United States
Environmental Protection Office of Water EPA 812/B-92-004
Agency (WH-550) May 1992
&EPA LEAD AND COPPER
MONITORING GUIDANCE for
WATER SYSTEMS SERVING
101 to 500 PERSONS
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Lead and Copper
Monitoring Guidance
for
Water Systems Serving
101 to 500 Persons
******
Definitions
Introduction
Conduct a Materials Evaluation to Identify Lead
and Copper Sampling Sites
How and When You Should Collect Lead and
Copper Tap Water Samples
How and When You Should Collect Water Quality
Parameter Samples
How and When You Should Collect Lead and
Copper Source Water Samples
Schedules
Sample Forms and Worksheets
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Definitions Applicable to the
Lead and Copper Rules
ACTION LEVEL (AL) is the concentration of lead or copper in water which determines
the treatment requirements contained in Subpart I of this part that a water system is
required to complete. The lead action level is 15 ppb measured in the 90th
percentile. The copper action level is 1.3 ppm measured in the 90th percentile.
See page 13 for calculation.
BLDGs means public or commercial buildings served by the PWS.
BLDG>82 means a public or commercial building constructed after 1982 with copper
plumbing using lead-based solder.
BLDG<82 means a public or commercial building constructed before or in 1982 with
copper plumbing using lead-based solder.
BLDG-LSL means a public or commercial building served by a lead service line
connection.
BLDG-Pb means a public or commercial building which has lead interior plumbing.
CORROSION INHIBITOR means a substance capable of reducing the corrosivity of
water toward metal plumbing materials, especially lead and copper, by forming a
protective film on the interior surface of those materials.
Cu is the symbol for copper.
EFFECTIVE CORROSION INHIBITOR RESIDUAL means a concentration sufficient
to form a passivating film on the interior walls of a pipe.
FIRST DRAW SAMPLE means a one-liter sample of tap water, collected in accordance
with §141.86(b)(2), that has been standing in plumbing pipes at least 6 hours and is
collected without flushing the tap.
LARGE WATER SYSTEM means a water system that serves more than 50,000 persons.
LEAD SERVICE LINE (LSL) means a service line made of lead which connects the
water main to the building inlet and any lead pigtail, gooseneck or other fitting which is
connected to such lead line.
MAXIMUM CONTAMINANT LEVEL (MCL) means the maximum permissible level of
a contaminant in water which is delivered to any user of a public water system.
MEDIUM-SIZE WATER SYSTEM means a water system that serves greater than 3,300
and less than or equal to 50,000 persons.
MFR>82 is the acronym for a multi-family residence constructed after 1982 with copper
plumbing using lead-based solder.
MFR<82 is the acronym for multi-family residences constructed before or in 1982 with
copper plumbing using lead-based solder.
MFR-LSL is the acronym for multi-family residences served by a lead service line
connection.
MFR-Pb is the acronym for multi-family residences which have lead interior plumbing.
MFRs is the acronym for multi-family residences.
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NRs is the acronym for non-residential structures constructed as single-family residence.
OPTIMAL CORROSION CONTROL TREATMENT means the corrosion control
treatment that minimizes the lead and copper concentrations at users' taps while insuring
that the treatment does not cause the water system to violate any national primary
drinking water regulations.
NTNCWS is the acronym for a Non-Transient, Non-Community Water Supply
Pb is the symbol for lead.
Pb/Cu-POE means lead and copper samples collected at the points of entry to the
distribution system representative of each source of supply after treatment.
Pb/Cu-TAP means lead and copper samples collected as first-draw tap samples from
targeted sample sites.
POE is the acronym for points of entry to the distribution system representative of each
source of supply after treatment.
PQL is the acronym for the Practical Quantitation Level
PWS is the acronym for a Public Water Supplier
SERVICE LINE SAMPLE means a one-liter sample of water, collected in accordance
with §141.86(b)(3), that has been standing for at least 6 hours in a service line.
SFRs is the acronym for single family residences, which can include for purposes of
identifying targeted sampling locations: (1) Non-Residential structures (NRs); and (2)
Multi-Family Residences (MFRs) if they constitute more than 20% of the service
connections within the PWS's service area.
SFR>82 is the acronym for a single-family residence constructed after 1982 with copper
plumbing using lead-based solder.
SFR<82 is the acronym for a single-family residence constructed before or in 1982 with
copper plumbing using lead-based solder.
SFR-LSL is the acronym for a single-family residence served by a lead service line
connection.
SFR-Pb is the acronym for a single-family residence which have lead interior plumbing.
SINGLE FAMILY STRUCTURE means a building constructed as a single-family
residence that is currently used as either a residence or a place of business.
SMALL WATER SYSTEM means a water system that serves 3,300 persons or fewer.
90%TL means the 90% lead and/or copper level.
90%TL-POE means the difference between the 90% lead level for first-draw tap samples
collected at targeted sample sites and the highest respective lead level measured at the
points of entry to the distribution system.
WQP means a water quality parameter, which includes pH, temperature, conductivity,
alkalinity, calcium, orthophosphate, or silica.
WQP-POE means water quality parameters measured at the points of entry to the
distribution system representative of each source of supply after treatment.
WQP-DIS means lead and copper measured at representative locations throughout the
distribution system.
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Page l Monitoring Guidance for Public Water Systems
Monitoring Requirements
The U.S. Environmental Protection
Agency promulgated National Primary
Drinking Water Regulations (NPDWRs)
for lead and copper on June 7, 1991
(56 FR 26460).
Three monitoring protocols are
included in the final rule: (1) tap water
monitoring for lead and copper; (2) water
quality parameter (WQP) monitoring;
and (3) source water monitoring for lead
and copper.
The monitoring requirements for non-
transient, non-community water systems
(NTNCWSs) are essentially the same as
those for community water systems
(CWS). Please refer to 40 CFR §141.86
(a)(6) and (7) for the different targeting
requirements for NTNCWSs.
The term "state" is used throughout
the guidance document to refer to the
primacy authority.
Monitoring Protocols
Lead and Copper
Tap Water Samples
The tap water monitoring protocol for
lead and copper is designed to identify
the contributions of different sources of
lead and copper corrosion by-products to
drinking water. These sources include:
lead service lines, lead and copper
interior piping, lead spider, and fixtures
and faucets. Tap water monitoring for
lead and copper allows a water system
to determine the lead and copper concen-
trations in drinking water to which its
customers may be exposed, as well as
the effectiveness of corrosion control
treatment for reducing concentrations of
those contaminants in water. Tap water
samples for lead and copper are collected
biannually. A small PWS that installs
and properly operates optimal corrosion
control treatment can collect lead and
copper tap water samples annually and
ultimately triennially.
Water Quality
Parameter Samples
A small PWS that exceeds the lead or
copper action level during any monitor-
ing period must collect WQP samples
during the same monitoring period in
which it exceeds an action level. The
WQP monitoring protocol is designed to
assist each system develop optimal cor-
rosion control treatment and help them
determine whether treatment is properly
operated and maintained over time.
Water quality parameter samples must
be collected at each entry point to the
distribution system (WQP-POE) and at
sites in the distribution system (WQP-
DIS) that are representative of water
quality throughout the distribution
system.
Initially, a small PWS that exceeds an
action level must collect samples for pH,
alkalinity, calcium, conductivity, water
temperature, and, if a corrosion inhibitor
is being used, orthophosphate or silica,
depending upon the inhibitor in use.
These WQP samples must be collected
biannually at each entry point to the
distribution system and at
representative sites throughout the
distribution system.
After optimal corrosion control
treatment has been installed, the WQP
samples a PWS must collect depends
upon the corrosion control treatment
installed. A PWS may have to collect
samples for pH, alkalinity (if adjusted),
calcium (if calcium carbonate
stabilization is used) and an inhibitor
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Page 2 Monitoring Guidance for Public Water Systems
residual (if inhibitors are used). Samples
collected after treatment is installed are
used to monitor the effectiveness of
treatment and determine whether the
PWS is operating in compliance with the
rule. After treatment has been installed
WQP samples must be collected
biweekly at each entry point to the
distribution system and biannually at
representative sites in the distribution
system. Once a system reduces
monitoring, WQP samples are collected
biannually, annually, and ultimately
triennially, at representative sites in the
distribution system. A PWS may not
reduce the frequency with which it
collects WQP samples at entry points to
the distribution system.
Lead and Copper
Source Water Samples
Source water monitoring for lead and
copper is only required if a PWS exceeds
the lead or copper action level in tap
water samples. The purpose of requiring
lead and copper sampling at the entry
points to the distribution system is to:
(1) determine the contribution from
source water to total tap water lead and
copper levels; (2) assist systems in
designing an overall treatment plan for
reducing lead and copper levels at the
tap; and (3) assist the state in determin-
ing whether source water treatment is
necessary to minimize lead and copper
levels at the tap. Source water samples
for lead and copper are collected
biannually. A small system that
maintains maximum permissible lead
and/or copper levels in source water can
collect lead and copper source water
samples annually, triennially, and
ultimately every nine years.
Additional Monitoring Data
Any system that collects tap water or
source water samples for lead, copper or
any of the WQPs, in addition to the
samples explicitly required in the rule,
must report the results to the state by
the end of the monitoring period during
which the samples are collected.
Demonstrating Optimal
Control Treatment with
Tap Water and Source
Water Samples
A small PWS can demonstrate optimal
corrosion control treatment has been
installed with monitoring data in one of
two ways.
First, a small PWS that meets the
lead and copper action levels has
installed optimal corrosion control
treatment.
Second, a small PWS that demon-
strates the difference between the 90th
percentile tap water lead level and the
highest source water lead level is less
than 0.005 mg/L has installed optimal
corrosion control treatment. To make
this demonstration the system must
collect tap water samples for lead at the
required number of sites, and source
water samples for lead at each entry
point to the distribution system during
each of two consecutive 6-month
monitoring periods. Once a small PWS
makes this demonstration, the state will
establish water quality parameter values
(WQP-POE and WQP-DIS) for the
system. The PWS must continue to
operate in accordance with the state-
specified WQPs to remain in compliance
with the rules.
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Page 3 Monitoring Guidance for Public Water Systems
Conduct a Materials Evaluation to
Identify Lead and Copper Sampling Sites
The Environmental Protection Agency's lead and copper regulations require all
public water systems to collect tap water samples to determine lead and copper levels
to which customers may be exposed. Sampling periods are 6-months in length. For
systems serving between 101 and 500 people the first sampling period begins July 1,
1993 and ends January 1, 1994. Collect 10 tap samples.
Questions about the lead and copper rule, or other drinking water rules, can be
answered by the EPA Drinking Water Hotline at 800-426-4791 or your State
Drinking Water Program.
When Should My Materials Evaluation Be Completed?
July 1, 1993
What Type of Material Am I Looking for at Sampling Sites?
If you are a community water system, lead and copper tap water samples must be
collected from sampling locations that meet one of the following criteria:
Tier 1. single family structures that contain lead pipes, or copper pipes with lead
solder installed after 2982, and/or are served by lead service lines.
Tier 2. buildings and multiple-family residences that contain lead pipes, or
copper pipes with lead solder installed after 1982, and/or are served by
lead service lines.
Tier 3. single family structures that contain copper pipes with lead solder
installed before 1983.
If you are a non-transient non-community water system, lead and copper tap water
samples must be collected from sampling locations that meet one of the following
criteria:
Tier 1. buildings that contain copper pipes with lead solder installed after 1982,
and/or are served by lead service lines.
Tier 2. buildings that contain copper pipes with lead solder installed before
1983.
If you have a community or non-transient non-community water system and it
contains lead service lines, at least 50% of your sites should be served by a lead
service line (see page 5).
If you have no lead service lines, but you have lead goosenecks or pigtails, collect
tap water samples at the sites with the goosenecks and/or pigtails.
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Page 4 Monitoring Guidance tor Public Water Systems
Conduct a Materials Evaluation to
Identify Lead and Copper Sampling Sites
What Sources of Information Should 1 Review to Identify
High Risk Materials?
To identify enough sites that meet the targeting criteria you should survey all
records documenting the materials used to construct and repair your
distribution system, and buildings connected to your distribution system.
Plumbing Codes
Plumbing Permits
Distribution Maps and Drawings
Inspection and Maintenance Records
Meter Installation Records
Capital Improvement and Master Plans
Standard Operating Procedures
Operation and Maintenance Manuals
Permit Files
Existing Water Quality Data
Interviews with Senior Personnel, Building Inspectors, and Retirees
Community Survey
It is recommended that you identify more sampling sites than the number of
samples you are required to collect during each monitoring period in case
volunteers drop out
For example, since you are required to collect 10 tap water samples during
each 6-month monitoring period you probably want to maintain a list of
about 20 sampling sites that meet the Tier 1 targeting criteria. If you cannot
identify 20 sites meeting the Tier 1 targeting criteria, then you should
complete your list with sites meeting the Tier 2 or Tier 3 criteria.
If your system contains lead service lines, then 5 of your sites must be
served by a lead service line. You probably want to maintain a list of about
10 sampling sites served by lead service lines.
Several worksheets for organizing the information collected during the materials
evaluation are included in your package. These worksheets should be useful when
you determine the sites that contain the highest priority materials. You do not have
to send them to the state, unless requested. You may want to conduct some site
surveys to be sure you have identified sites with lead.
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Page 5 Monitoring Guidance for Public Water Systems
Conduct a Materials Evaluation to
Identify Lead and Copper Sampling Sites
What Should I Do if I Cannot Find Enough Sampling Sites
with High Risk Materials?
PLUMBING MATERIALS
When a sufficient number of Tier 1 sites do not exist or are inaccessible you must
complete your sampling pool with Tier 2 sites.
When a sufficient number of Tier 1 and 2 sites do not exist or are inaccessible,
you must complete your sampling pool with Tier 3 sites.
If you plan on collecting tap water samples from Tier 2 or 3 sites you must
explain why you could not identify a sufficient number of Tier 1 sites, and notify
the state by July 1, 1993. You will need supporting documentation (see Form
141-A on page 27).
You are not required to target buildings with lead solder installed after the
effective date the lead ban was adopted in your state. All states were required to
ban the use of lead solder in all public water systems and all homes and buildings
connected to such systems by June 1988 (most states adopted the ban in 1987 or
1988). Contact the Drinking Water Program in your state to find out the effective
date.
LEAD SERVICE LINES
When a sufficient number of lead service line sites do not exist or are inaccessible
you must collect a tap water sample from each site served by a lead service line.
For example, the rule requires that you collect tap water samples from
5 sites served by a lead service line. If, after reviewing all of the records
listed above, you can identify only 2 sites served by a lead service line, you
must collect a tap water sample from each of those sites.
If you collect tap water samples from less than 5 sites served by a lead service
line, you must explain why you could not identify a sufficient number of lead
service line sites, and notify the state by July 1, 1993 (see Form 141-A on
page 27).
Exceptions
If your system contains only plastic plumbing, but the faucets and fittings contain
lead, you should collect tap samples at single family structures with such faucets
and fittings (kitchen or bathroom tap).
If all of your available sampling sites have water softeners, you should identify
the highest risk sites (Tier 1) and monitor at those locations (kitchen or bathroom
tap).
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WORKSHEET #1
MATERIALS SURVEY INVESTIGATION RESULTS
PV
PC
VS ID NUMBER
)PULATION SERVED BY PWS
Type of
Structure
location
Contact Pvnott
Name
Phone
LSI
Home
PturrtWno;
*-
VduiK
teerW
Selac^d
Rootirw
OptiOMl
Iteeerved
Training
Material
o
o
I
o
5!
3"
o
I
I
5?
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WORKSHEET #2
MATERIALS SURVEY RESULTS BY NUMBER OF SERVICE CONNECTIONS
FOR EACH PLUMBING MATERIALS TYPE
PWS ID NUMBER
POPULATION SERVED BY PWS
o
o
1
O
3
1982
Copper with
Lead Solder
<1983
Number of Service Connections
Distribution System Piping
LSLa
Entire Une
Partial Une
Number of Service Connections
in
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Page 8 Monitoring Guidance for Public Water Systems
WORKSHEET #3
SUMMARY OF MATERIALS SURVEY RESULTS
PWS ID NUMBER
POPULATION SERVED BY PWS
Plumbing Material
Interior Plumbing
Lead Pipe
. Copper Pipe With Lead Solder >1982
Copper Pipe With Lead Solder <1983
Service Lines
LSLs
Entire Line
Partial Line
Total Available Sites
Type of Structure
SFR
MFR [ BLDG
H umber of Service Connection*
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Page 9 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Lead and Copper Tap Water Samples
When Do I Collect Lead and Copper Tap Water Samples?
Lead and copper tap water samples must be collected every 6-months. The first
monitoring period begins on July 1, 1993 and ends on January 1, 1994.
You must submit the results of all tap water samples collected during each
monitoring period to the State. All of these samples collected during each
monitoring period must always be used to calculate the 90th percentile lead and
copper levels.
How Do I Collect Lead and Copper Tap Water Samples?
Always collect a one-liter sample in one container only.
Always collect the first draw.
Always allow the water to stand at least 6 hours (i.e., no flushing, showering,
etc.).
First draw samples collected at single-family residences should always be drawn
from the cold-water kitchen tap or the bathroom tap.
First draw samples collected from buildings other than single-family residences
should always be drawn from an interior tap from which water is typically taken
for consumption.
We encourage residents to collect samples. See the instruction form on page 14
which you should distribute to residents.
As a general rule, you should collect your lead and copper tap water samples early
in the monitoring periodduring the first 3 monthsto insure you have time to
collect water quality parameter samples during the same monitoring period (see
page 15).
During all repeat sampling, when you cannot gain access to an original sampling
site you should collect a tap water sample from another site meeting the same
targeting criteria as the original site. The replacement site should be located within
reasonable proximity of the original site (see Form 141-A on page 27).
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Page 10 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Lead and Copper Tap Water Samples
How Many Tap Water Samples Should I Collect During Initial
Monitoring?
You must collect at least 1 tap water sample at a minimum of 10 sites every
6 months.
All sites must meet Tier 1 targeting criteria.
5 sites must be served by a lead service line.
If you exceed the lead or copper action level you must complete the treatment
technique requirements (see pages 11 and 12).
If you meet the lead and copper action levels you may reduce samples (see Box 1
on page 11).
How Many Tap Water Samples Should I Collect After
Installing Optimal Corrosion Control Treatment?
You must collect 1 tap water sample at a minimum of 10 sites during each of
2 consecutive 6-month monitoring periods.
All sites must meet Tier 1 targeting criteria.
5 sites must be served by a lead service line.
If you meet both action levels during each of 2 consecutive 6-month monitoring
periods you can reduce monitoring to 1 tap water sample at a minimum of 5 sites
annually.
If you exceed an action level in any 6-month monitoring period after installing
optimal corrosion control treatment, you should continue to collect WQP samples.
The state will set water quality parameter values (see page 19).
How Many Tap Water Samples Should I Collect Alter the
State Sets Water duality Parameters?
You must collect 1 tap water sample at a minimum of 10 sites every 6 months.
All sites must meet Tier 1 targeting criteria.
5 sires must be served by a lead service line.
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Page 11 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Lead and Copper Tap Water Samples
How Many Tap Water Samples Should I Collect When
I Reduce Monitoring?
Any time you meet both action levels during 2 consecutive 6-month monitoring
periods you may reduce monitoring and collect 1 sample at a minimum of 5 sites
annually.
Any time you exceed an action level, but operate in accordance with water quality
parameters during 2 consecutive 6-month monitoring periods, you may request the
state to reduce the number of lead and copper samples from 10 to 5, and reduce
the frequency for collection from biannual to annual.
Any time you meet both action levels for 3 consecutive years you may reduce
monitoring and collect 1 sample at a minimum of 5 sites every 3 years.
Any time you exceed an action level, but operate in accordance with water quality
parameters during 6 consecutive 6-month monitoring periods, you may request the
state to reduce the frequency for collecting 5 lead and copper samples from
annual to triennial.
All tap samples collected during reduced monitoring must be collected between
June and September.
How Do I Calculate 9Oth Percentile Lead and Copper Levels
During Initial, Follow-up and Routine Monitoring?
When 40 samples are collected, the 2nd highest sample value recorded during a
6-month monitoring period is the 90th percentile.
If the 2nd highest lead level exceeds 15 ppb you must:
Collect water quality parameter samples (during the 6-month monitoring
period when the exceedance occurred).
Deliver the public education program described in U.S. EPA's Public
Education Primer (within 60 days of the exceedance).
Collect lead source water samples and submit a source water treatment
recommendation to the state, if you have not already done so (within
6 months of the exceedance).
Submit an optimal corrosion control treatment recommendation to the state,
if you have not already done so (within 6 months of exceedance).
If the 2nd highest copper level exceeds 1.3 ppm you must:
Collect water quality parameter samples (during the 6-month monitoring
period when the exceedance occurred).
Collect copper source water samples and submit a source water treatment
recommendation to the state, if you have not already done so (within
6 months of the exceedance).
Submit an optimal corrosion control treatment recommendation to the state,
if you have not already done so (within 6 months of the exceedance).
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Page 12 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Lead and Copper Tap Water Samples
How Do I Calculate 90th Pcrccntilc Lead and Copper Levels
During Reduced Monitoring?
When 5 samples are collected, the average of the 4th and 5th highest sample value
recorded during a reduced monitoring period is the 90th percentile.
If the average of the 4th and 5th highest lead level exceeds 15 ppb you must:
Stop monitoring at a reduced number and frequency, and recommence
collecting 10 tap water samples every 6 months, immediately.
If you have not installed optimal corrosion control treatment, start
collecting 2 WQP samples every 6 months at 1 site in the distribution
system and at each entry point. Submit a treatment recommendation to the
state within 6 months of exceedance.
// you have installed optimal corrosion control treatment, recommence
collecting 2 WQP samples every 6 months at 1 site in the distribution system,
and 1 WQP sample at each entry point every 2 weeks, immediately.
// you have installed optimal corrosion control treatment, start or
recommence replacing lead service lines (7% ofyourLSLs must be replaced
within 12 months of the exceedance, and an additional 7% every 12 months
thereafter).
If you have not collected lead source water samples and submitted a source
water treatment recommendation to the state, do so within 6 months of the
exceedance.
Recommence delivering the public education program within 60 days of
exceedance.
If the average of the 4th and 5th highest copper level exceeds 1.3 ppm you must:
Stop monitoring at a reduced number and frequency, and recommence
collecting 10 tap water samples every 6 months, immediately.
If you have not installed optimal corrosion control treatment, start
collecting 2 WQP samples every 6 months at 1 site in the distribution
system and at each entry point. Submit a treatment recommendation to the
state within 6 months of exceedance.
// you have installed optimal corrosion control treatment, recommence
collecting 2 WQP samples every 6 months at 1 site in the distribution system,
and 1 WQP sample at each entry point every 2 weeks, immediately.
If you have not collected copper source water samples and submitted a
source water treatment recommendation to the state, do so within 6 months
of the exceedance.
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Page 13 Monitoring Guidance for Public Water Systems
Calculating the 9Ot
3&itial, Follow-up and
&
Sample Number
1
2
3
4
5
Sample Value
0
0
0
0
6
h Percentile During
I Routine Monitoring
Sample Number
6
7
8
9 (90th %)
10
Sample Value
10
12
20
25
30
Calculating the 90th Percentile
During Reduced Monitoring
Sample Number
1
2
3
4
5
(Average of
4 and 5 is 90th %)
Sample Value
0
0
6
8
12
10
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Page 14 Monitoring Guidance for Public Water Systems
Suggested Directions for
Homeowner Tap Sample Collection Procedures
**
fThese samples are being collected to determine the lead and copper levels in your tap water. This
sampling effort is required by the U.S. Environmental Protection Agency and your state, and is being
accomplished through the cooperation of homeowners and residents.
A sample is to be collected after water has been sitting in the pipes for an extended period of time
(i.e., no water use during this period). Due to this requirement, either early mornings or evenings upon
returning from work are the best times for collecting samples. The collection procedure is described
in more detail below.
1. Prior arrangements will be made with the customer to coordinate the sample collection event Dates will be
set for sample kit delivery and pick-up by water department staff.
2. A minimum 6-hour period during which there is no water use throughout the house must be achieved prior
to sampling. The water department recommends that either early mornings or evenings upon returning home
are the best sampling times to ensure that the necessary stagnant water conditions exist.
3. A kitchen or bathroom cold-water faucet is to be used for sampling. Place the sample bottle (open) below the
faucet and gently open the cold water tap. Fill the sample bottle to the line marked "1000-mL" and turn off
the water.
4. Tightly cap the sample bottle and place in the sample kit provided. Please review the sample kit label at this
time to ensure that all information contained on the label is correct
5. IF ANY PLUMBING REPAIRS OR REPLACEMENT HAS BEEN DONE IN THE HOME SINCE THE
PREVIOUS SAMPLING EVENT, NOTE THIS INFORMATION ON THE LABEL AS PROVIDED.
6. Place the sample kit outside of the residence in the location of the kit's delivery so that department staff may
pick up the sample kit
7. Results from this monitoring effort will be provided to participating customers when reports are generated for
the State unless excessive lead and/or copper levels are found. In those cases, immediate notification will be
provided (usually 10 working days from the time of sample collection).
Call at if you have any questions regarding these
instructions.
TO BE COMPLETED BY RESIDENT
->X A-
Water was last used: Time Date_
Sample was collected: Time Date_
I have read the above directions and have taken a tap sample in accordance with these
directions.
Date
Signature
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Page 15 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Water Quality Parameter Samples
Exceeding an Action Level Triggers Water Quality Parameter
Sampling
If you exceed the lead or copper action level you must collect water quality
parameter (WQP) samples from each entry point to the distribution system and
from a representative site located in the distribution system.
Because the results of all WQP samples must be submitted to the state in the
same monitoring period in which you exceeded an action level, you should
collect lead and copper tap water samples early in the monitoring period.
For example, if you exceed an action level in the first monitoring period
(from July 1, 1993 to January 1, 1994) you must collect WQP samples and
submit the results to the state by January 1, 1994.
How Do I Select Representative Sampling Sites for Water
Quality Parameters?
You must identify 1 sampling site in your distribution system representative of
the water quality throughout the distribution system. For ease, you may want to
use a site used to sample for coliforms.
When you identify representative sampling sites in the distribution system you
should consider the following:
size of the population you serve and where the population is located,
different sources of water you currently use.
different treatments installed and operating.
effect of seasonal variability on treatment and water quality.
proximity of WQP sites to lead and copper tap water sampling sites.
proximity of WQP sites to supplemental chlorination feed points.
proximity of WQP sites to ground or elevated storage locations.
WQP sites' representativeness of typical detention times of water in the
distribution system.
WQP sites' representativeness of distinct pressure zones located
throughout the distribution system.
WQP sites' representativeness of distribution system materials.
Avoid areas in the distribution system where maintenance or flushing is
conducted because water quality upsets are more likely to occur in these places.
Remember, you are trying to collect data that is representative of typical water
quality conditions in the distribution system.
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Page 16 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Water Quality Parameter Samples
How Do I Collect Water Quality Parameter Samples?
Samples should be fully flushed.
Samples collected at entry points to the distribution system must be collected at
locations representative of each source of water after treatment.
If your system draws water from more than one source, and the sources are
combined before distribution, you must collect samples at sites in the distribution
system where the water is representative of all sources being used.
If you collect the WQP samples in the distribution system from the same location
as coliform and disinfectant residual samples you should collect the WQP
samples in the following manner:
Fully flush the tap and collect the coliform sample.
Collect a sample to measure disinfectant residual
Collect and analyze sample for temperature and pH.
Collect the samples for the other WQPs.
If fire hydrants or other types of distribution system fixtures are in the vicinity of
a sampling site, fully flush the sample before collecting.
When you collect WQP samples you should always record your observations
about color, suspended solids, and the flushing time required prior to achieving
acceptable sampling conditions.
When you collect WQP samples for alkalinity, calcium, conductivity,
orthophosphate, and silica you should take two 500-ml samples.
Temperature analyses must be conducted in the field to insure accuracy. Measure
temperature using either a hand-held thermometer or a combined temperature/pH
electrode and meter.
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Page 17 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Water Quality Parameter Samples
How Do I Collect Water Quality Parameter Samples?
pH measurements must also be conducted in the field and must be made with a
pH electrode and meter within 15 minutes of sample collection. The meter should
be capable of measuring to 1/10 of a unit.
The pH probe should be placed in a sample bottle and secured during transport.
The probe's membranes are very delicate and should not come in contact with
hard surfaces or be allowed to dry out. Pack a replacement probe just in case.
Before collecting the pH sample, the pH electrode should be calibrated
at pH 7.0 and a second pH level; either 40 or 10.0, depending on the
pH range typically found within the distribution system.
When collecting WQP samples, care should be taken to avoid agitating
the water sample (i.e., shaking, bouncing in transit, etc.).
Before collecting the sample, remove the faucet aerator and run the
water gently to flush the line,
Fill the sample bottle to slightly overflowing.
Use a closed-system bottlewhich allows you to insert the thermometer
or pH probeto reduce measurement error.
If you use a hand-held thermometer, insert it in the sample and record
the reading when it stabilizes. Insert the pH electrode immediately after
removing the thermometer.
// you use a combined electrode and meter, insert it in the sample
immediately after filling the bottle and measure temperature. Change the
meter to measure pH levels and gently rotate the bottle until the pH
reading stabilizes (may take several minutes).
Record the pH measurement, rinse the electrode with deionized water
and replace it in the holding bottle.
Plastic or glass containers can be used when collecting WQP samples except if
silica analyses are required (plastic must be used).
WQP samples should be stored separately from coliform samples to prevent
contamination. All samples should be stored in a cool environment until
analyzed.
You may take a confirmation sample for any WQP sample within 3 days of
receiving the results of the first sample. If you collect a confirmation sample, you
must average the two results to determine compliance.
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Page 18 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Water Quality Parameter Samples
How Many Water Quality Parameter Samples Should I Collect
in the Monitoring Period in Which an Action Level Is Initially
Exceeded?
*
Collect WQP samples at a representative site in the distribution system and at
each entry point to the distribution system for:
pH
Alkalinity
Calcium
Conductivity
Temperature
Orthophosphate, when a phosphate-based inhibitor is used
Silica, when a silicate-based inhibitor is used
Collect 2 samples at 1 site located in your distribution system during the first
6-month monitoring period in which you exceed an action level.
Collect 2 samples at each entry point to your distribution system during the
first 6-month monitoring period in which you exceed an action level.
Within 6 months of exceeding an action level you must submit an optimal
corrosion control treatment recommendation to the state (see § 141.82 or the
corrosion control treatment guidance for details).
The 2 WQP samples should be collected at different times in the monitoring
period to insure you have water quality data that is representative of seasonal
changes that can take place during a monitoring period.
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Page 19 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Water Quality Parameter Samples
How Many Water Quality Parameter Samples Should I Collect
After y»t»t**K**g Optimal Corrosion Control Treatment?
If you continue to exceed an action level after installing optimal corrosion
control treatment you must collect WQP samples during the 12 month period
immediately after you have completed installing treatment.
2 samples must be collected at 1 site in your distribution system during each
of 2 consecutive 6-month monitoring periods for:
pH
Alkalinity
Calcium, when calcium carbonate stabilization is used
Orthophosphate, when a phosphate-based inhibitor is used
Silica, when a silicate-based inhibitor is used
1 sample must be collected at each entry point to your distribution system
every 2 weeks for:
pH
When alkalinity is adjusted, the concentration of alkalinity
When an inhibitor is used, the concentration of orthophosphate or
silicate (whichever is used)
On the basis of WQP samples collected during this 12-month period the state
will establish WQP values you must meet in all subsequent monitoring periods
to remain in compliance with the regulation.
For example, the state might require you to maintain pH between 7.8
and 8.2 at each entry point and a pH of 7.0 to 8.0 at all sampling sites
in the distribution system. Similarly, the state might require you to
install sodium bicarbonate at a dosage rate of 10 mg/L (measured at
each entry-point) to maintain alkalinity above 20 (measured at all
distribution system sites).
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Page 20 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Water Quality Parameter Samples
How Many Water Quality Parameter Samples Should I Collect
After the State Sets Water Quality Parameter Valises?
2 samples must be collected at 1 sampling site in your distribution system
every 6 months for:
pH
Alkalinity
Calcium, when calcium carbonate stabilization is used
Orthophosphate, when a phosphate-based inhibitor is used
Silica, when a silicate-based inhibitor is used
1 sample must be collected at each entry point to your distribution system
every 2 weeks for.
pH
When alkalinity is adjusted, the concentration of alkalinity
When an inhibitor is used, the concentration of orthophosphate or
silicate (whichever is used)
How Many Water Quality Parameter Samples Should X Collect
During Reduced Monitoring? -
If you maintain the state-specified values for WQPs at representative sites in
the distribution system for 8 consecutive 6-month monitoring periods, you may
reduce the frequency with which you collect 2 WQP samples at 1 site in the
distribution system from biannually to annually.
If you maintain the state-specified values for WQPs at 1 site in your
distribution system for 3 consecutive years you may reduce the frequency with
which you collect 2 WQP samples at 1 site in the distribution system from
annually to every 3 years.
WQP samples must always be collected at each entry point to the distribution
system every 2 weeks.
WQP sampling may be discontinued any time you meet the lead and copper
action levels.
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Page 21 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Lead and Copper Source Water Samples
Exceeding an Action Level Triggers Source Water Monitoring
If you exceed the lead and/or copper action level you must collect one lead
and/or copper source water sample from each entry point to the distribution
system and submit the results to the state within 6 months of exceeding an action
level.
A water system can stop collecting lead and/or copper samples if the system
meets the lead and copper action levels during the entire source water sampling
period applicable to the system (i.e., 1 year or 3 years).
Where Do I Collect Lead and Copper Source Water Sample*?
If You Are a Ground Water System
Collect at least one sample at each entry point to the distribution system that
is representative of each well.
If there are separate entrances to your distribution system from either individual
wells or wellfields, a sample must be collected from each discrete entrance
point.
If you use multiple wells that draw from the same aquifer, the state can identify
an individual well for monitoring, as long as there is no treatment or blending.
You must take each repeat sample at the same sampling site unless conditions
make sampling at another site more representative of each source or treatment
plant.
If You Are a Surface Water System (or Combination Ground Water/Surface
Water System)
Collect at least one sample at each entry point to the distribution system which
is representative of each source of water. These samples may be collected after
storage or at the high service pumps.
You must take each repeat sample at the same sampling site unless conditions
make sampling at another site more representative of each source or treatment
plant.
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Page 22 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Lead and Copper Source Water Samples
How Many Lead and Copper Source Water Samples Should I
CoUect During Initial Monitoring?
If you exceed the lead or copper action level you must collect 1 sample at each
entry point to the distribution system and analyze it for the appropriate
contaminant. You must submit the results of all source water samples to the
state within 6 months of exceeding the lead or copper action level.
For example, if you exceed an action level in the first monitoring period
(from July 1, 1993 to January 2, 1994) you must collect source water
samples and submit the results to the state by July 1, 1994.
In addition to submitting source water samples, you must also submit a source
water treatment recommendation (which may include a recommendation that
no source water treatment is needed) to the state for review and approval (see
40 CFR § 141.83 for details).
How Many Lead and Copper Source Water Samples Should X
Collect After Installing Source Water Treatment?
If you are required to install source water treatment, you must collect 1 sample
at each entry point to the distribution system during each of 2 consecutive
6-month monitoring periods.
The state will set maximum permissible levels (MPL) for source water lead
and/or copper concentrations based on these results. See schedule on page 26.
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Page 23 Monitoring Guidance for Public Water Systems
How and When You Should Collect
Lead and Copper Source Water Samples
How Many Lead and Copper Source Water Samples Should I
Collect After the State Sets Maximum Permissible Levels?
If You Are a Groundwater System
You must collect 1 sample at each entry point to the distribution system
beginning in the 3-year compliance period in effect when the state specifies a
maximum permissible level(s). See the schedule on page 26 for the compliance
period in which you should begin monitoring.
You must continue to collect 1 sample at each entry point to the distribution
system during each subsequent 3-year compliance period.
If You Are a Surface Water System (or Combination Ground Water/Surface
Water System)
You must collect 1 sample at each entry point to the distribution system
annually, beginning on the date the state specifies a maximum permissible
level(s). See the schedule on page 26 for the year in which you should begin
monitoring.
How Many Lead and Copper Source Water Samples Should i
Collect During Reduced Monitoring?
If You Are a Groundwater System
If you meet the maximum permissible level(s) set by the state for 3 consecutive
3-year compliance periods you can reduce source water monitoring to once
every 9-year compliance cycle.
If You Are a Surface Water System (or Combination Ground Water/Surface
Water System)
If you meet the maximum permissible level(s) set by the state for 3 consecutive
years you can reduce source water monitoring to once every 9-year compliance
cycle.
-------
Tap Wafer Monitoring Requirements For Small Water Systems (101 to 500)
Reduced numtMt at iampkia
PWCu^Artton Uwri n«»» morttor won al each «r*y poM
ID tt«
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Source Water Monitoring For Lead and Copper For Small Systems (£3,300)
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-------
Number'and Frequency of Tap Water Monitoring For Systems Demonstrating Optimal Corrosion Control Treatment Installed
901 to 1X0
<[jy«terti> t^rvtogT^
I
Numbar o» ittm h dbMbullon iy«t«m whew PWS mu»t cotoct Ivxo (Z) nrptot to oppfcobto WQPi.
Syitam cotoct two (2) tcrrptot at «ach Ma tor: pH. ahdMty. cddum. conductMly. water terroaratura. orthaphatphatft
(wt»n pho«phate InhUtor UMd). and rttea (wrv»n Ofcoto inHbltor uMd).
» State jttootv«t9morxl^o^
tt Larga water lyttamt damoratratho OCCT with loriiptm tfxiiwlng that ti« dltai«nc« b*lw0«n tap water and iourc« water
toad tovak ore < S ppb muit cotoct WOP nmptoi to lh» itat* can wt vdUM txit rafloct optimal corrodon control.
-------
Page 27 Monitoring Guidance for Public Water Systems
Form 141-A
Page 1 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
System's Name:
Address:
Tvoe: D CWS D NTNCWS
Size: D > 100,000
D 10.001 to 100.000
D 3.301 to 10.000
D 501 to 3.300
Telephone number
System ID #:
Contact Person:
D 101 to SOO
n sioo
CERTIFICATION OF SAMPLING SITES
LEAD SOLDER SITES
# of single-family structures with copper pipes with lead solder installed
after 1982 or lead pipes and/or lead service lines (Tier 1)
# of multi-family structures with copper pipes with lead solder installed
after 1982 or lead pipes and/or lead service lines (Tier 1)
# of buildings containing copper pipes with lead solder installed
after 1982 or lead pipes and/or lead service lines (Tier 2)
# of sites that contain copper pipes with lead solder installed before 1983
(to be used only if other conditions have been exhausted) (Tier 3)
TOTAL
The following sources have been explored to determine the number of structures which have
Interior lead pipe or copper pipe with lead solder.
Plumbing and/or building codes
Plumbing and/or building permits
Contacts within the building department municipal clerk's office, or state regulatory
agencies for historical documentation of the service area development
Water Quality Data
Other Resources Which PWS May Utilize
Interviews with building inspectors
Survey of service area plumbers about when and where lead solder was used from 1982 to
present
Survey residents in sections of the service area where lead pipe and/or copper pipe with
lead solder is suspected to exist
Interviews with local contractors and developers
Explanation of Tier 2 and Tier 3 sites (attach additional pages if necessary)
-------
- Page 28 Monitoring Guidance tor Public Water Systems
Form 141-A (continued) Page 2 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
CERTIFICATION OF SAMPLING SITES
LEAD SERVICE LINE SITES
0 of samples required to be drawn from lead service line sites
# of samples actually drawn from lead service line sites
Difference (explain differences other than zero)
The following sources have been explored to determine the number of lead service lines In the
distribution system.
Distribution system maps and record drawings
Information collected for the presence of lead and copper as required under §141.42 of the
Code of Federal Regulations
Capital improvement plans and/or master plans for distribution system development
Current and historical standard operating procedures and/or operation and maintenance
(O&M) manuals for the type of materials used for service connections
Utility records including meter installation records, customer complaint investigations and all
historical documentation which indicate and/or confirm the location of lead service
connections
Existing water quality data for indications of 'troubled areas'
Other Sources Which PWS Utilized
Interviews with senior personnel
Conduct service line sampling where lead service lines are suspected to exist but their
presence is not confirmed
Review of permit files
Community survey
Review of USGS maps and records
Interviews with pipe suppliers, contractors, and/or developers
Explanation of fewer than 50% LSL sites identified (attach additional pages.if necessary):
CERTIFICATION OF COLLECTION METHODS
I certify that
Each first draw tap sample for lead and copper is one liter in volume and has stood motionless in the
plumbing system of each sampling site for at least six hours.
Each first draw sample collected from a single-family residence has been collected from the cold water
kitchen tap or bathroom sink tap.
Each first draw sample collected from a non-residential building has been collected at an interior tap
from which water is typically drawn for consumption.
Each first-draw sample collected during an annual or triennial monitoring period has been collected in
the months of June, July, August or September.
Each resident who volunteered to collect tap water samples from his or her home has been properly
instructed by [insert water system's name]
in the proper methods for collecting lead and copper samples. I do not challenge the accuracy of those
sampling results. Enclosed is a copy of the material distributed to residents explaining the proper collection
methods, and a list of the residents who performed sampling.
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Page 29 Monitoring Guidance for Public Water Systems
Form 141-A (continued)
Page 3 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
RESULTS OF MONITORING
THE RESULTS OF LEAD AND COPPER TAP WATER SAMPLES MUST BE ATTACHED TO THIS
DOCUMENT
of samples required
f of samples submitted
90th Percentile Pb
90th Percentile Cu
THE RESULTS OF WATER QUALITY PARAMETER SAMPLES MUST BE ATTACHED TO THIS
DOCUMENT
# of samples required # of tap samples submitted
# of entry point samples required # of entry point samples submitted
CHANGE OF SAM RUNG SITES
Original site address:
New site address:
Distance between sites (approximately):
Targeting Criteria: NEW:
OLD:
Reason for change (attach additional pages if necessary):
SIGNATURE
NAME
TITLE
DATE
-------
., Page 30 Monitoring Guidance for Public Water Systems
Form 141-B
Page 1 of 1
REQUEST FOR REDUCED LEAD AND COPPER TAP WATER MONITORING
System's Name:
Address:
Tvoe: n CWS D NTNCWS
Size: D > 100,000
D 10.001 to 100.000
D 3.301 to 10.000
D 501 to 3.300
Telephone number:
Svstem ID #:
Contact Person:
D 101 to 500
n sioo
REQUEST FOR REDUCTION
The
water system has:
D maintained tap water levels below the lead/copper action level(s); or
D operated in accordance with the state-specified water quality parameters during
each of the following six-month monitoring periods:
The above named water system hereby requests that the state permit the system to reduce lead and
copper tap water monitoring from:
n Biannual to Annual
D Annual to Triennial
D 100 to 50
D 60 to 30
D 40 to 20
D 201010
D 10 to 5
The results of ail water quality parameter samples and lead and copper tap water
samples collected during each of the monitoring periods are summarized and attached.
SIGNATURE
NAME
TITLE
DATE
-------
Page 31 Monitoring Guidance for Public Water Systems
Form 141-C
e 1 of 2
OPTIMAL CORROSION CONTROL TREATMENT/WATER QUALITY PARAMETER
System's Name:
Address:
Tvoe: D CWS n NTNCWS
Size: D >100,000
n 10.001 to 100.000
D 3.301 to 10.000
D 501 to 3.300
Telephone number
System ID #:
Contact Person:
a 101 to soo
a sioo
THE RESULTS OF SOURCE WATER AND TAP WATER SAMPLES MUST BE ATTACHED TO THIS
DOCUMENT
f of tap water samples required.
f of source water samples required
f of tap water samples submitted
_f of source water samples submitted
RESULTS OF OPTIMAL CORROSION CONTROL TREATMENT STUDIES
TEST 1 ALKALINITY & pH ADJUSTMENT
Before
Parameters
Pb
Cu
PH
alkalinity
calcium
conductivity
orthophosphate
silicate
water
temperature -
After
TEST 3 ADDITION OF CORROSION
INHIBITOR
Before
Parameters
Pb
Cu
PH
alkalinity
calcium
conductivity
orthophosphate
silicate
water
temperature
After
TEST 2 CALCIUM HARDNESS
TREATMENT
Before
TEST 4
Before
Parameters
Pb
Cu
PH
alkalinity
calcium
conductivity
orthophosphate
silicate
water
temperature
After
Parameters
Pb
Cu
pH
alkalinity
calcium
conductivity
orthophosphate
silicate
water
temperature
After
If the state requires the system to conduct additional treatment analyses, copy this form and attach
the results as specified above.
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Page 32 Monitoring Guidance for Public Water Systems
Form 141-C (continued)
Page 2 of 2
OPTIMAL CORROSION CONTROL TREAT ME NT/WATER QUALITY PARAMETER
OPTIMAL CORROSION CONTROL TREATMENT RECOMMENDATION
1. Treatment recommendation and rationale:
2. Test methodologies used to evaluate each treatment (e.g., pipe rig loop tests, metal coupon tests, etc.):
3. Identify any chemical or physical constraint that limits or prohibits the use of a particular corrosion control
treatment (attach all data indicating that a particular treatment has adversely affected other water
treatment processes or is ineffective for reducing corrosion):
CERTIFICATION THAT OPTIMAL CORROSION CONTROL TREATMENT HAS
BEEN INSTALLED ;
The
water system certifies that optimal
corrosion control treatment has been installed and is being properly operated as agreed to between the
above named water system and the state of . Optimal corrosion control treatment
was required to be installed by (date). Optimal corrosion control treatment was installed on
.(date).
MODIFICATION OF CURRENT CORROSION CONTROL
WATER QUALITY PARAMETERS
TREATMENT AND/OR
Reason for modification:
Attach all supporting studies, data, treatment specifications, etc. that substantiate this request for modification.
SIGNATURE
NAME
TITLE
DATE
-------
Page 33 Monitoring Guidance for Public Water Systems
Form 141-D
Page 1 of 2
SOURCE WATER MONITORING AND TREATMENT
System's Name:
Address:
Tree: D CWS D NTNCWS
Size: O > 100,000
a 10.001 to 100.000
D 3.301 to 10.000
D 501 to 3.300
Telephone number:
a 101 to soo
a sioo
System ID #:
Contact Person:
SOURCE WATER DATA
Attach al data collected a! all ertry points to the distribution system. List the highest values obtained fo
sampling for this mentoring period ami attach the resiAs of Softer samples coJtectedai each ertiy -
point .-. .-,-* ' -':.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Efitfv Point Location
Pb Values
Cu Value*
-------
Page 34 Monitoring Guidance for Public Water Systems
Form 141-D (continued)
Page 2 of 2
SOURCE WATER MONITORING AND TREATMENT
SbURCE WATER
TREATMENT RECOMMENDATION
Treatment recommendation:
Reason for treatment/no treatment recommendation:
Attach additional pages as necessary.
CERTIFICATION THAT SOURCE WATER TREATMENT HAS BEEN INSTALLED
The
water system certifies that source
water treatment has been installed and is being properly operated as agreed to between the above named
water system and the State of . Water treatment was required to be installed
by (date). Source water treatment was actually installed on (date).
MODIFICATION OF STATE TREATMENT DECISION AND/OR MAXfMUM
PERMISSIBLE LEAD AND COPPER LEVELS
Reason for modification:
Attach all supporting studies, data, treatment specifications, etc. that substantiate this request for modification.
SIGNATURE
NAME
TITLE
DATE
------- |