M/R violation and subsequently conducted the required monitoring, it was
considered "returned to compliance". However this is inconsistent with the regulation which
requires two consecutive 6-month rounds of monitoring to achieve compliance with the Initial
Tap monitoring requirements. The same applies to Follow-Up monitoring and the first set of
Routine monitoring requirements. Therefore, we are changing the definition for returned to
compliance for these monitoring conditions. Previously reported violations and RTC data
need not be changed. New violations for these requirements must be reported in this manner.
Therefore, a single 51 violation will cover the first day after the first missed designated
monitoring period through sampling completion of the second 6-month consecutive
designated monitoring period. The only exception to the requirement for two consecutive 6-
month rounds of sampling is for those medium and small systems which exceed the action
level. These systems have basically completed their monitoring requirements because they
are now triggered into CCT activities.
Once a system is reduced to annual or triennial monitoring, or is granted a monitoring waiver,
the old RTC definition applies. A system with a "pre-existing" monitoring waiver which fails
to meet the September 30, 2000 Initial Tap monitoring deadline will return to compliance
when it subsequently completes all monitoring requirements.
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Applicable Reporting
Requirements
Lead and Copper Initial Tap SNC
Initial Tap (51) Violation qualifies for SNC
when the system fails to complete Initial
Tap Monitoring and/or RTC within:
* Large: 6 months + 3 months
Medium: 6 months + 6 months
Small: 6 months + 12 months
Implementation of the LCRMR retains the additional time for a system to
return to compliance prior to it being designated as a significant noncomplier
(SNC).
The SDWIS/FED algorithm not only considers the time periods referenced
above, it adds an additional quarter of time before it queries the violations to
allow RTC actions which may have been reported at the end of the period to
be posted to SDWIS/FED due to EPA's normal one quarter reporting lag. The
bottom line is, EPA gives LCR violation reporting every opportunity to RTC
BEFORE EPA designates SNCs.
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Applicable Reporting
Requirements
Follow-up/Routine Tap M/R Violations
Contaminant Code "5000"
- Violation Type Code "52"
Follow-Up and Routine Monitoring
Compliance Portrayal Changed
RTC Sometimes Requires 2
consecutive 6-month rounds
NOT SNC condition
Basically the same as Initial Tap violations. The exceptions are:
Once a system achieves reduced monitoring (annual, triennial, or 9-
year), and for those systems which were granted a pre-existing waiver
(when only one round of monitoring is required) the system would
naturally return to compliance whenever it met all of the requirements
in the next round of designated monitoring.
This violation type is not an SNC condition.
Note: New violation condition for Routine monitoring/reporting. Once a
system is on routine monitoring, a system has 60 days from the addition of a
new source or a change in treatment to notify the State of the change. Failure
to do so is to be reported as a 52 violation.
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Applicable Reporting
Requirements
Enforcement/RTC
Formal Enforcement Follow-up actions
are Required Reporting
* Enforcement/follow-up action must be
linked to the violation
Compliance Period/ Violation Period End
Date is replaced by the RTC action date;
therefore, RTC must be reported
All formal enforcement / follow-up actions are required to be reported to
SDWIS/FED. A returned to compliance, or "RTC", (BOX or SOX =
compliance achieved action) is classified as an "other" action type and is also
required reporting for this rule.
Because SDWIS/FED defaults a future compliance period/ violation period
end date of 12/31/2015 for these violations, RTC reporting is required. When
the RTC record is reported and LINKED to the violation, the defaulted end
date is replaced with the RTC enforcement/ follow-up action date. Therefore,
reporting RTC actions and the appropriate violation link data is required.
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Applicable Reporting
Requirements
Initial/Follow-up/Routine WQP M&R (53)
* Contaminant Code "5000"
Violation Type Code "53" (Consolidated 54, 55)
Traditional begin and end dates
New 6 month compliance period
RTC reporting required
Actual monitoring for tap and entry point WQPs occur on different monitoring
frequencies. A new 6-month fixed compliance period has been established for
both Monitoring and Reporting and Noncompliance violations of the OWQPs.
To eliminate some of the reporting and tracking burden associated with a
violation which could occur every 2 weeks, all entry point M/R violations for a
given system occurring in a given 6-month period will be reported as one
WQP M/R violation. Similarly, if a system incurs both a tap and entry point
M/R violation during the same 6-month compliance period, you would report a
single violation for the 6-month compliance period. On the other hand, if a
system incurred both entry point and tap WQP M/R violations with different
compliance periods which overlap, you would report two separate 53
violations, one for each period. Example to follow.
The begin and end dates are the first and last days of the designated 6 month
period. SDWIS/FED does not default the end date to 12/31/2015 for WQP
violations.
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Applicable Reporting
Requirements
WQP Monitoring
One 6-month violation Second 6-month violation
Jan
June
Entry Point
Sept
Annual Tap
Dec
Period of overlap
Pb/Cu Tap
Note: Compliance is based on 6-month period regardless of frequency
of tap or entry point compliance periods.
Although the compliance periods overlap, they are of different lengths and in
this instance, two 53 violations would be reported for this system. One
violation for the January through June which covers both tap and entry point
WQP violations and one for the July through December for the tap WQP
violations.
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90th Percent!le Example
System Collecting 5 samples - Question
Assume 5 samples are collected with lead results as
follows:
Sitel: 0.008 mg/L
Site 2: 0.011 mg/L
Site 3: 0.020 mg/L
Site 4 : 0.008 mg/L
SiteS: 0.008 mg/L
What is the 90th Percentile Value?
This example shows how to determine the 90th percentile level when a system
is required to collect 5 samples.
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90th Percentile Example
System Collecting 5 samples - Answer
Step 1: Order results from lowest to highest:
No 1: 0.008 mg/L
No 2: 0.008 mg/L
No 3: 0.008 mg/L
No 4: 0.011 mg/L
No 5: 0.020 mg/L
Step 2: Average the 4th & 5th samples highest
samples to get 90th percentile value = 0.016 mg/L
0.011 ma/L + 0.020 mq/L = 0.0155 mg/L
2
Step 3: Compare to lead action level -» Exceedance
For systems collecting 5 samples, the 90th percentile level is computed by
averaging the 4th and 5th value. This is the only time that the 90th percentile
level is determined using the average.
In this example, the 90th percentile level = 0.016 mg/L, as shown in the
equation below.
0.011 me/L + 0.020 mg/L = 0.0155 mg/L
2
This rounds to 0.016 mg/L
This system has exceeded the lead action level because its 90th percentile level
is higher than the lead action level of 0.015 mg/L.
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90th Percent!le Example
System Collecting More Than 5 samples- Question
Assume 10 samples are collected with lead results
as follows:
Sitet:
Site 2:
Site 3:
Site 4:
Site 5:
Site 6:
Site 7:
Site 8:
Site 9:
0.005 mg/L
0.015 mg/L
0.005 mg/L
0.014 mg/L
0.014 mg/L
0.005 mg/L
0.040 mg/L
0.014 mg/L
0.014 mg/L
What is the 90th Percentile Value?
Site 10: 0.005 mg/L
This example shows how to determine the 90th percentile level when a system
is required to collect more than 5 samples.
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90th Percentile Example
System Collecting More Than 5 samples - Answer
Step 1: Order results from lowest to highest
No. 1:
No. 2:
No. 3:
No. 4:
No. 5:
0.005
0.005
0.005
0.005
0.014
No 6: 0.014
No.7: 0.014
No.8: 0.014
No.9: 0.015*
No.10: 0.040
Step 2: Multiply number of samples by 0.9 to determine
which sample represents 90th percentile level
10 x 0.9 = 9th sample
Step 3: Compare to lead action level -» No Exceedance
In this example, the 90th percentile value is the 9th highest sample. The lead
level of this sample is 0.015 mg/L and is at the lead action level of 0.015 mg/L.
Therefore, the system has not exceeded the lead action level.
The same procedure is used to determine the copper 90th percentile level.
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90th Percent!le Example
System that Collects More Than Minimum
Rounding
Example
The system collects 22 copper samples.
The 19th highest sample = 1.2 mg/L, the 20th highest = 1.5 mg/L.
Determining, 90th percentile using rounding
1. 90th percentile copper level is determined at
22x0.9 = 19.8th sample.
2. Round to nearest whole number
3. 90th percentile is 20th highest sample = 1.5 mg/L.
For systems collecting more than the minimum number of samples, the 90th
percentile value can be determined using rounding or interpolation.
Using rounding
If our example, 22 samples are collected. The 90th percentile level is the
19.8th sample. Rounded up, the 90th percentile value is the 20th sample or 1.5
mg/L, which is an exceedance of the copper action level of 1.3 mg/L.
The next page shows how the 90th percentile level would be determined using
interpolation for this same set of data.
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90th Percentile Example
System that Collects More Than Minimum
Interpolation
Example
The system collects 22 copper samples.
The 19th highest sample = 1.2 mg/L, the 20th highest =1.5 mg/L.
Determining 90th percent!le using interpolation
1. 90th percentile copper level is determined at
22 x 0.9 = 19.8th sample.
2. Take difference between 19th and 20th sample:
1.5 -1.2 = 0.3 mg/L
3. Multiply by 0.8 =
0.8 x 0.3 = 0.24; rounded to 0.2
4. Add 0.2 to lower of 2 results = 90th percentile of 1.4 mg/L
Using interpolation
To determine the 90th percentile value using interpolation, you would:
1. Multiply the number of samples by 0.9 to determine which sample represents your 90th
percentile level. This step is the same regardless of whether you use rounding or interpolation.
22 samples x 0.9 = 19.8th sample
2. Subtract the difference between the two samples between which your 90th percentile falls. In
this example you subtract the 19th sample of 1.2 mg/L from the 20th sample of 1.5 mg/L.
1.5 mg/L - 1.2 mg/L = 0.3 mg/L
3. Multiply the difference by 0.8.
0.3 x 0.8 = 0.24 mg/L
When rounded to the number of significant figures, the difference is 0.2 mg/L. The sample is
0.8 higher than the 19th sample. If the 90th percentile was 19.6, the difference would be
multiplied by 0.6.
4. Add 0.2 to the lower of the two sample results, in this example to the 19th sample result of 1.2
m/L.
0.2+ 1.2 =1.4 mg/L
Using interpolation, the 90th percentile level is 1.4 mg/L.
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Exceedance Determination
Scenario
90th percentile values for tap monitoring between
January and June 2000:
Pb = 0.0142mg/L
Cu = 1.4 mg/L
1. Has the system exceeded the lead or copper AL?
The system exceeded the copper action level.
2. Is the system in violation?
No, an exceedance is not a violation.
Answer 1
The 90th percentile lead level is 0.0142 mg/L, which is below the lead action
level of 0.015 mg/L. The 90th percentile copper level is 1.4 mg/L and exceeds
the copper action level of 1.3 mg/L.
Answer 2
A JkJUIhT TT %* A*
The system is not in violation for exceeding an action level. Exceeding an AL
triggers additional treatment requirements.
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State Calculation of
90th Percent!le
Scenario for Small System
> 1/1/01 - 6/30/01: System required to conduct monitoring
> 2/15/01: State notifies system that it will calculate 90th percentile
> 5/31/01: State deadline for results/supporting documentation from system
6/27/01: System provides results and supporting documentation
Pb 90th = 0.0142 mg/L
Cu 90th = 1.4 mg/L
16/29/01: System receives 90th percentile from the State
1. Is the system in violation?
The system has not violated a Federal requirement.
2. What problem might occur because system learned its 90th percentile
values on 6/29/01?
System may be unable to meet its WQP monitoring requirements.
Answer 1
The State is performing the 90th percentile calculation for the system. The
system did not meet the deadline specified by the State for reporting its tap
water sample results and supporting documentation (i.e., sampling site location,
site selection criteria, and identification and explanation of any changes to
sampling sites). This is not a federal violation that would need to be reported to
EPA. However, the State may consider it a violation of State requirements.
Answer 2
The system exceeded the copper action level and is required to conduct WQP
monitoring before June 30, 2001. The system did not learn of the exceedance
until June 29,2001 and therefore, may have difficulty fulfilling its WQP M/R
requirements. Had the system submitted the tap monitoring results earlier,
there would have been less risk of missing the WQP deadline if there was an
exceedance.
Remember: States cannot calculate and report 90th percentile
lead and copper values for all or some systems unless they have
incorporated this flexibility into their regulations.
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Violation Determination
Scenario for Large Water System
System reports 90th percentile values for tap monitoring between
January 1,2001 and December 31,2001:
Pb: 0,012 mg/L; Cu: 1.1 mg/L
Note: System collected only 28 of 30 required samples by 12/31/01
1. Has the system exceeded the lead or copper AL?
No, a 90th percentile value cannot be calculated until the required number of
samples have been collected and analyzed.
2. Is the system in violation?
Yes. the system incurred a Routine Tap M/R violation (52 violation type code).
3. How does the system return to compliance?
tt must meet monitoring and reporting requirements for 1 period.
Answer 1
A 90th percentile value cannot be calculated until the required number of
samples have been collected and analyzed in accordance with §§141.86 and
141.89.
Answer 2
The system is in violation for failure to meet its lead and copper tap monitoring
and reporting (M/R) requirements. The violation type is a routine lead and
copper tap M/R violation. In this example, the begin date for this violation is
October 1,2001. The end date is defaulted to December 31,2015.
Answer 3
The system will return to compliance when it collects samples that meet the
sampling, analytical, and reporting requirements for one monitoring period.
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Violation Determination
Scenario for New Small System
> Required to conduct initial monitoring during 1/1/01-6/30/01
Completes monitoring by June 30,2001, but reports on 8/29/01
1. Is the system in violation?
Yes, the system must report results by July 10,2001 (10 days after the end of
the compliance period).
2. If homeowners participated in the monitoring, does the system have to
submit a certification to the State that it provided sample collection
instructions?
Yes, until the State adopts the new provision that eliminates this requirement.
3. When does the system return to compliance?
On 8/29/01, when it submits all required results.
Answer 1
A system has until the 10th day following the end of the compliance period in
which to report its lead and copper tap results and other supporting
documentation (or by July 10th in this example). In this example, the system
has an initial lead and copper tap M/R violation (51 violation type code). The
begin date for this violation is July 1,2001; the end date is defaulted to
December 31,2001.
Answer 2
The LCRMR no longer requires systems to provide certification that
homeowners collected samples after having received sampling instructions. As
this provision is less stringent than the requirements of the LCR, it must first by
adopted by the State before it can be implemented.
Answer 3
The system returns to compliance once they provide the monitoring results and
all other relevant supporting documentation to the State (by August 29,2001).
The system is not an SNC because it return to compliance within 12 months of
the violation.
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Pre-existing Monitoring
Waivers
Scenario for Small System
Waiver granted on 7/10/96
System has never monitored
Tap monitoring conducted and reported to State on 6/19/01
1. Was the system required to conduct any lead and copper tap monitoring?
Yes, systems with waivers issued before the LCRMR must perform tap
monitoring by 9/30/00.
2. Is the system in violation?
Yes. it did not meet the 9/30/00 deadline and has incurred an initial tap M/R
violation (code 51) and becomes ineligible for its waiver.
3. When did the system return to compliance? Is it a SNC?
On 6/19/01, when it submitted the required results. No, it has not been out of
compliance for more than 12 months.
Answer 1
A system that was granted a waiver prior to April 11, 2000 (i.e., a pre-existing waiver) and that
never conducted lead and copper tap monitoring must collect one set of samples by September
30,2000.
Answer 2
The system is in violation because it did not meet the September 30,2000 deadline. Since this
violation pertains to the first set of lead and copper M/R requirements, the system has incurred
an initial lead and copper M/R violation (51 violation code). The begin date of this violation is
October 1,2000; the end date is defaulted to December 31, 2015. This system did not conduct
the required monitoring and therefore, becomes ineligible for its waiver. The system may
reapply for a waiver once it conducts the monitoring that shows that the system has lead and
copper 90th percentile levels that are < 0.005 mg/L and < 0.65 mg/L, respectively.
Answer 3
An initial lead and copper tap M/R significant noncomplier (SNC) is defined as a system that
does not return to compliance within:
3 months for large systems
6 months for medium systems
12 months for small systems.
The system in this example is not an SNC because it is a small system and was out of
compliance for approximately 9 months.
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Monitoring Waivers
Scenario for Small System
' Waiver granted on 2/15/01
1 As of 1/1/08, conducted last tap monitoring on 7/1/98
1. Is the system required to conduct monitoring after 1998?
Yes, systems with waivers must monitor every 9 years, or by 7/1/07 in this
example.
2. Is the system in violation?
Yes, it did not meet the 7/1/07 deadline and becomes ineligible for its waiver.
3. What type of violation has the system incurred? Is the system a SNC?
A routine lead and copper tap M/R violation (code 52}. No, this violation type
is not included in SNC definition.
Answer 1
A system that was granted a waiver under the LCRMR must monitor once
every 9 years from the last date it monitored. In this example, the system last
monitored on July 1,1998 and must collect its next round of samples by July 1,
2007.
Answer 2
The system is in violation because 9 years has passed since it last monitored.
The violation is a routine lead and copper tap M/R violation (violation code
52). The begin date of this violation is July 2,2007. The end date is defaulted
to December 31,2015. The system would lose its waiver because it no longer
meets the waiver criteria. The system could reapply for a waiver once it has
collected its samples, and the lead and copper 90th percentile levels are < 0.005
mg/L and < 0.65 mg/L, respectively.
Answer 3
As the violation did not occur during initial monitoring, it is considered a
routine lead and copper M/R violation. The system in this example is not a
SNC because a routine lead and copper M/R violation is not considered in the
SNC calculation.
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Sample Invalidation
Scenario
System must collect 10 samples during annual monitoring in 2001
Provides documentation on 8/15/01 for 2 samples to be invalidated
State grants invalidation request on 8/30/01
1. Is the system required to collect replacement samples?
Yes, two replacement samples are needed to meet minimum sampling
requirements.
2. What is the deadline for collecting these samples?
September 30, 2001.
3. If the system does not collect replacement samples, is it in violation?
Yes. It is a routine lead and copper tap M/R violation.
Answer 1
A system must collect replacement samples if they are needed to meet sampling
requirements. In this example, the system would have been left with 8 valid
samples and would not have met the minimum sampling requirements without
collecting replacement samples.
Answer 2
The deadline for collecting these samples is within 20 days of the State's
decision to invalidate the samples or by the end of the monitoring period,
whichever is later. In this example, the deadline would be the end of the
monitoring period (or by September 30,2001).
Answer 3
Yes, failure to collect timely, required replacement samples is a lead and copper
tap M/R violation. Because the system is on annual monitoring, the specific
violation type would be a routine lead and copper M/R violation. Please note,
that a system could also incur this violation during initial monitoring (for new
systems or ones with pre-existing waivers that are monitoring for the first time)
or during follow-up lead and copper tap monitoring.
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Non-First Draw Samples
Scenario for System Operating 24-hours per Pay
' System permitted to collect non-first draw samples
> Monitors during 1/1/2002 -12/31/2002
Does not collect samples from sites with the longest standing times.
1. Is the system in violation?
Yes. It must collect samples from sites with longest standing times.
2. What type of violation is this?
Routine lead and copper tap M/R violation (code 52).
3. How does the system return to compliance?
It must submit a round of samples from sites with the longest standing times.
Answer 1
A system that does not have enough or any sampling locations that can provide first-draw samples
must collect as many first-draw samples as possible, and then collect the remaining ones from sites
with the longest standing times.
The system in this example had no sites from which it could obtain first-draw samples. The
system is in violation because it did not collect its samples from locations with the longest
standing times.
Systems are required to either:
1. receive prior approval of a sampling plan for the collection of non-first draw samples, or
1. provide documentation with their lead and copper sample results that identifies each
site that did not meet the 6-hour minimum standing time and the length of standing
time for that particular sample.
Answer 2
Failure to collect non-first draw samples from sites with the longest standing times is a lead and
copper tap M/R violation. Because the system is on annual monitoring, the specific violation type
would be a Routine lead and copper M/R violation (52 violation code). Assuming that this system
is required to sample during June - September, the begin date of this violation is October 1,2002;
the end date is defaulted to December 31, 2015. Also note that a system could also incur this
violation during initial monitoring (for new systems or ones with pre-existing waivers that are
monitoring for the first time) or during follow-up lead and copper tap monitoring.
Answer 3
The system must collect samples from the appropriate sites during June - Sept (or other months
approved by State).
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Alternative Monitoring Period
Scenario for Seasonal NTNCWS
System is closed during summer months and is on annual monitoring
System last sampled on 7/7/01
On 9/10/01, State specifies alternative monitoring period of Oct. - Dec,
1. When are the next set of samples due?
December 31, 2002.
2. What if the system had been on triennial monitoring?
December 31,2004.
3. Can a system incur a violation for failure to meet the transitioning deadline?
Yes. It would be a routine lead and copper tap MIR violation.
4. How does the system return to compliance?
System submits monitoring results that meet sampling, analytical, and
reporting content requirements.
Answer 1
The LCRMR allow a maximum of 21 months for a system on annual monitoring to
transition to the new monitoring schedule or April 7, 2003 in this example.
However, since this system must collect its samples during October - December, it
only has until December 31, 2002 to complete this monitoring (a little under 18
months).
Answer 2
A system on triennial monitoring is allowed a maximum of 45 months to transition
to a new monitoring period. Had this same system been on triennial monitoring, it
only would have had until December 2004 to conduct its next set of monitoring (a
little under 42 months).
Answer 3
If this system misses the December 31,2002 deadline for monitoring and reporting
or does not follow proper sampling procedures, it would incur a lead and copper tap
M/R violation. Because this requirement is specific to systems on reduced
monitoring, a system can only incur a routine lead and copper M/R violation for
failure to meet the deadline for transitioning to the new monitoring schedule.
Answer4
The system would return to compliance after it submitted monitoring results in
subsequent monitoring period that met the sampling, analytical, and reporting
content requirements.
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Reduced Monitoring
Scenario
Small system never completed 2 rounds of initial monitoring in 2.
consecutive, 6-month periods, but has never exceeded action levels
State approved reduction to triennial monitoring, and current
monitoring period is 1/01/99 - 12/31/01
System last sampled on 6/28/98
1. Did the system meet the requirements for reduced monitoring?
No. The system must complete two rounds of standard monitoring in two
consecutive, six-month compliance periods to qualify for annual monitoring.
2. What if the system had completed two rounds of initial monitoring,
but the samples were not collected in consecutive periods?
System must collect 2 consecutive 6-month rounds.
Answer 1
Because the system never met the requirements for reduced monitoring, it must
return to the original, standard monitoring schedule and collect two consecutive
rounds of monitoring. After completing two, consecutive, six-month
compliance periods confirm that they are below the action level, small or
medium systems can collect samples at an annual frequency and at the reduced
number of sites. Any size system can be reduced to annual monitoring if they
meet their OWQPs, if applicable, for two consecutive, six-month compliance
periods.
The system in this example can return to a triennial monitoring frequency if it:
is below the action level for 3 consecutive years; or
has lead level of < 0.005 mg/L and copper level of < 0.65 mg/L for 2
consecutive, 6 months, and
the State has adopted the accelerated reduced monitoring provision
under the LCRMR.
Answer 2
The rule specifies that a system must conduct two consecutive 6-month rounds
of monitoring.
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Accelerated Reduced
Monitoring
Scenario for New Water System (population 5.500)
System put into service on 1/10/00.
> Completes first round of initial monitoring by 6/30/00:
Pb 90th = 0.008 mg/L; Cu 90th = 0.60 mg/L
> Completes second round of initial monitoring by 12/31/00:
Pb 90th = 0.005 mg/L, Cu 90th = 0.60 mg/L
1. Is this system eligible for accelerated reduced monitoring?
No. Although it met the criteria for copper, the system did not remain below
the threshold of a lead 90th percentile value of less than or equal to 0.005
mg/L for two, consecutive, six-month periods.
2. Could the system be reduced to annual monitoring?
Yes. The system met the requirements for annual monitoring at a reduced
number of sites.
Answer 1
LCRMR permit systems to reduce to triennial monitoring after completing two,
consecutive 6-month rounds if they meet the following 90th percentile lead
and copper levels at the tap:
Lead levels of less than or equal to 0.005 mg/L; and
Copper levels of less than or equal to 0.65 mg/L.
As the first round of sampling for this system met the action level for lead but
exceeded the above threshold, the system was ineligible for accelerated reduced
monitoring. Accelerated reduced monitoring for one contaminant is not
allowed when the other contaminant has a 90th percentile level above the
specified threshold level.
Answer 2
The system was below the lead and copper action levels for two, consecutive,
six-month rounds and therefore is eligible for annual monitoring. In addition,
the system may collect a reduced number of samples: at 20 sites instead of 40.
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WQP M/R Compliance
Scenario for New Water System
System serves 10,000 people
* Completes first round of initial monitoring by 12/31/02
Lead 90th = 0.010 mg/L; Copper 90th = 0.65 mg/L
1. Is this system required to conduct WQP monitoring?
No. This is a medium system that did not exceed an action level.
2. What if the system served > 50,000 people?
The system would be required to collect WQP samples within the same
compliance period as the tap samples, or by 12/31/02.
Answer 1
Medium and small water systems are only required to conduct WQP monitoring
during those compliance periods in which they exceed the lead or copper action
level. In this example, the system was a medium-size system and was below
both action levels. Therefore, no WQP monitoring is required.
Answer 2
All large systems are required to conduct initial WQP monitoring, regardless of
whether they exceed an action level. The system in this example is a new
system and is conducting lead and copper monitoring for the first time.
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Lead and Copper NPDWR
Requirements
Lead and Copper Tap/Initial WQP
Monitoring
Corrosion Control Optimization
Public Education
Source Water Monitoring & Treatment
Replacement of Lead Service Lines
State Reporting and Recordkeeping
Primacy and Implementation
This section discusses:
Systems that must begin corrosion control treatment steps; and
Systems that have negligible levels of lead and copper in their
distribution system and are not required to install corrosion control
(i.e., are already considered to have optimized treatment).
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What Is Corrosion Control?
Applicability
Corrosion control is chemical
treatment that is designed to reduce
the corrosivity of water
* Raising pH to make water less
acidic
Adding buffering to make water
more stable
Because corrosion of lead and copper plumbing is the primary means by which lead and
copper enters drinking water, corrosion control treatment may be required to help prevent
lead and copper contamination of drinking water.
A variety of water quality parameters, including pH, alkalinity, temperature, and hardness,
affect the corrosivity of water. Different types of treatment are used to address different
water characteristics. For example, corrosion of plumbing materials occurs more quickly if
the water flowing through lead and/or copper plumbing has a low pH or low alkalinity. If
water is "aggressive" or corrosive, chemicals can be added to the water to adjust pH or
alkalinity, thereby making it more stable or less aggressive. As will be discussed later in this
section, the LCR requires some systems to perform corrosion control studies. As part of this
study, a system must evaluate three types of treatments to determine which will provide
optimal corrosion control:
alkalinity and pH adjustment;
calcium hardness adjustment; and
addition of a phosphate- or silicate-based corrosion inhibitor.
Optimal Corrosion Control = "the corrosion control that minimizes lead
and copper concentrations at users* taps while insuring that the treatment
will not cause the water system to violate any National Primary Drinking
Water Regulations".
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Corrosion Control Treatment
Applicability
* < 50,000 that exceed either AL
> 50,000 regardless of 90th
percentile*
*(b3) systems not subject to CCT requirements
(b3) system = 90th percentile lead - highest
source water < 0.005 mg/L for 2 consec. 6 mos.
Corrosion control treatment (CCT) applies to those systems except those that have
optimized corrosion control. A system can be optimized even if it has not installed CCT if it
is:
A small or medium-size system that is below both the lead and copper action levels
(ALs) during two consecutive monitoring periods
A (b)(3) system. Also, note that a system can qualify as a (b)(3) system after it
installs corrosion control treatment.
Systems that meet the requirements of 141.81(b)(3), also known as (b)(3) systems are those
systems that have demonstrated that they have very little corrosion entering the distribution
system. A system qualifies as a (b)(3) system if for 2 consecutive 6-month rounds it can
show that the difference between the 90th percentile tap water lead level and the highest
source water lead concentration, is less than the Practical Quantitation Level for lead of
0.005 mg/L.
Note: The LCRMR expand the definition of a (b)(3) systems.
This revision is discussed in more detail later in this section.
A small or medium-size system (i.e., those serving 50,000 or fewer) must begin CCT steps if
it exceeds either the lead or copper AL.
All large systems (i.e., those serving more than 50,000), with the exception of (b)(3)
systems, must begin CCT even if their 90th percentile lead or copper levels are below the
action level.
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Corrosion Control Optimization
Steps
Study/Treatment Recommendation
State Treatment Determination
Treatment Installation
Follow-up Monitoring
State-Specified Operating Parameters
We will go through each of these steps in more detail in the pages that follow.
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Corrosion Control Optimization
Study
State discretion for < 50,000
Required for > 50,000, unless (b)(2) or (b)(3)
system
18 months to complete
System must identify constraints for:
pH and alkalinity adjustment
calcium adjustment
corrosion inhibitors
Fully document treatment recommendation
A study was required by July 1,1994 for all large systems (> 50,000 people), unless they
qualified for (b)(3) status. As discussed earlier, (b)(3) systems are not subject to corrosion
control requirements, unless they no longer meet the (b)(3) criteria. Additional studies are
not required for systems that meet the criteria in § 141.81 (b)(2) (also known as a (b) (2)
system). These system performed these studies prior to December 31,1992.
Systems serving < 50,000 are required to recommend optimal corrosion control treatment
within 6 months after exceeding an action level. The State determines whether these
systems need to conduct a corrosion control treatment study. The State is required to
make this decision within 12 months after a system exceeds the lead or copper action
level.
Large systems were required to conduct this study by July 1,1994. Small or medium-size
systems are required to complete the study within 18 months after the State requires the
study to be conducted. Note: A system that was a medium-size system during initial
monitoring and later became a large system, would not be required to complete a study by
July 1,1994. Instead, the study would be due within 18 months after the State notified
them that a study was required.
The study must evaluate the effectiveness of each of the following treatments:
Alkalinity and pH adjustment;
* Calcium hardness adjustment; and
The addition of a phosphate or silicate based corrosion inhibitor.
The system must identify constraints that limit or prohibit the use of a particular corrosion
contra
For more information on CCT, refer to Lead and Copper Rule Guidance
Manual; Volume II: Corrosion Control Treatment. (NTIS PB-93-101583).
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Corrosion Control Optimization
Treatment Installation &
Follow-up Monitoring
State approval/designation of
alternative CCT
24 months to install
2 consecutive 6 months for follow-up
monitoring
- Entry point monitoring changes to
biweekly and 1 sample per entry point
- < 50,000 systems only conduct during
monitoring period(s) in which exceed AL
State approval/Designation of treatment
After considering the information from the corrosion control study (where applicable), and a system's
recommended treatment alternative, the State will either approve the treatment recommended by the system or
designate alternative corrosion control treatment. The schedule for the decision is based on the system size and
whether a study was required as follows:
State Treatment Decision Due
January 1, 1995 (i.e., 6 months after system submits study
and recommendation)
within 18 months system exceeds an AL
6 months after study completion
within 24 months system exceeds an AL
6 months after study completion
System size
Large
Medium (no study)
Medium (w/study)
Small (no study)
Small (w/study)
Installation of treatment
Systems have 24 months to install treatment. For large system, treatment was to be installed by January 1,1997.
Follow-up monitoring
Systems must conduct two consecutive 6-month rounds of lead and copper tap and WQP monitoring immediately
following the installation of treatment. During follow-up monitoring, systems are required to collect 2 sets of WQP
samples on different days at each of the required tap sites during each of the two, consecutive 6-month periods.
The frequency of monitoring at entry points increases to no less frequently than every 2 weeks. The number of
WQP samples collected at each entry point location changes from 2 samples to 1.
For large systems, follow-up monitoring was due by January 1, 1998. Small and medium-size systems were
required to conduct follow-up lead and copper tap monitoring. For small and medium-size systems, WQP
monitoring is only required during each of the 6-month follow-up monitoring periods in which they exceeded the
lead or copper action level.
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Corrosion Control Optimization
Designation of OWQPs
State-specified Operating Parameters
Become Compliance Measures
pH
» alkalinity
calcium
orthophosphate
silica
State sets OWQPs within 6 months of
receiving follow-up results
The State uses the lead and copper and WQP data collected before and after
the installation of CCT to set WQP ranges or minimums (called optimal water
quality parameters or OWQPs) that indicate that a system is operating
corrosion control treatment at a level that most effectively minimizes the lead
and copper concentrations at users' taps. The State sets the following OWQPs
at each entry point and within the distribution system within 6 months of
receiving lead and copper and WQP follow-up monitoring results:
- pH
alkalinity (when alkalinity is adjusted)
orthophosphate (when an phosphate inhibitor is used)
silica (when a silicate inhibitor is used)
calcium (when calcium carbonate stabilization is used as part of
corrosion control)
The State can designate values for additional water quality control parameters.
OWQPs are federally-enforceable standards.
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Corrosion Control Optimization
Monitoring after OWQPs Specified
WQP tap monitoring every 6 months*
Reduced tap WQP monitoring if system in
compliance with OWQPs for:
* 2 consecutive 6 months -» reduced no. of sites
* 3 consecutive years of 6-month monitoring -» annual
frequency
3 consecutive years of annual monitoring -»triennial
frequency , , , , ,
FBJi
Entry point remains biweekly
' Systems serving < 50,000 people below AL are not required to collect WQPs
After the State sets OWQPs, a system can qualify for a reduction in the amount of monitoring
conducted at tap locations only. This reduction does not apply to entry point WQP monitoring
that remains at a frequency of every two weeks.
If the system is in compliance with its OWQPs after 2 consecutive, 6-month monitoring periods,
it can reduce the number of sample sites at which it collects tap samples from the standard
number to the reduced number. However, 2 samples are still required at each location.
System size
>100,000
10,001-100,000
3,301 to 10,000
501 to 3,300
101 to 500
<100
Standard no. of sites
25
10
3
2
1
1
Reduced no. of sites
10
7
3
2
1
1
A system that is in compliance with its OWQPs for 3 consecutive years, can qualify for annual
WQP tap monitoring.
A system that is in compliance with its OWQPs for 3 consecutive years of tap monitoring at the
annual frequency, can qualify for triennial WQP tap monitoring.
Remember: A small or medium-size system is not required to
conduct WQP monitoring during any monitoring period that it is
below the lead or copper action level, unless required by the State.
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Corrosion Control Optimization
Discontinuing Treatment Steps
< 50,000 can stop CCT steps if below
both ALs for 2 consecutive
monitoring periods
Must recommence steps if exceed
during any subsequent round
A small or medium-size system can discontinue following the CCT steps if it
is below the lead and copper action levels for two consecutive monitoring
periods.
If in any future monitoring the system again exceeds either action level, it
must begin CCT steps again, beginning with the treatment step that did not
complete or where State determines the system should start.
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LCR Minor Revisions
Optimized Systems with CCT
LCRMR clarify that "optimized" systems with
treatment in place must:
O Maintain corrosion control treatment; and
O Meet requirements that State determines
are needed to maintain optimal treatment
©Implement on April 11, 2000
These LCRMR provisions clarify the requirements for systems that are "deemed to have
optimized corrosion control" and have treatment in place, but which are not required to
collect WQPs. This group of systems include:
1. Small or medium-size systems that has completed treatment steps that are equivalent
to those in the LCR, prior to the 1991 Rule (i.e. before 12/7/92) and
2. Systems that installed treatment after 12/7/92, and then meet the criteria in:
141.81 (b)( 1) = a small or medium system that is below both action levels during two
consecutive 6-month rounds of monitoring
141.81 (b)(3) = a system has minimally corrosive water in their distribution systems.
States must ensure treatment is properly operated and maintained at all times. In many cases,
appropriate operational controls are already in place. Controls may involve dosage logs,
WQP monitoring, and other monitoring.
Systems must meet any requirements the State deems are needed to ensure this treatment is
maintained, such as additional monitoring. States must maintain records of any additional
requirements that they impose on a water system.
Remember: A system can also be optimized even if it has not
installed CCT. A system can qualify as a (b)(l) or (b)(3) system
without installing CCT.
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LCR Minor Revisions
Clarification of (b)(2) system requirements
"Optimized" systems that have
completed CCT prior to 12/7/92 must:
O Monitor for WQPs after OWQPs are
designated
O Continue lead and copper tap sampling
| Olmplement on April 11.2000
These LCRMR provisions outline requirements for systems that are deemed to have
optimized corrosion control after demonstrating that they completed CCT steps
equivalent to those described in the original Rule, prior to 12/7/92 (also known as (b)(2)
systems). The LCR was unclear regarding what monitoring requirements applied to
systems that meet the (b)(2) criteria.
These changes are intended to clarify the language of the original rule.
(b)(2) systems must:
1. Routinely monitor for water quality parameters after the State designates optimal
water quality parameters (OWQPs), [except those systems that serve 50,000 and
fewer people and no longer exceed an action level.] Entry point WQP monitoring is
conducted every 2 weeks. Tap WQP monitoring is conducted every 6 months
at the standard number of sites, until the system qualifies for reduced WQP
monitoring. WQP monitoring would not be required for small and medium-
size systems during any monitoring period in which they do not exceed the lead or
copper action level.
2. Continue lead and copper tap sampling at a frequency of once every 6 months at the
standard number of sites, until the system qualifies for reduced monitoring.
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LCR Minor Revisions
Expanded definition of (b)(3) system
Systems also qualify as "(b)(3)"system if
for 2 consecutive 6 month periods:
- source water lead levels < MDL, and
- 90th percentiie lead level < 0.005 mg/L
Expanded (b)(3) definition: Systems can now also be deemed "optimized" under
§141.81(b)(3) by demonstrating that source water lead levels are below the Method
Detection Limit (MDL) and the 90th percentiie lead level is < 0.005 mg/L for 2
consecutive, 6-month monitoring periods.
This new criterion was,added because systems with undetectable source water lead
levels and low 90th percentiie lead levels could be precluded from qualifying as a (b)(3)
system, under the 1991 LCR. This is because source water levels that are below the
MDL must be reported as 0; whereas, levels above the MDL, but less than 0.005 mg/L
must be reported as 0.0025 mg/L. This point is more clearly illustrated in the two
examples below.
Example 1: A system with source water lead levels just below a MDL of 0.001 mg/L
and a 90th percentiie tap level of 0.005 mg/L would not be deemed to be optimized
using the 1991 (b)(3) criteria, which requires the difference to be < 0.005 mg/L. The
difference here would be 0.005 mg/L (0.005 mg/L - 0 mg/L = 0.005 mg/L).
Example 2: With a lead MDL of 0.001 mg/L, a system with source water levels of
0.0011 mg/L and a 90th percentiie of 0.005 mg/L would be optimized under the 1991
criteria since the source levels could be reported as 0.0025 mg/L. The difference here
would be 0.0025 mg/L (0.005 mg/L - 0.0025 mg/L = 0.0025 mg/L).
The (b)(3) criteria primarily applies to large systems and allows them to forego WQP
monitoring. However, States may want to require those large systems that qualify as
(b)(3) systems after installing CCT to conduct WQP monitoring. Systems meeting the
new (b)(3) criterion must follow the requirements of §141.81(b)(3), including the
revisions that are discussed on the next page.
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LCR Minor Revisions
Clarification of (b)(3) system requirements
O (b)(3) systems must:
- Collect tap samples every 3 years (once
between 10/1/97 and 9/30/00)
- Not exceed the copper action level by 7/12/01; &
- Notify State of change in treatment or new
source
O Systems that no longer are (b)(3) must:
- Begin CCT steps under 141.81(e)
©Implement on April 11,2000
The LCRMR clarify the monitoring requirements for systems that qualify as (b)(3) systems. The LCR was
ambiguous regarding monitoring requirements for these systems.
The LCRMR require (b)(3) to:
1. Conduct one round of monitoring between 10/1/97 and 9/30/00 at the reduced number of sites, and
collect lead and copper tap samples at least once every 3 years, thereafter (Clarification of 1991 Rule).
Some States already require triennial or more frequent monitoring. In these instances, there will be no
need to change already existing monitoring periods.
2. Not exceed the copper action level by 7/12/01. The LCR did not contain language that prevented
systems from qualifying as (b)(3) systems if they exceeded the copper action level. The LCRMR
correct this oversight by specifying that systems that exceed the copper action level on or after July 12,
2001 no longer qualify as a (bX3) system and must begin CCT steps. The July 12,2001 date is 18
months after the rule was published in the Federal Register and allows systems time to make changes
to reduce copper levels and to conduct 2 additional rounds of monitoring.
3. Notify States in writing of any change in treatment or addition of a new source within 60 days of the
change, unless they require earlier notification. States may require systems to conduct additional
monitoring or other activities to ensure that optimal corrosion control is maintained. States must keep
records of any decisions that require a system to conduct additional actions in response to the change
in treatment/source addition.
Systems that no longer meet the (b)(3) criteria
The LCRMR specify that any system that no longer meets the (b)(3) criteria must begin CCT steps. Large
systems must follow the corrosion control treatment schedule for medium-size systems outlined in §141.81(e)
(because the deadlines for large systems have already passed), beginning with the requirement to complete a
corrosion control study. These systems must complete this study within 18 months of the date they were
triggered into the corrosion control treatment steps.
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LCf? Minor Revisions
New OWQP Compliance Procedure
OWQP Noncompliance
LCR:'
- Any value or average is outside OWQP range
or below minimum
LCRMR:
- Cannot be outside OWQP range or below
minimum on > 9 days in 6-month period
EPA developed new criteria for evaluating compliance. Under the 1991 Rule, any value
outside the OWQP range or below the OWQP minimum set by the State would result in a
violation. Systems were allowed to take confirmation samples within 3 days and average
the two results. Problems with the old approach are:
Disincentive for those monitoring more often than the required biweekly frequency.
Averaging is not a sound approach, as shown in the example below.
Example: Assume an' OWQP pH range of 7.3 to 7.8 for a system. Averaging would make
attainment of a passing average possible in a case where a caustic feed pump is used at the
wellhead or at the end of a water plant feeding into the system, and the system is not
adequately controlling the pump. The system could collect a sample with a pH of 6.9.
Three days later, they could collect a second sample with a pH of 8.4. Both results are
outside of the OWQP range. The average (7.6) is within the range, but the process control
is poor. '
Although, adoption of this new procedure is not required to maintain primacy, EPA
strongly encourages States to do so, as it should result in fewer violations and it more
accurately characterizes systems with process control problems.
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LCR Minor Revisions
New OWQP Compliance Procedure (Cont.)
New criteria for evaluating OWQP
compliance:
- Compliance based on a 6-month period
- First 6-month period begins when State
specifies OWQPs
- Daily values determined for each WQP at each
sampling location
- Daily values determined even if no monitoring
has occurred
The LCRMR do not change WQP monitoring frequencies; only the way in which
compliance is determined. Compliance determinations are always based on a 6-month
period, regardless of the system's monitoring schedule (daily, biweekly, semi-annually,
annually, etc.) or whether systems are collecting WQPs at taps or entry points. The first
six-month period begins on the date the State specifies OWQPs.
Daily values must be determined for each WQP at each sampling location. Daily values
are determined based on the frequency of sampling for the parameter at the sampling
location. It is quite possible for a system to collect several samples a day for a given WQP
at one sampling location and to conduct annual monitoring at another. Although the term
"daily values" contains the word "daily", in many instances, the daily value represents a
measurement that was collected more or less frequently than once per day.
If measurements for the parameter are collected at the sampling location:
more frequently than once a day, the daily value is the average of all the results
measured at the sampling location for the parameter during the day (regardless of
whether the results are measured through continuous monitoring, grab samples, or
both). (A State can use another procedure than averaging for determining compliance,
if it outlines this approach in its special primacy considerations and EPA
approves it.)
no more frequently than once a day at a sampling location, but no less frequently than
every six months to as, the daily value each measurement collected during the six-
month period that is being evaluated.
less frequently than once every six months, the daily value is the most recent
measurement taken, even if that measurement was collected during a previous
monitoring period. Thus, daily values are calculated even if no monitoring has
occurred.
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LCR Minor Revisions
New OWQP Compliance Procedure (Cont.)
Excursions
Excursion = "daily value" below the minimum
value'or outside the OWQP range
* Multiple excursions on same day count as 1
excursion
Cannot have excursions on > 9 days during 6
month monitoring period
> 9 days in 6 month period with excursions =
violation
Systems in violation return to standard Pb/Cu tap
and WQP tap monitoring
An excursion is any "daily value" for a WQP that is below the minimum value or outside
the range of OWQPs set by the State.
To determine the duration of the excursion:
1. Count the first day that the sample is outside the OWQP range or below the
minimum. Use the date that the sample was collected and not the day the State
receives the results.
2. Stop counting days when a sample result from the same location and for the same
parameter meets the OWQP range or is above the minimum value. Do not count the
day the sample falls within the OWQP or is above the minimum value in the calculation.
3. Repeat this procedure any time a measurement does not meet the OWQP
specifications. '
A system cannot have an excursion on more than a total of 9 days during a 6-month period.
The 9 days can be consecutive or occur anytime in the 6-month monitoring period. This is
roughly equivalent to no 'excursions for 95% of the time.
Systems with excursions on more than 9 days are in violation and must report this to the State
within 48 hours of determining their noncompliance. These systems revert back to standard
monitoring for WQPs and for lead and copper tap monitoring, if they qualified for reduced
monitoring based on meeting OWQPs.
We will now go through several OWQP examples that illustrate the new compliance
procedure. These examples are from the guidance document, How to Determine Compliance
with Optimal Water Quality Parameters as Revised by the Lead and Copper Rule Minor
Revisions, June, EPA 815-R-99-019.
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LCR Minor Revisions
Representative WQP Entry Point
Monitoring
Applies to ground water systems
Limits entry point WQP monitoring to
representative sites after CCT installed
Must demonstrate sites are representative of
water quality conditions throughout system
Representative sites for entry point WQPs
Some ground water systems, especially in the western States, can have dozens or even
more than a hundred wells and it can be difficult and expensive to conduct biweekly
monitoring at each entry point. Ground water systems subject to WQP monitoring
requirements after the installation of CCT may limit their entry point monitoring to those
locations that are representative of water quality conditions throughout the system. This
provision does not apply to surface water systems because these systems typically do not
have large numbers of entry points.
At a minimum, these systems must monitor for WQPs both at some points receiving
treatment and at some points receiving no CCT if the water from those points mixes with
other treated source water in the system.
Systems taking advantage of this provision are required to provide sufficient
documentation to the State to demonstrate that the locations monitored are representative
of water quality throughout the system. The specific documentation to be provided may
vary depending on the system's characteristics and State's specific reporting
requirements.
The documentation supporting the selection of these representative sites must be
submitted to the State prior to the start of any routine WQP monitoring that uses
representative sites.
States must maintain records of any decisions pertaining to representative entry point
WQP monitoring.
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LCR Minor Revisions
Accelerated Reduced Tap WQP
Monitoring
Applies to > 50,000
Applies to distribution ("tap") WQP
monitoring
Allows systems to monitor triennially for
tap WQPs more quickly than before
System must for 2 consecutive monitoring
periods:
- qualify for accelerated Pb/Cu tap monitoring &
- be in compliance w/ OWQPs
Accelerated Reduced WQP monitoring
This provision only applies to large systems (those serving > 50,000 people) because
small and medium systems that are below both action levels are not required to conduct
WQP monitoring.
A large system can reduce to a triennial monitoring schedule for WQP tap samples
without conducting interim rounds of monitoring, if it:
1. demonstrates during 2 consecutive monitoring periods that:
- its 90th percentile lead levels are < 0.005 mg/L (i.e., PQL) and
- its 90th percentile copper levels are < 0.65 mg/L (i.e., 1/2 action level),
2. is in compliance with its OWQP ranges or values.
The system does not need State approval to monitor on an accelerated schedule.
This provision does not impact entry point WQP monitoring. After the installation
of treatment, entry point WQP monitoring is still required at a minimum frequency of
every 2 weeks.
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LCR Minor Revisions
Summary of CCT Revisions
O Clarification of treatment operation and monitoring
requirements for:
- Systems with CCT installed
- (b)(3) systems
O (B)(3) systems cannot exceed the copper AL
System with source lead < MDL can qualify as (b)(3)
system
New OWQP compliance procedure
* Representative WQP entry point monitoring
* Accelerated reduced WQP "tap" monitoring
©Implement on April 11, 2000
LCRMR Revision
Continued requirements for systems with
CCT but that are not required to conduct
WQP monitoring
Continued requirements for (b)(2) systems
with treatment in place prior to 12/7/92
Continued requirements for (b)(3) systems
Requirement for (b)(3) systems to not
exceed the copper action level
Allowance for systems with source water
below MDL to qualify as (b)(3) system
Change in compliance procedure for
OWQPs
Representative WQP entry point
monitoring
& associated system reporting requirements
Accelerated reduced WQP tap monitoring
Where to Find It
§141.81(b)
§141.81(b)(2)
§141.81(b)(3)(iv)
§141.82(g) &§141.87(d)
§§141.87(c)(3)&141.90(a)(5)
§141.87(e)(2)(ii)
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1 Corrosion Control
Optimization
i
Compliance Examples
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Applicable Reporting
Requirements
Reported as 53 violation type
- Initial WQP M/R (pre-LCRMR code = 53)
- Follow-up or routine entry point WQP M/R (pre-
LCRMR code = 54)
- Follow-up or routine tap WQP M/R (pre-LCRMR
code = 55)
Reported as 59 violation type
- WQP Entry Point Noncompliance (pre-LCRMR
code = 59)
- WQP Tap Noncompliance (pre-LCRMR code = 60)
All WQP M/R violations are consolidated under the violation code type 53.
All violations resulting from noncompliance with OWQPs regardless of
whether they occur at the entry point or tap are reported as a 59 violation type.
The 53 violation type (WQP M/R violation) and the 59 violation type (WQP
Noncompliance), are the only violation types in which the begin date is not the
day after the end of the compliance period and the end date is not defaulted to
December 31,2015. Instead, these violations are specific to the 6-month
period for which compliance with OWQPs is being determined. The begin
date for a 53 or 59 violation is the first day of the compliance period. The end
date the last day of the compliance period. The State may designate a January
to June or July to December period.
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Applicable Reporting
Requirements
WQP Noncompliance (TT Violation)
Tap/Entry Point WQP Noncompliance (59)
Violation Type Code "59" (Consolidated 59,60)
* Traditional begin and end dates
New 6 month compliance period
WQP Noncompliance is a treatment technique (TT) violation and is
determined on a fixed 6-month compliance period and is reported with the
compliance period begin and end dates. Noncompliance is determined on the
number of both entry point and tap WQP "daily average" values which do not
meet their designated minimum value or range.
LCRMR Compliance determinations are always based on a 6-month
period, regardless of the system's monitoring schedule (e.g., daily, biweekly,
semi-annually, annually, triennially) or whether the WQP results are from an
entry point or tap samples.
This type of violation can only occur after you have designated OWQPs. For
both entry point and tap monitoring, compliance is determined based on 6-
month periods. If a system has more than 9 days with excursions for a given
6-month period, it has a violation. To simplify reporting, any combination of
WQP noncompliance violations during a 6 month period will be reported as a
single violation for that 6 month period. To return to compliance with WQP
Noncompliance violations, a system must complete all WQP monitoring at all
locations for the entire next six month period.
The Begin and End dates are the first and last days of the designated 6-month
period. SDWIS/FED does not default the end date to 12/31/2015.
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Applicable Reporting
Requirements
WQP M/R & WQP Noncompliance Violations
RTC must be reported
* Intentional No-Action candidate in certain
circumstances
No SNC conditions
A large system must continue to monitor every 6-month period beginning
from the day the State designates the optimal water quality parameters.
Therefore, it can not make up for missed samples and must complete all WQP
monitoring requirements in the following 6-month period before it may be
returned to compliance.
For a medium or small system, WQP monitoring is only required during the
period of lead and/or copper tap exceedance; however, because this
information is needed to evaluate the need for, or effectiveness of CCT, one
round of monitoring must be completed before the system is considered to be
RTC. WQP tap and entry point samples must be taken in the next 6 month
period.
Those medium and small systems which incurred a WQP noncompliance
(TT) violation and subsequently fell below the lead and copper action levels
are no longer required to monitor for WQPs. These systems do not actually
return to compliance. As with the WQP M/R scenario where they are no
longer required to monitor, we are proposing that an "Intentional No Action"
Enforcement/Follow-up Action record be reported instead of an RTC.
WQP monitoring or WQP treatment technique noncompliance violations are
not SNC conditions.
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Applicable Reporting
I Requirements
OCCT Treatment Technique Violations
* No violation code changes to:
- OCCT study/recommendation (57 violation
code)
- OCCT Installation/Demonstration (58 violation
code)
Consolidated OCCT/SOWT Installation
and/ or Demonstration into one SNC
The violation type code 57 has been expanded to include both:
optimal corrosion control treatment study and/or recommendation
violations, and
source water recommendation violations.
I
The violation type,code 58 has been expanded to include both:
optimal corrosion control treatment installation/demonstration
violations, and
source water treatment installation violations
The begin date for both 57 and 58 violations is the day after the event was
required to be completed. The end date is defaulted to December 31, 2015.
With the consolidation of the OCCT and SOWT installation violation types,
EPA will no longer produce separate SNCs for these two violations. Instead,
EPA will list a system that meets the OCCT Installation SNC criteria or SOWT
Installation SNC criteria as a Treatment Installation/Demonstration SNC.
The basic definition for this SNC has remained the same, a system that incurs a
treatment installation violation and has a 90th percentile lead level of > 0.030
mg/1 in most recent monitoring period.
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Applicable Reporting
Requirements
OCCT Treatment/Study Recommendation
Large systems are only subject to Study
violation
Medium and small subject to both
Recommendation and Study violation
OCCT Study/Recommendation Violation is reported for those medium and
small systems failing to make a recommendation. If State also requires a
study and the system fails to meet those requirements, a second
OCCT/Study Recommendation (57) would be reported.
Large systems must conduct a study and the recommendation is a specific
part of the study, therefore, large systems will only be subject to the Study
violation.
A SOWT Recommendation is due within 6 months of the exceedance;
Installation is required within 24 months of the State's determination of the
type of SOWT to be installed.
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WQP M/R Compliance
Scenario
System serves 55,000 people
Installed CCT
Fails to collect WQP samples at entry points during July and August 2002
1 System is on annual WQP tap monitoring during 2002 and collects samples
1. Is this system in violation?
Yes, The^ystem is in violation for the 6-month period of July - December
2002 for failure to conduct all of its required entry point WQP monitoring.
2. How can this system return to compliance?
It must meet monitoring and reporting requirements for an entire 6-month
period.
Answer 1 '
Routine WQP monitoring is required for all large systems, except (b)(3)
systems. Once treatment is installed, entry point WQP monitoring is required
no less frequently than every 2 weeks. In this example, the system would
incur a WQP M/R violation (53 violation type code) for the 6-month period,
July 1 - December 31,2002.
If the State has adopted the OWQP compliance procedure under the LCR, the
begin date for the violation in this example is July 1,2002. The end date is
defaulted to December 31,2015. If the State has not adopted the new
compliance procedure, entry point M/R violations that occur after the system
has installed corrosion control treatment are still quarterly violations. The
begin date in this instance would be July 1,2002 and the end date would be
September 30, 2002.
Answer 2
Unlike initial and follow-up sampling that occur for a limited period of 12
months each, this system cannot make up the 2 months of missed samples for
routine entry point WQP monitoring. Therefore, a system cannot return to
compliance for routine entry point WQP monitoring until it successfully
monitors and reports for an entire 6-month period.
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WQP M/R Compliance
Scenario
System serves 8,000 people
' System has installed corrosion control treatment
7/1/00 -12/31/00: Pb 90th = 0.018 mg/L; Cu 90th = 1.0 mg/L
1/1/01-6/30/01: Pb 90th = 0.013 mg/L; Cu90th= 1.0 mg/L
1. Is this system required to collect WQP samples during 7/1/00-12/31/00?
Yes. The system exceeded the lead action level and must collect WQP
samples.
2. Is this system required to collect WQP samples during 1/1/01-6/30/01?
No. The system did not exceed the AL and is not required to collect WQP
samples.
Answer 1
Yes, medium and small systems are required to collect entry point WQP samples in the
same compliance period(s) in which they exceed an action level. The system should have
collected entry point WQP samples at least every two weeks during July 1 - December 31,
2000. Unless the system is on reduced tap WQP monitoring, it is also required to collect
2 samples at a minimum of 3 WQP tap sampling sites during this 6-month monitoring
period.
The system would have met the criteria for reduced WQP tap monitoring if it was
required to conduct WQP monitoring in prior monitoring periods and it was in compliance
with its OWQPs for at least 4 consecutive years. Remember the first, two consecutive 6
months allow a system to reduce the number of tap sampling sites. For systems serving
10,000 and fewer people, the number of WQP tap sites remains the same under standard
and reduced monitoring. The next three years of semi-annual monitoring allow the
system to reduce the frequency of tap WQP monitoring to annually. Under the scenario
presented above, it is unlikely that a medium-size system would have conducted 4
consecutive years of WQP monitoring by 2000.
The system in this example would not qualify for accelerated reduced WQP monitoring
because it must satisfy the following two conditions:
demonstrates for 2 consecutive monitoring periods that its 90th percentile lead
level is < 0.005 mg/L and 90th percentile copper level is < 0.65 mg/L, and
be in compliance with its OWQP requirements.
Answer 2
No. The system is a medium-size system and did not exceed either action level, and
therefore, is not required to conduct WQP monitoring during this 6-month period.
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Corrosion Control Study
Scenario
State notifies system on 9/10/01 that corrosion control study is required
State receives study on 9/10/03; study contains evaluation of one type of
CCT ,
1. Did the system report the study on-time?
No. The study was due by 3/10/03 (18 months after the State required the
study to be completed).
2. Does the study contains the required components?
No. A system must evaluate 3 types of CCT.
Answer 1 '
A system has 18 months to complete a study. For small or medium systems,
the 18 months begins from the date that the State determines that a study is
required. For a large system that was in operation by 1992, the deadline is
specified in the regulation and the study must be completed by July 1,1994.
Answer 2
The system submitted the study on-time but it was incomplete. The study
must evaluate the effectiveness of each of the following treatments:
Alkalinity and pH adjustment;
Calcium hardness adjustment; and
Addition of a phosphate or silicate based corrosion inhibitor.
The system must also identify constraints that limit or prohibit the use of a
particular corrosion control treatment and document these constraints.
Note that this system incurred a study violation (violation type 57). Only one
57 violation should be reported for the system even though it failed to meet
two conditions (i.e., the study was both late and incomplete). The begin date
for this violation in this example is 3/11/2003. The end date is defaulted to
December 31,2015.
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Optimal Corrosion Control
Installation
Scenario
'12/15/97: 90th percentile lead value = 0.020 mg/L
16/9/98: State determines type of OCCT to be installed
'10/11 /2000: State receives certification of installation
1. Is this system in violation?
Yes. Certification was due by 6/9/2000 (24 months after State determination).
2. When is the system back in compliance?
Once certification is received by State, or on 10/11/2000.
3. Is the system a SNC?
No. the 90th percentile level was < 0.030 mg/L.
Answer 1
A system has 24 months after the State determines the type of OCCT to be
installed to complete installation and provide a certification to the State that
the treatment is properly operating. This system has incurred a treatment
installation violation (58 violation code). The begin date for the violation in
this example is June 10,2000. The end date is defaulted to December 31,
2015.
Answer 2
Although it was late, the system submitted its certification on October 11,
2000. It is in compliance if it has installed the treatment that was specified by
the State.
Answer 3
A system is considered to be a significant noncomplier (SNC) if it does not
install OCCT on-time and the lead 90th percentile level of its most recent
monitoring period is > 0.030 mg/L.
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Next Steps After Exceedance
Scenario for Small System (population 3.100)
System on annual monitoring schedule at 10 sites
Lead and copper tap results for 1/01/00-12/31/00:
Pb 90th = 0.011 mg/L; Cu 90th = 1.4 mg/L
1. What are the next steps and deadlines if this is the first time the
system exceeds an action level?
The system must:
collect WQPs before 12/31/00;
perform source water lead and copper monitoring before 6/30/01;
make SOWT and OCCT recommendations before 6/30/01; and
begin an OCCT study (if requested by the State).
2. What is the system's schedule for lead and copper tap monitoring?
It is required to conduct lead and copper tap monitoring for 2,6-month periods
after CCT installation at 20 sites.
Answer 1
The system exceeded the copper action level and is triggered into the following required steps:
i
System must collect WQPs within the same compliance period as the exceedance, or
12/31/00 in the example.
System must collect one source water sample for lead and copper at each entry point to the
distribution system, within six months of the exceedance, or 6/30/01.
System must provide Optimal Corrosion Control Treatment and Source Water Treatment
recommendations to the State within six months after the exceedance, or 6/30/01.
Within 12 months after the exceedance, the State may require the system to prepare an
Optimal Corrosion Control Study. If it is required, the system's OCCT recommendation
would be included in the study and would not be due on 6/30/01. The study is due 18
months after the State requires the system to prepare it. (Alternatively, the State may not
require the system to perform a study and specify OCCT within 24 months after the
exceedance.)
Answer 2
After the installation of treatment, the system must resume standardized monitoring at the standard
number of sites. In this example, the system must collect 20 samples each period, instead of the 10
samples required during annual monitoring. The system is eligible for reduced monitoring again
after it completes two, consecutive, six-month rounds where:
the 90th percentile values are below the lead and copper action levels; or
* the system meets OWQPs, if applicable.
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System that Increases Size
to > 50,000
Scenario for Medium System that Becomes A Large System
2/11/00: System adds new connections and increases size from
45,000 to 75.000 people
Monitoring results during annual tap monitoring conducted during 1999
Lead 90th = 0.010 mg/L; Copper 90th = 1.1 mg/L
1. What are the system's corrosion control treatment requirements?
System completes a corrosion control study and submits recommendation
within 18 months from State notification
State determines CCT within 6 months of study/recommendation submittal
System installs treatment within 24 months
2. What are the system's monitoring requirements?
System conducts follow-up lead and copper and WQP monitoring for 2
consecutive, 6 months following treatment installation. System continues on
semi-annual monitoring until it qualifies for reduced monitoring by meeting its
OWQPs.
Answer 1
This system has increased the number of people served and now qualifies as a large system. Unless, the system can
quality as a (b)(3) system, it is now triggered into corrosion control treatment requirements. The State should notify
the system as soon as practicable, about its new requirements.
18 months from this notification, the system must complete a corrosion control study and submit a CCT
recommendation
6 months from this submission, the State must notify the system regarding the type of treatment that it must
install
within 24 months from the State's CCT decision, the system must complete installing CCT.
Answer 2
The system must complete follow-up lead and copper tap and WQP monitoring during the two consecutive, 6-month
monitoring periods that immediately follow the system's installation of corrosion control treatment. Remember, that
entry point WQP monitoring increases to at least every two weeks, but the number of samples from each entry point
decreases from 2 sample to 1.
Once the State sets OWQPs (within 6 months of follow-up monitoring), the system must continue to collect lead and
copper tap and WQP samples.
If the system qualifies for accelerated reduced monitoring because its lead levels are < 0.005 mg/L and
copper 90th percentile level is < 0.65 mg/L and it meets its OWQPs for 2 consecutive 6-month periods, it
can immediately monitor for both lead and copper tap and WQP tap once every 3 years. Entry point WQP
monitoring continues at a minimum frequency of once every two weeks.
* If the system does not qualifies for accelerated reduced monitoring, but does not exceed either action
level, it must monitor every 6 months until it qualifies for reduced monitoring by meeting its OWQPs.
Please note, although, this system was on annual tap monitoring, the system can no longer qualify for
reduced lead and copper tap monitoring simply because it is below the action level. This provision is only
available to small and medium-size systems.
* If the system exceeds either action level, it must monitor every 6 months until it qualifies for reduced
monitoring by meeting its OWQPs.
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Lead and Copper NPDWR
Requirements
Lead and Copper Tap/Initial WQP
Monitoring
Corrosion Control Optimization
Public Education
Source Water Monitoring & Treatment
Replacement of Lead Service Lines
State Reporting and Recordkeeping
Primacy and Implementation
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Public Education
Applicability
* Any system that > lead AL
Continues as long as AL is exceeded
j|) STOP: Whenever below AL for 1
monitoring period
Recommence: If exceed in
subsequent period
Public education only is required if a system exceeds the lead action level.
Public education is not required if a system exceeds the copper AL only.
Public education must be delivered until the system no longer exceeds the lead
action level. i
Public education is again required if the system exceeds the lead action level
in any subsequent monitoring period.
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Public Education
Mandatory Language
Minimum Content Specified in Rule
- Introduction
- Health Effects
- Sources of Lead
- Steps at Home
System Can Add Information
Not the same as Public Notification
The LCR specifies mandatory public education language that must be included
in a system's public education materials. The language discusses steps that the
system is taking to minimize lead, the health effects of lead, the sources of
lead contamination, and measures that individuals can take to minimize their
lead exposure. Systems can also add other information to the public education
materials if it is consistent with the mandatory language.
Public notification is not the same as public education. Public notification
must be provided whenever a system is in violation for failure to meet
monitoring and reporting requirements or treatment technique requirements.
There is specific notification language that is required whenever a system is in
violation of the LCR monitoring and reporting requirements or treatment
technique requirements. For the specific public notification requirements,
refer to §141.32.
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Public Education
Delivery Requirement for CWSs
Within 60 days of exceeding Lead Action Level:
Bill staffers
i
Pamphlets to sensitive groups
(e.g., pediatricians)
Major newspapers
* Public Service Announcement
(PSA) to radio/TV
The public education requirements are different for CWSs and NTNCWSs.
CWS requirements under the LCR
j
Within 60 days of exceeding the lead action level, a CWS must:
i
Insert notices in each customer's water utility bill;
i
Deliver pamphlets and/or brochures that contain the public education
materials to facilities and organizations that provide services to pregnant
women and children;
Submit information to the editorial departments of the major daily and
weekly newspapers circulated throughout the community; and
Deliver public service announcements (PSAs) to radio and television
stations.
As explained on the next page, the frequency of public education delivery drops to
semi-annually or annually, depending on the requirements.
Please note that the 60-day requirement only applies when a system first
exceeds the lead action level or when it again exceeds again after having
one or more monitoring periods below the lead action level
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Public Education
Delivery Requirements for CWSs (Cont)
PSAs every 6 months
Inserts, pamphlets,
newspaper notification every
12 months
CWS requirements under the LCR (continued)
Under the LCR, all CWSs were required to repeat PSAs every 6 months for as
long as the system exceeds the lead action level.
AH other public education requirements (billing inserts, pamphlets/brochures,
and newspaper notification) were required to be repeated annually for as long
as the system exceeds the lead action level.
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; Public Education
Delivery Requirements for NTNCWSs
Within 60 days of lead exceedance
- posters in public places and buildings served
- pamphlets/brochures to each person served
Repeat annually
NTNCWS requirements under the LCR
Under the LCR, NTNCWSs were required to deliver the the same mandatory
written language as CWSs pertaining to lead health effects and steps that
homeowners can take to minimize exposure to lead.
i
Public education was distributed by:
i
posting informational posters in public places or in common areas of
buildings served by the system, and
distributing informational pamphlets and/or brochures to each person
served by the NTNCWSs.
A NTNCWS was required to repeat this information annually for as long as it
exceeded the lead action level.
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LCR Minor Revisions
Content and Delivery Flexibility
All CWSs may:
Delete language regarding LSLs
Change language regarding building
permit record availability
Delete the references to "control" of a LSL
Send materials separately from water bills
The LCRMR offer some flexibility in making revisions to the mandatory public education
language and the distribution of public education materials.
CWSs can:
delete reference to lead service lines (LSLs) from their public education language, if they
do not have any LSLs, and States approve this change.
change the language regarding the availability of building permit records and consumer
access to these records, if the records are not available and States approve this change.
delete the references to "control" of a LSL because this term is no longer used in the
LCRMR (i.e, the LCRMR requires systems to replace LSL that they "own" vs. "control").
use up old public education material even after the LCRMR takes effect.
do a separate mailing of public education materials if the system has difficulty sending the
materials with the regular bills. Systems must include the mandatory "alert" language in
the bill or on the outside of the envelope, and deliver the mailing within 60 days of
exceeding the lead action level and every 12 months thereafter for as long as the system
exceeds the lead action level. The system can also satisfy the annual delivery requirement
for those customers that receive water bills by including the mandatory language hi its
consumer confidence report. However, the alert must be included in the front of the
consumer confidence report.
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LCR Minor Revisions
Content and Delivery Flexibility (Cont.)
CWSs serving < 3,300 people may:
f
Forego PSAs
* Forego notification via newspapers* &
Limit,distribution of pamphlets*, but must:
- mail or hand deliver materials to customers who
don't receive water bills
- deliver to wider audience if State requires
"501-3.300 need State approval
The LCRMR contain provisions that allow small systems to reduce their public
education requirements.
CWSs serving < 3,300.people are not required to deliver PSAs. As discussed previously,
the 1991 LCR required CWSs to deliver PSAs every 6 months for as long as the system
exceeded the lead action level. With the elimination of the PSAs, CWSs serving < 3,300
people would repeat public education on an annual basis until they no longer exceed the
lead action level. i
CWSs serving < 500, and those CWSs serving 501 - 3,300 people with State permission:
Do not have to submit information to newspapers, and
Can limit the distribution of pamphlets to facilities served by the system that
most regularly serve pregnant women and children, but must also:
- mail or hand deliver the public education materials to all customers who don't
already receive water bills;
- must deliver to a wider audience if State requires them to do so.
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LCR Minor Revisions
Content and Delivery Flexibility (Cont.)
NTNCWSs may:
* Use specified alternative language
Delete references to LSLs in their language
Use electronic transmission
Special-case CWSs (prisons, hospitals) may:
Use NTNCWS language and delivery methods
NTNCWS may:
Use alternative language that is more suited to their type of systems (example,
do not contain a section on Steps you can take in the home to reduce exposure to
lead in drinking water.) Systems must obtain State approval to use this
language, unless the State waives this requirement.
Delete references to LSLs in their public education materials if they do not have
these LSLs and they obtain State permission.
Distribute public education materials electronically instead of, or with printed
materials, as long as this achieves at least the same coverage.
Special-case CWSs may request in writing permission to use the alternate
language and delivery methods allowed for NTNCWSs. States also can waive
the requirement for these systems to obtain prior approval.
A special-case CWS is a facility, such as a prison or hospital, where the
population served is not capable of or is prevented from making
improvements to plumbing or installing point-of-use treatment devices and
where the system provides water as part of the cost of services provided
and does not separately charge for water consumption.
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LCR Minor Revisions
Compliance Reporting to State
More Timely Reporting
LCR I
- Due by December 31st
LCRMR
O Due within 10 days after each period in which
public education was required
O States can allow system to forego
resubmission of distribution list
Ol implement on April 11, 2000
Systems must report completion of all required public education tasks to the State within
10 days after the date by which the system is required to complete the 60 day, semi-
annual, and/or annual public education tasks. This replaces the requirement to report
once per year by December 31. The rationale for accelerating the public education
reporting requirement is to improve compliance because, in addition to making the
requirements easier to enforce, it also will encourage water systems that exceed the lead
action level to deliver the public education program in a more timely manner.
i
!
This revision will require those CWSs that must deliver PSAs to radio and television
stations every six months to submit two letters to the State during a calendar year instead
of the single letter initially required. However, with the elimination of PSAs for CWSs
serving 3,300 or fewer people, most systems that are required to deliver public education
will be subject to annual requirements only and thus, will be required to submit one
letter.
States can allow systems to omit the public education distribution list as part of their
public education compliance letter, jf they have already submitted this information
previously to their State and the systems certify that this list has not changed. However,
States cannot implement this part of the provision unless they incorporate it into their
drinking water regulations.
States must maintain records of any decisions regarding the resubmission of detailed
documentation to demonstrate completion of public education tasks.
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LCf? Minor Revisions
Summary of Public Education Revisions
Allow content and delivery flexibility
- delete obsolete or irrelevant language
- mail notices separately from water bill
Reduce requirements for CWSs serving < 3,300
* Make NTNCWSs requirements more appropriate
- specific NTNCWSs language
- use of electronic transmission
Treat special-case CWSs like NTNCWSs
O Require more timely system compliance reporting
O Allow system to forego resubmission of distribution list
©Implement on April 11, 2000
LCRMR Revision
Delete obsolete'or irrelevant language
(reference to LSL, control of LSLs,
building records)
Mail notices separately from water bill
Reduce requirements for CWSs serving
< 3,300
Provide specific NTNCWS mandatory
language
Allow use of electronic transmission by
NTNCWSs
Allow special-case CWSs to use NTNCWS
language and delivery requirements
More timely compliance reporting
Allow system to forego resubmission of
distribution list
Where to Find It
§141.85(a)(l)(i)&§141.85(a)(2)
§141.85(c)(2)(i)
§§141.85(a)(2)(i)-(iv)
§141.85(c)(4)(ii)
§141.90(f)
§141.90(f)(2)
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\ : /
1
1
1
1
1
Public Education
pompliance Examples
i
/ \
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Applicable Reporting
Requirements
65 - Violation type code (no change)
SNC definition has not been revised
- system with violation and lead 90th percentile
> 0.030 mg/L
Violation
The period of violation is described by the first day after the 60 day, 6 month,
or 1 year compliance period in which the public education requirements were
to be performed. The violation period ends when the State determines those
requirements have been met. The system has 10 days after the end of the 60
day, 6 month or 1 year compliance period to report to the State. This 10-day
period is not added to the compliance period. In other words, the system does
not have 70 days to meet its requirements. It has 60 days to meet the
requirements and 10 days to report. As in other treatment technique
violations, SDWIS/FED will default a compliance period end date of
December 31,2015. When the State reports the RTC enforcement/follow-up
action data (including the required violation link data), SDWIS/FED will
replace the defaulted end date with the RTC date. This method more
accurately describes how long the system took to perform the public
education requirements.
SNC
A Public Education SNC is still defined as a system that incurs a public
education violation and its 90th percentile lead level is 0.030 mg/1 or higher in
its most recent monitoring period.
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Applicable Reporting
! Requirements
' Public Education
ONE Public Education (PE) Violation must
be reported for EACH discrete PE
compliance period requirement (i.e., 60 days,
semi-annual, and annual)
PWS could incur 3 separate violations In
first 14 months after exceedance
10-day period to report to State is not
included
Depending on the specific requirement and PWS type, the time frames
include the following:
"60 days after the end of the designated monitoring period" of a lead
action level exceedance;
"6 months after the 60 days" for repeat public service announcements
foraCWS;and
"12 months after the 60 days " (for both CWSs and NTNCWSs) for
repeat notices to customers and delivery of pamphlets and brochures.
Even though there are multiple requirements under each of the discrete PE
requirement periods, only one violation is reported for each discrete PE
period.
The rule allows 10 days after the date by which the system is required to
complete the 60 day, semi-annual, or annual requirement to report to the State
that it has conducted this requirement. This 10-day period is not included in
the violation begin date.
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Public Education
Scenario
' CWS serves 6,000 people
> 1/1/99-12/31/99: Pb 90th percentile = 0.014 mg/L;
Cu 90th percentile = 0.9 mg/L
1/1/00-12/31/00: Pb 90th percentile = 0.020 mg/L;
Cu 90th percentile - 0.9 mg/L
1. Is this system required to deliver public education?
Yes. it exceeded the lead action level.
2. What is the system required to do and in what timeframe?
Within 60 days of exceedance (by 3/1/01), must send notices with water bill,
provide newspaper notification, deliver pamphlets/brochures, & PSAs.
3. When is the system required to report compliance to the State?
By March 11, 2001.
Answer 1
The system must deliver public education because it exceeded the lead action
level. (Public education is not required if it exceeds the copper action level.)
Answer 2
Because the system did not exceed the lead action level in the previous
monitoring period, it must within 60 days of exceeding the lead action level:
Insert notices in each customer's water utility bill;
Submit information to the editorial departments of the major daily and
weekly newspapers circulated throughout the community;
Deliver pamphlets and/or brochures that contain the public education
materials to facilities and organizations that provide services to
pregnant women and children; and
Deliver PSAs to radio and television stations.
Note: If the State calculates the 90th percentile level for the system, the 60
days begins when the State notifies the system of the exceedance.
Answer 3
Systems must report completion of all required public education tasks to the
State within 10 days after each period in which the tasks were required to be
completed. This replaces the requirement to report once per year by December
31. In this example, the system was required to deliver public education
within 60 days of the exceedance or by March 1,2001. Therefore, the
compliance letter for the 60-day requirement is due on March 11,2001.
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Public Education
Scenario
CWS serves, 50 people
1/1/-12/31/01: Pb 90th percentile = 0.017 mg/L;
, Cu 90th percentile = 1.2 mg/L
1. Is this system required to deliver public education?
Yes it exceeded the lead action level.
2. If the system does not deliver PSAs is it in violation?
The system is not in violation if the State has adopted the small system public
education provisions.
Answer 1
A system must deliver public education when it exceeds the lead action level.
Answer 2 p
Under the LCRMR, CWSs serving < 3,300 people are not required to deliver
PSAs. However, the State must have incorporated these provisions into its
State drinking water regulations before they can implement them.
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Public Education
Scenario
NTNCWS serves 4,000 people
1/1/-6/30/01: Pb 90th percentile = 0.012 mg/L;
Cu 90th percentile = 1.6 mg/L
1. Is this system required to deliver public education?
No, public education is not triggered by a copper action level exceedance.
Answer
The system exceeded the copper action level only. Public education
requirements are not triggered by a copper exceedance.
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Public Education
Scenario
CWS serves!2,800 people
> System first delivered public education on February 1998
> System continues to exceed the lead action level in 1999 and 2000
1/1/-6/30/01 Pb 90th percentile = 0.020 mg/L; Cu 90th percentile = 0.9 mg/L
7/1/-12/31/01: Pb 90th percentile = 0.012 mg/L; Cu 90th percentile = 0.9 mg/L
1. Is this system required to deliver public education during 2001?
Yes, the system is required to deliver public education by February 2001.
t
i
2. If the system did not deliver any public education during 2001, how
does the system come back into compliance?
The system must complete one more round of public education.
Answer 1 i
A CWS must repeat public education every 12 months until it has one
monitoring period, in which the lead 90th percentile level is below the lead
action level. In this example, the system must complete its annual requirement
by February 15 of each year. The system was not below the lead action level
until monitoring that was conducted during July - December, thus the system
can discontinue public education in the 2002 and thereafter, if it continues to
be below the lead action level.
Answer 2
i
If the system did not deliver public education during 2001, it would incur a
public education violation for failure to meet its annual requirements (65
violation type code). The begin date for this violation would be March 1,2001
and the end date would be defaulted to December 31,2015.
t
A system cannot return to compliance for public education, until it fulfills the
public education requirement for which it is in violation. The system can add
language that explains that it did not exceed the lead action level in its most
recent monitoring period.
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Lead and Copper NPDWR
Requirements
Lead and Copper Tap/Initial WQP
Monitoring
Corrosion Control Optimization
Public Education
Source Water Monitoring & Treatment
Replacement of Lead Service Lines
State Reporting and Recordkeeping
Primacy and Implementation
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Monitoring &Treatment for Lead
and Copper at the Source
Steps
Triggered by lead or copper exceedance
* Within 6 months of exceedance:
- System provides monitoring results/treatment
recommendation
* Within 6 months of results:
\
- State treatment decision
ion exchange
reverse osmosis
lime softening
coagulation/filtration
no treatment needed
Monitoring/Treatment Recommendation
Within 6 months of exceeding the lead or copper action level, systems must collect
source water samples. The sample location, collection methods, and number of samples
required is the same as for Phase II/V contaminants. Ground water systems must take at
least one sample at every entry point to the distribution system which is representative of
each well after treatment. Surface water systems must take at least one sample at every
entry point to the distribution after the application of treatment or in the distribution
system at a point which|is representative of each source after treatment. Compositing is
also allowed under the LCR.
i
i
i
Systems must also provide to the State a source water treatment recommendation with
their source water monitoring results. This recommendation is based on source water
monitoring results. A source water treatment study is not required. Systems should
consider: ion exchange;, reverse osmosis, lime softening, and coagulation/filtration. A
system can also recommend that no source water treatment is needed. EPA's guidance
document Lead and Copper Rule GuidanceManual Volume II: Corrosion Control
recommends source water treatment when the concentration of lead in the source water
is greater than 0.005 mg/L or the concentration of copper in source water is greater than
0.800 mg/L.
State Decisions
Within 6 months of receiving the system's results and recommendation, the State must
determine whether source water treatment is needed. If the State determines this
treatment is needed, then the State must require either the installation of treatment
recommended by the system or one of those listed above. This decision and the basis for
this decision must be provided to the system in writing.
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Source Water Monitoring
&Treatment
Steps If Treatment Is Needed
If source water treatment is needed:
* 24 months after State decision
- System must install treatment
12 months after installation
- System conducts follow-up monitoring for 2
consecutive 6-months
6 months after follow-up monitoring:
- State sets MPLs for both lead and copper
System must be at or below MPLs
Source Water Treatment
A system that is required to install source water treatment must complete installing this
treatment within 24 months of State's decision to install treatment. Failure to do so is a
treatment technique violation.
Follow-up Monitoring
A system must collect lead and copper tap samples and source water samples during two,
consecutive 6-months immediately following the installation of treatment. This must be
completed no later than 36 months after the State determines the type of source water
treatment to be installed. A system must complete these two, consecutive, 6-months of
follow-up monitoring, even if the system is now below the lead and copper action level
in tap water monitoring.
State sets MPLs
Based on the monitoring data that was collected before and after the installation of
source water treatment, the State sets maximum permissible levels (MPLs) for lead and
copper. The State established MPLs for both lead and copper, even if the system only
exceeded the action level for one of these contaminants in tap water samples.
MPLs maximum level of lead and copper that is allowed in
finished water entering the distribution system.
Must be at or below MPLs
Systems that are above either MPL, incur a treatment technique violation. A system can
take a confirmation sample within 2 weeks of the original sample. The results of the
original and confirmation samples are averaged to determine whether a system is in
compliance with its MPLs. MPLs are federally-enforceable standards.
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Source Water Monitoring
; &Treatment
! Routine/Reduced Monitoring
If source water treatment is not needed
1 or after State sets MPLs*
Source Type
Grand v&er
Sirfaceor
cartoned
Routine
Monitoring
onos during 3-yBsr
oonplianoe per-od in
effect
annually
Reduced to every 9
years if:
I^M^ for 3 consecutive
oonrplianoB periods
Meet MPLs for 3 consec yrs
Assumes system continues to exceed Pb and/or Cu AL
Routine Monitoring '
Systems using ground water as their only source must monitor during 3-year compliance
periods. These are the same compliance periods that were established under the
Standardized Monitoring Framework (SMF) for Phase II/V contaminants (e.g., 1993 -
1995,1996 -1998, 1999 - 2001,2002 - 2004, etc.). Therefore, systems can coordinate
their source water monitoring for lead and copper with other monitoring requirements.
i
Systems using surface water or surface water combined with ground water must monitor
annually. The first annual monitoring period begins on the date that the State determined
the type of treatment to be installed or that no treatment was required.
Reduced Monitoring
Systems that qualify for reduced monitoring can reduce the frequency of monitoring to
once every 9 years. The 9-year schedule follows the 9-year monitoring cycle established
under the SMF (i.e., 1993 - 2001), (2001- 2010), etc.
A ground water systems qualifies for reduced monitoring if it does not exceed either
the lead or copper MPL for 3 consecutive, 3-year compliance periods (equals 9
years).
A surface water system or system using a combined source can qualify for 9-year
monitoring if they do not exceed either MPL for 3 consecutive years.
NOTE: Once a system qualifies for reduced monitoring, it is not required to return
to standard monitoring. In other words, an exceedance of an action level or of an
MPL does not impact a system's reduced source water monitoring schedule.
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Source Water Monitoring
&Treatment
When Monitoring Is Not Required
Once MPLs are set or State decides no
SOWT is needed, source water monitoring
is not required when:
The system is below both ALs for entire
source water monitoring period
Example:
- system is on 9-year source water monitoring
during 2002-2010
- 90th percentiles < ALs for all tap monitoring
during 2010 to 2010 -» no source monitoring
Once a system exceeds either the lead or copper action level, it is always subject to
source water monitoring requirements. However, after the State has designated MPLs or
determined that the system is not required to install source water treatment, the system is
not required to collect any source water samples if its 90th percentile lead or copper
level does not exceed the action level during the entire source water monitoring period in
effect.
For example, a system qualifies for reduced source water monitoring for the compliance
cycle of 2002-2010. During this time period, the system is on triennial lead and copper
tap monitoring. It conducts lead and copper tap monitoring during 2001-2003,2004-
2006,2007-2009, and 2010-2012. Both the lead and copper 90th percentile levels are
below the lead and copper action levels for all four monitoring periods. The system is
not required to conduct source water monitoring.
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| LCR Minor Revisions
Source Water Monitoring Changes
Reduced monitoring for systems w/o MPLs if
source water levels for:
i Lead are < 0.005 mg/L
! Copper are < 0.65 mg/L
Must maintain levels for 3 consecutive
compliance periods:
, Ground water = 9 years
I Surface water = 3 years
Reduced source water monitoring
The LCRMR expand the universe of systems that can qualify for reduced monitoring.
The 1991 LCR did not allow systems that exceeded an action level, but which were not
required to install source water treatment, to reduce the frequency of source water
monitoring.
The criteria for qualifying for reduced monitoring is the same as that under the LCR.
Systems exceeding an action level after the State has determined that source water
treatment is not needed,; can reduce the frequency of source water monitoring if:
source water lead concentrations are < 0.005 mg/L; and
source water copper concentrations are < 0.65 mg/L
AND ;
the system maintains these levels for 3 consecutive compliance periods.
Ground water systems would qualify for reduced monitoring after 3 consecutive, 3-year
compliance periods or after 9 years.
Surface water systems (or those using a combined source) would qualify after 3
consecutive years.
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LCR Minor Revisions
Source Water Monitoring Changes (Cont.)
OResampling triggers have been changed for
composite samples to:
> 0.160 mg/L for copper
* > 0.001 mg/L for lead
OCompositing done by certified laboratory
Labs not required to achieve Copper MDL to
analyze composite source water samples
©Implement on April 11, 2000
Resampling triggers for composite samples
In those States where compositing of source water samples is allowed, the resampling
trigger for copper has been increased from 0.001 mg/L or 0.002 mg/L (depending on the
method used) to 0.160 mg/L. The lead resampling trigger has been slightly changed
from > 0.001 mg/L to > 0.001 mg/L. Since up to five samples may be composited for
analysis, the resampling triggers are one-fifth of the levels above which EPA
recommends source water treatment. (EPA recommends source water treatment when
source water lead levels exceed 0.005 mg/L or source water copper levels exceed 0.800
mg/L.)
In addition, the requirements for source water sample location, number of source water
samples, and collection methods have been incorporated directly into §141.88(a)(l) and
the reference to §141.23 has been eliminated. Further, the LCRMR specifies that
compositing must be done by a certified laboratory.
Laboratory certification for composite samples
Changes to the composite source water resampling triggers for lead and copper
necessitate revisions to the laboratory certification procedures pertaining to composite
source water samples. Laboratories no longer have to achieve the copper MDL in order
to analyze composite source water samples. The copper resampling trigger of 0.160
mg/L is sufficient to prove laboratory capability requirements under
§141.89(a)(l)(iiXB).
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I LCR Minor Revisions
Summary of Source Water Monitoring
Revisions
Reduced monitoring for systems w/o MPLs
ORevisions to source water resampling
triggers for composite samples
OCompositing by certified lab
Labs not required to achieve Copper MDL
to analyze composite source water samples
| Complement on April 11,20001
LCRMR Revision
Reduced monitoring for systems w/o MPLs
i
Revisions to source water resampling
triggers for composite samples
Compositing by certified laboratory
Labs are not require^ to achieve Copper
MDL
Where to Find It
§§14L88(e)(l)&(2)
§141.89(a)(l)(iv)
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Source Water
Compliance Examples
/ \
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Applicable Reporting
| Requirements
Source Water M/R & MPL Noncompliance
No change to violation type code for:
- Source water M/R violations (56 violation type)
- MPL noncompliance (63 violation type)
Violation code change for:
Old New
i
SOWT recommendation 61
SOWT installation 62
57
58
Consolidated OCCT/SOWT Installation and/or
Demonstration SMC
The violation type codes have not been changed for:
Source water M/Rl vioiati ons. All source water M/R violations continue to be reported
using the 56 violation code.
Maximum Permissible Level (MPL) noncompliance. A violation type code 63 is still to
be used to report systems that exceed their lead and/or copper MPLs.
Violation codes associated with a source water treatment (SOWT) recommendation or SOWT
installation violation have been changed.
A 57 violation is used to report either:
A system's failure to meet its a source water treatment recommendation requirements
(formerly a 61 violation type), or
* A system's failure to meet its corrosion control study/recommendation requirements.
A 58 violation is used to report either:
A system's failure to meet its a source water treatment installation requirements
(formerly a 62 violation type), or
* A system's failure to meet its optimal corrosion control treatment installation
requirements.
EPA will list a system that meets the OCCT Installation SNC criteria or SOWT Installation
SNC criteria as a Treatment Installation/Demonstration SNC.
The basic definition for this SNC has remained the same, a system that incurs a treatment
installation violation and has a 90th percentile lead level of > 0.030 mg/1 in most recent
monitoring period. '
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Applicable Reporting
Requirements
Source Water M/R & MPL Noncompliance
Converted the end dates to 12/31/2015
Source water follow-up monitoring requires
two consecutive, 6-month rounds - only 1
M/R violation is reported.
Monitoring is conducted AFTER the lead or
copper action level exceedance (No
Grandfathering)
Like lead and copper tap monitoring, there can be 3 types of source water monitoring
requirements: Initial, Follow-up, and Routine. The initial round only requires one
round. Follow-up requires 2 consecutive 6-month rounds, and the Routine monitoring
is one round within 3-year compliance periods for groundwater and one round within a
1-year period for surface water systems or systems with a combined source. In
addition, systems on routine monitoring can qualify for reduced monitoring in which
source water samples are collected once every 9 years.
Only 1 M/R violation is reported for failure to sample for either lead or copper, or both
lead and copper per designated monitoring period.
Initial source water monitoring is conducted AFTER the lead or copper tap action
level(s) is exceeded. Even if the State requires lead and copper be monitored routinely
with the inorganic monitoring, the samples must be taken AFTER the lead or copper
tap exceedance. There are no provisions in the LCR/LCRMR for grandfathering of
data.
For follow-up source water monitoring, only one M/R violation is reported. The begin
date of the violation is the day after the first round missed. RTC may not be reported
until 2 consecutive 6-month rounds are completed.
For routine or reduced source water monitoring, the compliance period is annual,
triennial, or every 9 years. The begin date of a violation would be the day after the
compliance period in which the source monitoring was to be conducted. RTC is
reported once the system properly conducts the source water monitoring.
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'Applicable Reporting
! Requirements
MPL Noncompliance
A system may incur separate Violations for
exceeding the Lead MPL and the Copper MPL
Only ONE MPL Noncompliance Violation must be
reported for a single contaminant regardless of how
many entry points are in violation
Contaminant code is:
- 1022 = Copper,
- 1030 = Lead
- reported in lieu of 5000 code that is used for all other LCR
or LCRMR violations
If a system exceeds the MPL for only Lead or only Copper in more than one
source water sample, the State would report a single violation for that period,
for that contaminant.
If a system exceeds the MPL for both Lead and Copper, the State would
report two violations.
To simplify reporting, only ONE Lead or ONE Copper violation is required
to be reported in each designated monitoring period, regardless of how many
entry points incur an exceedance.
No SNC conditions for source water monitoring, failure to provide a source
water recommendation, or failure to meet source water treatment installation
requirements. i
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Source Water M/R
Scenario for a New System
The system's first lead and copper tap monitoring period is 1/1/00 - 6/30/00
Pb 90th percentile = 0.012 mg/L; Cu 90th percentile = 1.9 mg/L
1. Is tills system required to collect source water samples?
Yes.
2. When are these samples due?
By 12/31/00 (within 6 months of exceedance).
3. If the system has the source water samples analyzed for copper only.is it
in violation?
Yes. It must have the samples analyzed for both lead and copper.
4. How does the system return to compliance?
Must collect source water samples and have them analyzed for both lead and
copper samples for a &-month compliance period.
Answer 1
A system that exceeds the lead or copper action level must collect source
water samples at each entry point to the distribution system.
Answer 2
This monitoring must be completed within 6 months of the end of the
compliance period in which the exceedance occurred.
Answer 3
The system must collect both lead and copper tap samples even if exceeds only
one of the action levels. The system in this example would incur an initial
source water M/R violation (56 violation type code). The begin date of this
violation would be January 1,2001. The end date would be defaulted to
December 31,2015.
Answer 4
To achieve compliance for an initial source water M/R violation, the system
must properly fulfill its source water monitoring and reporting requirements
for one, 6-month monitoring period.
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Source Water M/R
Scenario for a New System
6/30/01: t Source water treatment installed
1/1/-6/30/02: System collects one round of follow-up monitoring
> 9/15/02: j State reviews status of system
1. Assuming die system followed proper monitoring and analytical
procedures, is it in violation with its source water M/R
requirements?
Yes. 2 consecutive 6-month rounds of follow-up monitoring are required.
i
2. How does'the system return to compliance
It collects 2 consecutive 6-month round of follow-up monitoring.
Answer 1
i
All systems that are required to install SOWT must collect follow-up source
water samples during two consecutive six-months compliance periods. The
State uses the data to set MPLs for lead and copper in source water. In this
example, the system is in violation for failure to collect the first, six-month
period of its source water follow-up monitoring (56 violation type code). This
monitoring was required to be conducted during the compliance period July 1
to December 31,2001. The begin date for this violation is the day after the
end of the first missed compliance period or January 1,2002 in this example.
The end date is defaulted to December 31,2015.
Answer 2 j
To achieve compliance, the system must collect two consecutive round of
source water samples. In this example, if the system conducts source water
monitoring during July 1 - December 31, 2002, it would return to compliance.
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Source Water M/R
Scenario
on 9-year source water monitoring cycle of 1/1/02 -12/31/10
1/1/00 -12/31/02: Pb 90th = 0.006 mg/L; Cu 90th = 1.1 mg/L
1/1/03- 12/31/05: Pb 90th = 0.007 mg/L; Cu90th= 1.0 mg/L
1/1/06 -12/31/08: Pb 90th = 0.006 mg/L; Cu 90th = 1.2 mg/L
1/1/09-12/31/11:Pb 90th = 0.007 mg/L; Cu90th= 1.5 mg/L
1. Is the system required to collect source water samples during
1/1/02-12/31/10?
If tap samples were collected during 2009 or 2010. then yes. If tap samples
were collected during 2011, then no source water samples are required.
However, source water monitoring must be conducted during the next
compliance cycle of 1/1/11 to 12/31/19.
Answer
The system exceeded the copper action level during the tap monitoring period
of Jan. 2009 to Dec. 2011, but did not have exceedances in any of the prior
monitoring periods. If the system collected the sample during 2009 or 2010,
the exceedance would occur during the 9-year source water compliance period
of January 1, 2002 - December 31,2010, and therefore, source water sample
would be required.
If lead and copper tap samples were collected during 2011, the system would
not be required to collect source water samples during January 1,2002 -
December 31,2010, but it would be required to conduct source water
monitoring during January 1,2011 - December 31,2019.
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SOWT Recommendation
Scenario for New Systems
System exceeds the lead action level for first time during annual monitoring
conducted in12000
Initial source water results: Pb = 0.005 mg/L;' Cu = 0.6 mg/L
I
1. Is the system required to provide a source water treatment
recommendation?
i
Yes. A recommendation must be provided with the initial source water
monitoring results within 6 months of exceeding the AL, even if the
recommendation is no treatment.
Answer
i
A system is required to conduct initial source water monitoring and to provide
a treatment recommendation within 6 months of when it first exceeds lead or
copper action level. The system may recommend that no treatment be
installed as its recommendation. A system that does not provide this
recommendation within 6 months would incur a treatment technique violation
with a revised violation type code of 57.
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SOWT Installation
Scenario
1/15/1998: State determines type of SOWT to be installed
7/15/2000: System installs SOWT
»Most recent tap monitoring results: Pb 90th = 0.035 mg/L; Cu 90th = 1.2 mg/L
1. Is the system in violation?
Yes. The system did not install SOWT on-time (within 24 months of State
decision).
2. Is the system an SNC?
Yes because the system incurred an SOWT violation and its most recent lead
90th percentile level was > 0.030 mg/L.
Answer 1
A system must complete the installation of SOWT and submit a certification
that this treatment has been installed within 24 months of the State's decision
regarding the type of SOWT to be installed. The system in this example
incurred a SOWT installation violation (revised violation type code 58). The
begin date for the violation in this example is January 16,2000. The end date
is defaulted to December 31,2015.
Answer 2
A system can become an SNC if it incurs a SOWT installation violation and
the 90th lead level for its most recent tap monitoring is > 0.030 mg/L.
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MPL Compliance
Scenario |
System has 1 entry point
Lead MPL = 0.008 mg/L; Copper MPL = 0.7 mg/L
Source water results for 2000: Pb = 0.007 mg/L; Cu = 0.6 mg/L
Source water results for 2001: Pb = 0.008 mg/L; Cu = 0.8 mg/L
1. Is the system in compliance with its MPLs for 2000?
Yes. The system did not exceed either MPL.
I
2. Is the system in compliance with its MPLs for 2001?
The system is in compliance with its lead MPL, but has exceeded the copper
MPL. :
Answer 1 !
The system is in compliance with its MPLs for source water monitoring
conducted in 2000 because both the lead and copper source water results are
below their respective MPLs.
Answer 2 |
During 2001, the system exceeded the copper MPL and therefore is in
violation. Failure to meet either MPL is a treatment technique violation (63
violation type code). The contaminant code for this violation is 1022 (for
noncompliance with copper MPL). Remember, a 63 violation is the only one
in which the State cannot use the contaminant code of 5000. Either the
contaminant code of 1022 (for copper) or 1030 (for lead) must be specified.
The begin date for the violation in this example is January 1,2002. The end
date is defaulted to December 31,2015.
Please note that this system could have collected a confirmation sample within
2 weeks of the original sample. If the average of the original confirmation
sample had been at or below the MPL, the system would have been in
compliance with its copper MPL requirements.
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MPL Compliance
Scenario
* System has 3 entry points
MPLs:set at Pb = 0.006 mg/L; Cu - 0.7 mg/L
Entry point 1: Pb = 0.006 mg/L; Cu = 0.6 mg/L
Entiy point 2: Pb = 0.008 mg/L; Cu = 0.8 mg/L
Entry point 3: No sample collected
1. is the system in violation?
Yes. The system is in violation with 2 requirements. Failure to meet its MPLs
and failure to collect enough source water samples.
An MPL violation can be incurred if the system exceeds the MPL for lead or
for copper in any sample collected. Therefore, the system would have MPL
violations for both copper and lead, even though the system failed to collect all
the required samples. In addition, the system would also incur a source water
M/R violation for failure to collect source water samples at all entry points.
Therefore, the system in this example has 3 violations as follows:
Source water M/R (56 = violation type code)
MPL noncompliance with copper (63 = violation type, 1022
contaminant code)
MPL noncompliance with lead (63 = violation type, 1030 =
contaminant code)
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'"<''
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Lead and Copper NPDWR
Requirements
Lead and Copper Tap/Initial WQP
Monitoring
Corrosion Control Optimization
Public Education
> Source Water Monitoring & Treatment
Replacement of Lead Service Lines
State Reporting and Recordkeeping
Primacy and Implementation
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Monitoring &Treatment for Lead
and Copper at the Source
Steps
Triggered by lead or copper exceedance
* With in 6 months of exceedance:
- System provides monitoring results/treatment
recommendation
Within 6 months of results:
- State treatment decision
ion exchange
reverse osmosis
lime softening
coagulation/filtration
no treatment needed
Monitoring/Treatment Recommendation
Within 6 months of exceeding the lead or copper action level, systems must collect
source water samples. The sample location, collection methods, and number of samples
required is the same as for Phase II/V contaminants. Ground water systems must take at
least one sample at every entry point to the distribution system which is representative of
each well after treatment. Surface water systems must take at least one sample at every
entry point to the distribution after the application of treatment or hi the distribution
system at a point which is representative of each source after treatment. Compositing is
also allowed under the LCR.
Systems must also provide to the State a source water treatment recommendation with
their source water monitoring results. This recommendation is based on source water
monitoring results. A source water treatment study is not required. Systems should
consider: ion exchange, reverse osmosis, lime softening, and coagulation/filtration. A
system can also recommend that no source water treatment is needed. EPA's guidance
document Lead and Copper Rule Guidance Manual Volume II: Corrosion Control
recommends source water treatment when the concentration of lead in the source water
is greater than 0.005 mg/L or the concentration of copper in source water is greater than
0.800 mg/L.
State Decisions
Within 6 months of receiving the system's results and recommendation, the State must
determine whether source water treatment is needed. If the State determines this
treatment is needed, then the State must require either the installation of treatment
recommended by the system or one of those listed above. This decision and the basis for
this decision must be provided to the system in writing.
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Source Water Monitoring
&Treatment
Steps If Treatment Is Needed
If source water treatment is needed:
24 months after State decision
- System must install treatment
12 months after installation
- System conducts follow-up monitoring for 2
consecutive 6-months
6 months after follow-up monitoring:
- State sets MPLs for both lead and copper
System must be at or below MPLs
Source Water Treatment
A system that is required to install source water treatment must complete installing this
treatment within 24 months of State's decision to install treatment. Failure to do so is a
treatment technique violation.
Follow-up Monitoring
A system must collect lead and copper tap samples and source water samples during two,
consecutive 6-months immediately following the installation of treatment. This must be
completed no later than 36 months after the State determines the type of source water
treatment to be installed. A system must complete these two, consecutive, 6-months of
follow-up monitoring, even if the system is now below the lead and copper action level
in tap water monitoring.
State sets MPLs
Based on the monitoring data that was collected before and after the installation of
source water treatment, the State sets maximum permissible levels (MPLs) for lead and
copper. The State established MPLs for both lead and copper, even if the system only
exceeded the action level for one of these contaminants in tap water samples.
MPLs = maximum level of lead and copper that is allowed in
finished water entering the distribution system.
Must be at or below MPLs
Systems that are above either MPL, incur a treatment technique violation. A system can
take a confirmation sample within 2 weeks of the original sample. The results of the
original and confirmation samples are averaged to determine whether a system is in
compliance with its MPLs. MPLs are federally-enforceable standards.
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Source Water Monitoring
&Treatment
Routine/Reduced Monitoring
If source water treatment is not needed
or after State sets MPLs*
SourceType
GKxndweter
Sufaoeor
oontined
Routine
Monitoring
cnoe during 3-year
ccrrpliance per-od in
effect
arrually
Reduced to every 9
years ft
IVfeet M\s Ibr 3 consecutive
ocnplianoe periods
Meet IWPLs for 3 ocnsec yrs
* Assumes system continues to exceed Pb and/or Cu AL
Routine Monitoring
Systems using ground water as their only source must monitor during 3-year compliance
periods. These are the same compliance periods that were established under the
Standardized Monitoring Framework (SMF) for Phase II/V contaminants (e.g., 1993 -
1995,1996 -1998,1999 - 2001,2002 - 2004, etc.). Therefore, systems can coordinate
their source water monitoring for lead and copper with other monitoring requirements.
Systems using surface water or surface water combined with ground water must monitor
annually. The first annual monitoring period begins on the date that the State determined
the type of treatment to be installed or that no treatment was required.
Reduced Monitoring
Systems that qualify for reduced monitoring can reduce the frequency of monitoring to
once every 9 years. The 9-year schedule follows the 9-year monitoring cycle established
under the SMF (i.e., 1993 - 2001), (2001- 2010), etc.
A ground water systems qualifies for reduced monitoring if it does not exceed either
the lead or copper MPL for 3 consecutive, 3-year compliance periods (equals 9
years).
A surface water system or system using a combined source can qualify for 9-year
monitoring if they do not exceed either MPL for 3 consecutive years.
NOTE: Once a system qualifies for reduced monitoring, it is not required to return
to standard monitoring. In other words, an exceedance of an action level or of an
MPL does not impact a system's reduced source water monitoring schedule.
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Source Water Monitoring
^Treatment
When Monitoring Is Not Required
Once MPLs are set or State decides no
SOWT is needed, source water monitoring
is not required when:
The system is below both ALs for entire
source water monitoring period
Example:
- system is on 9-year source water monitoring
during 2002-2010
- 90th percentiles < ALs for all tap monitoring
during 2010 to 2010 -» no source monitoring
Once a system exceeds either the lead or copper action level, it is always subject to
source water monitoring requirements. However, after the State has designated MPLs or
determined that the system is not required to install source water treatment, the system is
not required to collect any source water samples if its 90th percentile lead or copper
level does not exceed the action level during the entire source water monitoring period in
effect.
For example, a system qualifies for reduced source water monitoring for the compliance
cycle of 2002-2010. During this time period, the system is on triennial lead and copper
tap monitoring. It conducts lead and copper tap monitoring during 2001-2003,2004-
2006,2007-2009, and 2010-2012. Both the lead and copper 90th percentile levels are
below the lead and copper action levels for all four monitoring periods. The system is
not required to conduct source water monitoring.
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LCR Minor Revisions
Source Water Monitoring Changes
Reduced monitoring for systems w/o MPLs if
source water levels for:
Lead are < 0.005 mg/L
Copper are < 0.65 mg/L
Must maintain levels for 3 consecutive
compliance periods:
Ground water = 9 years
Surface water = 3 years
Reduced source water monitoring
The LCRMR expand the universe of systems that can qualify for reduced monitoring.
The 1991 LCR did not allow systems that exceeded an action level, but which were not
required to install source water treatment, to reduce the frequency of source water
monitoring.
The criteria for qualifying for reduced monitoring is the same as that under the LCR.
Systems exceeding an action level after the State has determined that source water
treatment is not needed, can reduce the frequency of source water monitoring if:
source water lead concentrations are < 0.005 mg/L; and
source water copper concentrations are < 0.65 mg/L
AND
the system maintains these levels for 3 consecutive compliance periods.
Ground water systems would qualify for reduced monitoring after 3 consecutive, 3-year
compliance periods or after 9 years.
Surface water systems (or those using a combined source) would qualify after 3
consecutive years.
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LCR Minor Revisions
Source Water Monitoring Changes (Cont.)
GResampling triggers have been changed for
composite samples to:
> 0.160 mg/L for copper
> 0.001 mg/L for lead
OCompositing done by certified laboratory
* Labs not required to achieve Copper MDL to
analyze composite source water samples
©Implement on April 11,2000
Resampling triggers for composite samples
In those States where compositing of source water samples is allowed, the resampling
trigger for copper has been increased from 0.001 mg/L or 0.002 mg/L (depending on the
method used) to 0.160 mg/L. The lead resampling trigger has been slightly changed
from > 0.001 mg/L to > 0.001 mg/L. Since up to five samples may be composited for
analysis, the resampling triggers are one-fifth of the levels above which EPA
recommends source water treatment. (EPA recommends source water treatment when
source water lead levels exceed 0.005 mg/L or source water copper levels exceed 0.800
mg/L.)
In addition, the requirements for source water sample location, number of source water
samples, and collection methods have been incorporated directly into §141.88(a)(l) and
the reference to §141.23 has been eliminated. Further, the LCRMR specifies that
compositing must be done by a certified laboratory.
Laboratory certification for composite samples
Changes to the composite source water resampling triggers for lead and copper
necessitate revisions to the laboratory certification procedures pertaining to composite
source water samples. Laboratories no longer have to achieve the copper MDL in order
to analyze composite source water samples. The copper resampling trigger of 0.160
mg/L is sufficient to prove laboratory capability requirements under
§141.89(a)(lXiiXB).
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LCR Minor Revisions
Summary of Source Water Monitoring
Revisions
Reduced monitoring for systems w/o MPLs
QRevisions to source water resampling
triggers for composite samples
OCompositing by certified lab
Labs not required to achieve Copper MDL
to analyze composite source water samples
| Olmplement on April 11,20001
LCRMR Revision
Reduced monitoring for systems w/o MPLs
Revisions to source water resampling
triggers for composite samples
Compositing by certified laboratory
Labs are not required to achieve Copper
MDL
Where to Find It
§§141.88(e)(l)&(2)
§141.89(a)(l)(iv)
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\ /
Source Water
Compliance Examples
/ \
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Applicable Reporting
Requirements
Source Water M/R & MPL Noncompliance
No change to violation type code for:
- Source water M/R violations (56 violation type)
- MPL noncompliance (63 violation type)
Violation code change for:
Old New
SOWT recommendation 61 57
SOWT installation 62 58
Consolidated OCCT/SOWT Installation and/or
Demonstration SNC
The violation type codes have not been changed for:
Source water M/R violations. All source water M/R violations continue to be reported
using the 56 violation code.
Maximum Permissible Level (MPL) noncompliance. A violation type code 63 is still to
be used to report systems that exceed their lead and/or copper MPLs.
Violation codes associated with a source water treatment (SOWT) recommendation or SOWT
installation violation have been changed.
A 57 violation is used to report either:
A system's failure to meet its a source water treatment recommendation requirements
(formerly a 61 violation type), or
A system's failure to meet its corrosion control study/recommendation requirements.
A 58 violation is used to report either:
A system's failure to meet its a source water treatment installation requirements
(formerly a 62 violation type), or
A system's failure to meet its optimal corrosion control treatment installation
requirements.
EPA will list a system that meets the OCCT Installation SNC criteria or SOWT Installation
SNC criteria as a Treatment Installation/Demonstration SNC.
The basic definition for this SNC has remained the same, a system that incurs a treatment
installation violation and has a 90th percentile lead level of > 0.030 mg/1 in most recent
monitoring period.
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Applicable Reporting
Requirements
Source Water M/R & MPL Noncompliance
Converted the end dates to 12/31/2015
Source water follow-up monitoring requires
two consecutive, 6-month rounds - only 1
M/R violation is reported.
Monitoring is conducted AFTER the lead or
copper action level exceedance (No
Grandfathering)
Like lead and copper tap monitoring, there can be 3 types of source water monitoring
requirements: Initial, Follow-up, and Routine. The initial round only requires one
round. Follow-up requires 2 consecutive 6-month rounds, and the Routine monitoring
is one round within 3-year compliance periods for groundwater and one round within a
1-year period for surface water systems or systems with a combined source. In
addition, systems on routine monitoring can qualify for reduced monitoring in which
source water samples are collected once every 9 years.
Only 1 M/R violation is reported for failure to sample for either lead or copper, or both
lead and copper per designated monitoring period.
Initial source water monitoring is conducted AFTER the lead or copper tap action
level(s) is exceeded. Even if the State requires lead and copper be monitored routinely
with the inorganic monitoring, the samples must be taken AFTER the lead or copper
tap exceedance. There are no provisions in the LCR/LCRMR for grandfathering of
data.
For follow-up source water monitoring, only one M/R violation is reported. The begin
date of the violation is the day after the first round missed. RTC may not be reported
until 2 consecutive 6-month rounds are completed.
For routine or reduced source water monitoring, the compliance period is annual,
triennial, or every 9 years. The begin date of a violation would be the day after the
compliance period in which the source monitoring was to be conducted. RTC is
reported once the system properly conducts the source water monitoring.
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Applicable Reporting
Requirements
MPL Noncompliance
A system may incur separate Violations for
exceeding the Lead MPL and the Copper MPL
Only ONE MPL Noncompliance Violation must be
reported for a single contaminant regardless of how
many entry points are in violation
* Contaminant code is:
- 1022 = Copper,
- 1030 = Lead
- reported in lieu of 5000 code that is used for all other LCR
or LCRMR violations
If a system exceeds the MPL for only Lead or only Copper in more than one
source water sample, the State would report a single violation for that period,
for that contaminant.
If a system exceeds the MPL for both Lead and Copper, the State would
report two violations.
To simplify reporting, only ONE Lead or ONE Copper violation is required
to be reported in each designated monitoring period, regardless of how many
entry points incur an exceedance.
No SNC conditions for source water monitoring, failure to provide a source
water recommendation, or failure to meet source water treatment installation
requirements.
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Source Water M/R
Scenario for a New System
The system's first lead and copper tap monitoring period is 1/1/00 - 6/30/00
Pb 90th percentile = 0.012 mg/L; Cu 90th percentile = 1.9 mg/L
1. is this system required to collect source water samples?
Yes.
2. When are these samples due?
By 12/31/00 (within 6 months of exceedance).
3. If the system has the source water samples analyzed for copper only,is it
in violation?
Yes. It must have the samples analyzed for both lead and copper.
4. How does the system return to compliance?
Must collect source water samples and have them analyzed for both lead and
copper samples for a 6-month compliance period.
Answer 1
A system that exceeds the lead or copper action level must collect source
water samples at each entry point to the distribution system.
Answer 2
This monitoring must be completed within 6 months of the end of the
compliance period in which the exceedance occurred.
Answer 3
The system must collect both lead and copper tap samples even if exceeds only
one of the action levels. The system in this example would incur an initial
source water M/R violation (56 violation type code). The begin date of this
violation would be January 1,2001. The end date would be defaulted to
December 31,2015.
Answer 4
To achieve compliance for an initial source water M/R violation, the system
must properly fulfill its source water monitoring and reporting requirements
for one, 6-month monitoring period.
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Source Water M/R
Scenario for a New System
6/30/01: Source water treatment installed
1/1/-6/30/02: System collects one round of follow-up monitoring
9/15/02: State reviews status of system
1. Assuming the system followed proper monitoring and analytical
procedures, is it in violation with its source water M/R
requirements?
Yes. 2 consecutive 6-month rounds of follow-up monitoring are required.
2. How does the system return to compliance
It collects 2 consecutive 6-month round of follow-up monitoring.
Answer 1
All systems that are required to install SOWT must collect follow-up source
water samples during two consecutive six-months compliance periods. The
State uses the data to set MPLs for lead and copper in source water. In this
example, the system is in violation for failure to collect the first, six-month
period of its source water follow-up monitoring (56 violation type code). This
monitoring was required to be conducted during the compliance period July 1
to December 31, 2001. The begin date for this violation is the day after the
end of the first missed compliance period or January 1,2002 in this example.
The end date is defaulted to December 31,2015.
Answer 2
To achieve compliance, the system must collect two consecutive round of
source water samples. In this example, if the system conducts source water
monitoring during July 1 - December 31,2002, it would return to compliance.
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Source Water M/R
Scenario
on 9-year source water monitoring cycle of 1/1/02 -12/31/10
1/1/00 - 12/31/02: Pb 90th = 0.006 mg/L; Cu 90th = 1.1 mg/L
1/1/03- 12/31/05: Pb 90th = 0.007 mg/L; Cu 90th = 1.0 mg/L
1/1/06 - 12/31/08: Pb 90th = 0.006 mg/L; Cu 90th = 1.2 mg/L
1/1/09 - 12/31/11:Pb 90th = 0.007 mg/L; Cu90th= 1.5 mg/L
1. Is the system required to collect source water samples during
1/1/02-12/31/10?
If tap samples were collected during 2009 or 2010, then yes. If tap samples
were collected during 2011, then no source water samples are required.
However, source water monitoring must be conducted during the next
compliance cycle of 1/1/11 to 12/31/19.
Answer
The system exceeded the copper action level during the tap monitoring period
of Jan. 2009 to Dec. 2011, but did not have exceedances in any of the prior
monitoring periods. If the system collected the sample during 2009 or 2010,
the exceedance would occur during the 9-year source water compliance period
of January 1,2002 - December 31,2010, and therefore, source water sample
would be required.
If lead and copper tap samples were collected during 2011, the system would
not be required to collect source water samples during January 1,2002 -
December 31,2010, but it would be required to conduct source water
monitoring during January 1,2011 - December 31, 2019.
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SOWT Recommendation
Scenario for New Systems
System exceeds the lead action level for first time during annual monitoring
conducted in 2000
Initial source water results: Pb - 0.005 mg/L; Cu = 0.6 mg/L
1. Is the system required to provide a source water treatment
recommendation?
Yes. A recommendation must be provided with the initial source water
monitoring results within 6 months of exceeding the AL, even if the
recommendation is no treatment.
Answer
A system is required to conduct initial source water monitoring and to provide
a treatment recommendation within 6 months of when it first exceeds lead or
copper action level. The system may recommend that no treatment be
installed as its recommendation. A system that does not provide this
recommendation within 6 months would incur a treatment technique violation
with a revised violation type code of 57.
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SOWT Installation
Scenario
1/15/1998: State determines type of SOWT to be installed
7/15/2000: System installs SOWT
Most recent tap monitoring results: Pb 90th = 0.035 mg/L; Cu 90th = 1.2 mg/L
1. Is the system in violation?
Yes. The system did not install SOWT on-time (within 24 months of State
decision).
2. Is the system an SNC?
Yes because the system incurred an SOWT violation and its most recent lead
90th percentile level was > 0.030 mg/L.
AnswerjL
A system must complete the installation of SOWT and submit a certification
that this treatment has been installed within 24 months of the State's decision
regarding the type of SOWT to be installed. The system in this example
incurred a SOWT installation violation (revised violation type code 58). The
begin date for the violation in this example is January 16,2000. The end date
is defaulted to December 31,2015.
Answer 2
A system can become an SNC if it incurs a SOWT installation violation and
the 90th lead level for its most recent tap monitoring is > 0.030 mg/L.
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%/15/00
MPL Compliance
Scenario
System has 1 entry point
Lead MPL = 0.008 mg/L; Copper MPL = 0.7 mg/L
Source water results for 2000: Pb = 0.007 mg/L; Cu = 0.6 mg/L
Source water results for 2001: Pb = 0.008 mg/L; Cu = 0.8 mg/L
1. Is the system in compliance with its MPLs for 2000?
Yes. The system did not exceed either MPL.
2. Is the system in compliance with its MPLs for 2001?
The system is in compliance with its lead MPL, but has exceeded the copper
MPL.
Answer 1
The system is in compliance with its MPLs for source water monitoring
conducted in 2000 because both the lead and copper source water results are
below their respective MPLs.
Answer 2
During 2001, the system exceeded the copper MPL and therefore is in
violation. Failure to meet either MPL is a treatment technique violation (63
violation type code). The contaminant code for this violation is 1022 (for
noncompliance with copper MPL). Remember, a 63 violation is the only one
in which the State cannot use the contaminant code of 5000. Either the
contaminant code of 1022 (for copper) or 1030 (for lead) must be specified.
The begin date for the violation in this example is January 1,2002. The end
date is defaulted to December 31,2015.
Please note that this system could have collected a confirmation sample within
2 weeks of the original sample. If the average of the original confirmation
sample had been at or below the MPL, the system would have been in
compliance with its copper MPL requirements.
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MPL Compliance
Scenario
System has 3 entry points
MPLsrset at Pb = 0.006 mg/L; Cu = 0.7 mg/L
Entry point 1: Pb = 0.006 mg/L; Cu = 0.6 mg/L
Entry point 2: Pb = 0.008 mg/L; Cu = 0.8 mg/L
Entry point 3: No sample collected
1. Is the system in violation?
Yes. The system is in violation with 2 requirements. Failure to meet its MPLs
and failure to collect enough source water samples.
Answer
An MPL violation can be incurred if the system exceeds the MPL for lead or
for copper in any sample collected. Therefore, the system would have MPL
violations for both copper and lead, even though the system failed to collect all
the required samples. In addition, the system would also incur a source water
M/R violation for failure to collect source water samples at all entry points.
Therefore, the system in this example has 3 violations as follows:
Source water M/R (56 = violation type code)
MPL noncompliance with copper (63 = violation type, 1022 =
contaminant code)
MPL noncompliance with lead (63 = violation type, 1030 =
contaminant code)
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5/15/00
Lead and Copper NPDWR
Requirements
Lead and Copper Tap/Initial WQP
Monitoring
Corrosion Control Optimization
Public Education
Source Water Monitoring & Treatment
Replacement of Lead Service Lines
State Reporting and Recordkeeping
Primacy and Implementation
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%/15/00
Lead Service Line
Replacement (LSLR)
Applicability
Triggered by continued exceedance
of lead action level
* State can require if system is more
than 1 year late installing CCT or
SOWT
* 7% of LSLs replaced each year (15
years total)
State can require shorter schedule
Triggered by Continued Exceedance of Lead Action Level
A system must begin replacing lead service lines (LSLs) if it continues to
exceed the lead action level after installing corrosion control treatment and/or
source water treatment (in whichever sampling occurs later).
The State can also require LSL replacement if the system is in violation for
failure to install treatment after the follow-up monitoring date has passed.
1% Replaced each year
System must replace at least 7% of the initial number of LSLs in its
distribution system. The initial number = the number of LSLs in place at the
time the replacement program began.
The initial number of lines is identified through materials evaluation, including
the one required prior to initial lead and copper tap monitoring.
First year of replacement begins on date the lead action level was exceeded.
State can require shorter replacement schedule
The State can place a system on a faster replacement schedule (i.e, replace
more than 7% per year). If the State determines that a faster schedule is
feasible, it must document the decision in writing and notify the system within
6 months of its being triggered into lead service line replacement (LSLR).
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LSLR
LSLs Not Requiring Replacement
No Replacement Required for
Individual Lines < 0.015 mg/L Lead
Monitoring Methods
- direct tap into line
-temperature change
- flush volume between end of line & tap
No Replacement for Individual Lines Below 0.015 mg/L
A system is not required to replace an individual LSL if the lead concentration
of all samples from the line is less than or equal to 0.015 mg/L.
Monitoring Methods
The procedure for collection is explained in § 141.86(b)(3). The service line
sample must be 1 liter in volume and have stood in the line for at least six
hours. The sample can be collected in one of the following ways:
At the tap after flushing the volume of water between the tap and the
LSL. The volume of water is calculated based on the interior diameter
and length of the pipe between the tap and the lead service line;
Tapping directly into the LSL; or
For single-family residences, allowing the water to run until there is a
significant change in temperature which would be indicative of water
that has been standing in the LSL.
<*
NOTE: These samples are not used in 90th percentile calculations.
Their sole purpose is to determine whether a LSL needs to be removed.
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S/15/00
LSLR
Continued Applicability
LSLR stops when < Pb AL for 2
consecutive monitoring periods
LSLR recommences if system again
exceeds lead AL
A system is no longer required to continue replacing lead service lines if it
meets the lead action level for two consecutive monitoring periods. The
monitoring periods can be of any duration (e.g., 6 month, annual, or triennial
monitoring).
If in any subsequent monitoring period, the system again exceeds the lead
action level, it must again begin replacing lead service lines.
REMEMBER: It takes 2 consecutive monitoring periods to
stop replacement, but only 1 monitoring period to trigger a
system back into LSLR.
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5/15/00
LCR Minor Revisions
Ownership Terminology
Ownership Replaces Control
©"Control" terminology eliminated
O Systems triggered into LSLR must:
- Replace portions of LSLs they own
- Document which portions they own
©Implement on April 11,2000
Systems must replace the portion of the LSL that they own. This definition is consistent
with the 1994 court ruling in which the courts vacated the Agency's definition of
"control" except for that portion owned by the water system.
Under the LCRMR, systems still are not required to replace a LSL if the lead
concentration in all service line samples from that line is less than or equal to 0.015
mg/L.
The provision that allowed systems to submit documentation demonstrating that the
system controlled less than the entire line has been eliminated, since the rule no longer
presumes that systems control the entire length of the LSL.
Systems must document in their files the portions of LSLs that they own and the relevant
legal authorities. The LCRMR do not require systems to submit this information to the
State.
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3/15/00
LCR Minor Revisions
Partial LSL Replacement
O Clarify who receives offer from system to
replace privately-owned portion
O Strengthen requirements for partial LSLR
- Notification prior to partial LSLR
- Samples collected after partial LSLR
- New reporting requirements for systems
©Implement on April 11, 2000
The LCRMR:
Clarify who receives the offer from the system to replace the privately-owned
portion of the LSL.
Strengthen the system's requirements when it does not replace the privately-owed
portion of the line regarding:
- notification requirements to residents prior to partial LSLR;
- sample collection requirements following partial LSLR; and
- system reporting compliance with partial LSLR requirements to the State.
Each is of these requirements is discussed in more detail on the following three slides.
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LCR Minor Revisions
Replacement Offer
Offer to replace privately-owned portion
LCR
- Unclear if offer to users or building owner
LCRMR
O Clarifies offer to owner of property or
authorized agent
$$$ Cost remains the responsibility of line owner
©Implement on April 11, 2000
The LCRMR clarify that the offer to replace the privately-owned portion of the LSL
must be made to the owner of the property (or the owner's authorized representative),
rather than to the user. Under the LCR, it was unclear whether this offer was to be made
to the users or building owner. The LCRMR also includes language that allows systems
to forego this offer if replacing the privately-owned portion is precluded by State, local,
or common law.
The cost of replacing the privately-owned portion of the line is still the responsibility of
the line owner. This portion of the provision has not changed from the original LCR.
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LCR Minor Revisions
Notification of Partial LSLR
If system only replaces portion it owns:
LCR
- No notification requirement except to collect
first-flush sample
LCRMR
O System must notify residents at least 45 days
prior to replacement
O Collect representative service line sample, and
analyze within 72 hours of replacement
©Implement on April 11,2000
The LCRMR strengthen the notification requirements in the event that the offer to
replace the privately-owned portion of the line is not accepted or the system is otherwise
precluded from replacing the privately-owned portion. This situation would result in
partial LSL replacement and systems must:
1. Notify all residents served by the line being replaced, at least 45 days prior to
partial replacement. States can allow systems to provide less advanced notice if the
line is being replaced in conjunction with emergency repairs. This notification must
also inform the users of a possible temporary increase in lead levels and the measures
they can take to reduce their exposure.
2. Collect a sample representative of the water in the service line and have it
analyzed for lead within 72 hours after the partial LSL replacement. The LCRMR
clarify that systems must pay for this analysis.
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LCR Minor Revisions
Notification of Partial LSLR
If system only replaces portion owned:
LCR
- Report results to residents within 14 days of
partial LSLR
- No requirement to report results to State
LCRMR
O Report results to owner/residents within 3
business days
O Submit monitoring results to State, unless
otherwise directed
©Implement on April 11, 2000
3. Report the results of the analysis to the owner and residents within 3 business days of
receiving these results (including those that are not billing units). Systems can post the
results in conspicuous places in common areas for multi-family residents. The results are
also considered to be sent "on-time" if they are post-marked within 3 business days.
Note: Number 2 and 3 replace the original requirement to collect a first-flush tap water sample
if the resident(s) so desire within 14 days of the partial replacement.
4. Submit these monitoring results to the State within 10 days of the month following that in
which the system receives the results. For example, if a system collected the samples in
September, and received the results during September, then it would be required to submit
these results to the State no later than October 10th. A system can submit all of the partial
lead service line monitoring results that it receives during any one month in a single report
to the State. However, the system cannot save monitoring results from month to month and
submit them collectively to the State in one report, without State approval. The LCRMR
give States the option to eliminate or modify the reporting of post-partial lead service line
monitoring results. States must describe in their primacy packages how they will
verify compliance with partial LSL replacement requirements.
EPA has developed a guidance document, entitled, Notification and Reporting
Requirements for Partial Lead Service Line Replacement under the Lead and
Copper Rule, April 2000, EPA 815-R-99-022. This document also provides
example letters that systems can use to ask the line owners/agents if they want their
portion of the line replaced, notify their users of the partial replacement, and
inform residents of the post-replacement analytical results.
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LCR Minor Revisions
Summary of LSLR Changes
O Elimination of control terminology
O Clarification of who receives replacement offer
O Stronger partial LSI notification requirements
Notification of replacement 45 days prior
General content of notification specified
O Representative service line sample
- Analyzed with 72 hours
Results reported within 3 business days
O Partial LSL reporting to State
©Implement on April 11,2000
LCRMR Revision
Elimination of control terminology
Clarification of who receives replacement
offer
Stronger partial LSL notification
requirements
Representative service line sample
Partial LSL reporting to State
Where to Find It
Deleted from rule language
§141.84(d)
§141.84(d)(l)
§141.84(d)(l)
§14L90(e)(4)
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\
/
Lead Service Line
Replacement
Compliance Examples
/
\
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Applicable Reporting
Requirements
LSLR Violation (64)
No change to violation type code 64
Includes violation of partial LSLR requirements
Failure to complete annual designated
replacement rate
Could incur multiple violations
The LCRMR expand the definition of what constitutes an LSLR violation. Under the LCR, a system incurred
this violation if it did not meet its annual replacement rate and/or report the supporting documentation that
demonstrated that it meet its replacement requirements. In those instances where the system does not replace
the entire line up to the building inlet (also known as partial replacement). Systems replacing only a portion
of a LSL, can incur a violation if they do not:
» Provide notice and guidance to residents at least 45 days before LSLR begins (unless the State allows
a shorter notification period because the partial replacement is being done in conjunction with
emergency repairs);
Collect a tap sample within 72 hours of completing the partial LSLR;
Mail and/or post results of the analysis to the owner and residents within 3 days of receipt of the
results; or
Report information that the State deem necessary to assess whether the system met its partial LSLR
monitoring and notification requirements.
EPA did not create a separate M/R violation for failure to conduct the notification, monitoring, and reporting
requirements associated with partial LSLR. Failure to conduct these activities are included as a treatment
technique violation and is reported using the 64 violation code. A system can have more than one LSLR
violation per 12 months for failure to meet one or more of its partial LSLR requirements. The system would
also incur a separate violation if it did not replace 7% (or higher if required by the State) of its LSLs b the 12-
month period.
The first year of LSLR begins when the State determines the PWS is triggered into LSLR. The violation
begins the first day after the end of the designated 12-month replacement year.
For Partial LSLR, the violation begins the first day after the due date of the requirement for that partial
replacement project (i.e., notification to the resident prior to partial LSLR, sampling of water in service line
and reporting results to users, and appropriate reporting to State.)
The end date is defaulted to December 31,2015. This date is replaced when the State reports RTC and links
it to the violation.
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Applicable Reporting
Requirements
LSLR Milestone
Required when system is first triggered into
LSLR
Required when system "retriggered" into
LSLR requirements
Replacement rate is no longer required to be
reported
States must report, on a quarterly basis, those systems which are required to replace lead
service lines and the date the system was required to start the replacement. States must also
report this milestone if systems are triggered back into LSLR requirements due to a
subsequent exceedance. Under the LCRMR, States are no longer required to report those
systems on an accelerated replacement schedule, the annual replacement rate, or submit a
separate report for those systems which are in compliance with their replacement schedule.
Replacement rates for LSLs which have already been reported to SDW1S/FED prior to January
12,2000 will be archived, and will no longer be available in SDWIS/FED. However, States
still must report a violation for systems that do not meet their replacement schedules.
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'5/15/00
LSLR Compliance
Scenario
Dec. 1998 -
Jan-June 1998-
Jufy-Dec 1998 -
Dec, 1999-
Jan-June 2000 -
July-Dec 2000 -
Instate SOWT
Follow-up monitoring 90th percentile value: Pb = 0.020 mg/L
Follow-up monitoring 90th percentile value: Pb = 0.022 mg/L
Installs CCT
Follow-up monitoring 90th percentile value: Pb = 0.020 mg/L
Follow-up monitoring 90th percentile value: Pb = 0.018 mg/L.
1. Is the system required to replace LSLs?
Yes.
2. When must replacement begin?
July 1,2000.
Answer 1
The system is required to replace LSLs because it continued to exceed the lead
action level after treatment had been installed.
Answer 2
The first year of LSLR begins on the first day after the end of the compliance
period in which the system exceeded the lead action level in samples collected
after the installation of OCCT and/or SOWT (whichever is later); in this
example, July 1,2000.
In general, systems that are required to install treatment will only be required
to install OCCT. In this instance, the samples collected after the installation of
OCCT will determine whether the system is required to replace lead service
lines.
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LSLR Compliance
Scenario
Dec. 1998 - Installs SOWT
Jan-June 1998 - Follow-up monitoring 90th percentile value: Pb = 0.020 mg/L
July-Dec 1998- Follow-up monitoring 90th percentile value: Pb = 0.022 mg/L
Dec. 1999 - Installs CCT
Jan-June 2000 - Follow-up monitoring 90th percentile value: Pb = 0.012 mg/L
* July-Dec 2000 - Follow-up monitoring 90th percentile value: Pb = 0.011 mg/L.
1. Is the system required to replace LSLs? If so, when?
No. It did not exceed the lead action level after CCT was installed.
Answer
The system is not required to replace LSLs because it did not continue to
exceed the lead action level after the later of the two treatments was installed.
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20$/15/00
LSLR Compliance
Scenario
Dec. 1999- Instate CCT
Jan-June 2000 - Follow-up monitoring 90th percentile value: Pb = 0.016mg/L
July-Dec 2000 - Follow-up monitoring 90th percentile value: Pb = 0.013 mg/L.
1. Is the system required to replace LSLs? If so, when?
Yes the system must begin LSLR on July 1 , 2000 because it
continued to exceed the lead action level during Jan. - June 2000.
System can discontinue LSLR if it has 2 consecutive
monitoring periods below the lead action level.
Answer
The system must begin LSLR on July 1,2000 because it continued to exceed
the lead action level after treatment. Although, it was below the lead action
level during July - December of 2000, it must have two consecutive
monitoring periods below the lead action level. Therefore, if the system
monitors during January - June 2001 and is below the lead action level, it can
discontinue LSLR monitoring. In reality, if this system monitors early in the
January - June 2001 monitoring period, it has time to determine if it is eligible
to discontinue LSLR before it needs to replace any lines. However, the system
needs to allow itself enough tune to meet the 7% replacement rate should it be
unable to have 2 consecutive rounds of tap monitoring that are below the lead
action level.
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LSLR Compliance
Scenario
* July 1,2000:
July 10,2000:
Aug 20.2000:
System required to replace LSLs
State specifies annual replacement rate of 10 percent
System submits letter
- indicating it replaced 6% of the LSLs, and
- with LSL monitoring results that show 4% of its lines contribute
< 0,015 mg/L of lead
1. Is the system in violation?
No. The system can count LSLs that contribute < 0.015 mg/L
toward its annual replacement requirement.
System must comply with LSLR schedule set by the
State.
Answer
The system is in compliance because it met the 10% replacement rate and
submitted documentation to that effect within 12 months. This system
replaced 6% of the LSLs and demonstrated through LSL monitoring that the
remaining 4% of the lines contribute < 0.015 mg/L. A system is not required
to replace any lines that contribute < 0.015 mg/L and can count these LSLs
toward the its annual replacement requirement. However, the system must
provide the LSL monitoring results as part of its annual LSL compliance letter
to the State.
For the exact requirements of pertaining to the LSL annual letter, refer
to§§141.90(e)(l)-(3).
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LSLR Compliance
Required annual replacement rate = 7%
Yr 2000, system replaces 15% of LSLs
Yr 2001, system replaces 0% of LSLs
1. Is the system in violation in 2001?
No. If approved by the State, the system can count LSLs replaced
during one year toward the next year's replacement requirements.
Answer
A system may find it easier to replace all the LSLs in a given area; this may
result in the system's replacing more than 7% of its lines in a given year.
During the first year of replacement, the system must provide the State with a
schedule for replacing at least 7% of its LSLs each year as part of its annual
LSL compliance letter. Through this letter, the State would be made aware of
the system's plans for replacing two-years' worth of LSLs in one year.
The system still is required to submit an annual compliance letter each year,
even if no lines are replaced.
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LSLR Compliance
Scenario
Required annual replacement rate = 7%
System is on annual tap monitoring
* Yr 2000, system replaces 7% of LSLs; Pb 90th = 0.011 mg/L
Yr 2001. system replaces 5% of LSLs; Pb 90th = 0.009 mg/L
1. is the system in violation for 2001 ?
No. The system is below the lead action level for two consecutive
monitoring periods and can discontinue LSLR.
2. What would be the system's compliance status if it had not replaced any
lines in 2000 or 2001?
The system would be in violation for compliance-period of Jan - Dec. 2000 only.
3. How would this system return to compliance for the Yr 2000 LSLR violation?
The system is below the lead action level and is not required to replace
any more lines, unless it again exceeds the lead action level.
A system can discontinue LSLR whenever it is below the lead action level for
two consecutive monitoring periods.
Answer 2
During 2000, the system was not eligible to discontinue LSLR because it only
had one monitoring below the lead action level. The system meet the criteria
for discontinuing LSLR in 2001, therefore, no replacement was required
during this year. The system has incurred a LSLR violation (64 violation type
code), which is a treatment technique violation. The begin date of this
violation would be January 1,2001. The end date would be defaulted to
December 31,2015.
Answer 3
Once the system is below the lead action level for 2 consecutive monitoring
periods they can cease lead service line replacement. If the system exceeds the
lead action level in a subsequent round of monitoring, it must again begin lead
service replacement. In this example, the State would report an "Intentional
No Action" and link it to the violation.
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Partial LSLR Compliance
Scenario
Owner does not want privately-owned LSL portion replaced
2/15/01: system notifies owner of partial replacement, impacts, protective measures
3/1/01: system replaces the portion that it owns
3/1/01: system collects LSL sample
3/15/01: system receives analytical results
3/30/01: system reports results to residents served by line
5/10/01: system provides results to the State
1. Is the system in violation?
Requirement
Notification prior to pLSLR
LSLR sample
Results to residents
Results to State
In violation?
Not if pLSLR done w/emergency repairs
No, collected within 72 hours of pLSLR
Yes. was not done within 3 business days
Yes, due by 4/10/01. unless State modifies req't
Answer
When the system does not replace the privately-owned portion, it must
fulfill the following requirements:
1. Notify all residents served by the line being replaced, at least 45 days
prior to partial replacement (pLSLR).
The system was required to deliver this notification by 1/14/01 unless the
State allowed the system to provide less advanced notice because the LSL
was being replaced in conjunction with emergency repairs.
2. Collect a sample representative of the water in the service line and have
it analyzed for lead within 72 hours after the partial LSL replacement. The
system collected the sample on the same day it completed pLSLR and,
therefore, met the 72 hour deadline.
3. Report the results of the analysis to the owner and residents within 3
business days of receiving these results To be in compliance, the system
would have had to mail the results by March 20,2001.
4. Submit these monitoring results to the State within 10 days of the month
following that in which the system receives the results. These results were
due on April 10,2001, unless the State had eliminated or modified this
reporting requirement.
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5/15/00
Lead and Copper NPDWR
Requirements
* Lead and Copper Tap/Initial WQP
Monitoring
Corrosion Control Optimization
Public Education
Source Water Monitoring & Treatment
Replacement of Lead Service Lines
State Reporting and Recordkeeping
Primacy and Implementation
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5/15/00
State Reporting Requirements
LCR
Under the LCR, States reported each
system that:
Exceeded lead or copper AL and date
Required to complete CC study & date study received
State determined CCT, date, and installed OCCT
* State designated OWQPs & date
Required to install SOWT, date, and installed SOWT
* State set MPLs
* Required to replace LSLs, on accelerated schedule,
and in compliance with schedule
Under the LCR, States were required to report the name and PWS ID number of
each PWS:
which exceeded the lead and copper action levels and the date upon which the
exceedance occurred;
required to complete the corrosion control study and the date the State received the
results of the study;
for which the State designated optimal corrosion control treatment, the date of the
determination, and each system that completed installation of the treatment;
for which the State designated OWQPs and the date of the determination;
which the State required to install source water treatment, the date of the
determination, and each system that completed installation of the treatment;
for which the State specified maximum permissible source water levels; and
required to begin replacing lead service lines, each public water system for which
the State established an accelerated replacement schedule; and each system
reporting compliance with its replacement schedule;
EPA requested that states report 90th percentile lead levels for all large systems.
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5/15/00
LCRMR Minor Revisions
LCRMR State Reporting Requirements
Under the LCRMR, States report:
All 90th percentile Pb values for > 3,300
90th percentile Pb exceedances for < 3,300
90th percentile Cu exceedances for all
systems
More streamlined LSL replacement milestone
States must report the 90th percentile values and the first and last dates of the monitoring
period for which the 90th percentile value were calculated for the following:
All 90th percentile lead values for systems serving 3,301 or more people, regardless of
whether these values are at, above, or below the action level.
Those lead 90th percentile levels that are above the lead action level of 0.015 mg/L
for small systems (25 - 3,300 people).
Those copper levels that are above 1.3 mg/L for all system sizes.
States must still report a milestone for systems that are required to begin replacing LSLs,
but States are no longer required to report whether the system is on an accelerated
replacement schedule, or submit a separate report of those systems that are in compliance
with their replacement schedules. States must still report violations to EPA for systems
that are not in compliance with their LSLR requirements.
Note: The State must report another LSLR milestone for any system that is required
to resume lead service line replacement.
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5/15/00
LCR Minor Revisions
LCRMR State Reporting Requirements
Under the LCRMR, States report (cont):
New "Deem" milestone
* New "Done" milestone
* EPA requests reporting by 2/15/01
States must report a new Deem milestone for each system for which States have:
Designated OWQPs;
Deemed to be optimized because it serves < 50,000 and is below the lead and
copper action level for 2 consecutive, 6-month monitoring periods; or
Deemed to be optimized because it has minimal levels of corrosion in its
distribution systems [i.e., (b)(3) system].
For each of these systems, States must report the date it first determined that the system
satisfied the DEEM milestone criteria and one of 3 reason codes. These codes are
explained in more detail on the next page.
States must report a Done milestone for each system that has implemented optimal
corrosion control, completed installation of sourcewater treatment and/or completed LSL
replacement. States need to report the latest of the following:
Date the State designates OWQPs or deems the system to have optimized
corrosion control because it meets the requirements of §141.81(b)(l) or (b)(3);
Date the State designates MPLs for systems required to install SOWT, or the date
the State determines source water treatment is not needed; or
Date the system completes LSLR or becomes eligible to stop LSLR because it is
below the lead action level for two consecutive, 6-month monitoring periods.
There are no reason codes associated with the Done milestone.
EPA is requesting that States report by February 15, 2001, those systems the meet the
Done and/or Deem milestone criteria by January 11,2002. After January 11, 2002 the
Done and/or Deem milestone must be reported within 45 days after the end of the quarter
in which the State determined the system met the Done or Deem milestone criteria.
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LCR Minor Revisions
Deem Milestone
C817 Code
Value
WQP
Definition
System < 50,000 that
is below both ALs for
2 consecutive 6
months
A (b)(2) system or one
for which State has
designated OWQPs
A (b)(3) system
Day Reported to
SDWIS/FED
State determines
system met
(b)(1 Criteria
Date State
Designates
OWQPs
State determines
system met
(b)(3)eriteria
States must report one of 3 reason codes (C817 code value) for the Deem milestone.
The code value Bl applies to a systems that are deemed to have optimized corrosion control by
meeting the criteria under §141.81(b)(l). It applies to systems serving < 50,000 or fewer people
that have met the lead and copper action levels during each of two consecutive 6-month monitoring
periods. The date for this reason code is the date State determines that the system met the (b)(l)
criteria. If the system met the (b)(l) criteria after installing CCT and the State set OWQPs, report
the reason code WQP instead of(b)(l).
The code value WQP applies to systems that are deemed according to criteria in §141.81(b)(2) or
for which the State has set OWQPs. A system meets the criteria of §141.81(b)(2) (i.e., is a (b)(2)
system) if the State has determined (DEEMED) that it has optimized corrosion control treatment
before December 1,1992, based on review of water quality parameters, a report on the evaluation
and selection of OCCT, a report on OCCT installation and maintenance, and tap sample results. Or
for which the State has designated OWQPs. The date for this reason code is the date State
designates OWQPs.
The code value B3 applies to systems that are deemed according to criteria in §141.81(b)(3) without
installing corrosion control treatment. These systems have minimally corrosive water in its
distribution system, and have demonstrated for two consecutive 6-month periods that the difference
between the 90th percentile tap water lead level and the highest source water lead concentration is <
0.005 mg/L. Also, the LCRMR expand the definition to include systems whose source water lead
levels are below the Method Detection Limit of 0.005 mg/L and whose 90th percentile lead level is
< 0.005 mg/L. In addition, after July 12, 2001, a system no longer qualifies as a (b)(3) system if it
exceeds the copper action level. The date for this reason code is the date State determines that the
system met the (b)(3) criteria. If the system met the (b)(3) criteria after installing CCT and the
State set OWQPs, report the reason code WQP instead of(b)(3).
Remember, a system can meet the DEEM milestone criteria without
actually being required to physically install corrosion control treatment (as
may be the case with a (b)(l) or (b)(3) system.)
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LCR Minor Revisions
Done Milestone
Replaces several LCR milestones
- STIN: System installs SOWT
- OTIN: System installs CCT
- MPLS: State sets MPLs
-OWQP: State sets OWQPs
System can become "undone"
- No longer qualifies as (b)(1) or (b)(3) system
- Does not meet MPLs or OWQPs
The DONE milestone replaces the requirement to report separate milestones for each
system that is required to: install source water treatment; that has installed the State-
designated source water treatment; required to install corrosion control treatment; that has
installed State-designated corrosion control treatment; and for which the State has
specified maximum permissible source water levels (MPLs) and/or OWQPs.
Some systems can become "Undone" because they no longer meet the Done criteria.
This would occur if:
a (b)(l) system subsequently exceeds the action level;
a (b)(3) system no longer meets the (b)(3) criteria because it exceeds the lead or
copper action level, or the difference between the 90th percentile lead level and the
highest source water lead concentration level exceeds 0.005 mg/L; or
a system does not meet its OWQPs or MPLs.
In these instances, the State would modify the Done milestone by adding a milestone end
date that corresponds to when the system no longer met the Done criteria. The end date
signifies that additional monitoring requirements, or lead service line replacement, or
modifications to the corrosion control treatment process, have been triggered. The
milestone end date must be reported to SDWIS/FED within 45 days after the end of the
quarter in which the State determined the system no longer met the Done criteria.
If, in the future, a system again met the DONE criteria, the State would report another
milestone record for the new DONE status, with a milestone begin date corresponding to
the date the State determined the system met the DONE criteria for the second time.
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LCR Minor Revisions
LCRMR State Reporting Schedule
Schedule for reporting new
requirements
- Option of reporting old requirements
until 1/11/02
- Report only new requirements by
1/12/02
5/15/00
Schedule for reporting new requirements
EPA has completed modifications to the Safe Drinking Water Information System
(SDWIS) ahead of the May 14,2000 schedule in the LCRMR. SDWIS began accepting
new data as early as January 20, 2000.
States have the option of reporting the old information until January 11, 2002.
By January 12,2002, States must report in accordance with the new requirements only.
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State Recordkeeping Requirements
LCRMR
Adds recordkeeping requirements that
correspond to new decisions
- Additional actions to maintain optimal
corrosion control
- Content of written public education materials
and their distribution
- Use of non-first-draw samples
- State-specified sampling locations for
systems on reduced monitoring
States must maintain records of the following.
Additional actions to maintain optimal corrosion control
Any additional requirements that States determine are needed to maintain optimal
corrosion control for those water system that have installed corrosion control treatment
treatment in place, or that change treatment or add a new source.
Content of public education materials
Any decisions that States make regarding:
Changes to mandatory public education language (such as deletion of reference
to LSLs, consumer access to records).
Use of NTNCWS alternate mandatory language and delivery methods for
special-case CWSs, if States require them to obtain prior approval.
Allowances for CWSs serving 501 to 3,300 to omit newspaper notification
and/or limit distribution of pamphlets.
Need for small systems to provide pamphlets to additional facilities than those
that primarily provide services to pregnant women and to children.
Use of non-first draw samples
State decisions regarding a system's use of non-first-draw sample to complete its
sampling pool.
Sampling locations for systems on reduced monitoring
Any decisions that States make regarding which sampling locations must be used.
Records must be kept for 12 years. This requirement has not changed.
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State Recordkeeping Requirements
LCRMR
Additional recordkeeping requirements
(continued)
- Alternative sample collection periods for
reduced monitoring
- Sample invalidation
- Monitoring waivers, revocations, renewals
- Representative entry point locations
States must maintain records of the following.
Alternate sample collection periods for reduced monitoring
Any system-specific determinations to alternative sample collection periods for systems
subject to reduced monitoring.
Sample invalidation
Decisions regarding the invalidation of a sample.
Monitoring waivers, revocations, renewals
Records pertaining to system-specific decisions regarding a small system's waiver
application, any conditions for granting the waiver; waiver revocations and the reasons for
this decision; and waiver renewals.
Representative entry point locations
Decisions on which entry point sites must be used by ground water systems wishing to
limit WQP entry point monitoring to representative sites.
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State Recordkeeping Requirements
LCRMR
Additional recordkeeping requirements
(continued)
- Compliance with partial LSL replacement
- Resubmission of public education
distribution list
- 90th percentile calculations
Removes determination of limited
control of LSL
States must maintain records of the following.
Compliance with LSL replacement
Decisions on what information must be provided by system to demonstrate compliance
with partial LSL notification and monitoring requirements.
Resubmission of public education distribution list
Any system-specific decisions regarding the resubmission of detailed documentation to
demonstrate completion of public education tasks.
90th percentile calculations
Decisions involving 90th percentile calculations, such as deadline for system to submit
monitoring data and any calculations performed by the State in lieu of the system.
Removes determination of limited control of LSL
The LCRMR eliminate the need for a system to submit documentation that demonstrates
that it has limited control of a line and for States to maintain records of this
documentation. This was required as part of § 142.14(d)(8)(vii).
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\ /
State Reporting
Compliance Examples
/ \
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SDWIS/FED Reporting
Milestones
DEEM Milestone
Reason Code (C817) used for DEEM milestone
Represents the basis for the State's determination
that a system is "deemed" to be optimized
under the LCR/LCRMR
Permitted values: B1, WQP, and B3
Bl = systems serving < 50,000 or fewer people that have met the lead and copper
action levels during each of two consecutive 6-month monitoring periods. The
date for this reason code is the date State determines that the system met the (b)(l)
criteria. If the system met the (b)(l) criteria after installing CCT and the State
set OWQPs, report the reason code WQP instead of(b)(l).
WQP = systems that are deemed according to criteria in §141.81(b)(2) or for
which the State has set OWQPs. The date for this reason code is the date State
designates OWQPs.
B3 = systems that have for two consecutive 6-month periods that the difference
between the 90th percentile tap water lead level and the highest source water lead
concentration is < 0.005 mg/L. Under LCRMR, also includes systems whose
source water lead levels are below the Method Detection Limit of 0.005 mg/L and
whose 90th percentile lead level is £ 0.005 mg/L. The date for this reason code is
the date State determines that the system met the (b)(3) criteria. If the system met
the (b)(3) criteria after installing CCT and the State set OWQPs, report the
reason code WQP instead of (b)(3).
Remember: After July 12,2001, a system no longer qualifies
as a (b)(3) system if it exceeds the copper action level.
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SDWIS/FED Reporting
Milestones
DONE Milestone
"UNDONE" must be reported (Modify
DONE milestone with END Date)
Report only most Recent DONE status
Reason Codes not required
SDWIS/FED & DTFWriter change
Report only Most Recent Done Status when reporting DONE for the first time.
When a system no longer meets the DONE criteria, the milestone is
"UNDONE" and the status is changed by modifying the milestone record by
reporting the milestone END DATE.
If and when, the system meets the DONE criteria, a second DONE milestone
should be reported.
EPA recently decided Reason Codes would not be required for "DONE"
Milestone. SDWIS/FED and DTFWriter software, however, REQUIRE a
reason code to be reported for both DEEM and DONE Milestones, at present
Both applications are scheduled for modified by July 2000.
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SDWIS/FED Reporting
Milestones
SDWIS/FED Implementation
Conversion of F^BSO and CU90 to samples
Rejection of discontinued milestones
Requesting DEEM milestones be reported
by February 15,2001
Continued tracking of discrete Milestones by State
Missed milestones reported as violations
SDWIS/FED Implementation:
Database frozen and LCR data archived. Milestones no longer required
(CCSR, CCSC, OTDE, OTTN, SIDE, STIN, WQPS, MPLS) were deleted, and
CU90, PB90 converted to Sample records.
As of January 2000, unwanted milestones will be displayed on the errors
reports. After January 11, 2002, they will be rejected.
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SDWIS/FED Reporting
Milestones
SDWIS/FED Milestone Record Format
DATA ELEMENT
Number Name Type Length Format/Comment
C101 PWSID A/N 9 SSxxxxxxx
C801 Milestone ID Number 4 nnnn
Milestone ID
C803 Milestone Date
C804 Milestone End Date
C805 Milestone Code
C813 Milestone Comment
C815 Milestone Value
C817 Milestone Reason Code
Number
Date
Date
A/N
A/N
Decimal
A/N
4
8
8
4
40
7.8
4
YYYYMMDD
YYYYMMDD
DEEM, DONE, LSLR
text field
nn nnnnn. nnnnnnn n*
B1.B3, WQP
* Milestone Value no longer valid for LCRMR violations as of January 2000
REQUIRED MILESTONE DATA:
PWS-ID
Milestone-ID: must be unique for this PWS in the input file
Milestone Date: the day system met the milestone criteria for DEEM, DONE,
OR, date State determines system must begin LSLR
Milestone End Date: Day system no longer meets DONE criteria, only valid
for DONE milestone
Milestone Code: DEEM, DONE, or LSLR
Milestone Value: No longer valid for LCRMR violations
OPTIONAL ATTRIBUTES: Milestone Comment: 40 character text field
- SDWIS/FED DEFAULTS: NONE
EXCEPTION CONDITIONS: NONE
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5/15/00
SDWIS/FED Reporting
Milestones
DTF Transaction Form
Data Batch
Form * Data Qualifiers Action Element Data Element Seq.
ID Quail Qual2 Qual3 Code Number Value N/A Num.
1-2 3-11 12-18 19-25 26 27-31
32-71
72-74 75-80
C4 DC1234567 0001
C4 OC1234567 0001
C4 DC1234567 0001
C4 DC1234567 0002
C4 DC1234567 0002
C4 DC1234567 0002
C4 DC1234567 0004
C4 DC1234567 0004
C803 19940701
C805 DEEM
C817 B1
C803 19940701
C805 DONE
C813 B1 criteria
010715
010715
010715
010715
010715
010715
M C804 20010801 030011
M C813 Exceeded Copper August 2001 030011
All Milestones reported as "C4" DTF Transactions Form
This example shows the State's first reporting of the DEEM milestone with
reason code - Followed by the DONE milestone with a comment. The
Comment is optional. The Reason Code is required for DEEM and not valid
for other LCRMR milestones.
NOTE: When systems become "UNDONE" only the Milestone End Date
needs to be submitted. Because the DONE milestone exists on the database, it
must be submitted as a "M" (MODIFY) transaction.
A second DONE milestone would be reported when the State designated
OWQPsinMayof2005.
NOTE: Report only the most RECENT DONE milestone for
the first reporting of the DONE milestone.
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SDWIS/FED Reporting
Summary
SDWIS/FED
Reporting and Implementation
Summary
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SDWIS/FED Reporting
Summary
Sample Records
PB90 - Lead 90th percent!le levels
AH for Large and Medium
ONLY exceedances required for Small
CU90 - Copper 90th percentile levels
Exceedances only for ALL systems sizes
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Summary
SDWIS/FED LCRMR Sample Implementation
Copper milestones converted to samples
Lead samples generated when lead
milestone existed without matching sample
Copper and lead milestone data archived
Will accept data under LCR reporting
requirements until January 11, 2002
After January 12, 2002 will reject
With implementation of the LCRMR in SDWIS/FED the following changes
were made:
All copper milestones were converted to sample records and the milestone
data was archived.
Lead samples were generated when the lead milestone record existed and
no matching sample record existed.
All lead milestone records were archived.
* SDWIS/FED does not generate milestones from 90th sample exceedances
as of January 2000.
States may continue to submit data under the LCR (old) reporting requirements
until January 11, 2002. After that date, SDWIS/FED will no longer convert
data, and will reject data which does not meet the correct format and/or content.
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SDWIS/FED Reporting
D.E.
Number
C101
C2101
C2103
C2105
C2107
C2111
Summary
Pb/Cu Sample Record
Name Type Length
PWS ID A/N 9
Sample ID Number 5
Sample Begin Date Date 8
Sample End Date Date 8
Sample Contaminant Code A/N 4
Sample Result Number 7.8
Format/Comment
SSxxxxxxx
nnnnn
yyyymmdd
yyyymmdd
Cu90, Pb90
nnnnnnn.nnnnnnnn
REQUIRED SAMPLE DATA:
PWS-ID
Sample-ID - must be unique for this PWS
Sample Begin Date and End Date = first and last day of designated
monitoring period for which 90th Percentile Result was calculated (6
month, 12 month/annual, 3 year, 9 year periods) 1/1/2001, and
6/30/2001
Sample contaminant code = Cu90, Pb90
Sample Analysis Result = 90th Percentile Result 1.72
OPTIONAL ATTRIBUTES:
Sample Reconciliation ID C2139 is a 40 character field for alternative
sample identifier
SDWIS/FED DEFAULTS: NONE
INVALID ATTRIBUTES:
Sample META Data attributes are not valid for LCR/LCRMR data
(attributes required for unregulated monitoring samples, e.g., altitude,
etc.)
EXCEPTION CONDITIONS: NONE
Page 202-d
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SDWIS/FED Reporting
Summary
General Violation Information
15 pre-LCRMR Violations
10 post-LCRMR Violations
No new Violations under LCRMR
Five Violations previously reported as discrete
Violations have been consolidated for reporting
with other Violations
In an attempt to reduce the reporting burden on States, the Data Sharing
Committee recommended and EPA adopted, reductions in the number and type
of violations reportable to EPA.
The LCRMR clarifies how WQP compliance is to be determined and actually
reduces the number of violations to be reported. More details later.
15 pre-LCRMR Violations ... 51 through 65
10 post-LCRMR Violations ... 51-53, 56-59, 63-65
Consolidations
54 & 55 with 53 - WQP M/R
60 with 59 - WQP Tap and Entry Point
61 with 57 - Treatment Study/Recommendation (OCCT/SOWT)
62 with 58 - Treatment Ins
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SDWIS/FED Reporting
Summary
Typical Noncompliance Portrayal
Noncompliance traditionally has been portrayed
by a Compliance Period ... Begin Date and End
Date (or Begin Date and Duration in months) of
the monitoring period in effect
Noncompliance has traditionally been portrayed by a period of time related
to the associated monitoring frequency period's begin and end date.
Discussions have been ongoing between EPA, States, water systems, and
the public, as to whether this method accurately portrays violation
conditions. The public finds it confusing and the water systems do not
believe it to be accurate. Strong arguments have been made on both sides
of the issue.
The LCR/LCRMR have requirements which do not "fit" into a monitoring
frequency period and thus required a different approach. Specifically,
milestone activities such as CCT Study, and OCCT Installation. In
addition, several monitoring requirements are one time requirements (two
consecutive rounds of initial and follow-up monitoring). EPA has
addressed this issue as discussed on the next two pages:
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SDWIS/FED Reporting
Summary
NEW Violation Noncompliance
Begins when the monitoring event or requirement
due date is missed, with the exception of WQP
non-compliance
Ends when the monitoring requirements have
been fulfilled or requirement has been
completed (RTC reported to SDWIS)
Portrayed as the actual time it took the system to
complete the event or fulfill the requirement past
the due date
New terms and definitions:
Compliance Period: The period associated with the overall period of time
or frequency interval established for a requirement. (6 month, annual,
triennial, or nine-year waiver period)
Monitoring Period: The specific period within the compliance period in
which the system was designated to perform the requirement. (June-
September)
Event Due Date: The due date or deadline for an event (e.g., installation
completion date)
Non-Compliance Period: The first day after the due date of the requirement
to the day compliance achieved, (e.g., October 1,2000 to August 1,2002)
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SDWIS/FED Reporting
Summary
NEW Violation Non-compliance
Compliance Period End Date (or Duration)
should not be specified when these Violations
initially reported to SDWIS/FED
SDWIS/FED defaults end date of 12/31/2015
RTC Enforcement Action date replaces
defaulted 12/31/2015 date
Proposed Intentional No Action Enforcement
would also replace defaulted 12/31/2015 date
Upon receipt of Enforcement stating that the system has Returned to
Compliance, SDWIS/FED will replace the defaulted 12/31/2015 end date
with the Enforcement Date.
Until receipt of an Enforcement stating that the system has Returned to
Compliance, SDWIS/FED will use 12/31/2015 as the Compliance Period
End Date and the Violation will be considered current or outstanding.
Proposed Intentional No Action relates to WQP, Public Education and Lead
Service Line Replacement requirements when a system falls below the
action level prior to the system's completing these requirements. For
WQPs, this applies only to small or medium-size systems.
These and other implementation issues will be discussed further in the
applicable sections which follow.
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SDWiS/FED Reporting
Summary
SDWIS/FED Violation Record Layout
DATA ELEMENT
Number Name
C101 PWS ID
Violation ID
Contaminant Code
C1101
C1103
C1105 Violation Type Code
C1107 Compliance Period Begin
C1109 Compliance Period End, or
C1111 Compliance Period Duration
Type Length Format/Comment
A/N 9 SSxxxxxxx
A/N 7 FFxnnnn
Number 4 1022,1030, or 5000
Number 2 51-53,56-59,62-65
Date 8 YYYYMMDD
Date 8 YYYYMMDD
Number 3 # of months
GENERAL LCR Violation Reporting Requirements:
PWS ID format...
SS USPS State code or EPA Region number
xxxxxxx 7-characters, alphanumeric
Violation ID format...
FF 2-digit Fiscal Year,
x- A number if the Violation ID is/was user-supplied
- The letter "G" if the Violation ID is to be generated
- The letter "V" if the Violation ID was previously generated nnnn 4-digit number
Violation Contaminant Code...
5000 - for all violation types except MPL TT violation (63=1022/1030)
Violation Dates format...
EPA standard is YYYY/MM/DD, however MM/DD/YYYY is acceptable
Violation End Date and duration...
End date and duration (Cl 109 and C1111) shall not be reported for LCR violations
except WQP (53 and 59). SDWIS default of 12/31/2015.
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SDWIS/FED Reporting
Summary
Four Monitoring and Reporting Violations
51 - Initial Tap Lead and Copper
52 - Follow-up / Routine Lead and Copper
53 - Water Quality Parameter (WQP)
56 - Source Water
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SDWIS/FED Reporting
Summary
Initial, Follow-up/ Routine Tap M/R
Contaminant Code "5000"
Violation Type Codes "51" and "52"
New criteria = 60 day notification to State from
change in source or treatment (type 52)
Compliance Portrayal Changed
RTC May require 2 consecutive 6-month rounds
SNC condition for Initial Tap ONLY
Compliance portrayal has changed for Initial Tap violations. The violation
begins the first day after the missed designated monitoring period. Previously,
the State would have reported one violation for each of the two 6-month
periods. Now a single violation is reported. This change affects systems which
have never monitored and new systems.
A system will return to compliance (RTC) when it meets all appropriate M/R
requirements, for two consecutive 6-month monitoring periods unless system
is on reduced monitoring or on a waiver.
Once a system is reduced to annual or triennial monitoring, or is granted a
monitoring waiver, the old RTC definition applies. A system with a "pre-
existing" monitoring waiver which fails to meet the September 30, 2000 Initial
Tap monitoring deadline will return to compliance when it subsequently
completes all monitoring requirements.
Previously reported violations and RTC data need not be changed. New
violations for these requirements must.be reported in this manner.
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SDWIS/FED Reporting
Summary
Initial Tap (51) Violation qualifies for SNC when
system fails to complete Initial Tap Monitoring
and/or RTC within:
Large:
Medium:
Small:
6 months + 3 months
6 months + 6 months
6 months + 12 months
Implementation of the LCRMR retains the additional time for a system to
return to compliance prior to it being designated as a significant noncomplier
(SNC).
The SDWIS/FED algorithm not only considers the time periods referenced
above, it adds an additional quarter of time before it queries the violations to
allow RTC actions which may have been reported at the end of the period to be
posted to SDWIS/FED due to EPA's normal one quarter reporting lag. The
bottom line is, EPA gives LCR violation reporting every opportunity to RTC
BEFORE EPA designates SNCs.
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SDWIS/FED Reporting
Summary
Initial Tap Follow-up & Routine M/R
Implementation
Converted compliance period end date to
12/31/2015
Will convert follow-up and routine end
dates to 12/31/2015 in Sept 2000 (estimated)
Only 1 violation reported when 2 consecutive
6-month monitoring periods required
Initial implementation only converted the initial tap compliance period end date
to 12/31/2015. Recent decision to implement follow-up and routine monitoring
violations in the same manner as initial tap require conversion of the
compliance period end dates of 12/31/2015. This conversion is scheduled to
take place in Sept of 2000.
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SDWIS/FED Reporting
Summary
SDWIS/FED LCRMR WQP Implementation
Converted Pre-Existing WQP M/R Violations to 53
(violation types 54 and 55 to type 53)
Converted Pre-Existing WQP TT Violations to 59
(tap violation type 60 to type 59)
Pre-existing WQP Violation begin dates unchanged
Standard compliance period
No SNC conditions
Conversion of the pre-existing WQP M/R and Noncompliance (Treatment Technique)
violations in SDWIS/FED took place in January 2000 during the implementation of the
LCRMR in SDWIS/FED. The database was frozen prior to the conversion for a
historical reference to that violation data.
The appearance of multiple "53" monitoring violations resulted, because of that
conversion. However, those violations have different violation begin and or end dates
and are not viewed as "duplicates", but rather as valid multiple violations of the same
type.
Under LCRMR a system will only incur one M/R, and/or one noncompliance
(Treatment Technique) violation during each 6-month compliance period. To eliminate
some of the reporting and tracking burden associated with a violation which could occur
every 2 weeks, all entry point M/R violations for a given system occurring in a given 6-
month period will be reported as one WQP M/R violation. Similarly, if a system incurs
both a tap and entry point M/R violation during the same 6-month compliance period,
you would report a single violation for the 6-month compliance period. On the other
hand, if a system incurred both entry point and tap WQP M/R violations with different
compliance periods which overlap, you would report two separate 53 violations, one for
each period. Example to follow.
The begin and end dates are the first and last days of the designated 6 month period.
SDWIS/FED does not default the end date to 12/31/2015 for WQP violations.
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SDWIS/FED Reporting
Summary
WQP Monitoring
One 6-month violation Second 6-month violation
Jan June Sept Dec
Entry Point
Annual Tap
Period of overlap
Pb/Cu Tap
Note: Compliance is based on 6-month period regardless of frequency
of tap or entry point compliance periods.
Although the compliance periods overlap, they are of different lengths and in
this instance, two 53 violations would be reported for this system. One
violation for the January through June which covers both tap and entry point
WQP violations and one for the July through December for the tap WQP
violations.
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SDWIS/FED Reporting
Summary
LCR WQP Non-Compliance
A single entry point WQP Noncompliance
Violation must be reported for any system in
which the WQP values of any sample collected
during the quarter are below the minimum value
or outside the range established by the State
per §141.82(g)
Tap WQP non-compliance violations are
reported with either 6 or 12 month compliance
periods
SDWIS/FED currently accepts the traditional quarterly and 6-month
compliance periods for WQPs.
Because the 6-month period is triggered from when the State designates
OWQPs, the first month of the 6 month period will not necessarily coincide
with the typical January through June and July through December periods.
SDWIS/FED will calculate the period based on the begin and end date
submitted or the begin date and number of months in the duration field.
Adoption of the new 6 month compliance period is optional.
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SDWIS/FED Reporting
Violations
LCRMR WQP Non-Compliance (TT)
LCRMR established fixed 6 month periods
Compliance determinations are always
based on a 6-month period, regardless of
the system's monitoring schedule (e.g.,
daily, biweekly, semi-annually, annually,
triennially) or whether the WQP results are
from an entry point or tap samples
ANY combination is a single violation
LCR Entry Point WQP noncompliance was determined and reported on a
quarterly period. Tap WQP noncompliance was reported on a 6 or 12 month
period. Now accepts compliance periods 3,6, 12 and 36 month duration to
accommodate reporting under LCRMR.
LCRMR Compliance determinations are always based on a 6-month
period, regardless of the system's monitoring schedule (e.g., biweekly, semi-
annually, annually, triennially), or whether the WQP results are from an entry
point or tap samples.
This type of violation can only occur after the State has designated OWQPs.
To simplify reporting, any combination of WQP noncompliance violations
during a 6-month period will be reported as a single violation for that 6-month
period. To return to compliance with WQP Noncompliance (TT) violations, a
system must complete all WQP monitoring at all locations and be in
compliance with all parameters for the entire next 6-month period.
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SDWIS/FED Reporting
Summary
Six LCR Treatment Technique Violations
OCCT/SOWT Study/Recommendation (57)
OCCT/SOWT Installation/Demonstration (58)
Entry Point/Tap WQP Noncompliance (59)
MPL Noncompliance (63)
Lead Service Line Replacement (64)
Public Education (65)
Violation Type is in parentheses.
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SDWIS/FED Reporting
Summary
OCCT Treatment Technique Violations
* No violation code changes to:
- OCCT study/recommendation (57 violation code)
- OCCT Installation/Demonstration (58 violation code)
* Consolidated OCCT/SOWT Installation and/or
Demonstration into one SNC
Converted violation end date to 12/31/2015
The violation type code 57 has been expanded to include both:
optimal corrosion control treatment study and/or recommendation
violations, and
source water recommendation violations.
The violation type code 58 has been expanded to include both:
optimal corrosion control treatment installation/demonstration
violations, and
source water treatment installation violations
The begin date for both 57 and 58 violations is the day after the event was
required to be completed. The end date is defaulted to December 31, 2015.
With the consolidation of the OCCT and SOWT installation violation types,
EPA will no longer produce separate SNCs for these two violations. Instead,
EPA will list a system that meets the OCCT Installation SNC criteria or SOWT
Installation SNC criteria as a Treatment Installation/Demonstration SNC.
The basic definition for this SNC has remained the same, a system that incurs a
treatment installation violation and has a 90th percentile lead level of > 0.030
mg/1 in most recent monitoring period.
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243
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SDWIS/FED Reporting
Summary
Treatment Study/Recommendation (OCCT)
Large systems are only subject to
Study violation
Medium and small subject to both
Recommendation and Study violation
OCCT Study/Recommendation Violation is reported for those medium and
small systems failing to make a recommendation. If State also requires a
study and the system fails to meet those requirements, a second OCCT/Study
Recommendation (57) would be reported.
Large systems must conduct a study and the recommendation is a specific part
of the study, therefore, large systems will only be subject to the Study
violation.
A SOWT Recommendation is due within 6 months of the exceedance;
Installation is required within 24 months of the State's determination of the
type of SOWT to be installed.
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SDWIS/FED Reporting
Summary
Public Education Implementation
65 - Violation code has not changed
SNC definition has not been revised
- system with violation and lead 90th percentile >
0.030 mg/L
Converted violation end date to 12/31/2015
Violation
The period of violation is described by the first day after the 60 day, 6 month, or 1 year
compliance period in which the public education requirements were to be performed. The
violation period ends when the State determines those requirements have been met.
The system has 10 days after the end of the 60-day, 6-month or 1-year compliance period
to report to the State. This 10 day period is not added to the compliance period. In other
words, the system does not have 70 days to meet its requirements. It has 60 days to meet
the requirements and 10 days to report.
As in other treatment technique violations, SDWIS/FED will default a compliance period
end date of December 31,2015. When the State reports the RTC enforcement/follow-up
action data (including the required violation link data), SDWIS/FED will replace the
defaulted end date with the RTC date. This method more accurately describes how long
the system took to perform the public education requirements.
SNC
A Public Education SNC is still defined as a system that incurs a public education
violation and its 90th percentile lead level is 0.030 mg/1 or higher in its most recent
monitoring period.
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SDWIS/FED Reporting
Summary
Public Education
ONE Public Education (PE) Violation must be
reported for EACH discrete PE compliance
period requirement (i.g., 60 day, semi-annual,
and annual)
PWS could incur 3 separate violations in first 14
months after exceedance
10 day period to report to State is not included
Depending on the specific requirement and PWS type, the time frames include
the following:
"60 days after the end of the designated monitoring period" of a lead
action level exceedance.
"6 months after the 60 days" for repeat public service announcements for
aCWS.
"12 months after the 60 days " (for both CWSs and NTNCWSs) for
repeat notices to customers and delivery of pamphlets and brochures.
Even though there are multiple requirements under each of the discrete PE
requirement periods, only one violation is reported for each discrete PE period.
The rule allows 10 days from the end of the due date for the system to report to
the State. This 10 day period is not included in the violation begin date.
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SDWIS/FED Reporting
Summary
Source Water Monitoring & MPL Non-Compliance
No change to violation type code for:
- Source water M/R violations (56 violation type)
- MPL noncompliance (63 violation type)
Converted SOWT Recommendation violations to type 57
Converted SOWT Installation violations to type 58
Consolidated OCCT/SOWT Installation and/or
Demonstration SNC
The violation type codes have not been changed for:
Source water M/R violations. All source water M/R violations continue to be reported
using the 56 violation code.
Maximum Permissible Level (MPL) noncompliance. A violation type code 63 is still to
be used to report systems that exceed their lead and/or copper MPLs.
Violation codes associated with a source water treatment (SOWT) recommendation or SOWT
installation violation have been changed.
A 57 violation is used to report either:
A system's failure to meet its a source water treatment recommendation requirements
(formerly a 61 violation type), or
A system's failure to meet its corrosion control study/recommendation requirements.
A 58 violation is used to report either:
A system's failure to meet its a source water treatment installation requirements (formerly
a 62 violation type), or
A system's failure to meet its optimal corrosion control treatment installation
requirements.
EPA will list a system that meets the OCCT Installation SNC criteria or SOWT Installation SNC
criteria as a Treatment Installation/Demonstration SNC.
The basic definition for this SNC has remained the same, a system that incurs a treatment
installation violation and has a 90th percentile lead level of > 0.030 mg/1 in most recent
monitoring period.
39
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SDWIS/FED Reporting
Summary
Source Water M/R & MPL Noncompliance
Converted the end dates to 12/31/2015
Source water follow-up monitoring requires
two consecutive, 6-month rounds - only 1
M/R violation is reported.
Monitoring is conducted AFTER the lead or
copper action level exceedance (No
Grandfathering)
Like lead and copper tap monitoring, there can be 3 types of source water monitoring
requirements: Initial, Follow-up, and Routine. The initial round only requires one round.
Follow-up requires 2 consecutive 6-month rounds, and the Routine monitoring is one
round within 3-year compliance periods for groundwater and one round within a 1-year
period for surface water systems or systems with a combined source. In addition,
systems on routine monitoring can qualify for reduced monitoring in which source water
samples are collected once every 9 years.
Only 1 M/R violation is reported for failure to sample for either lead or copper, or both
lead and copper per designated monitoring period.
Initial source water monitoring is conducted AFTER the lead or copper tap action
level(s) is exceeded. Even if the State requires lead and copper be monitored routinely
with the inorganic monitoring, the samples must be taken AFTER the lead or copper tap
exceedance. There are no provisions in the LCR/LCRMR for grandfathering of data.
For follow-up source water monitoring, only one M/R violation is reported. The begin
date of the violation is the day after the first round missed. RTC may not be reported
until 2 consecutive 6-month rounds are completed.
40
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248
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SDWIS/FED Reporting
Summary
MPL Noncompliance
A system may incur separate Violations for
exceeding the Lead MPL and the Copper MPL
Only ONE MPL Noncompliance Violation must be
reported for a single contaminant regardless of how
many entry points are in violation
Contaminant code is:
- 1022 = Copper,
- 1030 = Lead
- reported in lieu of 5000 code that is used for all other LCR
or LCRMR violations
If a system exceeds the MPL for only Lead or only Copper in more than one
source water sample, the State would report a single violation for that period,
for that contaminant.
If a system exceeds the MPL for both Lead and Copper, the State would report
two violations.
To simplify reporting, only ONE Lead or ONE Copper violation is required to
be reported in each designated monitoring period, regardless of how many
entry points incur an exceedance.
No SNC conditions for source water monitoring, failure to provide a source
water recommendation, or failure to meet source water treatment installation
requirements.
41
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SDWIS/FED Reporting
Summary
Lead Service Line Replacement
64 Violation Type Code
- Includes violation of partial LSLR requirements
- Failure to complete annual designated
replacement rate
- Could incur multiple violations
Converted pre-existing end dates to 12/31/2015
Default violation end dates until 1/11/2002
No SNC conditions
Violations
The LCRMR expand the definition of what constitutes an LSLR violation. Systems replacing only a portion of
an LSL, can incur a violation when they fail to complete all requirements of each partial replacement project.
EPA did not create a separate M/R violation for failure to conduct the notification, monitoring, and reporting
requirements associated with partial LSLR. Failure to conduct these activities are included as a treatment
technique violation and is reported using the 64 violation code.
Systems only replacing a portion of the line (i.e., partial LSLR) have additional notification and reporting
requirements. A system can have more than one LSLR violation per 12 months for failure to meet one or more
of its partial LSLR requirements. The system would also incur a separate violation if it did not replace 7% (or
higher if required by the State) of its LSLs in the 12-month period.
The first year of LSLR begins when the State determines the PWS is triggered into LSLR. The violation begins
the first day after the end of the designated 12-month replacement year.
For Partial LSLR, the violation begins the first day after the due date of the requirement for that partial
replacement project (I.e., notification to the resident prior to partial LSLR, sampling of water in service line and
reporting results to users, and appropriate reporting to State.)
No SNC conditions, and RTC reporting is required.
LSLR Milestone: States must report, on a quarterly basis, those systems which are required to replace lead
service lines and the date the system was required to start the replacement and those systems that are
"retriggered" back into LSLR requirements do to a subsequent lead exceedance. Under the LCRMR, States are
no longer required to report those systems on an accelerated replacement schedule, the annual replacement rate,
or submit a separate report for those systems which are in compliance with their replacement schedule.
Replacement rates for LSLs which have already been reported to SDWIS/FED prior to January 12, 2000 will be
archived, and will no longer be available in SDWIS/FED. However, States still must report a violation for
systems that do not meet their replacement schedules.
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250
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Data Transfer Format (DTP)
DTP transactions are 80 characters long
DTP is the only way to get data into
SDWIS/FED, Except for SETS (restricted to
EPA)
Single DTP transaction is required for each
piece of data to be inserted, modified, or
deleted, Except for Enforcement Linking
43
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251
5/15/00
Data Transfer Format (DTP)
DTP Transaction Format
Form
ID
1-2
Data Qualifiers
Quail Qua!2 Qual 3
3-11 12-18 19-25
Action
Code
26
Data
Element
Number
27-31
Data Element
Value
32-71
N/A
72-74
Batch Seq.
Number
75-80
1. Form ID - Uniquely identifies Records in SDWIS.
2. Data Qualifiers - Groups data of "like" types (e.g., Inventory, Milestones,
Violations, Enforcements, Samples)
A. Qualifiers must be unique to that PWS, at each record level, within each
input file.
B. Up to 3 qualifiers per transaction
- Qual 1 = PWS-ID
- Qual 2 = 1 st subordinate level record (source to PWS)
- Qual 3 = 2nd subordinate level record (treatment to source).
C. Qualifiers 2 and 3 may be user assigned (must be numeric), or
Generated by SDWIS via Group Generation codes (GGCs). The first
position of a GGC must be "G" - the remainder must be numeric except
Violations, Enforcements, Variance & Exemptions, and V&E Schedules.
The first two positions for these records must be the Fiscal year followed by
the "G" and a unique numeric number for each record of that type for that
PWS in that file (e.g., two violations in a 1999 file - the first record would be
"99G0001", the second "99G0002").
D. GGCs and user defined qualifiers cannot be mixed.
E. DTP Qualifiers cannot be deleted, inserted, or modified (i.e., specified as a
Data Element Value).
44
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252
5/15/00
Data Transfer Format (DTP)
DTP Transaction Format
Form
ID
Data Qualifiers
QuaM Qual2 Qua! 3
Action
Code
Data
Element
Number
Data Element
Value
N/A
Batch Seq.
Number
1 -2
3-11 12-18 19-25
26
27-31
32-71
72-74
75-80
3. Action Code (DIM Code) - Used to specify a Delete, Insert, or Modify
operation upon SDWIS/FED data
4. Data Element Number - 4-digit number preceded with the letter "C". Used
in DTP to identify each piece of data, and used by Edit/Update software
for cross-edit checking (i.e., one data element requires another). The
element is not stored in SDWIS/FED (e.g., water system name).
5. Data - Contains the actual data to be posted (40 character).
6. Batch Sequence Number - Used to sequence DTP transactions for
Edit/Update processing.
NOTE that positions 72 through 74 are used to display the 3-character error
codes in the generated ERRORS file and are otherwise ignored by the
edit/update process.
45
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25
715/00
Data Transfer Format (DTP)
DTF Content - Form ID Illustrated
A2 NH0199050
A2NH0199050
A2NH0199050
A2 NH0199050
A2NH0199050
A2 NH0199050
B1 NH0199050 001
IC011725
I C0147 0000010
IC01634
I C0165 B
IC01590101
I C0161 1231
I C0403 BRW 1, 85' WEST OF BLDG
990224
990224
990224
990224
990224
990224
990224
NOTE: Blank spaces have been inserted between OTF Components above for clarity
Example of inventory data - population, service connections, system begin and
end dates, and a source address. All data belongs to one PWS. All being
inserted into the database.
46
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254
5/15/00
Data Transfer Format (DTP)
DTP Content - Form Ids and Data Qualifiers
FORM
ID
A1
A2
A3
B1
B1(2)
B2
B3
B4
FORM NAME Record
System Address Data 1 00
PWS Characteristics Data 1 00
Other Address Data 300
Source/Entity Data 400
Location Data
Treatment Data 480
Facility Flow Data A5000
Treatment Plant Address Data 350
QUAL 1 QUAL 2 QUAL 3
PWS-ID
PWS-ID
PWS-ID ADDRESS- ID
PWS-ID SE-ID
PWS-ID SE-ID
PWS-ID SE-ID TREATMENT-ID
PWS-ID SE-ID
PWS-ID SE-ID
List of form types, displaying the qualifiers, the appropriate number and type of
subordinate qualifiers and record types, and the record number for that form.
Example: Form B-2 is Treatment Data, its record number is 480, its first
qualifier is the PWS-ID, the second is the Source/Entity (water system facility)
Identifier and the third is the Treatment Identifier.
A PWS may have many water system facilities, each water system facility may
have many treatments. However a treatment is related to only one water system
facility, and a water system facility is only related to one PWS.
47
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255
I
a
9
h-
Z
LLJ
HI
a:
Q
LU
X
O
CO
&
fr t LLJ
LU«^
CO > S
5
o
o
Q
Z LU LU
LU > >
9
LU
bi bi Q-
CO
ID Q
E|
O co
II- (A
*" QQQ QQQQQ QQQ
_J
O
CO CO CO
CO CO CO
a. a. a.
g
i
Q.
ODD
Q. Q. Q.
1
*£ E
o
TO O
Q o
u_
Q
i_
o
u
0)
{£,
FORM NAME
Q
O
o
«
CO
o
System Address
<£
o o
O 0
5
CO
o
CA
0 CO
V ^»*
PWS Character!)
Other Address D
CM CO
O
o
^
+5
Source/Entity Ds
5
o
CO
*
Location Data
Treatment Data
s
ffl CD
O
O
0 o
ID if)
< CO
m
"co
Q
CO
CO
TJ
CO <
Facility Flow Dat
Treatment Plant
CO TT
GO CD
O O
0 O
CD h-
-------
256
5/15/00
Data Transfer Format (DTP)
DTP Content - Data Qualifiers Illustrated
A2 NH0199050
A2 NH0199050
B1 NH0199050 001
B1 NH0199050 001
B1 NH0199050 001
B1 NH0199050 001
B2 NH0199050 001
B2 NH0199050 001
01
01
(C01590101
(C0161 1231
I C0403 BRW 1, 85' WEST OF BLDG
I C0405 S
I C0407 G
I C0409P
I C0483 D
I C0485 423
990224
990224
990224
990224
990224
990224
990224
990224
NOTE: Blank spaces have been inserted between DTP Components above for clarity.
Example of Valid user-assigned IDs in BOTH Data Qualifier #2 and #3.
Note State code in PWS ID - 2 char USPS State code or 2-digit EPA Region
code for Direct Implementation Programs (Indian PWS).
Positions 3-9 may contain any combination of 0-9 or A-Z.
49
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25
1/15/00
Data Transfer Format (DTF)
DTP Content - Data Qualifiers Illustrated
B1 NH0199050 G01
B1 NH01990SO G01
B1 NH0199050 G01
B1 NH01990SO 601
B2 NH0199050 G01 G1
B2 NH0199050 G01 G1
B2 NH01990SO G01 G2
B2 NH0199050 G01 G2
I C0403 BRW 1, 85' WEST OF BLDG
I C0405S
I C0407 G
I C0409 P
I C0483 D
I C0465 423
I C0483 P
I C0485 344
990224
990224
990224
990224
990224
990224
990224
990224
NOTE: Blank spaces have been inserted between DTF Components above for clarity.
Example of Group Generation Codes (GGC) - This PWS has two treatment
objective/process combinations for the same water system facility. The water
system facility is represented by the G01 and the treatment objective/process
combination is represented by Gl and G2.
If EPA did not differentiate them with the unique numbers, Gl and G2,
SDWIS/FED would interpret the data to indicate that there were two treatments
and two objectives, but it could not tell which two were to be considered "valid
combinations".
50
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258
5/15/00
Data Transfer Format (DTP)
DTF Content - Action Code Illustrated
A2 NH0199050
B1 NH0199050 001
B2 NH0199050 002 01
B2 NH0199050 002 01
MC011725
D C0300
I C0483D
I C0485423
990224
990224
990224
990224
NOTE: Blank spaces have been inserted between DTF Components above for clarity
Examples of the Action Codes
M = Modify the population (Cl 17) to be 25.
I = Insert the new treatment process (C485 = chlorination) and objective (C483 =
D disinfection) for water system facility 002.
D = Delete the Record COS 00 (Other Address Data) - all data elements associated
with it for address record 001.
Next slide explains Record Numbers Used for Deletion of data.
51
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25
'1/15/00
Data Transfer Format (DTP)
DTP Content - Data Element Number
Record Numbers
Used in DTP ONLY to identify entire
records in SDWIS/FED to be deleted in a
Traditional update
Valid record numbers are shown on the
Record Deletion Form
52
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260
5/15/00
Data Transfer Format (DTP)
DTF Content -
- Data Element Number
Record Numbers Illustrated
A3 NH0199050 1
B1 NH0199050 001
B2NH01 99050 001 01
B3NH01 99050 001
B4NH01 99050 001
C1NH01 99050 00001
C2NH01 99050 00001
C3NH01 99050 00001
C4 NH01 99050 0001
01 NH0199050 9900001
E1 NH01 99050 9900001
F1NH01 99050 9900001
F2 NH01 99050 9900001 01
H1 NH0199050 00001
NOTE: Blank spaces have been
D C0300
D C0400
D C0480
D ASOOO
D C0350
D C0500
0 C0600
D C0700
D C0800
DC1100
D C1200
D C3000
D C3100
D C2100
990224
990224
990224
990224
990224
990224
990224
990224
990224
990224
990224
990224
990224
990224
inserted between DTF Components above for clarity
Example of Record numbers used as method of Deletion for all data elements
contained in that record. Remember the record is identified by the qualifier, or
combination of qualifiers for that record.
The third line represents a treatment record of 01 belonging to water facility
001 for PWS-IDNH199050.
53
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15/15/00
Data Transfer Format (DTP)
Deletion of a Single Attribute
Attribute level deletion allowed for "optional" data
Data Entry Instructions provides attribute deletion
indicator
Example: Deletion of the milestone comment attribute
C4 LQ1234567 00045
DC813S
000025
Some attributes may be deleted. Attributes which are required to register a
record do not allow deletion. See the SDWIS/FED Data Entry Instructions for
specific details on which data elements or attributes allow deletion at the
attribute level.
The example above displays the DTP transaction for the deletion of the
milestone comment (C813) for milestone with the record identifier of "00045".
A dollar sign ($) is placed in the first position of the data value field in the DTP
format.
54
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262
5/15/00
Data Transfer Format (DTP)
DTP Content - Batch Sequence Number
Used to sequence update events in traditional
updates only ... not used in total replace updates
Lowest number processed first
Alpha/numeric format
Batch sequence numbers are not required unless a State wishes to sequence the processing
order of the data in a traditional update file.
To ensure the desired result is achieved, care must be given when using batch sequence
numbers. Example on next slide
55
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263.
5/15/00
Data Transfer Format (DTP)
DTP Content - Batch Sequence Number
Enforcement Won't be Linked to Violation - Why?
D1 CT0099233 9900147
D1 CT0099233 9900147
D1 CT0099233 9900147
D1 CT0099233 9900147
E1 CT0099233 9900144
E1 CT0099233 9900144
E1 CT0099233 9900144
NOTE: Blank spaces have been
IC11031025
IC110503
I C1 107 19980701
IC1111 001
IC120319990111
I C1205 SIF
IY50009900147
990224
990224
990224
990224
990223
990223
990223
inserted between DTP Components above for clarity.
The enforcement action "SIF" in the bottom set of information will be posted before the
violation it is linked to and will cause an orphan enforcement to be posted. The link will
reject.
56
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264
5/15/00
Data Transfer Format (DTP)
Review
DTP Transaction Format
DTP Content
Questions?
DTP Transaction Format
80 characters
Only way to get data into SDWIS/FED presently
One Transaction for one piece of data
DTP Content
Form ID, Data Qualifiers, DIM Code, Data Element Number, Data
Element Value, Batch Sequence Number
Batch Sequence Number applicable for Traditional updates only
Successful use of Qualifiers is critical to successful processing.
57
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265
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SDWIS/FED Reporting
Enforcements
Enforcement/Follow-Up Actions (RTC)
and Enforcement Linking
58
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266
5/15/00
SDWIS/FED Reporting
Enforcements
MUST be reported for ALL Enforcement Actions
PWSID
Enforcement ID
Enforcement Date
Follow-up Action Code
Enforcement Comment
(C101 -Data Qualifier#1)
(C1201 - Data Qualifier #2)
C1203 - Date Action taken
C1205-See Notes
C1215-Optional
Data Element Numbers, in parentheses, are used in the DTP transaction to
associate attributes within the record with other records (e.g., enforcement to
PWS)
The remaining Data Element Numbers identify the data value to the database.
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SDWIS/FED Reporting
Enforcements
Enforcement Record Data
Data Element
Number Name
C101 PWS ID
C1201 Enforcement ID
C1203 Enforcement Date
C1205 Follow-up Action Code
C1215 Enforcement Comment
And the appropriate Link data.
Type Length Format/Comment
A/N
Date
A/N
A/N
9
7
8
3
40
SSxxxxxxx
FFxnnnn
YYYYMMDD
Optional
PWS ID format...
SS USPS State code or EPA Region number
xxxxxxx 7-characters, alphanumeric
Enforcement ID format...
FF 2-digit Fiscal Year - FY action was taken
x A number if the Enforcement ID is/was user-supplied
The letter "G" if the Enforcement ID is to be generated for a new
Enforcement
The letter "E" if the Enforcement ID was generated by SDWIS/FED
nnnn 4-digit number
Enforcement Action Code...
XXX Pos. 1- represents the Origin: E=EPA, S=State
Pos. 2- represents formality: F=formal, I=informal, O=other
Pos. 3- represents enforcement code
(Example: SIF = State Informal Request for Public Notice action)
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SDWIS/FED Reporting
Enforcements
Links to Violations
Formal Enforcement Actions should be linked to
the appropriate violation(s)
RTC and Intentional No Action are "Formal"
Unlinked Enforcements are "Orphans"
4 Methods to Link Enforcements to Violation(s)
It is possible to post an Enforcement to the SDWIS/FED data base without
linking it to any Violation.
Failure to link an Enforcement to one or more Violations, however, results in an
"Orphan" Enforcement, which is highly undesirable.
If XA7Z5000 link fails, the Enforcement will still be posted to the SDWIS/FED
data base.
If J5000 link fails, the Enforcement will NOT be posted to the SDWIS/FED
data base.
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Enforcements
Link Methods
X5000 - Associated Violation Range
Y5000 - Associated Violation IDs
Z5000 - Associated Violation Contaminant Groups
J5000 - Associated J5000 Group
The next several slides provide enforcement reporting requirements and
characteristic details for each enforcement link method listed above.
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Enforcements
X5000 - Associated Violation Range
Enforcement is linked to Violation(s) between
specified date range
Maximum of one Associated Violation Date
Range in the Data Element Value
Links to violations matching begin or end dates
Links to ALL violations of ALL Rules (CAUTION)
Failed Link - posts Enforcement - rejects Link
Will link all violations of all rules or violation types where the violation
compliance period begin OR compliance period end dates fall within the
range specified by the X5000 dates. Caution should be used when reporting
under this link method.
Only one Associated Date Range may be specified in a single X5000 DTP
transaction's Data Element Value
SDWIS/FED X5000 Link Record Layout
D.E.
Number Name Type
X5000 Associated Violation Range
Compliance Period Begin Date Date
Compliance Period End Date Date
Length
8
8
Format/Content
YYYYMMDD
YYYYMMDD
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Enforcements
X5000 - Associated Violation Range Illustration
E1 CT0099233 9900144
E1 CT0099233 9900144
E1 CT0099233 9900144
or
E1CT0099233 9900144
I C1203 19990511
IC1205SIF
I X5000 1999030119990331
I X5000 1999010119990331
990224
990224
990224
990224
First example links to violations in one month:
3/1/1999 to 3/31/1999
Second example links violations in one quarter:
1/1/1999 to 3/31/1999
NOTE: Blank spaces have teen inserted between DTP Components above for clarity
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Enforcements
Y5000 - Associated Violation IDs
Enforcement is linked to specific Violation(s) by
Violation ID
Maximum of four Associated Violation IDs in the
Data Element Value
Failed link - posts Enforcement - rejects Link
Accurate entry of valid violation record identifiers is critical to successful
enforcement/ violation linking. Careful consideration should be given to the
use and management of record identifiers for all data, particularly violation
and enforcement data.
One, two, three, or four Associated Violation IDs may be specified in ONE
Y5000 DTP transaction's Data Element Value
A failed Y5000 link will result in the link being rejected and the enforcement
being posted as an orphan.
SDWIS/FED Y5000 Enforcement Link Record Layout
D.E.
Number Name Type Length Format/Comment
Y5000 Associated Violation ID(s)
Violation ID 1 A/N 7 FFxnnnn
Violation ID 2
Violation ID 3
Violation ID 4
A/N
A/N
A/N
FFxnnnn
FFxnnnn
FFxnnnn
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Enforcements
Y5000 - Associated Violation IDs Illustrated
(Proper Use of Y5000)
E1 CT0099233 9900144
E1 CT0099233 9900144
E1 CT0099233 9900144
E1 CT0099233 9900144
E1 CT0099233 9900144
1C1203 19990111
1C1205SIF
IY5000 9900047
I Y5000 9900048
1 Y5000 9900049
990224
990224
990224
990224
990224
Allows 3 transaction rows - one violation link on each
row, OR
NOTE: Blank spaces have been inserted between DTP Components above for clarity.
OK to link this way.
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Enforcements
Y5000 -Associated Violation IDs Illustrated
(Proper Use of Y5000)
E1 CT0099233 9900144
E1 CT0099233 9900144
E1 CT0099233 9900144
I C1203 19990111 990224
I C1205 SIF 990224
I Y5000 9900047 9900048 9900049 990224
3 violation ID s on One transaction row
NOTE: Blank spaces have been inserted between DTP Components above for clarity.
OK to link this way.
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Enforcements
Y5000 - Associated Violation IDs Illustrated
(Improper Use of Y5000)
E1 CT0099233 9900144
E1 CT0099233 9900144
E1 CT0099233 9900144
E1 CT0099233 9900145
E1 CT0099233 9900145
E1 CT0099233 9900145
E1 CT0099233 9900146
E1 CT0099233 9900146
E1 CT0099233 9900146
I C1203 19990111
I C1205 SIF
I Y5000 9900047
I C1203 19990111
I C1205 SIF
IY5000 9900048
I C1203 19990111
I C1205 SIF
I Y5000 9900049
990224
990224
990224
990224
990224
990224
990224
990224
990224
Results in "Duplicate" Enforcements when in fact only one
Enforcement exists - SDWIS/FED will post these link
transactions using only the FIRST enforcement record ID
Note that the entire Enforcement is duplicated with three different record
identifiers.
This method of linking is incorrect.
SDWIS/FED posts the enforcement and the link from the first record in the file,
then posts the links from the remaining "duplicates" using the enforcement
record identifier from the first record. SDWIS/FED rejects the "duplicate" data
and sends it to "transaction heaven". This results in the enforcement record
identifiers being posted to SDWIS/FED not matching record identifiers in State
records.
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Enforcements
Z5000 - Associated Violation Contaminant Groups
Link requires exact match of:
- Violation Type
- Contaminant, and
- Violation Compliance Period Begin Date
Maximum of two Associated Violation
Contaminant Groups in the Data Element Value
Failed Link - posts Enforcement - rejects Link
Enforcement is linked to Violation(s) exactly matching Violation
Type, Contaminant, and Compliance Period Begin Date
Maximum of two Associated Violation Contaminant Groups in the
Data Element Value
If link fails, the Enforcement will still be posted to the SDWIS/FED
data base
Reporting Enforcement Data - Z5000
Number Name Type Length
25000 Associated Violation Contaminant Group(s)
Violation Type Code Number 2
Contaminant Code Number 4
Compliance Period
Begin Date Date 8
Format/Comment
51-53,56-69,63-65
5000,1022, 1030
YYYYMMDD
Remember: When States are switching over to the new reporting
requirements, they should not revise pre-existing violation begin
dates. This is because enforcement actions are linked to violation
begin dates. Thus modifying pre-existing begin dates will cause
these links to be broken.
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Enforcements
Z5000 - Associated Violation Contaminant
Groups Illustrated (Proper Use of Z5000)
E1 CT0187031 99G0001
E1 CT0187031 99G0001
E1 CT0187031 99G0001
E1 CT0187031 99G0001
I C1203 19970129
IC1205SFO
I Z5000 51500019920101
I Z5000 53500019920101
990224
990224
990224
990224
NOTE: Blank spaces have been inserted between DTP Components above for clarity.
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Enforcements
Z5000 - Associated Violation Contaminant
Groups illustrated (Proper Use of Z5000)
E1 CT0187031 0260001
E1 CT0187031 02G0001
E1 CT0187031 02G0001
I C1203 20020429 020224
I C1205 SFO 020224
I Z5000 6550002002030153500020010701 020224
Links the following 2 violation groups:
Vio type: 65, Contain: 5000, Vio begin date: 3/1/2002
Vio type: 53, Contam: 5000, Vio begin date: 7/1/2001
NOTE: Blank spaces have been inserted between DTP Components above for clarity.
Example: System exceeded the lead action level in the July through December
2001 designated monitoring period. The system was required to conduct its
initial public education activities within 60 days and fails to do so. The system
is also required to monitor WQPs and fails to do so. Violations were issued for
both conditions. On 4/29/2002, the State takes a formal action (SFO - State
Administrative Order with penalty). By 8/15/2002, the formal enforcement
action and link data is reported to SDWIS/FED.
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Enforcements
J5000 - Associated J5000 Group
Link requires exact match of:
- Violation Type
- Contaminant or Rule
- Enforcement Period Begin Date, and
- Enforceable Compliance Date
Maximum of one Associated Violation J5000 Group
in Data Element Value
Failed link REJECTS ENFORCEMENT
Enforcement is linked to Violation(s) which match exactly based on the following
criteria:
Violation Type, Contaminant or Rule, Enforcement Period Begin Date, and
Enforceable Compliance Date (deadline)
Only one Associated J5000 Group may be specified in a J5000 DTP transaction's
Data Element Value
If link fails, the Enforcement will NOT be posted to the SDWIS/FED data base
Reporting Enforcement Data - J5000 Format
D.E Number Name
J5000 Associated J5000 Group
Enforcement Action Begin Date
Enforceable Compliance Date
Violation Type Code
Contaminant Code
Rule Code
Type Length
Date
Date
Number
Number
A/N
8
8
2
4
4
Format/Comment
YYYYMMDD
YYYYMMDD
51-53,56-69,63-65
5000,1022,1030
LCR
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Enforcements
J5000 - Associated J5000 Group Illustrated
E1 PR045511499G1118
E1 PR045511499G1118
E1PR045511499G1118
I C1203 19990715
I C1205 SFL
IJ5000 1999013120000715
990224
990224
LCR 990224
Enforcement Period begin Date: 1/31/1999
Enforceable Compliance Date: 7/15/2000
Rule Code: LCR - Lead and Copper Rule, or
contaminant code of 5000
NOTE: Blank spaces have been inserted between DTP Components above for clarity.
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Enforcements
Violation, Enforcement and Z5000 - Associated
Violation Contaminant Groups Link Example
D1 CT0187031 0400221
D1 CT0187031 0400221
D1 CT0187031 0400221
D1 CT0187031 0400221
E1 CT0187031 0400035
E1 CT0187031 0400035
E1 CT0187031 0400035
E1 CT0187031 0400035
I C1103 5000
IC110559
I C1107 20030701
I C1109 20031231
I C120319990129
I C1205 SFO
I C1215 CASE REFERENCE T-2275
IZ5000 59500020030701
Y5000 would look like the following:
E1 CT0187031 0400035 I Y5000 0400221
040224
040224
040224
040224
040224
040224
990224
040224
040224
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General Information
All LCR/LCRMR data is required to be reported to SDWIS/FED
within 45 days after the end of the quarter in which the
monitoring, violations, milestone determinations, and or
enforcement/follow-up actions were completed, issued, made
or taken.
Data review and error correction should be completed by the
90th day after the end of the quarter.
The Production database is frozen on or about the 5th day of
the 4th month after the end of the quarter and the data is
provided to EPA's ENVIROFACTS web site for public access.
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SDWIS/FED Reporting
Information Resources
SDWIS/FED Documentation: EPA Home Page
WWW.EPA.GOV/SAFEWATER/SDWISFED/SDWIS3.htm
SDWIS/FED User Support: Michelle Stoner 202-260-2798
SDWIS/FED Production Control/Help Line: 703-292-6121
SDWIS/FED Technical information: Fran Haertel 214-665-8090
* LCRMR Implementation and Compliance Determination
Questions: Leslie Cronkhite 202-260-0713
EPA Regional Data Management Coordinators
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SDWIS/FED Reporting
Enforcements
Enforcement/RTC
Formal Enforcement Follow-up actions are
Required Reporting
Enforcement/follow-up action must be linked to
the violation
Compliance Period/ Violation Period End Date
is replaced by the RTC action date; therefore,
RTC must be reported
All formal enforcement / follow-up actions are required to be reported to
SDWIS/FED. A returned to compliance, or "RTC", (EOX or SOX =
compliance achieved action) is classified as an "other" action type and is also
required reporting for this rule.
Because SDWIS/FED defaults a future compliance period/ violation period end
date of 12/31/2015 for these violations, RTC reporting is required. When the
RTC record is reported and LINKED to the violation, the defaulted end date is
replaced with the RTC enforcement/ follow-up action date. Therefore,
reporting RTC actions and the appropriate violation link data is required.
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"Deemed" Determination
Scenario
System serves 75,000 people
* July - Dec 1993: Pb 90th = 0.007 mg/L; Cu 90th = 0.7 mg/L
Jan.-June 1994: Pb 90th * 0.008 mg/L; Cu 90th = 0.8 mg/L
No lead or copper is detected in source water samples collected during
1993 and 1994.
4/30/00: State reviews file to determine if system meets "deemed" criteria
1. Does the system meet the "deemed" criteria?
No. A large system can only meet the deemed criteria when the State
sets OWQPs or it qualifies as a (b)(3) system.
Answer
A system that is below the lead and copper action level for two consecutive 6-
months meets the criteria of §141.8l(b)(l) (i.e., is a (b)(l) system). This
criteria only applies to small and medium-size systems (those serving < 50,000
people).
A large system meets the "deemed" criteria:
1. If it qualifies as a (b)(3) system or
2. When the State sets OWQPs.
These criteria also apply to small or medium-size systems.
The system in this example does not qualify as a (b)(3) system and therefore,
will not be "deemed" until the State sets OWQPs.
Note: If the system in this example had served 50,000 or fewer people, then
the system would have met the deemed criteria on July 1, 1994.
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"Deemed" Determination
Scenario
System serves 55,000 people
Jan - June 1992: source Pb = 0.005 mg/L; Pb 90th = 0.007 mg/L; Cu 90th = 1.2 mg/L
July - Dec 1992: source Pb = 0.005 mg/L; Pb 90th = 0.008 mg/L; Cu 90th = 1.4 mg/L
July - Dec 2000: source Pb = 0.005 mg/L; Pb 90th - 0.008 mg/L; Cu 90th = 0.8 mg/L
1. Does the system meet the "deemed" criteria?
Yes, on Dec. 31, 2000 when it meets the (b)(3) criteria, based on the
LCRMR definition.
2. What if the system was below the copper action level during
monitoring conducted in 1992.
The system would have met the deemed criteria on Dec. 31,1992.
Answer 1
Under the LCR, the system meets the definition of a (b)(3) system. However,
under the LCRMR, the system must also be below the action level by June 12,
2001 (i.e., 18 months after publication of the LCRMR).
Therefore, this system does not qualify as a (b)(3) system, and therefore, does
not meet the "deemed" criteria unless it also is below the copper action level in
monitoring conducted no later than June 12,2001. In this example, the system
conducted monitoring during July - December 2000 in which it was below the
copper action level. Therefore, the system meets the (b)(3) criteria under the
LCRMR, and thereby the "deemed" criteria on December 31,2000
Answer 2
If the system had been below the copper action level during initial monitoring
that was conducted in 1992, it would have met the (b)(3) criteria under both the
LCR and LCRMR. The date that the system met the "deemed" criteria would
have been December 31, 1992.
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"Deemed" & "Done"
Determinations
Scenario
System serves 35,000 people
System has lead service lines
July- Dec. 31 1992: Pb 90th = 0.020 mg/L; Cu 90th = 1.2 mg/L
Dec. 15,1996: System installs CCT
Jan - June 1997: Pb 90th = 0.007 mg/L; Cu 90th = 0.8 mg/L
July to Dec 1997: Pb 90th = 0.007 mg/L; Cu 90th = 0.8 mg/L
May 15,1998: State designates OWQPs
1. Does the system meet the "deemed" criteria?
Yes, on 5/15/98, when the State sets OWQPs.
2. Does the system meet the "done" criteria?
Yes, also on 5/15/98.
3. What if it had exceeded the lead AL level during 1997?
No, the system would have been triggered into LSLR and would not be
"done" until LSLR completed or no longer required.
Answer 1
Any size system meets the "Deem" criteria when the State sets OWQPs.
Although the system in this example qualified as a (b)(l) system during follow-
up monitoring conducted after the installation of CCT, the bl reason code
should not be reported. Instead, the bl reason code is reserved for systems that
meet the (b)(l) criteria without installing treatment.
Answer 2
The system meets the "Done" criteria when the State set OWQPs unless:
1. The system is required to install source water treatment and has not
completed installing this treatment by the date the State designates
OWQPs.
2. The system is subject to lead service line replacement requirements and
has not completed these requirements by the date the State designates
OWQPs.
Answer 3
If the system had exceeded the lead action level in the monitoring that was
conducted after the system installed treatment, it would be triggered into LSLR.
The system in this instance would not be "Done" until it completed replacing
all of its LSLs or it no longer was subject to the LSLR requirements (i.e., below
the lead action level for 2 consecutive monitoring periods.)
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"Done" Determination
Scenario
System serves 500 people
Initial monitoring:
July - Dec. 1993: Pb 90th = 0.007 mg/L; Cu 90th = 1.2 mg/L
Jan - June. 1994: Pb 90th = 0.007 mg/L; Cu 90th = 1.1 mg/L
* Reduced monitoring during Aug 2001: Pb 90th = 0.008 mg/L; Cu 90th
Monitoring after CCT installation:
Jan - June 2004: Pb 90th = 0.006 mg/L; Cu 90th = 0.7 mg/L
July- Dec2004: Pb90th = 0.007mg/L; Cu 90th = 0.6 mg/L
* May 1,2005: State designates OWQPs
1.5 mg/L
1. Does the system meet the "Done" criteria?
June 31,1994 Done, meets (b)(1) criteria
Aug 2001 Undone because exceeds copper AL
May 1, 2005 Done, State sets OWQPs.
Answer
This example illustrates a system that met the "Done" criteria but because of a
subsequent exceedance no longer meets the "Done" criteria. In this example,
the system first met the "Done" criteria during initial monitoring that was
conducted during 1993 and 1994 because it was below the lead and copper
action level for 2, consecutive, 6-month monitoring periods (i.e., it was a (b)(l)
system). During reduced monitoring that was conducted during August 2001,
the system exceeded the copper action level. The system no longer qualified as
a (b)(l) system.
The system again met the "Done" criteria when the State set OWQPs. If the
system had continued to exceed the copper action level after the installation of
treatment, the system would still meet the "Done" criteria. A copper
exceedance does not trigger LSLR requirements and therefore, the setting of
OWQPs represents the latest event that qualifies as system as being "Done".
States need to keep track of changes in a system's "Done" status.
SI
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Supplemental Information
> Key Points for Determining Compliance with OWQPs A-l
* Compliance with OWQPs - Examples A-2
* Compliance with OWQPs - Solutions A-24
* Summary of Changes to System Reporting Requirements A-35
» Comparison of Required Reporting for Milestones and 90th A-38
Percentile Levels under the LCR and LCRMR
+ Revisions to Reporting for Lead and Copper Violations A-39
+ Schedule for Reporting Revised Milestones, Lead 90th A-41
Percentile Data, and Consolidated Violations
+ Basis for Determining that a System is "Deemed" to have A-42
Optimized Corrosion Control Treatment
+ Changes to the Violation Reporting Requirements A-43
+ Revised Definition of Compliance Achieved by Violation A-46
Type
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Key Points for Determining Compliance with OWQPs
A "daily value" is calculated for each WQP and each sampling point
separately. You must also consider all sampling points collectively
to determine if the system is in compliance.
The procedure for determining the "daily value" of a WQP is based
on how often the system collects samples for that WQP at a
sampling location.
Compliance determinations are always based on a 6-month period,
regardless of the monitoring schedule.
To remain in compliance, a system cannot be outside the OWQP
ranges or below the OWQP minimum for more than a total of 9 days
during a 6-month period. The 9 days need not be consecutive.
Confirmation samples are no longer used, but the results of all
samples collected during the 6-month period at sites used to assess
compliance with OWQPs must be reported and used in determining
compliance.
To determine the beginning date of an excursion, use the date the
sample was collected and not the date the system or State received
the results.
To determine the duration of the excursion, do not count the day the
sample meets the OWQP specifications. This sample must be for
the same WQP and at the same sampling point for which the
excursion occurred.
Count multiple excursions that occur on a single day as one
excursion.
A-l
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293
Compliance with OWQPs
EXAMPLES
Example 1: How To Determine Compliance At Different
Monitoring Locations And For Different WQPs
Example 2: How To Determine Compliance When Additional
Samples Are Not Collected In A Monitoring Period
Following An Excursion
Example 3: How To Calculate Daily Values When A System
Monitors More Frequently Than Daily At A Sampling
Locations
Example 4: How To Determine Compliance When A System
Monitors Annually At A Sampling Location
Example 5: How To Determine Compliance When A System
Monitors Triennially At A Sampling Location
Example 6: How To Determine Compliance For A System That
Operates Seasonally
Example 7: How To Determine Compliance for A Small or
Medium System with Intermittent Exceedances
A-2
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294
EXAMPLE 1: How To Determine Compliance
At Different Monitoring Locations And For Different WQPs
EXAMPLE DESCRIPTION
Purpose of this example: This example is the most detailed of the 7 examples included in this
handout. The purpose of this example is to demonstrate how to determine compliance for
different monitoring frequencies and to provide a total compliance picture for one system during
a 6-month compliance period. It is also designed to emphasize that you must evaluate each
sampling point and each WQP independently, and then look at all excursions collectively to
determine whether the system is in compliance with its OWQP requirements.
Compliance Period: January - June 2001
System description: The system has 1 entry point and 1 distribution ("tap") site. It monitors
biweekly at its entry point and eveiy six months at its tap site. The system's treatment is pH &
alkalinity adjustment, using lime & sodium bicarbonate.
State Action: The State designates the following OWQPs:
pH = 7.5 at entry point
= 7.2 at tap site
alkalinity (mg/L as CaCO3) = 40 at entry point
= 35 at tap
MONITORING RESULTS
A. Entry Point Monitoring pH Results
This portion of the example shows how to determine compliance for pH at the system's entry point.
Please note in the table below that the system sampled more frequently than biweekly following an
excursion. These results were also used to determine compliance. Each value below the OWQP pH
minimum of 7.5 is shown in bold. This format is similar for all examples.
Entry Point pH Results for the 6-month Monitoring Period of January - June 2001
State-specified pH minimum = 7.5
Collection.
Date
Jan. -3
Jan. 17
Jan. 31
Feb. 14
Feb. 28
Result =
Daily value
8.1
8.2
7.8
7.8
7.2
. Collection
-!;0atie::r'v ;
March 3
March 13
March27
March 29
April 10; ,
Result =
Daily value
7.6
7.8
7.0
7.9
7.6
Collection
' "&#&'"' ";
AprIJ28
May8
May 22
JuneS
June. 19
Result =
Daily value
7.8
7.8
7.8
8.2
7.8
A-3
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295
REMEMBER: To determine the total number of days for which the system had excursions:
1. Count the first day the sample is below the pH minimum value. Use the date the sample was
collected and not the date the sample results were received.
2. Stop counting when a sample result from the same location and for the same parameter is at or
above the minimum (in this example a sample taken from the entry point and measured for pH).
Do not count the day the sample is at or above the pH minimum value in the calculation.
3. Repeat this procedure for each pH reading that falls below the pH minimum value (or 7.5 in this
example).
Q: How many days was the pH < 7.5 at the entry point? Use the table below to assist you.
Number of Days that the System Had Excursions
Collection Date of Sample That Began the Excursion
Total Number of Days with Excursions
Number of Days with Excursions
B. Distribution (Tap) Monitoring pH Results
This part of the example demonstrates how to determine compliance at the system's distribution (or tap)
sampling location. The system is on semi-annual monitoring and at a minimum is required to collect two
sets of tap samples at each location. The pH monitoring results are shown in the table below.
Distribution Sample pH Results for the 6-month Monitoring Period of January - June 2001
State-specified pH minimum = 7,2
Date
- Jan. 17
)..., May 22 !
,,. May,23
Result = Daily Value
8.1
6.8
6.9
Date
':.., May-24 : -:;
May 25
";::--- May '.26 **'^:\
Result = Daily Value
7.0
7.1
8.0
Q: How many days was the pH < 7.2 at the tap? Use the table below to assist you.
Number of Days that the System Had Excursions
Collection Date of Sample That Began the Excursion
Total Number of Days with Excursions
Number of Days with Excursions
A-4
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C. Entrv Point Monitoring Alkalinity Results
This part of the example demonstrates how to assess compliance for alkalinity at the system's entry point.
The procedure is the same as that shown in Part A.
The following table shows the alkalinity results for samples collected at the entry point.
Entry Point Alkalinity Results For January - June 2001
State-Specified Alkalinity minimum = 40 mg/L as CaCO3
Collection Date
!« '-Ian.- 3 V:'*
Jan. 17
Jan.:31 v '*
Feb. 14
:: W.: ' ' :-
.';-^Feb^:-28;.:.:.'Ci::-
:::.;. .:. -.:..:. ; :/ .-.:"
': -':₯: : ' ".V ::
March 3 :
Result =
Daily Value
45
42
45
41
35
55
Collection
Date
";;::- Marchis
March 27
v ; MarehpZSt
: April 10
£...;; /April. :fl; .- . . ;.
April 24
Result =
Daily Value
50.
35
45
32
45
43
Collection Date
'' 'May 8
May 22 ;
; May 23 ,';B
May 25
.; .. ;.:,-June:.5 :U
-June 19
Result =
Daily Value
45
32
33
45
40
42
Q: How many days was the alkalinity concentration < 40 mg/L as CaCO3 at the entry
point? Use the table below to sissist you.
Number of Days that the System Had Excursions
Collection Date of the Sample That Began
the Excursion
Total
Number of Days with Excursions
Number of Days with Excursions
A-5
-------
297
D. Distribution (Tap) Monitoring Alkalinity Results
This part of the example demonstrates how to assess compliance for alkalinity at the tap monitoring
location. The procedure is the same as that shown in Part C. It is included to emphasize that you must
evaluate each sampling location independently [See §141.82(g)].
The table below contains the alkalinity sample results from the distribution sampling location.
Distribution (Tap) Alkalinity Results For January - June 2001
State-Specified Alkalinity Minimum = 35 mg/L as CaCO3
: Collection; Date, .' .
....... : ::
;'''..;,' ",Jan.:17:,j. ,.:-;;'
:|fV;i,-:;&ay:22:":;Vs-. .
'"", May 23
Result = Daily Value
40
25
30
/Gollectiqii Date
'.V<,Y>.May,-24. U.,'
-.'.'.- ':May.;25..', ;'»':*
May<26
Result = Daily Value
34
30
38
Q: How many days was the alkalinity concentration < 35 mg/L as CaCO3 at the tap?
Use the table below to assist you.
Number of Days that the System Had Excursions
Collection Date of the Sample That Began
the Excursion
Total Number of Days with Excursions
Number of Days with Excursions
A-6
-------
298
E. Overall Compliance with Optimal WOPs
Q: Is the system in compliance for January to June 2001 with its OWQPs?
Use the following table to summarize the system's compliance with OWQPs.
Indicate excursions with a checkmark.
Example System 1
Overall Compliance with WQPs for January - June 2001
Day w/ excursion
Entry Point
pH
alkalinity
Tap
pH
alkalinity
Total Number of days w/ excursions =
Hint: Multiple excursions that occur on the same day are only counted once.
check that you have completed your tables correctly, refer to pages A-25
and A-26.
A-7
-------
299
EXAMPLE 2: How To Determine Compliance When Additional Samples Are Not Collected
In A Monitoring Period Following An Excursion
EXAMPLE DESCRIPTION
Purpose of this example: This example emphasizes that an excursion continues for a given
WQP and monitoring location until the system collects a sample at the same location and for the
same WQP that is within the OWQP range or above the minimum set by the State.
Compliance Period: January - June 2000
System description: This example focuses on the pH results at a system's two tap monitoring
sites. The State designates a minimum pH of 7.2 for both tap sampling points. The system is on
semi-annual schedule for WQP tap monitoring.
MONITORING RESULTS
Distribution (Tap) Monitoring Alkalinity Results
The following table contains the pH sample results from the two distribution sampling locations.
Entry Point pH Results For The 6-month Monitoring Period of January - June 2000
State-specified pH minimum = 7,2
Tap Sampling Point 1
-Date
"t »' Jjandi?' -.
- : . :.. ..> . - -
|:-rr- v ^ay|22> ":,
May;23
May;:24
s""' '"' 'May-:25 '{
May26
Result = Daily Value
8.1
6.8
6.9
7.0
7.1
8.0
Tap Sampling Point 2
Date
-------
300
Q: How many days was the pH < 7.2 at Tap Sampling Point If Use the table below to assist
you.
Number of Days that the System Had Excursions At Tap Sampling Point 1
Collection Date of Sample That Began the Excursion
Total Number of Days with Excursions
Number of Days with Excursions
Q: How many days was the pH < 7.2 at Tap Sampling Point 2? Use the table below to assist
you.
[Hint: The system's last measurement at Tap Sampling Point 2 was below the minimum pH value, so
each subsequent day that the system did not collect a sample was an excursion. Remember, that the
system could not use the sample collected on May 26* at Tap Sampling Point 1 to demonstrate that the
system was above the pH minimum at Tap Sampling Point 2. Each sampling point is evaluated
independently. A sample collected at one location cannot be used to demonstrate compliance at a
different sampling point.]
Number of Days that the System Had Excursions At Tap Sampling Point 2
Collection Date of Sample That Began the Excursion
Total Number of Days with Excursions
Number of Days with Excursions
solution to this example, refer to page A-27.
A-9
-------
301
EXAMPLE 3: How To Calculate Daily Values When
A System Monitors More Frequently Than Daily At A Sampling Location
EXAMPLE DESCRIPTION
Purpose of this example: The purpose of this example is to describe how to calculate daily values
when a system collects more than one sample per day. This example focuses on the pH reading at
one sampling location.
System description: The system installs an in-line pH meter to record its entry point pH levels.
The State-specified pH minimum for this system is 7.5. The system records these levels 3 times per
day. The results shown in the table below are for July only.
MONITORING RESULTS
Entry Point pH Results For The Month of July 2000
State-specified pH minimum = 7,5
Datejp
7/i/00: :
7/2/obfc
7/3/60
7/4/00
. 7/5/00: ;i
'7/6/00 ;;
7/7/00
V;7/8/OOJ
7/9/00-
7/iO/OO ;
:7/l:lWl
7/12/00
7/l3/OQ:
7/14/00 '
7/15/00
7/16/00
pH Measurements
8.1
7.9
8.1
7.9
8.1
8.1
8.2
7.8
7.8
7.3
7.9
8.2
6.8
6.7
8.3
8.2
8.0
8.0
7.9
8.2
8.0
7.9
8.1
7.8
7.7
7.6
7.9
8.0
7.4
7.4
8.2
8.0
8.0
8.0
7.9
8.0
7.9
8.0
7.7
7.8
7.6
7.2
8.0
7.9
6.7
6.8
8.2
8.0
Daily value
8.0
8.0
8.0
8.0
8.0
8.0
7.9
7.8
7.7
7.3
8.0
8.0
6.9
7.1
8.2
8.1
.|E>ate-.. i
7/17/00
7|l«p-'
7/19/00
7/20/00
:7/2ipO
7/22/00
7/23/00
.7/24?00;:i
7/25/00
7/26/00
7/27/00
7/28/00
7/29/00
7/3:0/00
7/31/00
---
pH Measurements
7.8
7.9
7.9
8.1
7.9
8.0
8.1
8.1
7.9
8.0
7.9
8.0
7.9
7.9
8.1
8.1
8.6
8.0
8.1
8.0
8.1
8.1
7.8
8.0
7.9
8.1
8.0
7.9
8.0
8.0
8.1
7.8
8.0
8.0
8.0
8.0
8.0
8.1
7.9
8.1
7.9
7.9
7.9
8.1
8.0
Daily value
8.0
8.0
8.0
8.1
8.0
8.0
8.0
8.0
8.0
8.0
8.0
8.0
7.9
8.1
8.0
A-IO
-------
302
The daily value is calculated by averaging the results of each pH sample collected during the day. This
includes any additional samples that the system conducts to assess/fix the problem. The State has the
discretion to delete the results of obvious sampling errors from the calculation. Please note that to calculate
the "true" pH average, pH is converted to the hydrogen ion concentration, averaged, and then the average is
converted back to pH. However, straight averaging of pH samples (as shown in this example) is acceptable
for assessing compliance. Systems that take multiple samples per day are not expected to experience large
fluctuations in pH. The two methods for calculating pH yield similar averages when the pH readings that
are being averaged fail within a limited range.
Remember: You may develop a different formula for
determining compliance when multiple samples are
collected at the same location and on the same day if you
have outlined this procedure in your primacy package and
this alternate formula is approved by EPA.
Q: How many days was the pH < 7.5 at the entry point during the month of July? Use the
table below to assist you.
Number of Days that the System Had Excursions in July for pH At the Entry Point
Collection Date of Sample that Began the Excursion
Total Number of Days with Excursions
Number of Days with Excursions
3
-
To determine whether the system is in compliance during the entire July through December 2000 time
period, you must also consider whether there were any excursions during the months of August through
December. In this example, assume the system did not have any excursions for the four months of August
through November. However, this system had excursions during December. The pH monitoring results for
entry point samples for December are shown in the table on the next page.
A-ll
-------
303
Entry Point pH Monitoring Results For The Month Of December 2000
State-specified pH minimum = 7.5
V: :t>ate ' "|
12/1/00 ;
;i2/2/oo '-I
12/3/00 :
NL2/4700 J
12/5/00 'I
12/6/00
12/7/00
12/8/00
12/9/00
12/10/00
12/1 1/00
12/12/00
12/13/00
12/14/00
12/15/00
12/16/00
pH Measurements
8.1
7.9
8.0
8.2
7.5
8.1
8.0
7.9
7.9
7.9
7.4
7.4
7.4
7.6
7.5
8.0
8.0
8.0
8.0
7.9
8.3
7.5
8.1
7.9
7.9
7.8
7.3
7.4
7.3
7.2
8.2
8.0
7.9
8.0
8.1
8.1
8.2
8.0
8.1
7.8
8.0
7.6
7.4
7.4
7.6
7.2
8.1
8.0
Daily value
8.0
8.0
8.0
8.1
8.0
7.9
8.1
7.9
7.9
7.8
7.4
7.4
7.4
7.3
7.9
8.0
- ' v:I3ate:
12/17/00
J12WOO
12/19/00
; ,,12|2t)/pO ;.:
12/21/00
.12/22/00
12/23/00
\:12/2&QQ.<:
12/25/00 '
; 12/26/00
\ 12M/00
12/28/00
12/29/00
12/30/00
12/3!l:/00
._
pH Measurements
8.0
8.1
7.9
7.8
8.2
8.7
7.2
7.3
7.2
7.2
7.2
7.9
8.0
7.6
7.7
-
8.1
8.1
8.6
7.5
8.4
7.3
7.2
7.3
7.4
7.2
7.2
8.1
8.3
7.6
7.6
-
8.1
8.0
7.7
7.8
8.1
7.9
7.3
7.3
7.3
7.2
7.0
7.6
7.4
7.5
7.8
Daily value
8.1
8.1
8.1
7.7
8.2
8.0
7.2
7.3
7.3
7.2
7.1
7.9
7.9
7.6
7.7
Q: How many days was the pH < 7.5 at the entry point during the month of December? Use
the table below to assist you.
Number of Days that the System Had Excursions in December for pH At the Entry Point
Collection Date of the Sample That Began
the Excursion
Total Number of Days with Excursions
Number of Days with Excursions
=
=
A-12
-------
304
Q: Is the system in compliance for July - December 2000, assuming the system had no
excursions for other OWQPs or at other sampling sites? Use the table below to assist
you.
Number of Days the System Had
Excursions during July - December 2000
July
August
September
October
November
December
Total
«s"For the solution to this example, refer to page A-28.
A-13
-------
305
EXAMPLE 4: How To Determine Compliance When A System
Monitors Annually At A Sampling Location
EXAMPLE DESCRIPTION
Purpose of this example: This example illustrates how to determine the "daily value" for an entry
point, when monitoring is conducted annually. This example focuses on one parameter (alkalinity) for
one sampling location (within the distribution system).
System description: This example system is on annual WQP tap monitoring. The State has
designated an alkalinity minimum of 85 mg/L as CaCO3 at this sampling location. The monitoring
period for this system is January through December 2000.
MONITORING RESULTS
Distribution (Tap) Alkalinity Results
For January - December 2000
State-Specified Alkalinity Minimum = 85 mg/L as CaCO3
Date of Sample
March 8, 2000
June 28, 2000
Monitoring Results
(in mg/L as CaCO3)
90 mg/L
80 mg/L
Assume that the system had no excursions for other WQPs or at other sampling points.
The system elected to collect its two distribution ("tap") samples during the first half of the annual
compliance period of January - December 2000. (Remember, a system is required to collect two samples at
each of its sampling locations in the distribution system.) Compliance is still evaluated based on a 6-month
compliance period, even though the monitoring period is one year. Complete the following steps to
determine compliance:
Step 1: Divide the compliance period into 6-month periods.
Step 2:
Step 3:
In this example, the two compliance periods are January 1 through June 30,2000, and July
1 through December 31,2000.
Determine if the daily values are above the State-specified minimum.
Calculate the duration of the excursion.
A-14
-------
306
Questions
1. What are the "daily value(s)":
a. for January - June 2000?
b. for July - December? (Hint: If no monitoring is conducted during the 6-month period you are
evaluating, the daily value is the most recent sample collected during the previous monitoring
period.)
2. How many days did the system have excursions:
a. during the January through June compliance period?
b. during the July through December compliance period?
3. Is the system in compliance for:
a. the January through June compliance period?
b. the July through December compliance period?
4. If the system is out of compliance, what must this system do?
the solution to this example, refer to page A-29.
A-15
-------
307
EXAMPLE 5: How To Determine Compliance When
A System Monitors Triennially At A Sampling Location
EXAMPLE DESCRIPTION
Purpose of this example: This example demonstrates how to calculate compliance for a system on a
triennial WQP tap monitoring schedule. It focuses on one WQP (orthophosphate) at one distribution
sampling location.
System description: This system uses a phosphate inhibitor. The State has set a minimum
orthophosphate concentration of 0.5 mg/L at its tap sampling point. The system met its OWQPs at
each of its sampling locations and can now collect WQPs within its distribution system at a frequency
of once every three years. The three-year compliance period is January 1, 2000 through December 31,
2002. This system collects a sample on March 28, 2001.
A. Compliance Periods January - June 2000 and July - December 2000
As stated in the system description above, the system collected a sample on March 28, 2001. Thus, the
system has not conducted any monitoring during the compliance periods of January - June 2000 and July -
December 2000. Assume that the system has no excursions for the other WQPs at this site or at any of its
other monitoring locations.
Q: Is the system is in compliance for these two monitoring periods, assuming the system
had no excursions for other OWQPs or at other sampling sites?
Hint: Remember, if a system is on annual or triennial monitoring and no sample was collected during the
6-month period you are evaluating, the daily value is the most recent sample collected, even if it occurred in
an earlier 6-month period.
A-16
-------
308
B. Compliance Period January - June 2001
The system collected a sample on March 28,2001 that was below the orthophosphate minimum set by the
State, and therefore, had an excursion. Assume this system took additional samples during this compliance
period as follows:
Tap Orthophosphate Results for January - June 2001
State-specified orthophosphate minimum = 0.5 mg/L
Collection Date
March 28
March 29
Result
0.4 mg/L
0.4 mg/L*
* Result is average of 2 samples collected on
March 29th (1B = 0.2 mg/L; 2nd = 0.6 mg/L)
Collection Date
March 30
April 1
June 28
Result
0.7 mg/L
0.8 mg/L
0.4 mg/L
Q: Is the system in compliance for January - June 2001, assuming the system had no
excursions for other OWQPs or at other sampling sites? Use the table below to assist
you. Hint: Remember, all of the samples collected during this 6-month period must be considered in
the compliance assessment. Whenever, a system collects more than one sample in a day, the daily
value is the average of these samples. Also, ask yourself. Are there any unresolved excursions from
a previous monitoring period that I must consider?
Number of Days that the System Had Excursions for January - June 2001
Collection Date of the Sample That
Began the Excursions
Total Number of Days with Excursions
Number of Days with Excursions
=
-
A-17
-------
309
C. Compliance period July - December 2001
The system collected samples during this compliance period as follows:
Tap Orthophosphate Results for July - December 2001
State-specified Orthophosphate minimum = 0.5
Collection Date
July 2
September 30
October 1
October 2
October 3
Result
0.6mg/L
0.2mg/L
0.3mg/L
0.3mg/L
0.4mg/L
Collection Date
October 4
October 5
October 6
December 15
December 22
Result
0.4 mg/L
0.4mg/L
0.6 mg/L
0.5 mg/L
0.4 mg/L
Q: Is the system in compliance for July -December 2001, assuming the system had no
excursions for other OWQPs or at other sampling sites? Use the table below to assist
you.
Hint: Although the first sample collected during this compliance period was above the minimum (the
July 2nd sample), the system had an excursion during the previous period for which it never collected a
sample to demonstrate it met the OWQP for that sampling point. Until the system collected this sample,
it still has an excursion.
Number of Days that the System Had Excursions for July - December 2001
Collection Date of Sample That Started the
Excursion
Total Number of Days with Excursions
Number of Days with Excursions
=
=
=
A-18
-------
310
D. Compliance period January - June 2002
A system that is on reduced WQP tap, or lead and copper tap monitoring and that is out of compliance with
its OWQPs, no longer qualifies for reduced lead and copper or WQP tap monitoring. During the
compliance period of January - June 2002, the system will be on semi-annual monitoring and collecting
WQP samples at the standard number of sites. This does not impact the system's entry point monitoring
frequency which remains at a minimum of every two weeks.
Assume the system collects a sample on January 3rd and June 2nd. Both of these samples are above 0.5
mg/L.
Q: Is the system in compliance for January - June 2002, assuming the system had no
excursions for other OWQPs or at other sampling sites? Use the table below to assist
you.
Hint: The system had an excursion on December 22, 2001 and the system did not collect a sample that
demonstrated it was above the minimum value for orthophosphate at its entry point until January 3rd.
Number of Days that the System Had Excursions January - June 2002
Collection Date of Sample That Started the
Excursion
Total Number of Days with Excursions
Number of Days with
Excursions
=
E. Compliance period July - December 2002
Assume this system collects its two samples at this location on August 29* and October 31s" and both
samples are above 0.5 mg/L.
Q: Is the system in compliance for July - December 2002, assuming the system had no
excursions for other OWQPs or at other sampling sites?
the solution to this example, refer to pages A-30 through A-32.
A-I9
-------
311
EXAMPLE 6: How To Determine Compliance For
A System That Operates Seasonally
EXAMPLE DESCRIPTION
Purpose of this example: This example focuses on compliance determinations for seasonal systems.
This example illustrates how to calculate excursions if the 6-month compliance period includes
months when the system is not in operation. It focuses on one WQP (pH) at one sampling location
(entry point).
System description: This system is in operation during January 1 through March 31 of 2000 and
again in November 1 through December 31,2000. The State has set a pH minimum of 7.0 at the
system's one entry point.
MONITORING RESULTS
A. Monitoring Results for the Compliance Period of January - June 2000
Entry Point pH Results for The 6-month Monitoring Period of January - June 2000
State-specified pH minimum = 7.0
Collection Date
o 'f January i3 , :j
January; 16 i
-] fanuaryl20 ;-i
'February 2
Result = Daily Value
7.5
7.6
7.5
7.5
Collection Date
: . ' "-..
;: :Febrtiary 15::; ;v\
March 1
; March 14
March 28
Result = Daily Value
7.4
7.6
6.6
6.8
Q: Is the system in compliance for January - June 2000, assuming the system had no
excursions for other OWQPs or at other sampling sites? Use the table below to assist you.
Hint: For this system, you would not consider the time period of April 1 through June 30 in your
compliance assessment because the system closed on March 31. For a seasonal system, you do not
consider the days that the system is closed down and not delivering water when you are calculating the
length of an excursion.
Number of Days that the System Had Excursions for pH at the Entry Point During
January - June 2000
Collection Date of the Sample That Began
the Excursion
Total Number of Days with Excursions
Number of Days with Excursions
A-20
-------
312
B. Monitoring Results for the Compliance Period of July - December 2000
The table below shows the monitoring results for July through December 2000. Remember in this
example, the system reopened on November 1, 2000.
Entry Point pH Results for The 6-month Monitoring Period of July - December
2000
State-specified pH minimum = 7.0
Collection Date :
^November 3 ,
; 'jjifoyember 17 5
November 30 \
Result = Daily
Value
7.3
7.3
7.2
: Collection Date
December M
? December 1 3
December 27
Result = Daily Value
6.8
7.6
7.3
Q: Is the system in compliance for July - December 2000, assuming the system had no
excursions for other OWQPs or at other sampling sites? Use the table below to assist
you. Hint: Ask yourself, are there any unresolved excursion I must consider from a previous
monitoring period.
Number of Days that the System Had Excursions
Collection Date of the Sample That
Began the Excursion
Total Number of Days with
Excursions
Number of Days with Excursions
=
=
Hint: This system is in compliance if during the period of July - December 2000, if it had no more than 6
additional days in the monitoring period with excursions.
the solution to this example, refer to page A-33.
A-21
-------
313
EXAMPLE 7: How To Determine Compliance For
A Small or Medium System with Intermittent Exceedances
EXAMPLE DESCRIPTION
Purpose of this example: This example focuses on compliance determinations for a small or
medium-size system that periodically exceeds the lead or copper action level. The system is not
required to monitor for WQPs during those monitoring periods in which it is below the action level.
This example illustrates how to calculate excursions if a system has monitoring periods in which it is
not required to collect WQPs. It focuses on one WQP (pH) at one sampling location (entry point).
System description:
System serves 25,000 people
It was above the lead action level in tap monitoring that was conducted during July -
December 2000.
It had excursions on December 29 - 31, 2000 for pH at Us entry point
It was below both action levels in all monitoring conducted during 2001 and 2002, and was
not required to conduct WQP monitoring.
It conducted lead and copper annual tap monitoring during September 2003, and exceeded the
lead action level.
The State set a pH minimum of 7.5 at the system's one entry point.
The system began collecting WQP entry point samples on October 2,2003.
MONITORING RESULTS
Monitoring Results for the Compliance Period of Julv - December 2003
Entry Point pH Results for The 6-month Monitoring Period of July - December 2003
State-specified pH minimum = 7,5
Collection Date :
October 3 ?
i., October,!? ..,
p 'October 31 '
, November 14
Result = Daily Value
7.7
7.6
7.7
7.7
Collection Date
Novemberls
December!!
December 24
Result = Daily Value
7.6
7.6
7.2
The LCRMR define the timing of a 6-month monitoring period for small and medium systems on reduced
lead and copper tap monitoring that are triggered into WQP monitoring because of an action level
exceedance. For these systems, the end of the six-month period for WQP monitoring is synchronized with
the end of the reduced lead and copper tap monitoring period during which an action level was exceeded. In
this example, the lead and copper tap reduced monitoring period ends on December 2003; therefore, the first
A-22
-------
. 314
6-month period for which compliance with OWQPs can be determined after the system exceeds the lead
action level is July - December 2003.
Q: Is the system in compliance for July - December 2003, assuming the system had no
excursions for other OWQPs or at other sampling sites? Use the table below to assist
you.
Hint: The unresolved excursions during December 2000 is not considered for this system. An
unresolved excursion from a previous monitoring period is not considered for a small or
medium-size system if the 6-month period you are evaluating was preceded by a 6-month
OWQP compliance period in which the system was not required to conduct WQP
monitoring because the system was below the lead and copper action levels. Therefore, in
this example do not consider October 1 - 3 as days with excursions for the monitoring
period of July - December, 2003. This is the only instance in which you do not consider an
unresolved excursion from a previous monitoring period.
Number of Days that the System Had Excursions
Collection Date of Sample that Began the Excursion
Total Number of Days with Excursions
Number of Days with Excursions
=
"s?For the solution to this example, refer to page A-34.
A-23
-------
315
Compliance with OWQPs
SOLUTIONS
»* Example 1: How To Determine Compliance At Different
Monitoring Locations And For Different WQPs
»^ Example 2: How To Determine Compliance When Additional
Samples Are Not Collected In A Monitoring Period
Following An Excursion
»* Example 3: How To Calculate Daily Values When A System
Monitors More Frequently Than Daily At A Sampling
Location
»* Example 4: How To Determine Compliance When A System
Monitors Annually At A Sampling Location
»* Example 5: How To Determine Compliance When A System
Monitors Triennially At A Sampling Location
»* Example 6: How To Determine Compliance For A System That
Operates Seasonally
»* Example 7: How To Determine Compliance for A Small or
Medium System with Intermittent Exceedances
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SOLUTION TO EXAMPLE 1
How To Determine Compliance
At Different Monitoring Locations And For Different WQPs
Q: How many days was the pH < 7.5 at the entry point?
5 days as shown in the table below.
Number of Days that the System Had Excursions At the Entry Point for pH
Collection Date of Sample That Began the Excursion
Feb. 28
March 27
Total Number of Days with Excursions
Number of Days with Excursions
Feb. 28 - March 2=3 days
March 27-28 = 2 days
5 days
Q: How many days was the pH < 7.2 at the tap?
4 days as shown in the table below.
Number of Days that the System Had Excursions At the Tap for pH
Collection Date of Sample That Began the Excursion
May 22
Total Number of Days with Excursions
Number of Days with Excursions
May 22-25 = 4 toys
4 days
Q: How many days was the alkalinity concentration < 40 mg/L as CaCO3 at the entry point?
9 days as shown in the table below.
Number of Days that the System Had Excursions at the Entry Point for CaCO3
Collection Date of the Sample That Began
the Excursion
Feb. 28
March 27
April 10
May 22
Total
Number of Days with Excursions
Number of Days with
Feb. 28 - March 2
March 27 & 28
April 10
May 22 - May 24
Excursions
= 3 days
= 2 days
= 1 day
3 days
9 days
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Q: How many days was the alkalinity concentration < 35 mg/L as CaCO3 at the tap?
4 days as shown in the table below.
Number of Days that the System Had Excursions At the Tap for CaCO,
Collection Date of the Sample That Began
the Excursion
May 22
Total Number of Days with Excursions
Number of Days with
May 22 - 25
Excursions
= 4 days
4 days
Q: Is the system in compliance for January to June 2001 with its OWQPs?
No. The system had excursions on more than 9 different days during the 6-month compliance period.
Remember, multiple excursions that occur on the same day are only counted once. In this example, the
system had multiple excursions on all but one day (see the table below). In each instance, all excursions
occurring on the same day are counted once.
Example System 1
Overall Compliance with WQPs for January - June 2001
(/ indicates an excursion)
Day w/ excursion
Feb. 28, 2001
Mar. 1, 2001
Mar. 2, 2001
Mar. 27, 2001
Mar. 28, 2001
Apr. 10, 2001
May 22, 2001
May 23, 2001
May 24, 2001
May 25, 2001
Entry Point
PH
/
/
/
V
V
alkalinity
V
/
/
V
/
V
/
V
V
Tap
PH
-
V
/
/
V
alkalinity
V
/
V
/
Total Number of days w/ excursions = 10 days
Note: A system can be in violation because of excursions at one sampling point for a specific OWQP. Also
note that multiple violations occur during the same 6-month period, only report 1 violation to SDWIS/Fed?
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SOLUTION TO EXAMPLE 2
How To Determine Compliance When Additional Samples Are Not Collected
In A Monitoring Period Following An Excursion
Q: How many days was the pH < 1.2 at Tap Sampling Point 1?
4 days as shown in the table below.
Number of Days that the System Had Excursions At the Tap for pH
Collection Date of Sample That Began the Excursion
May 22
Total Number of Days with Excursions
Number of Days with Excursions
May 22-25 = 4 days
4 days
Q: How many days was the pH < 7.2 at Tap Sampling Point 2?
39 days as shown in the table below. The duration of the excursion was from May 22nd to the end of the
6-month period or June 30 in this example. The system's last measurement at Tap Sampling Point 2 was
below the minimum pH value, so each subsequent day that the system did not collect a sample was an
excursion. More importantly, the system was out of compliance on 10th day of the excursion or May 31
in this example.
Number of Days that the System Had Excursions At the Tap for pH
Collection Date of Sample That Began the Excursion
May 22
Total Number of Days with Excursions
Number of Days with
May 22 - June 30 =
Excursions
40 days
40 days
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SOLUTION TO EXAMPLE 3
How To Calculate Daily Values When
A System Monitors More Frequently Than Daily At A Sampling Location
Q: How many days did the system have excursions during the month of July?
3 days, as shown in the table below.
Number or Days that the System Had Excursions for July
Collection Date of Sample that Began the Excursion
July 10
July 13
Total Number of Days with Excursions
Number of Days with Excursions
July 10
July 13 & 14 =
1 day
2 days
3 days
Q: How many days did the system have excursions during the month of December?
9 days, as shown in the table below.
Number of Days that the System Had Excursions for December
Collection Date of the Sample That Began
the Excursion
December 1 1
December 23
Total Number of Days with Excursions
Number of Days with
December 11-54
December 23-27
Excursions
4 days
5 days
9 days
Q: Is the system in compliance for July - December 2000, assuming the system had no excursions for
other OWQPs or at other sampling sites?
The system is out of compliance because it had excursions for a total of 12 days during the 6-month
monitoring period of July through December 2000, as follows:
Number of Days the System Had Excursions
during July - December 2000
July
August
September
October
November
December
Total
3 days
Odays
0 days
0 days
0 days
9 days
12 days
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SOLUTION TO EXAMPLE 4
How To Determine Compliance When A System
Monitors Annually At A Sampling Location
1. What are the "daily values":
a. for January - June?
During January - June, the system had two "daily values". One concentration of 90 mg/L as CaCO3
and one of 80 mg/L as CaCO3. The alkalinity concentration of the June 28th sample did not meet the
OWQP minimum and therefore, beginning on June 28, 2000, the system had an excursion.
b. for July - December?
During July through December 2000, no samples were collected. Therefore, the daily value is the most
recent sample collected during the previous monitoring period, or 80 mg/L in this example.
2. How many days did the system have excursions:
a. during the January through June compliance period?
For the January through June compliance period, the duration of the excursion is from June 28 to the
end of the compliance period (June 30, 2000). Therefore, the system had excursions on 3 days.
b. during the July through December compliance period?
For July through December, the duration of the excursion is from July 1 to the end of the compliance
period of December 3 1, 2000. Therefore, the system had excursions on 184 days.
3. Is the system in compliance for:
a. the January through June compliance period?
The system is in compliance, if it has no more than 6 additional days in the monitoring period with
excursions.
b. the July through December compliance period?
The system had excursions on more than 9 days. Therefore, for the compliance period of July
through December 2000, the system was not in compliance.
4. If the system is out of compliance, what must this system do?
1 . Report its noncompliance to you within 48 hours of becoming aware the violation.
2. Collect WQP samples in the distribution system every six months at the standard number of sites. In
addition, if the system was on reduced lead and copper tap sample, it must now monitor every six
months at the standard number of sites [See §141.87(e)(4)]. The first 6-month monitoring period
for standard WQP and lead and copper tap monitoring is January to June 2001 in this example.
The system can again qualify for reduced WQP tap and lead and copper tap monitoring if it again
meets it OWQPs for two, consecutive 6-month periods.
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SOLUTION TO EXAMPLE 5
How To Determine Compliance When
A System Monitors Triennially At A Sampling Location
1. Is the system in compliance during January through June 2000 and July through December
2000, assuming the system bad no excursions for other OWQPs or at other sampling sites?
Yes, the system is in compliance for these two monitoring periods, although it has not collected a
sample during either of these compliance periods. Remember, if a system is on annual or triennial
monitoring and no sample was collected during the 6-month period you are evaluating, the daily value is
the most recent sample collected, even if it occurred in an earlier 6-month period. As stated above in
the system description, the previous samples met the OWQP levels. In fact, the system could not be on
triennial WQP tap monitoring if it had not meet its OWQPs for 3 consecutive years.
2. Is the system in compliance during January - June 2001, assuming the system had no excursions
for other OWQPs or at other sampling sites?
Yes, the system is in compliance because it had excursions on 5 days during the 6-month compliance
period. The start of the excursion is on March 28th. The system still has an excursion on March 29*
because the average of the two samples collected on this date is 0.4 mg/L. Remember, all of the samples
collected during this 6-month period must be considered in the compliance assessment. Whenever, a
system collects more than one sample in a day, the daily value is the average of these samples, (unless
you have an outlined an alternative approach in your primacy revision package that has been
approved by EPA). The sample collected on March 30th is again above the minimum set by the State.
Thus, the duration of the first excursion is 2 days.
The system again has an excursion on June 28th and did not collect another sample during the period of
June 28 - 30. The duration of the second excursion is 3 days. The system is in compliance for the
monitoring period of January - June 2001 because the number of days with excursions did not exceed
9 days. The table below shows the number of days with excursions.
Number of Days that the System Had Excursions
Collection Date of the Sample That
Began the Excursions
March 28
June 28
Total Number of Days with Excursions
Number of Days with
March 28 & 29
June 28 - 30
Excursions
= 2 days
3 days
5 days
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322
3. Is the system in compliance during July through December 2001, assuming the system had no
excursions for other OWQPs or at other sampling sites?
No, the system is out of compliance because it had excursions on more than 9 days as shown in the
table below.
Number of Days that the System Had Excursions
Collection
Date of Sample That Started the Excursion
June 28
September 30
December 22
Total Number of Days with Excursions
Number
July
of Days with
1
September 30 -
December
22
Oct. 5 =
-31
Excursions
1
6
10
day
days
days
17 days
This system had three separate excursions during the compliance period of July through December 31,
2001. Although the first sample collected during this compliance period was above the minimum (the
July 2nd sample), the system had an excursion during the previous period for which it never collected a
sample to demonstrate it met the OWQP for that sampling point. Until the system collected this
sample, it still has an excursion. Because the system did not collect such a sample until July 2, it had
an excursion on July 1. The length of the excursion is counted from the beginning of the July to
December 2001 compliance period (or July 1s* in this example) until a sample is collected at this
sampling location that meets the OWQP minimum for orthophosphate (or July 2nd ).
The second excursion lasted from September 30* until October 5*. The third excursion lasted from
December 22nd to December 31st because the system did not collect a sample subsequent to the
December 22nd sample that demonstrated it met its OWQP for orthophosphate at this sampling
location.
4. Is the system in compliance during January through June 2002, assuming the system had no
excursions for other OWQPs or at other sampling sites?
The number of days that the system had excursions is summarized below.
Number of Days that the System Had Excursions
Collection Date of Sample That Started the
Excursion
December 22
Total Number of Days with Excursions
Number of Days with
Excursions
January 1-2 =2 days
2 days
The system has one excursion from January lsl to January 2nd because there is an outstanding excursion
from the previous compliance period. The system had an excursion on December 22, 2001 and the system
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323
did not collect a sample that demonstrated it was above the minimum value for orthophosphate at its entry
point until January 3rd. The length of the excursion is counted from the beginning of the January 1 to June
30, 2002 compliance period (or January Pl in this example) until a sample is collected at this sampling
location that meets the OWQP minimum for orthophosphate (or January 3rd). The length of the excursion
is 2 days. Thus, the system is in compliance if the system does not have excursions on more than 7 other
days for other WQPs at this location or for WQPs at its entry point sampling site.
5. Is the system in compliance during July - December 2002, assuming the system bad no excursions
for other OWQPs or at other sampling sites?
This system collected its two samples at this location on August 29th and October 31st and both samples are
above 0.5 mg/L. If the system has no more than 9 days widi excursions for its other WQPs or sampling
points, the system is in compliance. During this monitoring period, the system has no excursions for
orthophosphate at its tap sampling point. Further, if this system has been in compliance for all its WQPs
at each entry point and distribution sampling location for January through June 2002 and July through
December 2002, it can collect tap WQP samples at a reduced number during the monitoring period of
January - June 2003. The system may also reduce the frequency of lead and copper tap monitoring to
annually with written approval from the State.
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SOLUTION TO EXAMPLE 6
How To Determine Compliance For
A System That Operates Seasonally
Q: Is the system hi compliance for January - June 2000, assuming the system had no excursions for
other OWQPs or at other sampling sites?
The system is out compliance. The system had excursions on 18 days (March 14 through March 31.)
For this system, you would not consider the time period of April 1 through June 30 in your
compliance assessment because the system closed on March 31. For a seasonal system, you do not
consider the days that the system is closed down and not delivering water when you are calculating the
length of an excursion.
Number of Days that the System Had Excursions
Collection Date of the Sample That
Began the Excursion
March 14
Total Number of Days with
Excursions
Number of Days with
March 14-31
Excursions
18 days
18 days
Q: Is the system hi compliance for July - December 2000, assuming the system had no excursions for
other OWQPs or at other sampling sites?
Yes, this system is in compliance if during the period of July - December 2000, if it had no more than 6
additional days in the monitoring period with excursions. During July through December 2000, the
system had excursions on 3 days. The system was in operation and providing water on November 1.
The system had an excursion from the previous compliance period and did not collect a sample that
demonstrated that it was above the pH minimum until November 3. Therefore, the duration of the first
excursion was two days (i.e., November 1 and 2). The system was again below the pH minimum on
December 12. The system collected a sample on December 13 that showed it was above the pH
minimum set by the State. A summary of the excursions are shown below.
Number of Days that the System Had Excursions
Collection Date of the Sample That
Began the Excursion
March 28
December 12
Total Number of Days with
Excursions
Number of Days with
Nov. 1 & 2
December 12 =
Excursions
2 days
1 day
3 days
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SOLUTION TO EXAMPLE 7
How To Determine Compliance For
A Small or Medium System with Intermittent Exceedances
Number of Days that the System Had Excursions
Collection Date of Sample that Began the Excursion
December 24
Total Number of Days with Excursions
Number of Days with Excursions
Dec. 24-31
8 days
8 days
Q: Is the system in compliance for July - December 2003, assuming the system had no excursions for
other OWQPs or at other sampling sites?
During the compliance period of July 1 - December 31,2000, the system had 8 days with excursions.
The system is in compliance for the compliance period of July - December 2003, if it had no more than
1 other days with excursions for at any other sampling location, or for a different WQP at this sampling
location.
Remember: An unresolved excursion from a previous monitoring period is not considered for a small
or medium-size system if the 6-month period you are evaluating was preceded by a 6-month OWQP
compliance period in which the system was not required to conduct WQP monitoring because the
system was below the lead and copper action levels. This is the only instance in which you do not
consider an unresolved excursion from a previous monitoring period.
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326
Summary of Changes to System Reporting Requirements
Citation
LCR Requirement
LCRMR Requirement
Timing of reporting of tap water monitoring for lead and copper, and water quality parameter monitoring
§141.90(a)(l)
intro text
Required the system to report monitoring
data to the State for all tap water samples
within the first 10 days following the end of
each applicable monitoring period, as
specified in §§141.86, 141.87, and 141.88
(i.e., every 6 months, annual, and triennial).
Removes reference to §141.88 and revises
examples of "applicable monitoring periods"
to include a 9-year monitoring period for
monitoring waivers.
Elimination of certification requirements for first-draw samples/Adding sample invalidation documentation
§141.90(a)(l)(ii)
§141.90(aXD(iii)
Required the system to certify that each
sample collected by the system according to
§141.86(d) was one-liter in volume and had
stood motionless in the service line or in the
interior plumbing of a sampling site for at
least 6 hours (first-draw sample).
Required the system to certify that each tap
sample collected by residents was taken
after the system had informed residents of
proper first-draw sampling procedures.
Removes requirement for certification of
first-draw samples collected by the system.
Replaced with new requirement for
documentation to accompany sample
invalidation requests.
Removes requirement for certification of
first-draw samples collected by residents.
State calculation/reporting of9ffk percentUe lead and copper levels
§141.90(a)(l)(iv)
Required the system to report 90* percentile
lead and copper levels, calculated using all
lead and copper tap water samples collected
during each monitoring period.
Modified to NOT require reporting of 90*
percentile values from the system for whom
the State calculates the 90th percentile lead
and copper levels.
Reporting of WQP monitoring results
§141.90(a)(l)(viii)
N/A
Adds requirement for reporting WQP
monitoring results collected under
§ 14 1 .87(c)-(f). A system must report WQP
monitoring results to the State no less
frequently than 10 days after the end of each
six-month monitoring period, unless that
State has specified a more frequent reporting
requirement.
Eliminating justification of non-Tier J sites for CWSs/Adding Non-First Draw Documentation
§141.90(a)(2)
Required CWSs with insufficient Tier 1
sampling sites to send a letter to State
demonstrating why a sufficient number of
Tier 1 sites could not be located and
justifying its selection of Tier 2 and Tier 3
sites.
Removed requirement for CWSs to send
letter to State justifying its selection of non-
Tier 1 sites.
Replaced with a new requirement for
NTNCWSs that cannot find enough first-
draw sampling sites to identify non-first-draw
sample times and locations.
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Summary of Changes to System Reporting Requirements
Citation
LCR Requirement
LCRMR Requirement
Eliminating justification of non-Tier 1 sites for NTNCWS/Adding Reporting Requirements for Change in
Treatment or Addition of New Source for Systems on Reduced Lead and Copper Tap Monitoring.
§141.90(a)(3)
Required NTNCWSs to send a letter to the
State demonstrating why a sufficient
number of Tier 1 sites could not be located.
Removed requirement for NTNCWSs to send
letter to State demonstrating why a sufficient
number of Tier 1 sites could not be located.
Replaced with a new requirement for systems
monitoring at the tap less frequently than
once every 6 months to notify the State
within 60 days if there are any changes in
treatment of addition of a new source water.
Eliminating justification for insufficient lead service line sampling sites/Adding reporting requirements for
monitoring waivers
§141.90(aX4)
Required the system to send a letter to the
State demonstrating why 50% of sampling
sites are not served by lead service lines.
Removed requirement to send letter to State
demonstrating why 50% of sampling sites are
not served by lead service iines.
Replaced with new reporting requirement for
small systems requesting a monitoring
waiver.
Eliminating request for reduced monitoring/Adding demonstration of representative entry point WQP
monitoring
§141.90(a)(5)
Required the system to explicitly request
State approval to begin reduced monitoring,
after installing corrosion control and
maintaining the range of values for WQPs
reflecting OCCT.
Removed reporting requirements associated
with requesting reduced monitoring.
Replaced with new reporting requirement
demonstrating representative locations for
biweekly entry point water quality parameter
monitoring after the installation of corrosion
control treatment
Replacement schedule for lead service lines
§141.90(e)(2)
Requirements for schedules for replacing
lead service lines was contained in
§141.84(f).
Requirements for schedules for replacing lead
service lines is now contained in §141.84(e).
Revised all references to "§14l.84(f)" to read
"§141.84(e)"
Control of lead service lines
§141.90(e)(4)
Required systems seeking to rebut
presumption of control of entire length of
LSL to send a letter to the State
documenting the legal authority limiting the
system's control of the LSLs and the extent
of the system's control.
Removed reporting requirements associated
with rebutting presumption of control of
entire length of LSL.
Adds new requirement for systems collecting
LSL samples after partial lead service line
replacement to report results to the State.
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Summary of Changes to System Reporting Requirements
Citation
LCR Requirement
LCRMR Requirement
Public education reporting
§141.90(f)
Required the system required to perform
public education to send a letter to the State
by December 31" demonstrating that public
education was properly performed.
Revised deadlines for reporting completion of
public education tasks. Reporting is now
required more frequently than once a year,
improving timeliness of notification.
Reporting lead and copper levels for the system for whom the State calculates 90* percentile values
§141.90(h)
N/A
Adds new requirement for reporting all lead
and copper concentrations for those systems
for whom the State is calculating die system's
90th percentile levels.
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Comparison of Required Reporting for Milestones
and 90th Percentile Levels under the LCR and LCRMR
Milestone
Code
CU90
PB90
N/A
CCSR
ccsc
OTDE
STDE
OTIN
STIN
WQPS
MPLS
LSLR
DEEM
DONE
Description
Copper action level exceedance
Lead action level exceedance
90* percentile lead levels that are below the lead action level
System that is required to conduct a corrosion control study
System that has completed a corrosion control study
System in which the State has designated or approved optimal
corrosion control treatment (OCCT)
Indicates a system in which the State has designated or approved
source water treatment (SOWT)
Indicates a system mat has installed OCCT
Indicates a system that has installed SOWT
Indicates s system in which the State has designated or approved
ranges for water quality parameters (WQPs)
Indicates a system in which the State has designated or approved
maximum permissible levels (MPLs) for lead and copper in source
water
Designates a system that is required to conduct Lead Service Line
Replacement
Indicates a system for which the State has:
(I) designated optimal water quality parameters under §141 .82(f)
(includes systems deemed to have optimized treatment under
§I41.8i(b)(2)),OT
(2) deemed to have optimized corrosion control under
§14!.81(b)(l) or (b)(3)
Completed all applicable corrosion control, source water treatment,
and lead service line replacement requirements
Required to be reported under:
LCR?
Yes
Yes
No*
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
LCRMR?
Yes, but to be
reported as a sample
record
Required for large &
medium systems
No
No
No
No
No
No
No
No
Yes, but no longer
required to report
replacement rate
Yes
Yes
*The LCR did not require States to report any 90* percentile levels below the action level (i.e., non-exceedances).
However, in the 1992 LCR reporting guidance, EPA requested that States report the 90th percentile lead non-
exceedances for all large systems, and for medium and small systems once they exceeded the lead action level.
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330
Revisions to Reporting
for Lead and Copper Violations
Old Requirements
Violation
Type
Code
51
52
53
54
55
56
57
58
59
60
61
62
Description
Initial Lead and Copper
TapM/R
Follow-up or Routine
Lead and Copper Tap
M/R
Initial Water Quality
Parameter (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
Optimal Corrosion
Control Treatment
Study/ Recommendation
Optimal Corrosion
Control Treatment
Installation/Demonstrati
on
WQP Entry Point
Noncompliance
WQP Tap
Noncompliance
Source Water Treatment
Recommendation
Source Water Treatment
Installation
Revised Requirements
Violation
Type
Code
51
52
53
56
57
58
59
57
58
Description
Initial Lead and Copper
Tap M/R
Follow-up or Routine Lead
and Copper Tap M/R
WQP M/R
Initial, Follow-up, or
Routine Source Water M/R
Treatment Study/
Recommendation
Treatment Installation /
Demonstration
WQP Entry Point or Tap
Treatment Technique
Noncompliance
Treatment
Recommendation
Treatment Installation/
Demonstration
Change in Reporting
Requirement
Violation begin and end
dates'
Violation begin and end
dates'
Combined violation types 53,
54, & 55 under code 53
Violation begin and end
dates2
Violation begin and end
dates'
Combined violation types 57
&61 under code 57
Violation begin and end
dates'
Combined violation types 58
& 62 under code 58
Violation begin and end
dates2
Combined violation types 59
& 60 under code 59
Violation begin and end
dates2
Combined violation types 57
&61 under code 57
Violation begin and end
dates'
Combined violation . types
58 & 62 under code 58
Violation begin and end
dates1
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33.1
Revisions to Reporting
for Lead and Copper Violations
Old Requirements
Violation
Type
Code
63
64
65
Description
Maximum Permissible
Level Noncompliance
Lead Service Line
Replacement (LSLR)
Public Education
Revised Requirements
Violation
Type
Code
63
64
65
Description
Maximum Permissible
Level Noncompliance
Lead Service Line
Replacement
Public Education
Change in Reporting
Requirement
Violation begin and end
dates'
Violation begin and end
dates'
Violation begin and end
dates1
' . The begin date is the day after the requirement was to occur. The end date is defaulted by SDWIS/FED to December
31, 2015. The return to compliance date or "no-action" date (proposed) replaces the defaulted December 31, 2015.
This change will better characterize the period of time in which a system is in violation.
1 The begin date is the first day of the compliance period and the end date is the last day of the compliance period.
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Schedule for Reporting Revised Milestones,
Lead 90th Percentile Data, and Consolidated Violations
Prior to May 15,2000
May 15, 2000 to January 1 1,
2002
January 12, 2002 and thereafter
States must continue to report the requirements described in the 1992
reporting guidance, (i.e., the 15 violation types and 1 1 milestones)
States have the option to:
continue to report the requirements under the 1991 LCR
or
report in accordance with the new requirements under the
LCRMR:
- all lead 90th percentile levels for large and medium systems
- lead 90* percentile exceedance for small systems
- copper 90* percentile exceedances for all systems
- streamlined LSLR milestone
- Done and Deemed milestones (Initial - deemed and done
requested by February 15, 2001)
- the 1 0 consolidated violation codes (i.e., DO NOT USE
codes 54, 55, 60, 6 1,& 62)
- the end date of 12/3 1/20 1 5 for all violations except WQP
TT non-compliance violations - 59
- 6 month WQP non-compliance periods for 59 violations
States must report in accordance with all new LCRMR requirements
Note: The LCRMR do not change the frequency of reporting. States are still required to report 90"1
percentile levels, milestones, and violations quarterly.
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333
Basis for Determining that a
System is "Deemed" to have Optimized Corrosion Control Treatment
C817 Code
Value
Bl
WQP
B3
Description
Deemed according to criteria in §141.81(b)(l). Applies
to a system serving 50,000 or fewer people that has met
the lead and copper action levels during each of two
consecutive 6-month monitoring periods.
Systems for which the State has set optimal water
quality parameters.
Applies to any water system:
1. any water system which the State has determined
(DEEMED) has optimized corrosion control
treatment (before December 7,1992), based on
review of water quality parameters, a report on the
evaluation and selection of OCCT, a report on
OCCT installation and maintenance, and two
consecutive rounds of tap sample results, or
2. any water system for which the State has set optimal
water quality parameters.
Deemed according to criteria in § 141.81 (b)(3).
Applies to a system, with minimally corrosive water in
its distribution system, which demonstrates for two
consecutive 6-month periods that the difference
between the 90th percentile tap water lead level and the
highest source water lead concentration is less than
0.005 mg/L. Also, the LCRMR expands the definition
to include systems whose source water tead levels are
below the Method Detection Limit and whose 90*
percentile lead level is <. 0.005 mg/L. After January
12, 2000 system may not exceed copper action level.
Date Reported to SDWIS/FED
Day after the two consecutive
compliance periods in which the
system meets the (b)(l) criteria
Date State designates OWQPs
Day after the two consecutive
compliance periods in which the
system meets the (b)(3) criteria
Note: If a system meets the DEEM milestone criteria, it may be deemed to have optimized
corrosion control treatment, without actually being required to physically install
corrosion control treatment (as may be the case with a (b)(l) or (b)(3) system.)
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334
Changes to the Violation Reporting Requirements
INITIAL LEAD AND COPPER TAP M/R (Violation Code: 51)
Failure to meet any of the following:
Use appropriate sampling procedures in accordance with §§141.86(a) and (b),
* Collect the required number of samples during the specified time frame in accordance with
§§I41.86(c)and(d)(l),
Ensure samples are analyzed properly in accordance with § I41.89(a), or
Submit all required monitoring information on time in accordance with § 141.90(a).
If these less stringent provisions are adopted into your revised drinking water regulations, the LCRMR
expand the definition to include systems that:
Did not meet replacement sample requirements for invalidated samples as described in § 141.86(f)(4)
where these samples are needed to meet minimum sampling requirements;
Did not meet the conditions of their monitoring waivers in § 141.86{g) or provide required information
in§§141.90(a)(4)(ii)-(iv),
Did not provide sample information needed for you to perform the 90* percentile calculation as
outlined in §141.90(h); or
Collected non-first draw samples that did not meet the criteria in § 141.86{b)(5).
NOTE: This violation type is no longer applicable for most systems and now only applies to new systems or
system that were not previously required to conduct lead and copper tap monitoring.
FOLLOW-UP OR ROUTINE LEAD AND COPPER TAP M/R (Violation Code: 52)
Failure to meet any of the following:
Use appropriate sampling procedures in accordance with § § 141.86(a) and (b),
Collect required number of samples during the required time frames in accordance with §§141.86(c)
&(d)(2>(4),
Ensure samples are analyzed properly in accordance with §141.89(a), or
Submit all required monitoring information on time in accordance with § 141.90(a).
The LCRMR expand the definition to include:
Those new monitoring provisions listed above, under the initial tap "Less stringent provisions" (e.g.,
sample invalidation, non-first draw samples, State calculation of 90* percentile values, and monitoring
waiver compliance)
Systems on reduced monitoring which fail to report a change in treatment, or an addition of a new
source, widiin 60 days or within ihe time frame which you specify (violation type code 52).
Systems on reduced monitoring, and placed on alternate lead and copper tap schedules, which do not
meet the monitoring deadline when transitioning to the alternate period, if your regulations include
this provision (violation type 52).
INITIAL, FOLLOW-UP, OR ROUTINE WQP M/R (Violation Code: 53)
Failure to meet any of the following:
Use appropriate sampling procedures in accordance with §§141.87(a)(l), (b)-(e);
Collect required number of samples in accordance with § 141.87(a)(2) or (e);
Ensure samples are analyzed properly in accordance with § 141.89(a); or
Submit all required monitoring information on time in accordance with § 141,90(a)
If this less stringent provision is adopted into your revised drinking water regulations, the LCRMR
expand the definition to include ground water systems that:
Did not meet their State-approved sampling plan for collecting WQPs at representative entry point
locations in accordance with §§141.87(a)(5) & (c)(2).
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335
Changes to the Violation Reporting Requirements
INITIAL, FOLLOW-UP, OR ROUTINE SOURCE WATER M/R (Violation Code: 56)
Failure to meet any of the following:
Use appropriate sampling procedures in accordance with §§141.88(a)(l) and (2);
Collect required number of source water samples in accordance with §§ 141.88(a)(l) - (e);
Ensure samples are analyzed properly in accordance with § 141.89(a); or
Submit all required sampling information on time in accordance with § 141.90(b).
OPTIMAL CORROSION CONTROL TREATMENT (OCCT) STUDY/ RECOMMENDATION or
SOURCE WATER TREATMENT (SOWT) RECOMMENDATION (Violation Code: 57)
For an OCCT Study/Recommendation violation, failure to meet any of the following:
Submit an OCCT recommendation on time in accordance with §§141,82(a) and 141.90(c)(2);
Submit an "acceptable" study on time in accordance with §§141.82(c) and 141.90(c)(3); or
Provide additional information needed by the State to make an OCCT determination in accordance
with§141.82(d)(2).
For an SOWT Recommendation violation, failure to meet the following:
Submit a SOWT recommendation within 6 months of exceeding the action level in accordance with
§§141.S3(a)(l)&141.90(d)(l).
OCCT INSTALLATION/DEMONSTRATION or SOWT INSTALLATION (Violation Code: 58)
For an OCCT Installation violation, failure to meet any of the following:
Have the State-designated treatment properly installed and operating in accordance with § J 41.82(e),
* Submit a certification of proper installation and operation in accordance with §141,90(c)(4), or
Demonstrate that OCCT already exists in accordance with §§141.81 (b)( 1 )-(3) and 141.90(c)(l).
For an SOWT Installation violation, failure to meet any of the following:
Properly install and operate SOWT in accordance with §§141 -83(b)(3) and (5), or
Submit certification to the State of proper SOWT installation and operation, in accordance with
§141.90(dX2).
WQP ENTRY POINT or TAP NONCOMPLIANCE (Violation Code: 59)
Failure to:
Maintain OWQP minimum or ranges in accordance with §141.82(g).
If the revised definition for OWQP compliance is adopted into your revised drinking water regulations,
the LCRMR expands the definition to include failure to:
Meet daily values for more than 9 days in a 6-month monitoring period in accordance §141.82(g).
MAXIMUM PERMISSIBLE LEVEL (MPL) NONCOMPLIANCE (Violation Code: 63)
Failure to:
Meet either State-designated or approved MPL in accordance with §141.83(b)(5).
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336
Changes to the Violation Reporting Requirements
LEAD SERVICE LINE REPLACEMENT (Violation Code: 64)
Failure to meet any of the following:
Replace the required amount of LSLs by the annual deadline, in accordance with §§141.84(a) & (b);
or
Report the required LSL information on time, in accordance with § 141.90(e) that demonstrates that
the replacement rate was met.
In cases of where the system does not replace the entire LSL (i.e., "partial LSLR replacement")? the
LCRMR expand the definition to include failure to:
provide notice and guidance to residents at least 45 days before LSLR begins (unless you allow a
shorter notification period);
collect a tap sample within 72 hours of completing the partial LSLR;
* mail and/or post results of the analysis to the owner and residents within 3 days of receipt of the
results; or
report information that you deem necessary to assess whether the system met its partial LSLR
monitoring and notification requirements.
PUBLIC EDUCATION (Violation Type: 65)
Failure to meet any of the following:
Provide public education that meets the content requirements in § § 141.85(a) & (b);
Meet the public education delivery requirements of § 141.85(c).
Report required public education information on time, within 10 days after the end of the period in
which public education was required, in accordance with §141.90(f).
Notes:
(l)Under the LCRMR, some requirements for small CWSs are optional, if you adopt these provisions into your
State regulation.
(2)The LCRMR revised the reporting schedule. Under the LCR, a system was required to submit one letter by
December 31" of each year in which it was subject to public education requirements.
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337
Revised Definition of Compliance Achieved by Violation Type
Criteria for Return to Compliance
Change Resulting from LCRMR
INITIAL LEAD AND COPPER TAPM/R (Violation Code: 51)
System meets M/R requirements, during subsequent compliance
period(s), for each 6-month monitoring period:
In which samples were not properly collected [§§141.86(a)~
(d)(l) and/or analyzed [§141.89(a)], or
For which required information was not reported to the State
[§I41.90(a)J.
Note: If a system is required to monitor for two consecutive 6-
month monitoring periods, it must monitor for both 6-month
periods consecutively to be considered RTC. If a medium or small
system is triggered into OCCT requirements during the first
sampling period, a second round of monitoring is not required, and
therefore in this case, it would be considered RTC after one round
of sampling is properly performed.
Based on the reason for the violation, the
definition also includes, the system:
Collects replacement samples that
meet sample location criteria in
§141.86(f);
Meets monitoring waiver conditions
outlined in §141.86(g) and/or provides
required information for waiver to
State in §§141.90 (a)(4XiiHiv);
Provides needed sample information
for State calculation of 90th percentile
levels as required in §141.90(h); or
Meets sampling requirements in
§141.86(b)(5) for the collection of
non-first draw samples.
FOLLOW-UP OR ROUTINE LEAD AND COPPER TAP M/R (Violation Code: 52)
Follow-up
System meets M/R requirements, during the subsequent
compliance period(s), for each 6-month compliance period:
In which samples were not properly collected [§§ 141.86(a>(c)
and (d)(2)], and/or analyzed [§141.89(a)], or
For which required information was not reported to the State
[§141.90(a)j.
Routine
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 violation) that includes:
Proper sample collection [§§141.86(a)-(c) & (d)(3) or (4)],
and/or analysis [§141.89(a)], and
Reporting to the State [§141.90(a)].
Follow-up or Routine
Based on the reason for the violation, the
definition also includes:
The first 4 reasons listed under
violation code 51 above;
System meets State-approved non-first
draw sampling plan,
System reports change in treatment or
source water or State finds out about
change during an inspection, or
System that monitors during an
alternate period, meets conditions
specified by State.
INITIAL TAP & ENTRY POINT WQP M/R (S3)
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)(l),
(2) & (b)], and/or analyzed [§I41 .89(a)], or
For which required information was not reported to the State
[§141.90(a)}
No Change
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338
Revised Definition of Compliance Achieved by Violation Type
Criteria for Return to Compliance
Change Resulting from LCRMR
FOLLOW-UP OR ROUTINE ENTRY POINT WQP M/R (53)
Follow-up
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)(l),
(2) & (c)J, and/or analyzed [§ 141.89(a)], or
For which required information was not reported to the State
[§141.90(a)]
Routine
System meets M/R requirements, during one subsequent 6-month
period, that includes:
Proper sample collection [§§141.87(a)(l), (2), (d)&(e)],
and/or analysis [§141.89(a)], and
Reporting to the State [§141.90(a)]
Note: If a medium or small system no longer exceeds the action
level for either lead or copper, it still must collect and analyze
samples for compliance with the designated WQPs in a subsequent
monitoring period to RTC.
Follow-up or Routine
The definition also includes a ground
water system that has State permission to
collect WQPs from representative entry
points, which subsequently meets its
sampling plan {§141.87 (c)(3)].
FOLLOW-UP OR ROUTINE TAP WQP M/R (53)
Follow-up
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)(l),
(2), & (c)], and/or analyzed [§ 141 .89(a)], or
For which required information was not reported to the State
[§141.90(a)].
Routine
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 violation) that includes:
Proper sample collection [§§141.87(a)(l), (2),(d) and (e)],
and/or analysis [§141.89(a>], and
Reporting to the State [§141.90(a)].
Note: If a medium or small system no longer exceeds the action
level for either lead or copper, it still must properly collect and
analyze samples for compliance with the designated WQPs in a
subsequent monitoring period to RTC.
Follow-up or Routine
Clarification
INITIAL SOURCE WATER M/R (56)
System meets M/R requirements, during a subsequent compliance
period, for the 6-month compliance period:
In which samples were not properly collected [§§I41.88(a)(0>
(2), and (b)], and/or analyzed [§141.89(a)], or
For which required information was not reported to the State
[§141.90(b)].
No change
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339
Revised Definition of Compliance Achieved by Violation Type
Criteria for Return to Compliance
FOLLOW-UP SOURCE WATER M/R (56)
System meets M/R requirements, during a subsequent compliance
period, for each 6-month compliance period:
In which samples were not properly collected [§§141.88(a)(l)
& (2), & (c)-(e)], and/or analyzed [§141.89(a)], or
For which required information was not reported to the State
[§!41.90(b)].
Change Resulting from LCRMR
No change
ROUTINE SOURCE WATER M/R (56)
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 die violation) that includes:
Proper sample collection [§§141.88(a) (1) & (2) and (d) or
'(e)], and/or analysis [| 1 4 1 .89(a)], and
'Reporting to the State [§141.90(b)J.
No change.
OCCT STUDY/RECOMMENDATION OR SOWT RECOMMENDATION (57)
OCCT Study/Recommendation
System submits, during a subsequent compliance period:
The OCCT recommendation [§§I41.82(a)& 141.90(c)(2)],
Completes and submits the OCCT study to the State
[§§141.82(c)& 14 1.90(c)(3)], and/or
Provides additional information to the State that is needed to
make an OCCT decision [141.82(d) (2)].
SOWT Recommendation
System submits SOWT recommendation to the State
[§§141.83(a)(l) & (b)(l) and 141.90(d)(l)].
OCCT Study/Recommendation or
SOWT Recommendation
No change
OCCT INSTALLATION/DEMONSTRATION OR SOWT INSTALLATION (53)
OCCT Installation/Demonstration
System properly installs and operates treatment (§141.82(e)],
System submits certification of proper installation and
operation [§141.90(c)(4)],or
System demonstrates that OCCT already is in place
[§§141.81(b)(lM3)&141.90(cXl)].
SOWT Installation
System properly installs and operates SOWT [§§141.83 (b)(3)
& (5)] and/or
System submits certification of proper installation and
operation [§141.90(d)(2)].
OCCT Installation/Demonstration or
SOWT Installation
No change
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340
Revised Definition of Compliance Achieved by Violation Type
Criteria for Return to Compliance
ENTRY POINT OR TAP WQP NONCOMPLIANCE (59)
Entry Point WOP Noncompliance
System meets State designated or approved WQP values or ranges
for one subsequent quarter [§141 -82(g)J. (See note under Entry
Point or Tap WQP Noncompliance in the Change Resulting from
LCRMR column.)
Tan WOP Noncompliance
System meets State designated or approved WQP values or ranges
for one subsequent 6-month compliance period [§14 1.82(g)].
Change Resulting from LCRMR
=-
Entry Point or Tap WOP
Noncompliance
Note: Violations are no longer based on
quarters. All WQP non-compliance '
violations are 6-month violations
1) System has excursions for less than 1 0
days in the subsequent 6-month
monitoring period [§14I.82(g)] and
does not incur an WQP M/R violation;
or
2) System is a small or medium-size
system and no longer exceeds either
action level Note: In this case,
"Intentional no action required" would
be reported, rather than "RTC".
SOURCE WATER MPL NONCOMPLIANCE (63)
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)].
No change
LEAD SERVICE LINE REPLACEMENT (LSLR) (64)
System meets the 7% replacement rate (or higher if required by the
State) by any one or a combination of:
Demonstrates it replaced that portion of the line that it owns
[§141.84(d)}
Replaces entire line [§§141.84(a) & (b)]
Shows the lead service line contributes <. 15 ppb of lead
[§ 141 .84(c) and § 141 .90(e)(2)(ii)]
* Reports all required information to the State [§141.90(e)], or
No longer exceeds the lead action level for two consecutive
monitoring periods. Note: In this case, "Intentional no action
required" would be reported, rather than "RTC".
In the case of a partial replacement, the
system:
Notifies the users of the replacement and
measures to minimize their exposure to
lead [§141.84(d],
Collects a post-replacement lead sample
and notifies the residents of the results
[§ 14 1.84(d], and/or
Reports the required information to the
State[§I41.90(e)(4)].
PUBLIC EDUCATION (65)
System delivers one round of public education [§§141.85(a)-(c)J,
and submits written documentation to State that demonstrates
measures taken to meet these public education requirements
[§141.90(f)].
Note: If a system no longer exceeds the lead action level for one
monitoring period, it still must properly perform public education.
Clarification
i
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