United States
Environmental Protection Office of Water EPA 812/B-92-007
Agency (WH-550) May 1992
vvEPA MONITORING REQUIREMENTS
FOR LEAD AND COPPER RULES
WATER SYSTEMS SERVING
10,001 to 50,000 PERSONS
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Monitoring Requirements
for Lead and Copper Rules
Water Systems Serving
10,001 to 50,000 Persons
for
Office of Ground Water and Drinking Water
U.S. Environmental Protection Agency
Washington, D.C.
March 1992
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Table of Contents
Definition! Applicable to the Lead and Copper Rule* iii
Monitoring Protocol! 1
Additional Monitoring Data 2
Demonstrating Optimal Control Treatment with Tap Water
and Source Water Sample* 2
Lead and Copper Tap Water Monitoring — §141.86 5
Conducting a Material! Evaluation 5
Identifying Interior Plumbing Material* 5
Source* Required by Rule 5
Suggested Source* 6
Identifying Distribution Syttem and Service Line Material! 6
Source* Required by Rule 6
Suggested Source* .....' 7
Organizing the Data 8
Identifying and Certifying Targeted Sampling Site* 9
When Tier 1 or Tier 2 Site* Cannot Be Pound 9
Illegally Installed Lead Plumbing Material* 10
When Lead Service Line Site* Cannot Be Found 10
Prioritizing Sampling Site* 10
Sample Collection Method* 12
Tap Water Sample* 12
Lead Service Line Sample* 18
Flushing a Specified Volume 18
Direct Service Line Sample* 18
Temperature Variation 20
Data Anaiyri* and Interpretation 20
Number and Frequency of Sampling 21
Initial Monitoring 21
Follow-up Monitoring 21
Routine Monitoring 21
Reduced Monitoring 21
Reporting Sample* 22
Water Quality Parameter Monitoring — §141.87 23
Selecting Representative Sampling Site* 23
Sample Collection Method* 24
Water Quality Parameter Analyse* 24
Number and Frequency of WQP Sampling 27
WQP Sampling Before Tn^iHtig Optimal Corrosion Control Treatment 27
WQP Sampling After T"*Hli"g Optimal Corrosion Control Treatment and
After the State Specifies Numerical Value* 27
Reduced WQP Sampling 28
Reporting WQP Saap&ng 28
Cessation of WQ? Sampling 28
Lead and Copper Stmu Water Monitoring — §141.88 29
Sample Collection Method* 29
Number and Frequency of Lead and Copper Sampling 30
Lead and Copper Sampling After System Exceed* Lead or Copper Action Level 30
Lead and Copper Sampling After System Install* Source Water Treatment 30
Lead and Copper Sampling After State Specifies Maximum Permissible
Lead and Copper Level* 30
Reduced Monitoring 30
Reporting Source Water Samples 31
Cessation of Lead and Copper Source Water Sampling 31
Tap Water Monitoring Schedules 32
Source Water Monitoring Schedules 45
Sample Forms 52
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List of Tables
PAGE
Table 1. Timeframe for Large PWS Corrosion Control Submissions to the State 3
Table 2. Sample Handling Requirements for Lead, Copper, and Water Quality Parameters 17
Table 3. Pipe Volume Table 19
Table 4. Determination of 90th Percentile Values for Lead and Copper Monitoring Results 21
List of Figures
Figure 1. Preferred Sampling Pool Categories for Targeted Sampling Sites 13
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Definitions Applicable to the
Lead and Copper Rules
§141.2
• ACTION LEVEL (AL) is the concentration of lead or copper in water specified in §141.8082 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 walla of a pipe.
DRAW SAMPLE means a one-liter sample of tap water, collected in accordance with §141. 86(b)(2),
tfia* 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 th» 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.
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• MFRs is the acronym for multi-family residences.
• NRs is the acronym for non-residential structures constructed as single-family residence.
• OPTIMAL CORROSION CONTROL TREATMENT means the corrosion control treatment that
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 mean* 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 meant 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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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.
Monitoring Protocols
The tap water monitoring protocol for lead
and copper is designed to identify the contribu-
tions 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 solder, and fixtures
and faucets. Tap water monitoring for lead and
copper allows a water system to determine the
lead and copper concentrations in drinking water
to which its customers may be exposed, as well
as the effectiveness of corrosion control treat-
ment for reducing concentrations of those
contaminants in water. Tap water samples for
lead and copper are collected biannually. A
medium PWS that installs and properly operates
optimal corrosion control treatment can collect
lead and copper tap water samples annually and
ultimately triennially.
A medium PWS that exceeds the lead or
copper action level during any monitoring 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 corrosion
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 medium PWS that exceeds an
action level must collect samples for pH,
alkalinity, calpin^ conductivity, water tempcra-
ture, 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 forpH, alkalinity (if adjusted), calcium
(if calcium carbonate stabilization is used) and
an inhibitor 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 representa-
tive sites in the distribution system. Once a
system reduces monitoring, WQP samples are
collected biannually, and ultimately, annually
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.
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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
determining 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 medium
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 medium PWS can demonstrate optimal
corrosion control treatment has been installed
with monitoring data in one of two ways.
First, a medium PWS that meets the lead and
copper action levels has installed optimal
corrosion control treatment.
Second, a medium PWS that demonstrates
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 (60), 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 medium 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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Table 1. Timeframe for Medium PWS Corrosion Control
Submissions to the State*
PWS Action
Justification for Insufficient Number
of LSI Sites and/or Expansion to Tier
II or Tier III Sites in Sample Plan
First Six-Month Initial Monitoring
Period Results* •
• Exceeds ALs
• Meets ALs
Treatment Recommendation
State Requires Corrosion Studies
Corrosion Study and Treatment
Recommendation (if Required by
State)
Certification that the State-
designated treatment has been
installed
• Without Study
• With Study
First Six-Month Follow-Up Monitoring
Period Results* *•
• Without Study
• With Study
Second Six-Month Follow-Up
Monitoring Period Results
• Without Study
• With Study
State Specifies Optimal Water Quality
Parameters
• Without Study
• With Study
First Six-Month Monitoring Period
After State Specifies Optimal
WOP— /Routine Monitoring
• Without Study
• With Study
DudSn*
July 1, 1992
Jan. 11, 1993
Jan. 11, 1993
July 1, 1993
Jan. 1, 1994
July 1, 1995
July 1, 1996
Jan. 1, 1998
Jan. 11, 1997
July 11, 1998
July 11, 1997
Jan. 11, 1999
Jan. 1. 1998
July 1. 1999
July 11, 1 998
Jan. 1 1 , 2000
Submission te State
LSL Site and/or Targeting Criteria Sections of
Form 141 -A
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-OIS; WQP-POE; Pb/Cu-POE
Pb/Cu-TAP
Treatment recommendations for corrosion
control and/or source water treatment
As necessary. State notifies PWSs required
to perform corrosion stuoTes
Treatment study report and results as
discussed in Volume II
Letter of Certification
Letter of Certification
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-OIS; WQP-POE
Pb/Cu-TAP; WQP-OIS; WQP-POE
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-OIS; WQP-POE
Pb/Cu-TAP; WQP-OIS; WQP-POE
Based on Follow-Up Monitoring Results
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-OIS; WQP-POE
Pb/Cu-TAP; WQP-DIS; WQP-POE
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Table 1. Timeframe for Medium PWS Corrosion Control
Submissions to the State* (Continued)
:: :. :;.:, .-•:•• PWS Action
Second Six-Month Monitoring Period
After State Specifies Optimal Water
Quality Parameters— Routine
Monitoring
• Without Study
• With Study
Reduced Monitoring
Ultimate Reduced Monitoring
Dudfira
Jan. 11 , 1 999
July 1 1 , 2000
See Appendix A
for Dates
See Appendix A
for Dates
Submission to Stat*
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE
Pb/Cu-TAP; WQP-DIS; WQP-POE
Form 141-B when state-specified WQPs have
been maintained for two consecutive six-
month monitoring periods
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE
Form 141-B when state-specified WQPs have
been maintained for three consecutive years
under reduced monitoring
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE
* Specifically for those PWSs which exceed the ALs and must implement corrosion control treatment and must
meet state specified WQPs. If a smaU PWS does not exceed the ALs in the two consecutive monitoring periods,
then they may request reduced monitoring (Form 141-B) when submitting results of the second six-month
monitoring period. Those systems that meet the ALs are only required to submit Form 141-A and Pb/Cu-TAP
monitoring results under reduced monitoring.
* * PWSs that meet the ALs in the first six-month round of initial monitoring and fail in the second six-month
monitoring period would submit Form 141-A with Pb/Cu-TAP results on January 11, 1993, and submit Form
141-A with Pb/Cu-TAP, WQP-DIS, WQP-POE, Pb/Cu-POE results on July 11, 1993. All other deadlines shown
in this table should be delayed by six months.
• * • PWSs that meet the ALs in the first six-month period and fail to meet the ALs in the second six-month period
of the follow-up monitoring only need to submit Pb/Cu-TAP results for the first six-month period of follow-up
monitoring.
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Lead and Copper Tap Water Monitoring
§141.86
In establishing the tap water monitoring
protocol, EPA sought to ensure that it would
be stringent enough to identify water systems
with significant lead and copper problems, while
insuring that systems could implement the
protocol in the real world. While the monitoring
requirements in this rule are significantly more
comprehensive than requirements established
for other drinking water* contaminants, EPA
believes the protocol is justified by the unique
nature in which corrosion by-products enter
drinking water and the significant risk that lead
and copper pose to the public health.
The tap water monitoring requirements are
presented in six sections: (1) conducting a
materials evaluation; (2) identifying and
certifying targeted sampling sites; (3) sample
collection methods; (4) number and frequency
of monitoring; (5) reduced monitoring; and (6)
reporting.
Conducting a Materials
Evaluation
All medium PWSs must complete a materials
evaluation of their distribution system to identify
a pool of targeted sampling sites. The purpose
of the materials evaluation is to determine the
location of lead and copper materials in a
distribution system, and in structures served
by the system, and to develop a pool of
sampling sites from which lead and copper tap
water samples can be drawn.
The sampling sites must meet the targeting
criteria at 40 CFR S141.86(a)(3), (4), or (5),
for community water systems (CWS), and at
40 CFR §141.86(a)(6) or (7), for non-transient,
non-community water systems (NTNCWSs).
To the extent a PWS has lead service lines, at
least SO percent of sites from which it collects
first draw samples must be served by a lead
service line [40 CFR §141.86(a)(9)].
When conducting a materials evaluation, a
PWS should review all written records that
document the materials used in the construction
and maintenance of the distribution system, and
the structures connected to the distribution
system. The records that a PWS must review
according to the regulation, as well as the
records EPA recommends a PWS review, are
discussed below.
Identifying Interior Plumbing
Materials
The following is a list of potential resources
which should be investigated to determine the
materials used in interior plumbing. The rule
requires that the first three sources be-investi-
gated if an insufficient number of Tier 1 sites
are available.
Sources Required by Rule
A. Plumbing Codes—A review of historical
and current local plumbing codes should
be conducted to identify the array of
interior plumbing materials expected in
a PWS service area. Plumbing codes are
generally available from either die building
or public works department of the appro-
priate governmental body. In cases where
there is multi-jurisdictional control within
the PWS service area, an investigation of
each jurisdiction's code is necessary. In
selecting potential targeted sites for further
investigation, it may be assumed that
plumbing materials will conform to the
code in effect at the time of construction.
B. Plumbing Permits—Plumbing permits
should show the type of materials used,
location of construction, and the date of
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the permit application. In many munici-
palities, construction permits for new
construction and kitchen/bathroom
remodeling are issued through the building
department. Tracing the historical permits
with the plumbing code provisions should
indicate locations where copper plumbing
with lead solder is likely to be found. The
permits may also indicate those residences
that have replaced lead and/or copper-
containing materials with other materials
such as plastic.
C. Existing Water Quality Data—Water
quality data for lead and copper levels in
home tap samples and service line samples
can be used to indicate problem areas.
They may also be used to confirm the
presence of lead and copper-containing
materials in areas where insufficient
information exists. Site visits and verifi-
cation checks on individual sites should
be performed to confirm the site's
materials.
Suggested Sources
D. Historical Documentation of Service Area
Development—-The PWS service area may
be characterized by the age of various
regions. Where detailed information is
missing, housing developments within
identifiable regions may be assumed to
have been constructed using plumbing
codes and typical practices of that time.
E. Internets with Plumbers/Building Inspec-
tors—Tbae personnel, particularly senior
personnel and retimes, may have first hand
knowledge of materials used for original
and remodeled homes. This information
can be used to supplement incomplete
records or provide basic data for systems
lacking records. Local contractors or de-
velopers may have reliable information
on the construction materials used in
sections of the service area.
F. Community Survey—A community survey
may be helpful in identifying plumbing
materials and LSLs. A utility could
perform this survey by mail, using a
standard questionnaire. Many PWSs have
indicated a preference for the use of some
form of a community survey to assist in
identifying potential targeted sampling sites
since these owners or residents may be
predisposed to volunteering their partici-
pation in later sampling. Selective mailings
to new billing units identified since 1982
and/or those residents located in sections
of town where LSLs are anticipated (per-
haps, organized by zip code area) could
reduce the total number of surveys to be
distributed as well as the effort's aqyiriaiari
costs.
Identifying Distribution
System and Service Line
Materials
The following is a list of potential resources
which should be investigated to determine the
materials used in the distribution system. The
rule requires that the first two sources (A and
B) be investigated if an insufficient number of
lead service line sites are available.
Sources Required by Rule
A. Utility Records—Historic and current
records maintained by PWSs can provide
excellent information on the materials used
in the distribution system for service lines
and connections.
1. Information collected on lead and copper
as part of the monitoring for corrosivity
required under Section 141.42 (d) of the
Code of Federal Regulations—This section
refers to previous requirements set by the
EPA, that all community water suppliers
(1) determine corrosivity characteristics
by measuring water quality parameters for
corrosion indices, and (2) perform a
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materials survey to identify lead, copper,
galvanized iron, and asbestos cement as
being present in the system.
2. Distribution Maps and Record Drawings-
Maps and drawings of the distribution
system should be a primary source for
service line and connection information
including materials, line sizes, and dates.
Even with a lack of detail such sources
may be useful in indicating the historical
growth of the system. The maps would
also provide a visual aid in developing the
materials survey.
3. Maintenance Records—Maintenance
records often identify such information
as (1) existing materials; (2) replacement
materials; (3) date of event; and (4)
particular site conditions of note. LSLs
may be specifically identified when
encountered during maintpnanrg activities.
4. Historical Documentation—Every utility
has its own unique system of collecting
and filing information. This documentation
should be investigated to determine (1)
the progressive growth of the distribution
system; (2) dates and materials used for
installation and replacement of distribution
system components; and, (3) the construc-
tion practices throughout the development
of the PWS service area.
5. Meter Installation Records—Meter
installation records could provide
information on service line materials and
indicate the type and age of construction.
Meter size is also an important element
as it may be used as the basis for dif-
ferentiating among structure types, i.e.,
SFRs, MFRs, and BLDGs.
6. Existing Water Quality Data—Water
quality data obtained from utility and/or
regulatory agency records can indicate
areas that exhibit high or unusual lead and
copper levels. This information could be
used to confirm existing information on
materials or on areas where records are
missing or incomplete. This data may also
be useful to support justification claims,
if necessary, for sample site selections.
7. Capital Improvements and Master Plans—
Information regarding planned or executed
improvements to portions of the distribu-
tion system may be provided by existing
and/or historical Capital Improvement or
Master Plans. In particular, base maps of
the system may be available for use in
tracking and recording the material survey
information.
8.
Standard Operating Procedures (SOPs)—
SOPs will often list the type of materials
to be used during the construction and/or
repair of distribution system mains, lines,
and connections.
9. Operation A Maintenance Manuals
O&M manuals may also indicate the type
of materials installed, the method for
replacement as well as replacement ma-
terials to be used.
B. Permit Files— Whether maintained by the
PWS or other municipal agency, permit
files should be reviewed to determine the
presence and location of LSLs. Pre-1940
documents are especially important Recent
records should also be reviewed to
ascertain service line replacements and/or
repairs.
Suggested Sources
C. Senior Personnel and Retirees— PWS
personnel or other agency staff experienced
in the operation, maintenance, or material
usages within the distribution system
and/or home plumbing environments
should be consulted. These personnel will
often have first-hand knowledge regarding
these matters which can supplement
incomplete records or provide basic data
when information is otherwise lacking.
Additionally, local contractors or develop-
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ers may have reliable information on the
materials of construction for sections of
the distribution system.
D. Community Survey—A. community survey
may be helpful in identifying LSL
connections. A utility could perform this
survey by mail using a standard
questionnaire. Many PWSs have indicated
a preference for the use of some form of
a community survey to assist in identifying
potential targeted sampling sites where
owners or residents may be predisposed
to volunteering their participation.
Selective mailings to new billing units
identified since 1982 and/or those residents
located in sections of town where LSLs
are anticipated (perhaps, organized by zip
code area) could reduce the total number
of surveys distributed and the cost.
E. Other Sources—AH other sources available
to the utility that might help identify
materials in the system should be
investigated. For example, piping suppliers
may be able to fill-in or confirm material
supplied during a specific time period or
to a specific development Historical USGS
maps and aerial photography records may
be used to retrace the development of the
service area over time. This is very useful
in identifying those locations where LSLs
are most likely to be found since the use
of LSLs in many communities was
discontinued after approximately 1940.
In some areas, mis generalization may not
be applicable.
Each PWS should select a method for
documenting the information obtained from
these sources. Methods could include: (1)
updating information on service connections
or billing units; (2) labeling detailed drawings
of the distribution system; (3) listing permits
for new construction and remodeling by service
areas; and (4) creating large-scale maps of areas
with widespread use of lead and copper
materials or elevated tap water lead and copper
levels.
Organizing the Data
While the rule does not require a PWS to
identify all existing materials, EPA recommends
that each PWS complete as comprehensive a
survey as possible to identify as many sampling
sites as possible. Such an evaluation will
generate a substantial amount of data which must
be organized so the PWS can develop an
appropriate sampling pool.
The worksheets provided on pages 56 to 58
can be used by a PWS to organize its data and
document the results of the materials evaluation.
Worksheet # 1 provides a PWS with a format
for identifying and listing all possible sampling
sites. EPA recommends that a medium-size PWS
identify five times the required number of
sampling sites to insure it can locate the required
number of sites once field verification and
confirmation of participation in the monitoring
program ^ITHI*^^?^ in^nrax^p^ty and unavailable
sites. Worksheet #2 provides a PWS with a
format for identifying SFRs, MFRs, and BLDGs
that contain lead soldered copper plumbing
materials, interior lead piping, and are served
by a lead service line. Worksheet #3 allows a
PWS to summarize data gathered during the
materials evaluation and identify the total
number of sites meeting Tier 1, Tier 2, Tier
3, and LSL criteria. These worksheets should
be used to complete Form 141-A.
EPA recommends that a PWS include more
than the minimum number of sample sites in
its sample pool to insure that a "sufficiently
large" pool of high priority sites is available
during sampling. A PWS should maintain a
targeted sampling pool between one and one-half
to two times the number of sample sites required
during each monitoring period to insure alterna-
tive sites are available for repeat sampling. Once
monitoring begins, the same sample sites must
be used unless a location has been dropped
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because it is inaccessible or no longer meets
the targeting criteria.
Each PWS should conduct an in-field
inspection of those residences identified as
possibly meeting the targeting criteria, especially
if records are incomplete or contradictory.
Physical inspections should include inspection
of the service lines to and from the water meter,
identification of the piping materials within the
plumbing system and scrapings for lead analysis
of solder from the outside of joints or connec-
tions. Test kits are available to determine the
presence of lead in solder materials. In cases
where there appears to be mixed service line
materials, the PWS should use their best
judgement as to whether the predominant
material is lead. Lead and copper concentrations
in tap or service line samples may be used to
assess the materials present and support the
judgement of the PWS in service line identifica-
tion. Meter readers can be trained to perform
on-site inspections and sample collections.
Identifying and Certifying
Targeted Sampling Sites
Community water systems (CWSs) must
collect lead and copper tap water samples from
sites that meet either Tier 1, 2, or 3 targeting
criteria.
Tier 1:
• SFRs (which includes any NR structures
constructed as a SFR structure, and MFRs
if they comprise more than 20% of the
PWS service connections) with lead
soldered copper pipe installed after 1982,
or interior lead piping; or SFRs served
by a lead service line.
Tier 2:
• MFRs or BLDGs with lead soldered
copper pipe installed after 1982, or interior
lead piping; or serviced by a lead service
line.
Tier 3:
• SFRs (which includes any NR structures
constructed as a SFR structure) with lead
soldered copper pipe installed prior to
1983.
Non-transient, non-community water systems
(NTNCWSs) must collect lead and copper tap
water samples from sites that meet either Tier
1 or 2 targeting criteria.
Tierl:
• BLDGs with lead soldered copper pipe
installed after 1982, or interior lead
piping; or BLDGs served by a lead service
line.
Tier 2:
• BLDGs with lead soldered copper pipe
installed prior to 1983.
The highest priority sites are Tier 1. For
CWSs this means single family residences
(SFRs) or certain non-residential (NRs) locations
which meet the Tier 1 targeting criteria. Non-
residential structures are those constructed in
a similar style and fashion as single-family
residences, but used for commercial purposes,
such as small insurance agencies, law offices,
or boutiques. Multifamily residences (MFRs),
including apartments, can be considered Tier
1 sites when such housing constitutes more than
20 percent of the total service connections in
the community. For NTNCWS Tier 1 sites are
BLDGs with lead soldered copper pipes installed
after 1982.
When Tier 1 or Tier 2 Sites
Cannot Be Found
In cases where a sufficient number of Her 1
sites do not exist or ate unavailable, CWSs must
complete the sampling pool with Tier 2 sites.
In cases where a sufficient number of Tier 1
and Tier 2 sample sites do not exist or are
unavailable, CWSs must complete the sampling
pool with Tier 3 sites.
- 9 -
-------
In cases where a sufficient number of Tier 1
sites do not exist or are unavailable, NTNCWS
must complete the sampling pools with Tier 2
sites.
It is the responsibility of CWSs and
NTNCWSs to demonstrate to the state that a
sufficient number of high priority sites (Tier 1
sites) do not exist, or are inaccessible, and as
a consequence the sample pool must be
completed using lower priority sites (Tier 2 or
Tier 3 sites). Those systems which supplement
their sampling pool with lower priority sites,
and collect samples from those sites, must
explain why they could not identify a sufficient
number of Tier 1 sites before initial monitoring
begins on July 1, 1992. Form 141-A on
page 52 should be submitted to the state to
justify the use of Tier 2 and/or 3 sites.
Illegally Installed Lead
Plumbing Materials
The rule does not require PWSs to target sites
with illegally installed lead solder (Le., installed
after the effective date of the State or local lead
ban). If a system locates a site with illegally
installed lead solder, such a site would qualify
as Tier 1 since it was installed after 1982. If
one of these sites is sampled during a monitor-
ing period, and then found to be in violation
of the lead ban, the results must be included
for that monitoring period. Systems are not
required to conduct extensive investigations to
determine whether buildings built after the
effective date of the state or local lead ban
contain illegally installed lead solder. Such
situations should be rare, and finding these sites
would be time consuming and delay
implementation of the rule. To initially identify
targeted sites, PWSs should identify those SFRs
constructed after 1982 and before the effective
date of their state's lead ban.
When Lead Service Line Sites
Cannot Be Found
Both CWSs and NTNCWSs are required to
develop sampling pools with at least 50 percent
of the sites served by lead service lines. In cases
where a sufficient number of lead service line
sites do not exist or are unavailable, the system
must explain why it could not identify the
necessary number of sites, and submit the
information to the state before initial monitoring
begins. All such systems must collect first draw
tap water samples from all sites identified as
being served by a lead service line. For
example, if a PWS serving 10,001 to 50,000
people can only confirm 10 specific SFRs served
by LSLs willing to participate in the monitoring
program, men this system would have to submit
to the State the reasons for not having at least
20 LSL sites. While EPA expects PWSs to
conduct a thorough review of their distribution
system to identify the location of lead service
lines, PWSs are not expected to excavate their
distribution systems to identify lead service line
locations.
Prioritizing Sampling Sites
After completing a review of all written and
oral records of materials used to construct and
maintain die distribution system (as well as die
structures connected to the system) each PWS
should make the following decisions in order
to identify the highest priority sites in its
distribution system:
• Whether MFRs make up over 20 percent
ofihe total connections served by the PWS,
and if so, include them in the definition
ofaSFR.
• Where SFRs served by T-*T-* are located
in the distribution system.
• Which SFRs instatted copper pipe \vith lead
solder after 1982. Consider the date that
the lead ban went into effect in the PWS
- 10 -
-------
service ana. PWSs may want to bracket
their targeted sampling pool by SFRs built
after 1982 and before the lead ban imple-
mentation date.
• Where potential SFRs with lead interior
piping are located.
• Where any MFRs or BLDGs which
installed copper pipe with lead solder after
1982 are located. Consider the date that
the lead ban went into effect in the PWS
service area. PWSs may want to bracket
their targeted sampling pool by MFRs or
BLDGs constructed after 1982 and before
the lead ban implementation date.
• Where any MFRs/BLDGs with lead interior
plumbing still in place are located.
• Where SFRs built prior to 1983 which have
copper pipe with lead solder are located.
The results of the materials survey can then
be used to determine the Sample Pool Category
most appropriate for the PWS. The sampling
sites are to be selected on the basis of high
priority materials; those sites which have the
greatest likelihood of experiencing high lead
and copper levels. Six possible configurations
of a sample pool may result based on the highest
to the lowest desirability of the type of sites and
the possibility of exceptional cases. The six
configurations are labeled as Sample Pool
Categories A through F, where Category A is
the most desirable configuration of sample sites,
Category E is the least desirable configuration,
and Category F represents the exceptional cases
(see page 12).
TIER1
Category A
All sample sites in Category A and B are
considered high priority sites for lead and/or
copper contamination. They consist of SFRs
with lead interior piping or copper pipe with
lead solder installed after 1982. For those
communities where MFRs make up over
20 percent of the total service connections in
the PWS service area, these structures may be
included in the definition of SFRs for purposes
of the targeted sample pool. Only one sample
point (one unit) per multi-femily residence
should be selected. Any SFR receiving potable
water through a lead service line (LSL) is
considered a high priority site and should be
included. For those systems with a sufficient
number of sites, 50% of their sample pool shall
be SFRs with LSLs and the remaining 50%
should contain lead interior plumbing or copper
pipe with lead solder installed after 1982.
Category B
If a PWS cannot identify enough SFRs with
LSLs to fill 50% of the sample pool, then all
of the available LSL sites from SFRs and MFRs
meeting Tier 1 criteria should be included in
the sample pool. The remainder should consist
of SFRs with lead interior plumbing or copper
pipe with lead solder installed after 1982.
Category C
If a PWS cannot identify any SFRs with LSLs
but does have a sufficient number of SFRs with
lead interior plumbing or copper pipe with lead
solder installed after 1982, then the entire
sample pool should consist of these sites.
TIER 2
Category D
If a PWS cannot identify enough SFRs with
LSLs to fill 50% of the sample pool, and does
not have enough SFRs meeting the criteria in
Categories A through C to fill the y^mple pool,
then the MFRs and/or public or commercial
buildings (BLDGs) having lead interior pipe,
copper pipe with lead solder installed after 1982,
and/or LSL connections may be used to supple-
ment the sample pool.
TIER 3
Category E
If a PWS cannot meet the conditions of the
above categories, then it must fill any
outstanding requirements with SFRs having
copper pipe with lead solder installed prior to
1983.
- 11 -
-------
EXCEPTIONAL CASES
Category F-l
PWSs that only have plastic plumbing, but
cannot demonstrate that the system is "lead-free"
because of the presence of brass faucets should
monitor at SFRs with brass faucets.
Category F-2
PWSs where all available sites have water
softeners should select the highest risk sites
(SFR>82, SFR-Pb, SFR-LSL) and monitor at
these locations even though the water softener
is present.
Sample Collection Methods
Tap Water Samples
All lead and copper tap water samples must
be collected in accordance with the following
criteria:
• first draw
• one-liter volume
• standing time at least six hours
• CWSs must collect samples from the kitch-
en or bathroom tap
• NTNCWSs must collect samples from an
interior tap from which water is consumed
EPA believes a one-liter sample provides the
best representation of typical drinking water
consumption and a more accurate portrayal of
an individual's exposure to lead and copper in
drinking water. A one-liter sample represents
the concentrations of lead and/or copper
throughout the distribution system, and is useful
when evaluating die effectiveness of corrosion
control. A smaller volume of water would only
be representative of a small portion of the
household plumbing and would not indicate if
corrosion control treatment is effective.
EPA believes the 6-hour standing time
requirement is essential because the standing
time of the water in plumbing pipes is one of
the most important determinants of lead and
copper levels found at the tap and because a
significant portion of a person's drinking water
consumption comes from standing water.
Controlling the standing time of the water in
the pipes also is important for reducing the vari-
ability in tap water lead levels. Lead levels show
a rapid increase within the first few hours of
standing in the pipes and then a slower increase
as equilibrium solubility is approached.
First-draw samples need not be collected in
the morning. The water utility personnel can
arrange with the customer to meet them at their
home at a pre-arranged time to collect the
sample.
First-draw samples may be collected by the
water system or the system may allow residents
to collect these samples. EPA believes customers
can be easily instructed on how to properly
collect samples and place them outside for the
water utility personnel. This should reduce the
potential inconvenience of entering homes. If
a PWS chooses to allow homeowners to collect
\csy\ and copper samples, statements of permis-
sion or agreement to participate in the sampling
program should be obtained from the owners
of the property being considered. With each
sampling event, if residents are collecting the
first-draw samples, they will be required to
certify that they were informed about sample
collection procedures. An example of the
instruction sheet with resident certification
statement included is provided on page 15. This
information should be kept on file, but the PWS
need only submit a statement that each tap
sample collected by residents was taken after
the water system informed them of proper
sampling procedures (see Form 141-A on
page 52).
- 12 -
-------
Figure 1. Preferred Sampling Pool Categories for
Targeted Sampling Sites
SAMPLE POOL DESCRIPTION
Most preferred sampling sites pool would consist of ail Single Family
Residences (SFRs)*. wrtti 50% of the sample sites consisting of LSLs and
50% consisting of either intemai lead pipe or copper pipe with lead
solder installed after 1962.
If CATEGORY A sampling pool cannot be achieved, the pool should consist
of all SFR where all identified LSL sites are included and the remainder
of the required samples should consist of tap samples from homes with
lead pipe or copper pipe with lead solder installed after 1982.
If CATEGORIES A and B cannot be met and the utifity can prove that there
are no LSLs in SFRs, 100% of the sample pool should be tap samples
collected from homes with lead pipe or copper pipe with lead solder
installed after 1982.
If enough SFRs with LSLs and lead or copper pipe with lead solder
installed after 1982 cannot be identified to fill the required number of
sample sites, the utility may supplement the pod with sites from Multi-
Family Residences(MFRs) and/or public and private buildings (BLOGs)
supplied by LSLs or lead or copper pipe with lead solder installed after
1982.
If the above categories cannot be fully met then the remainder of the
sites required must be filled with SFRs having copper pipe with lead
solder installed prior to 1983.
LEGEND
[TAP] Tap Samp* SUM Horn SFR«.> 1962
L.LSLJ LSL Samp* Silw from SFR»
MFFVBLDO Tap (> 1982) and LSL Sunp* Sitw
Tap Sampto SM Oom SFRs. < 1983
- 13 -
-------
Figure 1. Preferred Sampling Pool Categories for
Targeted Sampling Sites (Continued)
SAMPLE POOL DESCRIPTION
F
F.1
EXCEPTIONAL CASES
Category F.1 consists of those PWSs that only have plastic interior plumbing
but cannot demonstrate 'lead-free1 conditions due to the presence of brass
faucets. These systems should monitor at SFRs with brass faucets.
F.2
Category F.2 includes those PWSs that only have sites where water
softeners have been installed. These systems should select the highest
risk sites (SFRs>82, SFRs_Pb, SFRs.LSL) and monitor at these locations
even though the water softener is present.
LEGEND
. Plartc inferior pfcjmttng but noc
•LMd-FrW.
WttrMftmnataJUvaflafito
- 14 -
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Suggested Directions for
Homeowner Tap Sample Collection Procedures.
These samples are being collected to determine the contribution of faucet fixtures and household
pipes and/or solder to the lead and copper levels in tap water. This sampling effort is required
by the Environmental Protection Agency, and is being accomplished through the cooperation of
homeowners and residents.
A sample is to be collected after an extended period of stagnant water conditions (i.e., no
water use during this period) within the interior piping. 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 wifl be nude 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 nf fi-8 hour period during which them in net wat*r uaa must he aghW«H pnqf fa Sampling
The water department recommends that either early mornings or evenings upon returning home are
the best sampling times to ensure mat 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 die 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 thi« time to enmire thai all itiformatimi rn^t^in^f nji thf libf! \g TOTTfC*.
5. IF ANY PLUMBING REPAIRS OR REPLACEMENT HAS BEEN DONE IN THE HOME SINCE
THE PREVIOUS SAMPLING EVENT, NOTE THE INFORMATION ON THE LABEL AS PROVIDED.
6. Place the sample kit outside of the residence in the location of the kit's delivery in order that department
staff may pick up the sample kit
7. Results from mis monitoring effort will be provided to participating customers when reports are generated
for the State unless excessive lead and/or copper levels are found. La those cases, «««*•*•** notification
will be provided (usually 10 working days from the time of sample collection).
Call _ at _ if you have any questions regarding
these instructions.
TO BE COMPLETED BY RESIDENT
Water was last used: Time Date
Sample was collected: Time Date_
I have read the above directions and have taken a tap sample in accordance with these directions.
Date
Signature
- 15 -
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The procedure for collecting samples is
simple. A clean, plastic, one-liter sample bottle
should be placed below the spout of the cold
water tap in the kitchen (or bathroom). The cold
water tap should be turned on gently to maintain
low flow conditions during the sample
collection. It should take approximately 45
seconds to fill the bottle. The sample bottle
should be filled to the one-liter level marked
on the container, and then capped. To avoid
problems of residents handling nitric acid,
acidification of first draw samples may be done
by laboratory personnel up- to 14 days after the
sample is collected. Neither the homeowners
nor the sample collectors should handle nitric
acid used for sample acidification. For those
systems that do not use disposable sample
bottles, care must be taken to assure that the
glassware used in each of the sample handling
steps is free of trace amounts of lead and copper
since it can introduce a significant degree of
analytic error. To reduce errors, especially in
cases where very low lead concentrations are
expected, acid soak all appropriate glassware
for 2 hours prior to use. The recommended
acid-soaking procedure is one part nitric acid,
two parts hydrochlonc acid, and nine parts good
quality laboratory water, such as deionized
water.
EPA understands the concern with ensuring
that customers have properly collected the
samples, but anticipates that customers willing
to participate will collect the samples correctly
when given proper instruction. EPA believes
most consumers are concerned with tap water
lead and copper levels to which they may be
exposed and, consequently, will want to
participate. Systems allowing residents to collect
samples may not challenge the accuracy of the
sampling results in any subsequent administra-
tive or civil enforcement proceedings or citizen
suit on the grounds that errors were committed
by the customer during sampling.
Each PWS must collect first-draw samples for
lead and copper from the same sampling site
from which it collected all previous samples.
If the system cannot gain entry to a sampling
site to collect a Mow-up tap sample, the system
may collect the follow-up sample from another
sampling site. When reporting these samples
the system must explain why the site has been
changed and why the new site was selected. The
new site must meet the same targeting criteria
and be within reasonable proximity of the
original sampling site.
The lead and copper action levels are based
on total lead and copper. Metals can be present
in several forms in a sample of water soluble,
paniculate, or as a dissolved constituent but
adsorbed onto a particle. The analyses for total
metals include steps which make each form of
the metal available for measurement. This is
accomplished by first acidifying the sample to
approximately a pH 2 through the addition of
nitric acid (see third footnote of Table 5).
Particulate lead and copper dissolve and enter
solution under these low pH conditions. The
sample is then subjected to a digestion step
which applies elevated temperatures and
agitation to further dissolve paniculate and
adsorbed lead and copper and to concentrate
their presence in a smaller volume of sample
for analysis. Digestion is required.
PWSs finding unusually high lead or copper
levels in any samples should consider performing
filtered lead and copper analyses in the future
in addition to the total analyses. Sample
collection can cause particulates to be sheared
from the pipe walls causing sporadic spikes in
lead and copper levels found in the monitoring
program. Results from recent corrosion control
studies have confirmed that lead solder can
become 'flaky' and release particulates into first-
draw tap samples (Neukrug, 1991). Identifying
elevated metal levels as particulates may assist
PWSs and States in targeting appropriate actions
- 16 -
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Table 2. Sample Handling Requirements for Lead,
Copper, and Water Quality Parameters
Contaminant or
Parameters
Lead
Copper
pH
Conductivity
Calcium
Alkalinity
Orthophosphate
Silica
Temperature
Preservative
Cone. HN03topH <23
Cone. HN03topH <23
None
*
Cool, 4°C
Cone. HN03topH <25
Cool, 4°C
Cool, 4°C
Cool, 4°C
None
Container1
PorG
PorG
PorG
PorG
PorG
PorG
PorG
P only
PorG
Maximum Holding
Time*
6 months
6 months
Test Immediately*
28 days
6 months
1 4 days
48 hours
28 days
Test Immediately4
P - Plastic, hard or soft; G - Glass, hard or toft.
In all cases, Mmplaa should ba analyzed as soon aftar collection as possible.
If HNO, cannot ba used because of shipping restrictions or is not used tx
i hornet
rs are cosseting samples, ths sample
for analysis can ba shipped to a laboratory where it must be acidified (generally to pH < 2) with concentrated HNO, as soon
as possible but not later than 14 days aftar cample collection. Sample must stand in the original container used for sampling
for at least 28 hours aftar aoidrScation. Laboratories should match ths acid matrix of their samples, qualty control, and caferation
standards for accurate results. The latter two sett of solutions wil have the same, fixed concentration of acid, rt la recommended
that good laboratory practice would ba to determine by prior tests ths amount of add necessary to achieve some pH <2,
and make it consistent with the standards used. For instance, for most waters, the previous EPA recommendation of 0.15%
v/v of HNO, wM result in a pH < 2. Therefore, aH samples can be automatically preserved with 1.5 mL of the acid, and all
standarda can be made with the same acid concentration. In some extreme, high-akaSnrty cssss, more acid may be necessary.
* 'Test imndlatalv" janaia>» miens within 15 minutes of sample collection. In the eass of pH, the sample should be measured
as soon aa the sample ie taken and should ba measured under closes system conditions, particularly if the water is poorly
buffered.
6 If HNO, cannot be uaed because of shipping restrictions or safety concerns for sampling personnel, the sample for analysis
may be initially preserved by icing and immediately shipping it to the laboratory. Upon receipt in the laboratory, the sample
must be acidified with concentrated HNO, to pH < 2.
- 17 -
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and assessing treatment performance. Filtered
metal analysis requires the use of special
procedures. [Reference* for dissolved metal analysis
are: Schock and Gtnlek, 1983, JAWWA, 75<2):87; Harri-
son, R.M. A P.H. Laxen, 1980, Nature (August 21):791-
793; deMora, SJ. et al., 1987, Water Res. 21(l):83-94;
Brach, R.A., et al., 1991, Proc. AWWA Annual Conf.
(Philadelphia); Hulsmann, A.D., 1990,7WEM(Feb.): 19-25.]
Split-sampling must be used to generate filtered
and total metal analyses. Regardless of the
filtered analysis results, the total metal content
measured must be reported to the State.
Lead Service Line Samples
A one-liter sample representing water from
the service line which has been standing for at
least six hours may be collected by those
systems required to implement a LSL replace-
ment program. In cases where LSLs are
sampled, LSLs which do not exceed the lead
AL need not be replaced. Three methods are
available for collecting LSL samples: (1)
flushing a specified volume from the kitchen
tap; (2) direct sampling of the service line; and,
(3) flushing the kitchen tap until a change in
temperature is noted. Acidification of the sample
should be completed by the laboratory personnel
upon receipt of the sample, but in no case later
than 14 days after sample collection. Neither
the homeowners nor the sample collector should
handle the nitric acid used for sample
acidification.
Flushing a Specified Volume
After completing a field inspection of the
site, the length aad diameter of piping from the
kitchen tap to die service connection and the
length and Hiam^y of the service connection
itself should be estimated. Flushing the esti-
mated volume is necessary to receive service
connection water at the kitchen tap. Open the
tap and flush the estimated volume into a
graduated beaker or cylinder, men close the tap.
Collect a one-liter sample from the sampling
tap by filling the sample bottle to the one-liter
mark, then cap immediately. EPA believes that
utility personnel should collect samples when
using this approach due to the potential difficul-
ties in accurately estimating the volume
necessary to collect the LSL sample.
Direct Service Line Samples
If the LSL is accessible, or can be made
accessible, a tap could be installed directly into
the line for sample collection purposes. The
sample tap should be constructed of all lead-free
materials, definitely avoiding brass. A copper
or plastic fitting with plastic piping to the tap
would be lead-free.
The installation of a tap directly into the LSL
could disturb the pipe conditions and induce
additional corrosion activity by destroying
established, protective layers or by introducing
galvanic reactions. The expense of installing
taps into service lines could make this option
infeasible. It would make little sense to dig up
service lines to install a sample tap, when the
line itself may need to be replaced due to the
results of the sampling effort. This option is
not recommended unless existing taps to the
service line are in place.
Where a tap is installed, the line should be
flushed for several hours to ensure that any
debris caused by installation is removed so as
to not effect sampling results. After flushing,
the water must stand in contact with the LSL
for at least six hours before sampling. In those
communities where the meters are located
outside the buildings (or unmetered areas) taps
may already exist on the service lines. When
samples are to be collected, the water should
be run initially to flush the pipe connecting the
faucet and the service line. That is, the faucet
may be located some distance from the service
line and connected by a length of pipe which
should be flushed prior to collecting the LSL
sample. For example, exterior faucets often tap
directly into the service line, but a short distance
of piping connects the faucet to the service line.
- 18 -
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Table 3. Pipe Volume Table (Volumes Listed in Liters)
. 5'i -'
-rr
Pip* Length (Fee*)
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
25
30
35
40
60
Pipe DoBMtor On.)
3/8
.06
.09
.11
.14
.17
.20
.23
.26
.28
.31
.34
.37
.40
.43
.46
.49
.51
.54
.57
.71
.86
1.00
1.14
1.43
1/2
.09
.14
.18
.23
.27
.32
.36
.41
.45
.50
.55
.59
.64
.68
.73
.78
.82
.86
.91
1.14
1.36
1.59
1.82
2.27
5/8
.14
.21
.27
.34
.41
.48
.55
.62
.69
.75
.82
.89
.96
1.03
1.10
1.16
1.23
1.30
1.37
1.71
2.06
2.40
2.74
3.43
3/4
.19
.29
.38
.48
.57
.67
.76
.86
.95
1.05
1.14
1.24
1.33
1.43
1.52
1.62
1.71
1.81
1.90
2.38
2.85
3.33
3.80
4.76
1
.32
.49
.65
.81
.97
1.14
1.30
1.46
1.62
1.78
1.95
2.11
2.26
2.43
2.60
2.76
2.92
3.08
3.24
4.06
4.87
5.68
6.49
8.11
! 1-1/4
.50
.74
.99
1.24
1.48
1.73
1.98
2.22
2.47
2.72
2.96
3.21
3.46
3.71
3.95
4.20
4.45
4.70
4.94
6.18
7.41
8.65
9.88
12.36
Notes:
1 . Volumes cm be added together for pipe lengths not listed.
2. Liters can be converted to gallons by dividing by 3.785.
- 19 -
-------
Temperature Variation
This method for collecting a LSL sample is
recommended for those cases when a clear
delineation in LSL and interior piping
temperatures can be discerned. During winter
months, water held in the interior plumbing of
a heated home will be significantly warmer than
the water standing in a service line. There are,
however, some locations where this method
should not be relied upon for LSL sampling.
In temperate climates the difference in water
temperatures may not be distinguishable. Homes
with a crawl space instead of a basement may
have colder water in the crawl space than in
the interior plumbing. For temperature variation
sampling, the sample collector should gently
open the kitchen tap and run the water at a
normal flowrate, keeping a hand/finger under
the flowing water. When a change in water
temperature is detected, a one-liter sample
should be collected by filling the sample bottle
to the appropriate level and capping.
Data Analysis and
Interpretation
The concentration of lead and copper in
consumers' tap water exhibits a log-normal
distribution. The interpretation of the
monitoring results must consider the skewed
nature of typical results. If a frequency distribu-
tion of lead and copper levels found from tap
monitoring were to be developed, most systems
would find a large number of samples with low
concentrations.. Some systems might find that
they also experience extremely high concen-
trations of lead, but only at a limited number
of sites and the behavior of the high lead levels
is inconsistent. The nature of lead and copper
monitoring results does not lend itself to the
typical data analyses used by utilities.
Consequently, the average concentration is not
a very useful measurement of the behavior of
lead and copper levels experienced in the
distribution system because it can be overly
influenced by a large number of low
concentrations and a few extremely high
concentrations. For this reason, distribution
frequency or the percent of samples below or
above a specified value proves most useful in
analyzing lead and copper data. This is the basis
for the ALs being based on a certain frequency
of samples which have lead and copper levels
less than 0.015 mg/L and 1.3 mg/L,
respectively.
Action levels are exceeded if the "90th
percentile" value is greater than 0.015 mg/L
for lead and 1.3 mg/L for copper. To determine
whether the monitoring results meet the action
levels stipulated for lead and copper, list the
collected data from the highest value recorded
to the lowest value recorded. The 90th percentile
values for lead and copper can be determined
by multiplying the number of samples taken by
0.9. This number is the position of the 90th
percentile value. Starting from the bottom
(lowest value) count up until the calculated
number (0.9 x # samples) is reached. The
sample value in this number position is the 90th
percentile value. The 90th percentile values for
lead and copper can be determined by moving
down the listed values the number of positions
indicated in Table 4 for each water system size.
Interpolation of lead and copper levels may
be necessary in some cases to determine system
performance at the desired frequency. If the
90th percentile value is represented by a sample
position other than an integer, (e.g. 0.9 x
# samples = 17.3), then the 90th percentile
value must be found by interpolating the results
of the lower and higher samples (e.g., the 17th
and 18th results in this case). The rounding
convention to be used when interpolating
between two analytical results is as follows:
all results greater than or equal to 0.5 units
round to the next unit, and results less than 0.5
units round down.
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Table 4. Determination of 90th Percentile Values
for Lead and Copper Monitoring Results
System Size
10,001 to 50,000
Minimum No. Sample*
Required
initial, FoBow-Up,
and Routine
Monitoring
60
Reduced
Monitoring
30
90% Value Position from
Bottom of List
Initial, Foflow-Up,
end Routine
Monitoring
54
Reduced
Monitoring
27
Number and Frequency of
Sampling
Initial Monitoring
Initial monitoring for medium PWSs begins
July 1, 1992. Initial monitoring periods are
6 months in length. During each monitoring
period each medium PWS must collect at least
60 tap samples for lead and copper (Pb/Cu-
TAP) at targeted sampling sites. A medium
PWS that exceeds an action level must also
collect WQP samples at representative sites in
the distribution system and at each entry point
Follow-Up Monitoring
All medium PWSs required to install optimal
corrosion control treatment by the state must
collect follow-up lead and copper tap water
samples. Follow-up monitoring consists of two
consecutive six-month monitoring periods.
During each monitoring period a medium PWS
must collect at least 60 tap water samples for
Lead and copper (Pb/Cu-TAP) at targeted
sampling sites. A medium PWS that exceeds
an action level must also collect WQP samples
at representative sites in the distribution system
and at each entry point (see routine monitoring).
A medium PWS that meets both action levels
during each six-month monitoring period may
reduce tap water sampling.
Routine Monitoring
Routine lead and copper tap water sampling
is conducted by each medium PWS after the
state establishes WQP values. Such systems must
collect lead and copper tap water samples and
WQP-DIS and WQP-POE samples. The lead
and copper tap water samples are collected
biannually to measure potential exposure after
optimal treatment has been installed. The
WQP-DIS and WQP-POE samples are collected
to insure a water system is continuing to operate
with optimal corrosion control treatment in
place. Routine WQP-DIS samples are collected
biannually. Routine WQP-POE samples are
collected every two weeks. Each PWS must
continue to meet all WQP values established
by the state during each subsequent monitoring
period to remain in compliance with the rules.
After a system complies with state specified
WQPs for two consecutive six month monitoring
periods it may request mat the state reduce lead
and copper tap water sampling.
Reduced Monitoring
A medium PWS that meets the lead and
copper action level for two consecutive
six-month monitoring periods after installing
optimal corrosion control treatment may reduce
the number of lead and copper tap water samples
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it collects from 60 to 30, and reduce the
frequency of collection from biannual to annual.
A medium PWS that meets the lead and
copper action levels for three consecutive years
may reduce the frequency with which it collects
30 lead and copper tap water samples from
annual to triennial.
A medium PWS that exceeds the lead or
copper action level after installing optimal
corrosion control treatment, but operates in
accordance with state-specified WQPs during
each of two consecutive six-month monitoring
periods, may request that the state reduce the
required number of lead and copper tap water
samples from 60 to 30, and reduce the
frequency of collection from biannual to annual.
A medium PWS that exceeds the lead or
copper action level, but operates in accordance
with state specified WQPs for three years (six
consecutive six-month monitoring periods), may
request that the state reduce the frequency with
which the PWS collects 30 lead and copper tap
water samples from annual to triennial. The
state must respond in writing to a water system's
request to reduce the number and frequency of
lead and copper tap water monitoring.
A water system sampling less frequently man
once every six months must collect tap water
samples for lead and copper during the months
of June, July, August, or September. Form
141-B on page 55 provides water systems with
an easy way of requesting a reduction in lead
and copper tap water monitoring.
Reporting Samples
All medium PWSs must report several pieces
of information for all lead and copper tap water
samples within the first 10 days of the end of
each monitoring period (i.e., semiannually,
annually, triennialry).
Each PWS must report the results of all tap
water samples for lead and copper, the location
of each site, and the targeting criteria under
which the site was selected for the system's
sampling pool.
Each PWS must report the 90th percentile
lead and copper concentrations measured from
among all lead and copper tap water samples
collected during each monitoring period.
Each PWS must certify that each first draw
sample that has been collected is one-liter in
volume and to the best of its knowledge, has
stood motionless in the service line, or in the
interior plumbing of a sampling site, for at least
six hours.
Each PWS must, where residents collect
samples, certify that each tap sample collected
by the residents has been taken after the water
system informed them of proper sampling proce-
dures.
With the exception of tap samples collected
during each water system's first monitoring
period, each PWS must designate any site which
was not sampled during previous monitoring
periods, and include an explanation of why the
sampling site(s) has changed. Form 141-A on
page 52 provides water systems with a simple
and concise way of reporting this information
to the state.
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Water Quality Parameter Monitoring
1141.87
Any medium PWS that exceeds an action
level must collect WQP samples. Water quality
parameters such as pH, alkalinity, calcium and
inhibitor residuals are important to measure
when identifying optimal corrosion control
treatment, evaluating the effectiveness of the
treatment, and determining a system's com-
pliance with the rules. WQPs are measured at
representative sites in the distribution system
(WQP-DIS) and at each entry point to the
distribution system (WQP-POE) for several
reasons.
First, measuring WQPs provides baseline
data on current corrosion control treatment.
Without WQP data, PWSs will have no
information on which to base comparative
corrosion control treatment evaluations. States
will have no way of evaluating existing water
quality conditions, which will limit their ability
to evaluate the effectiveness of alternative
treatments.
Second, the WQPs are needed to assess the
effectiveness of corrosion control treatment.
After installing optimal treatment, states are
required to designate values, or ranges of
values, for applicable WQPs measured at taps
in the distribution system, and concentrations
or dosage rates, measured at the entry points
to the distribution system for chemicals used
to maintain optimal corrosion control. The
purpose of «>mpKng at both locations is for a
system and the state to have an indication of
water quality changes as water travels through-
out the system. If the difference in the values
between the plant and the field is small, it is
a good indication that the levels for the parame-
ters are being maintained throughout the system.
If there is a large difference in the values or
if they are volatile over time, this could indicate
mat the system may need to adjust its treatment
to stabilize water quality or maintain higher
values for parameters at the treatment plant.
Third, the WQP measurements collected in
the distribution system and at each entry point
are needed to determine compliance with the
corrosion control treatment requirements. The
most reliable indicator of whether a water
system is continually operating with optimal
corrosion control treatment in place, and thereby
complying with the requirements of the rule,
is to measure the set of WQPs (both DIS and
POE) established by the state. Systems main-
taining state-specified values in die distribution
system and at each entry point to the system
remain in compliance with the rule. Systems
that do not maintain these values are in violation
of the rule.
The WQP monitoring requirements are
presented in five sections: (1) selecting
representative sampling sites; (2) sample
collection methods; (3) number and frequency
of monitoring; (4) reduced monitoring; and (5)
reporting.
Selecting Representative
Sampling Sites
When identifying representative sampling
sites throughout the distribution system a water
supplier must consider: (1) the size of the
population served; (2) the different sources of
water from which the supplier draws water, (3)
the different treatment methods used by the
supplier, and (4) the effect of seasonal variability
on treatment.
Samples collected at entry points to the
distribution system must be collected from
- 23 -
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locations representative of each source of water
after treatment. If a system draws water from
more than one source and the sources are
combined before distribution, the system must
sample at points in die distribution system where
the water is representative of all sources being
used.
Tap sampling for WQP-DIS is not required
at sampling sites targeted for lead and copper.
The Agency recommends that systems collect
WQP-DIS samples at colifonn sites because they
should be representative of water quality
throughout the distribution system and be easy
to access. The advantages associated with using
these sites are (1) access is available since the
PWS is currently using the sampling locations;
(2) personnel are already in place to perform
monitoring at these sites; and (3) the locations
should be representative of the distribution
system conditions as required by the Total Coli-
form Rule.
Sample Collection Methods
Distribution system samples for alkalinity,
calcium, conductivity, orthophosphale, and ^Kga
will require two samples of approximately 500
mL each to be collected. Fully flush the sample
tap prior to collection of the sample. If the PWS
collects these samples from the same location
as coliform and disinfectant residual samples,
then samples should be collected in the
following manner:
• Fully flush the sample tap and collect
the conform sample;
• CoUea a sample to measure disinfectant
residual;
• Collect and analyze a sample for
temperature andpH;
• Collect the samples for the other water
quality parameter analyses.
The water quality parameter samples to be
brought back to the laboratory for analysis
should be stored separately from the coliform
samples to prevent contamination. In all cases,
store in a cool environment until analyzed.
To reduce any sampling error or site-specific
influences on WQP-DIS monitoring results,
several general steps and conditions should be
considered when sampling. First, avoid areas
of the distribution system where maintenance
or flushing is being conducted as water quality
upsets are likely to be encountered. Since the
purpose of WQP-DIS monitoring is to identify
the typical conditions existing in the distribution
system, introducing anomalous data would only
add confusion and error to data analyses and
interpretations.
Second, select distribution system sites which
are distributed throughout the entire service area
to include locations representing the distribution
system characteristics as follows, ranked by
relative importance to site-selection decisions:
(1) in the vicinity of targeted tap monitoring
sites, (2) detention time within the distribution
system, (3) within distinct pressure zone, (4)
distribution system materials, (5) relationship
to supplemental chlorination feed points, and
(6) ground or elevated storage locations.
Third, if fire hydrants or other distribution
system fixtures are in the vicinity of a sampling
site, fully flush the sample tap prior to collecting
the sample.
Fourth, samplers should always record their
observations about color, suspended solids, and
the flushing time required prior to achieving
acceptable sampling conditions to assist in the
interpretation of the analytical results and overall
distribution system behavior.
Water Quality Parameter
Analyses
pH and water temperature analyses can be
performed in the field. Conductivity may be
performed either in the field or laboratory.
- 24 -
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Temperature may be measured either by a
hand-held thermometer or by a combined
temperature/pH electrode and meter. In all
cases, pH measurements must use a pH elec-
trode and meter. All of the remaining WQP
analyses should be performed by a laboratory.
EPA believes that pH and temperature
measurements should be collected on-site for
the following reasons. First, temperature
variations during transport do occur, invalidating
any laboratory measurements of temperature
and introducing error into the pH analysis.
Temperature differentials of 5 to 10°C can
introduce substantial shifts in pH. Since
correcting for such error is difficult, EPA
believes that taking field measurements for pH
and temperature simplifies the efforts for PWSs
and provides higher confidence in the data.
Second, chemical changes may occur within
the sample during transport which could
introduce variability in the pH measurements.
The loss and/or gain of carbon dioxide from
solution can result in pH increases and/or
decreases, respectively. Additionally, continued
disinfectant residual reactions can induce pH
shifts.
Colorimetric analyses for pH do not produce
sufficiently accurate results, and as such, are
not approved analytic methods for pH analysis.
These methods are subject to several shortcom-
ings: (l)each field sampler subjectively judges
the results, such mat large variability in the data
can be found among sample sites and sampling
events; (2) the reagents used in the analysis
degrade over time, increasing the likelihood of
error being introduced into the results; and (3)
under ideal conditions, the accuracy of the
method is only ± 0.2 pH units.
The minimum sample volumes recommended
for the water quality parameters in "Methods
for Chemical Analysis of Water and Wastes"
[USEPA, 1983, •Method* fat Chemical Analyn* of Water
and Wastes'. EPA 600/4-79-020] 316 presented below.
Conductivity
PH
Temperature
Calcium
Orthopaosplute
Silica
Alkalinity
50 mL
25 mL
1000 mL
100 mL
50 mL
50 mL
100 mL
Since temperature and pH are to be measured
in the field, a single sample may be used for
their analysis. PWSs with poorly buffered water
supplies may consider performing pH analyses
under a "closed system" to reduce measurement
shift and increase the accuracy of the pH
analyses [Schock,M., «t«i., WSQ,JAWWA, 72(5):304;
Schock, M. and S.C. Schoclc, 1982, Water Research,
16:1455]. Under no circumstances should the pH
electrodes, conductivity probes, or thermometers
be placed in samples that are to be analyzed
for the other water quality parameters.
Plastic or glass containers can be used when
collecting WQP samples except if silica analyses
are required, where only plastic may be used.
Since temperature and pH measurements are
performed in the field, the other water quality
parameters will require two samples of approxi-
mately 500 mL each to be collected (this
assumes that either orthophosphate or silica is
included). These volumes are based upon the
recommendation that at least twice this minimum
volume be collected, permitting replicate
analyses if desired. Two samples are required
because calcium analysis is to be performed
using a separate sample in order to acidify the
sample prior to measurement. It is further
recommended that the sample acidification step
for calcium be performed in the laboratory by
trained personnel upon receipt of the sample.
It should be noted that if orthophosphate is to
be measured, this analysis must be performed
within 48 hours of sample collection.
- 25 -
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Before beginning the distribution system
sampling, the pH electrode should be calibrated
at pH 7.0 and a second pH level, either 4.0 or
10.0, depending on the pH range typically found
within the distribution system. For most
systems, the second pH level for calibration
should be pH 10.0. For more accurate results,
the pH standard solution used for calibration
should be near the temperature anticipated for
the water in the distribution system even if the
pH meter is temperature compensated. In most
cases, the temperature of the finished water will
be representative of the temperature found in
the distribution system. To attain the desired
temperature, a small amount of buffer solution
could be placed in a closed container in a flow-
through water bath overnight.
During transport, the pH probe should be
placed in a sample bottle and secured in the
vehicle. The pH probe membranes are very
delicate, and they should not come in contact
with hard surfaces or be allowed to dry out.
It may be a good idea to pack a replacement
probe (calibrated prior to leaving) in case
problems are experienced with the primary
probe.
During sample collection for the water quality
parameters, care should be taken to avoid over-
agitation of die water sample. Remove the faucet
aerator, and run the water gently to flush the
line prior to sample collection. Fill the sample
bottle to slightly overflowing. A closed-system
sample bottle, (terigped to insert the thermome-
ter and/or pH probe, should be used to reduce
measurement error. If using a hand-held
thermometer, insert it in the sample and record
the reading when it atahiiirgq After removing
the thermometer, insert the pH electrode
immediately. If using a combined electrode,
insert it into the sample bottle directly after
filling it and measure the sample temperature.
After recording the temperature, change the
meter to reading pH levels. Gently rotate the
bottle with the probe inside until the pH reading
stabilizes; this could take several minutes. When
stable, record the measurement, rinse the
electrode with deionized water and replace it
in its holding bottle. When the temperature and
pH measurements are completed, discard the
sample. Recalibrate the pH probe if not used
over an extended period of time to adjust any
measurement shift which may have occurred
and record this information.
While small changes in the levels of
conductivity, alkalinity, calcium, orthophos-
phate, and silica may occur between the time
of a sample's original collection and its analysis
in the laboratory, the error introduced by the
delay should be negligible as long as the sample
bottles are fully filled, kept cool throughout the
day, and the handling practices summarized in
Table 2 are followed. If these parameters are
measured as part of the normal operating
practices of the utility, then the distribution
system and entry point water samples should
be analyzed in exactly the same fashion and by
the same personnel. This will allow the data
collected to be directly comparable to water
quality data collected throughout the water
treatment plant.
For those PWSs which apply a phosphate-
based corrosion inhibitor, measurement of
orthophosphate is required. These samples must
be unfUtered with no digestion or hydrolysis
step performed. The direct coJorimetric approach
is required. This method prevents the conversion
of polyphosphate constituents to the
orthophosphate form prior to measurement.
However, polyphosphates which have converted
to orthophosphate in the distribution system will
be detected by this scheme. The inclusion of
polyphosphates in the measurement of ortho-
phosphate would over-estimate the active
corrosion protection being provided.
The water quality parameter data, including
pH data, collected from distribution system
monitoring should be organized and stored in
a permanent data file by sampling location so
- 26 -
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that they can be directly compared with lead
and copper results from nearby locations. The
average, maximum arxl minimum values found
for each water quality parameter should be
determined for each site over time as well as
for the distribution system overall for each
monitoring period.
Storing water quality data on a computer
database would be extremely helpful and
efficient for large and medium PWSs. If the
water quality data is stored on a computer
database, long-term trend analysis of the water
quality data could be performed. Such an
analysis might include an assessment of the
relative changes in water quality parameters
before and after treatment modifications;
changes experienced between segments of the
service area; and the relationship between source
water quality and distribution system water
quality in terms of the stability of water quality
parameters within the service area.
Number and Frequency of
WQP Sampling
WQP Sampling Before
Installing Optimal Corrosion
Control Treatment
During the first monitoring period in which
a medium PWS exceeds an action level the PWS
must collect two samples for each of the fol-
lowing WQPs at 10 sampling sites in the
distribution system and at each entry point to
the distribution system:
pH
alkalinity
calcium
conductivity
water temperature
orthophosphate, when a phosphate
inhibitor is used
silica, when a silicate inhibitor is used
Fewer WQP samples must be collected to
accurately characterize the quality of water
throughout the distribution system because these
parameters do not vary to the same extent as
lead and copper levels. Systems should attempt
to collect two samples at each sampling site in
the distribution system as far apart in time as
possible to capture any seasonal changes that
may occur. Water systems should also collect
WQP-DIS samples and WQP-POE samples at
die same approximate time during each monitor-
ing period so that correlations can be drawn
that are not distorted by seasonal effects.
WQP Sampling After
Installing Optimal Corrosion
Control Treatment and After
the State Specifies
Numerical Values
Each medium PWS that exceeds an action
level after installing optimal corrosion control
treatment must collect two samples for each
of the following WQPs at 10 sampling sites in
the distribution system during each six-month
monitoring period in which die system exceeds
the action level:
• pH
• alkalinity
• calcium, when calcium carbonate
stabilization is used
• orthophosphate, when a phosphate
inhibitor is used
• silica, when a silicate inhibitor is used
EPA believes that these samples, collected
in conjunction with the lead and copper tap
water samples, are necessary to determine the
effectiveness of corrosion control treatment,
and to determine whether additional adjustments
in treatment are necessary or feasible. States
have the discretion to require systems to measure
additional WQPs.
- 27 -
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Each medium PWS that exceeds an action
level after installing optimal corrosion control
treatment must collect one sample for each of
the following WQPs at each entry point to the
distribution system every two weeks:
• pH
• the concentration of alkalinity, when it
is adjusted
• the concentration oforihophosphate or
silica (whichever is applicable) when
an inhibitor is used
EPA believes requiring measurements at each
entry point to the distribution system every two
weeks is important to evaluate fluctuations in
these parameters and to assist in establishing
operational targets for water systems to maintain
optimal treatment.
A PWS may take a confirmation sample for
any WQP value within three days after receiving
the results of die first sample. If a confirmation
sample is collected the result of the two samples
must be averaged for the purpose of determining
compliance with the state-specified parameter.
Reduced WQP Sampling
Each medium PWS that maintains die range
of values for each state-specified WQP for two
consecutive six-month monitoring periods must
continue to collect two WQP-DIS samples
during each six-month monitoring period, but
may reduce the number of sites from which it
collects samples from 10 to 7.
A medium PWS that n^intains the range of
values for state-specified WQPs for six consec-
utive six-month monitoring periods may reduce
the frequency with which it collects WQP-DIS
samples from biannual to annual.
A medium PWS that maintains the range of
values for state-specified WQPs for three
consecutive years may reduce the frequency with
which it collects WQP-DIS samples from annual
to triennial.
Any water system that collects WQP-DIS
samples annually or triennially must collect
samples that reflect the seasonal variability to
which corrosion control treatment is subject.
Water systems may not reduce the number or
frequency of WQP-POE samples. A water
system that fails to operate within the range of
values established by the state for any WQP
must resume collecting WQP-DIS samples at
10 sites every 6 months.
States are required to review and revise water
quality parameter determinations when a system
submits new monitoring or treatment data, or
when other data relevant to the number and
frequency of tap sampling becomes available.
Reporting WQP Samples
All medium PWSs that collect WQP samples
must report die results of all tap water samples
collected at representative sites in the
distribution system for all applicable WQPs,
and all source water samples collected at each
entry point to the distribution system for all
applicable WQPs. These results must be
submitted to the state no later than 10 days
following the end of each monitoring period
(i.e., bimonthly, biannually, annually,
triennially).
Cessation of WQP Samples
A medium PWS can stop cofecting WQP-DIS
and WQP-POE samples in any monitoring
period in which it meets the lead and copper
action levels. If a PWS exceeds an action level
in a future monitoring period, the PWS must
recommence WQP monitoring.
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Lead and Copper Source Water Monitoring
§141.88
The final rule requires all water systems that
exceed the lead or copper action level to collect
source water samples at each entry point to the
distribution system. The purpose of monitoring
for lead and copper at each entry point to the
distribution system is to assist systems in
designing an overall treatment plan for reducing
the concentrations of each contaminant in tap
water. These samples will also be used by the
states to determine whether a system must install
treatment to minimize tun water lead ^fx* copper
levels, and to determine whether a system is
maintaining maximum permissible lead and
copper levels in source water.
In those instances where the state requires
a water system to install source water treatment,
the system has 24 months to complete installa-
tion and an additional 12 months to collect fol-
low-up samples to determine the effectiveness
of that treatment. Once treatment is '"stalled
and follow-up samples collected, the state will
establish maximum permissible lead and copper
levels. From that point on, the system must
monitor in accordance with the standardized
monitoring framework (SMF) established for
inorganic contaminants to insure lead and copper
levels are maintained below the state-specified
contaminant levels.
The lead and copper source water monitoring
requirements are presented in five sections:
(1) sample collection methods; (2) number and
frequency of monitoring; (3) reduced monitor-
ing; (4) reporting; and (5) cessation of source
water monitoring.
Sample Collection Methods
Groundwater systems must collect at least
one sample at each entry point to the distribution
system, which is representative of each well.
For groundwater systems with separate entrances
to the distribution system from either individual
wells or wellfields, a sample must be collected
from each discrete entrance point. If new
sampling taps to wells are required, it would
be best not to use brass. If brass taps are
installed, then the line should be adequately
flushed prior to sampling to ensure the sample
is representative of the source. States have the
discretion to identify an individual well for
monitoring (when there is no treatment or
blending) for those PWSs using multiple wells
that draw from the same aquifer.
Surface water systems must collect at least
one sample at each entry point to the distribution
system which is representative of each water
source. For surface water systems, source water
samples may be collected after storage or at the
high service pumps. Groundwater and surface
water systems must take each repeat sample at
the y*"g sampling point unless conditions make
sampling at another point more representative
of each source or treatment plant. Any water
system that draws water from multiple sources
that are combined before distribution must
sample at entry points to the distribution system
that are representative of the quality of water
in all sources being used. All water systems
must report the results of all lead and copper
source water samples within the first 10 days
of the end of each monitoring period (i.e.,
biannually, annually, per compliance period,
per compliance cycle).
The state may reduce the total number of
samples that must be analyzed by allowing
systems to composite. Systems may composite
as many as five samples. Compositing must be
conducted in the laboratory. If the concentration
in the composite sample is greater than or equal
to the detection limit for lead (0.001 mg/L) or
copper (0.001 mg/L, or 0.020 mg/L when
- 29 -
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atomic absorption direct aspiration is used), then
the system must collect follow-up samples from
each point included in the composite. The
system must collect these samples within 14
days of determining the detection limit is
exceeded. Systems serving > 3,300 persons may
only composite with samples from a single
system.
Number and Frequency of
Lead and Copper Sampling
Lead and Copper Sampling
After System Exceeds an
Action Level
Any water system that meets both the lead
and copper action levels in tap water sampling
is not required to collect source water samples
for lead and copper.
Within six months of exceeding the lead or
copper action level, a system must collect one
sample at each entry point to the distribution
system and submit the results to the state. In
addition to the results of source water moni-
toring, the systems must submit a source water
treatment recommendation to the state for
review and approval. On the basis of the results
of source water monitoring, the state will either
approve the water system's 1|g?<|||p>lt recommen-
dation, require the system to install an alterna-
tive treatment, or allow the system to forego
source water treatment altogether. In cases
where the state believes that more information
would be useful, it may require the water system
to collect additional source water samples.
Lead and Copper Sampling
After System Installs Source
Water Treatment
Any water system that is required to install
source water treatment must collect one lead
and copper sample from each entry point to the
distribution system during two consecutive six
month monitoring periods after treatment has
been installed and is being operated. The system
must submit the monitoring results to the state,
and the state must establish maximum
permissible source water levels for lead and
copper.
Lead and Copper Sampling
After State Specifies
Maximum Permissible Lead
and Copper Levels
Once the state has specified maximum
permissible lead and copper concentrations, a
water system must monitor in accordance with
the SMF.
Groundwater systems must collect lead and
copper samples once during the three year
compliance period in effect when the state
.specifies maximum permissible lead and copper
concentrations or determines that no treatment
is needed. These systems are required to collect
samples once during each subsequent three year
compliance period.
Surface water systems (or groundwater
systems under the influence of surface water)
must collect lead and copper samples annually
beginning when the state specifies maximum
permissible lead and copper concentrations or
determines that no treatment is needed. These
systems are required to continue collecting
samples annually.
Reduced Monitoring
Groundwater systems that demonstrate to the
state that lead and copper levels have been
maintained below the maximum permissible
levels for lead and/or copper for three
consecutive three year compliance periods (nine
years) may collect lead and copper samples once
during each nine-year compliance cycle.
- 30 -
-------
Surface water systems that demonstrate to
the state that Trwriimim permissible lead and/or
copper levels have been maintained below the
maximum permissible levels for three
consecutive years may collect lead and copper
samples once during each nine-year compliance
cycle.
A system using new water sources may not
reduce source water monitoring until the system
meets the maximum permissible lead and copper
concentrations set by the state for three
consecutive monitoring periods.
Reporting Source Water
Samples
Each medium PWS must report the results
of all source water samples within 10 days of
the end of each source water monitoring period
(i.e., annually, per compliance period, per
compliance cycle.
Except for the first source water monitoring
period, a water system must inform the state
of any site which was not sampled during the
previous monitoring period, and include an
explanation of why the sampling point has
changed.
Cessation of Lead and
Copper Source Water
Sampling
A water system can stop collecting lead and
copper source water samples if the system meets
the lead and copper action levels during an entire
source water sampling period applicable to the
system (i.e., annually, triennially, or every nine
years). If a system exceeds the lead or copper
action level measured at the tap in a future
sampling period, the system is required to
recommence monitoring lead and copper in
source water.
- 31 -
-------
TOD Water Monitorina Reaulrements For Medium Water Systems (10.001 to 50.000)
t?n - DS»
nsru. — nan
rwi - rasp
•KMdPtVCu Acton LM)
" n*duc*d lutntw <* ion***) iflw
I9(i»«T» »>CMC»XI (*/Cu Adkm Uwl muM mooBoc WCft ol «ooh «r«iv poW
-------
INITIAL MONITORING REQUIREMENTS FOR
SYSTEMS SERVING 10,001 TO 50,000 PERSONS
°
FIRST MONITORING PERIOD July 1. 1992 to January 1, 1993
The schedule oTecussed in this section assumes the water system exceeds
an action level in the first monitoring period. Systems meeting both action
levels should see the monitoring schedule on page 44 of this guidance.
LEAD AND COPPER TAP WATER SAMPLING
COLLECTION METHODS NEVER CHANGE
• Onattter
» Rr«t draw
• 6-hour standing tern*
NUMBER AND FREQUENCY Of SAMPUNG
• 1 sampte at 60 stta* avary
ADDITIONAL SAMPUNG
* System axcaadto? art «ctk»t lav«t shouW consWar coltocting toad and
cooper samptes ttoring a second: 6-momh montoorlnc fwrtod todafarmtaa
recommonctitaon
* System s*x*iM coScrt lead «nd <^p* «»n^
WCH»
QUALITY PARAMETER tWOJ*) SAMPLING
WOP SAMPLES COLLECT1D AT REPRESENTATIVE SITES HI THE
DISTRIBUTION SYSTEM AND AT EACH ENTRY POINT
Alkalinity
Catelum
ConduetMty
Tamparatura;
Ofthoph
-------
WATER QUALITY PARAMETER (WQP) SAMPLING
(Continued)
ADDfnOKAtSAMPUNG
«n action level should consider collecting WQP
8 second 6-month monitoring period to deter mine the
effecttvrtet* of corrosion control treatment over the course of an entire
year
», These samples should be submitted to the state with the treatment
recommendation
MONITORING PERIODS
RRST MONITORING PERIOD
• July 1, 1992 to January 1,1993 {submit by January 11, 1993)
SECOND MONITORING PERIOD (ftecommendad*
• January 1,1993 to Jury 1,1933 (submit with treatment
recommendation}
-34 -
-------
FOLLOW UP MONITORING REQUIREMENTS
FOR SYSTEMS SERVING 10,001 TO 50,000 PERSONS
SYSTEMS NOT CONDUCTING STUDIES
July 1. 1996 to January 1, 1997
January 1, 1997 to July 1. 1997
SYSTEMS CONDUCTING STUDIES
January 1, 1998 to July 1. 1998
July 1, 1998 to January 1, 1999
A SYSTEM THAT MEETS BOTH ACTION LEVELS MUST CONTINUE
TO MONITOR ONLY LEAD AND COPPER
g
LEAD AND COPPER TAP WATER SAMPLING
NUMBER AND FREQUENCY OF SAMPLING
* 1 sarvJ» at 60 ^tw during sach of 2 consecutive 6-month
monitoriflo, parted*
A SYSTEM CONTINUING TO EXCEED AN ACTION LEVEL MUST
MONITOR WATER QUALITY PARAMETERS
WATER QUALITY PARAMETER (WOP) SAMPLING
AT REPRESENTATIVE SUES IN THE DISTRIBUTION SYSTEM
* PARAMETERS SAMPLED
o pH
o ABcaJmity
o Calcium, when calcium carbonate stabilization used
o Oithophospnatt, vvto*vpno*0hate4>a6ed inh&ttor u*ed
o saka, when saicat*-basedihha»t0f used
• NUMBER AND FREQUENCY OF SAMPUNG
o 2 sample* at. 1$ aft** &&*&*«& of 2 comecutfv* &-month
monftorinfl
AT EACH ENTRY POINT TO THE DISTRIBUTION SYSTEM
* PARAMETERS SAMPLED
** *%»****> ^>* dosaoft rat* of the chemical
^ iml ** concentration of alkalinity
the dosage rate of the Inhibitor and
Of orthophoaphate or siiicata {wrfrichever is
used!
NUMBER AND FREQUENCY OF SAMPLING
o 1 sample at each entry point every 2 week*
-35 -
-------
MONITORING PERIODS
SYSTEMS WOT CONDUCTING STUDIES
FIRST JlNrrORlNG PERIOD
t996 to Januarv 1' 1997 (submit
• SECOND MONITORING PERIOD
t o January \t 1997 to July 1,199? (submit by July 1t. 1997)
SYSTEMS CONDUCTING STUDIES
* FIRST MONITORING PERIOD
o January t, 1998 to -kdy t, 1998 (submit by July 11, 1998)
* SECOND MONITORING PERJOD
o July 1, 1998 to January I, 1999 (submit by January 11,
1999)
- 36 -
-------
STATE REVIEWS RESULTS OF FOLLOW UP SAMPLES ;
SYSTEMS NOT CONDUCTING STUDIES
July 1, 1997 to January t. 1998
SYSTEMS CONDUCTING STUDIES
January 1, 1999 to July 1, 1999
5°
Jo
-------
MONITORING REQUIREMENTS FOR SYSTEMS
SERVING 10.001 TO 50,000 PERSONS
AFTER STATE ESTABLISHES WQPs
SYSTEMS NOT CONDUCTING STUDIES
January 1, 1998 to July 1, 1998
July 1, 1998 to January 1, 1999
SYSTEMS CONDUCTING STUDIES
July 1, 1999 to January 1, 2000
January 1, 2000 to July 1, 2000
A SYSTEM THAT MEETS BOTH ACT/ON LEVELS MUST CONTINUE
TO MONITOR ONLY LEAD AND COPPER
JO
<0
LEAD AND COPPER TAP WATER SAMPLING
NUMBER AND FREQUENCY OF SAMPLING
* 1 sample at 60 sites every
-------
MONITORING PERIODS
SYSTEMS H&T CONDUCTING STUDIES
* FwsrrriipfGWNG PERIOD
o J4M** 1, 1398 to July 1, 1998 (submit by July 1*, 19981
• SECO^IlONrrORING PERIOD
o July 1, 1998 to January I, 1999 (submit by January tt,
4999)
SYSTEMS CONDUCTING STUDIES
* FIRST MONPTOWNG PERIOD
9 July 1,1999to January *< 2000 (submit by January tl,
2000)
• SECOND MONITORWG PEWOD
o January 1, 2000 to Jufy T, 2000 (submit by Jufy II, 2000)
- 39 -
-------
REDUCED MONITORING REQUIREMENTS FOR
SYSTEMS SERVING 10,001 TO 50,000 PERSONS
SYSTEMS NOT CONDUCTING STUDIES
SYSTEMS CONDUCTING STUDIES
Beginning January 1, 1999
Beginning July 1, 2000
NO
1
A SYSTEM THA T MEETS BOTH ACTION LEVELS MUST CONTINUE
TO MONITOR ONLY LEAD AND COPPER AND MAY REDUCE
MONITORING AS FOLLOWS:
LEAD AND COPPER TAP WATER SAMPLING
System exceeding an action level, but maintaining value* for WOP* at
representative sites in the distribution system for 2 consecutive
6-month monitoring period*, and at each entry point to the distrfljution
system for 1 year, may reduce lead and copper tap water sampling as
follows:
NUMBER AND FREQUENCY Of SAMPLING
• 1 sample at 30 site* anrtuaHy
REQUESTING REDUCED SAMPLING
* System mtw si&niit wn^ten reojuast asking the state to reduce the
number and; frequency of lead and copper tap water sampBng (see
Form 141-B on paid* 55J
• State most review teed and copper data submitted by the system
and provide a written response
A SYSTEM CONTINUING TO EXCEED AN ACT/ON LEVEL MUST
MONITOR WATER QUALITY PARAMETERS
WATER QUALITY PARAMETER (WOP) SAMPLING
System inairitainifts values for WOP* at representative sites to 1h*
dfetr&Mitton system for 2 consecutive 6-month monitoring periods,
at each entry point to the dfstr&iution system for 1 year, may reduce
WOP samptfog a* foflowe;
TIVE SITES IN THE DISTRIBUTION SYSTEM
SAMPLED
Or
O
o Calcium, when catekwn carbonate stabaizatkm used
o Orthophosphate. when phosphate-based inhibitor used
o SStcar when silicate-based inhibitor used
• NUMBER AND FREQUENCY OF SAMPUNG
o 2 samples at 7 sites every 6 months
-40 -
-------
WATER QUALITY PARAMETER (WOP) SAMPLING
(Continued)
AT EACH ENTRY POINT TO THE DISTRIBUTION SYSTEM
• PARAMETERS SAMPLED
o When aJkaSnity is adjusted, the dosage rate of the chwnicat
used to adf ust it and the concentration of alkalinity
~ o When an inhibitor i» used, the dosage rate of the inhftator and
the concantratiof* of enfeophosphate or si&cate (whichever ia
used)
• NUMBER AND FREQUENCY OF SAMPLING
o 1 sample at each entry point every 2 week*
REDUCED MONITORING PERIODS
SYSTEMS NOT CONDUCTING STUDIES
* Lead and Copper Must Be Sampled Annually
o January f , 2000 (submit by January tl, 2000}
o January 1, 2001 (submit by January T 1 , 2001)
o January 1, 2002 (submit by January 11, 2002}
• WQf^Rfo«B« Sampf^ at Rtiwwwtath^Srtw in th«Di«rawtk)n
System Every 6 Mtttihe
o July 1, m9 (submit fey July 11, 1 999}
o January 1, 200O (submit by January $1,20001
o JuJy 1,2000 Submit by Juiy? 1,20001
o January ?, 2061 fsubmH by January f 1 , 20011
o July 1, 2001 (iubmft by July 1 1 , 2001}
o January 1,2002 <«ubmit by January 1 1,2002}
* WQP»Nfet»t Be Samptodat Each Entry Point to t*»CH«tr*utk)n
System Every 2 Weeks
SYSTEMS CONDUCTING STUDIES
* Lead and Coppw Must B« SampJad Annually
o Juty 1,2OO1 {»ubmft by Jtdy 11,2001}
o July 1 , 2002 Uubmit by July 11, 2002}
o July 1, 2003 {aufamtt by J«*v 1 1, 2OO3)
System EvetyfMomlui
o January^ 3001 faobinH by January 11,2001}
o Jp^ 2001 {submit by July 11, 2001)
* 2002 (submit by January 11, 2002}
:2002 (submit by July 1 1, 2002}
o January 1, 2003 (submit by January 11, 2003}
o Jury 1,2003 (submit by Jtdy 11,2003}
WQPs Must Be Sampta* at Each Ehtiy Point to 1h« DlstrUxrtk»n
System Every 2 Weeks
-41 -
-------
REDUCED MONITORING REQUIREMENTS FOR
SYSTEMS SERVING 10,001 TO 50,000 PERSONS
SYSTEMS NOT CONDUCTING STUDIES
SYSTEMS CONDUCTING STUDIES
Beginning January 1, 2002
Beginning July 1, 2003
ISJ
1
NO
I
A SYSTEM THA T MEETS BOTH ACT/ON LEVELS MUST CONTINUE
TO MONITOR ONLY LEAD AND COPPER AND MAY REDUCE
MONITORING AS FOLLOWS:
LEAD AND COPPER TAP WATER SAMPLING
System exceeding an action (aval, but maintaining values for WQPt at
representative site* in the distribution system for 6 consecutive
6-month monitoring periods, and at each entry point to the distr&ution
system for 3 years, may reduce toad and copper tap water sampling as
foOows:
NUMBER AND FREQUENCY OF SAMPLING
* 1 sample at 30 sites every 3 years
REQUESTING REDUCED SAMPLING
» System 4mtatftA^wilga*ir««|u»^
number and frvoMency; «l Kwd and copper tap water sampfttg; {see
Form 141-B on page S&)
• State muetfewew toad and copper data submitted: by the systefln
and provide « written response
^ SYSTEM CONTINUING TO EXCEED AN ACTION LEVEL MUST
MONITOR WATER QUALITY PARAMETERS
WATER QUALITY PARAMETER (WOP) SAMPLING
System niaMe*ti*g value* Jar WQP» at rep
distrftKitian system for € consecutive 6-month monitoring periodSr mtt
at each entry point 4ft Jit* dJatrfeutfon system for 3 yeers^ mey reduce
SITES IN THE DISTRIBUTION SYSTEM
SAMPLED
wneft cafcium carbonate stabilization used
Orthophosphate, when phosphate-based Inhibitor used
Sflica, when s8icate*based inhibitor used
NUMBER AND FREQUENCY OF SAMPUKG
o 2 samples at 7 sites annualy
-42 -
-------
WATER QUALITY PARAMETER (WOP) SAMPLING
(Continued)
AT EACH BURY POINT TO THE DISTRIBUTION SYSTEM
SAMPLED
•ftalmty MI adjusted, the dosage rate of the enemies}
used to ad{ust it and the concentration of alkalinity
o When an inhibitor i» used, the dosage rate of the inhStitor and
the concentration of Ofthopfcosphate or aaicate {whichever is
used)
NUMBER AND FREQUENCY OF SAMPLING
o 1 sample at each entry point every 2 weaks
REDUCED MONITORING PERIODS
SYSTEMS NOT CONDUCTING STUDIES
• Laadaraf Copper Must Be Sampled Every 3 Years
o January f , 2005 (submit by January 1t, 2005)
o January t, 2008 (submit by January t1, 2008)
o January 1, 201 1 (submit by January 11r
o Eveiy 3 years thereafter
System AnnueUy
9 January 1,2003 (submit by Ja«««ryt1,2003J
o January 1,2004 (submit by January 11,2004}
a Januaryl, 200S (submit by January 11, 2O05)
o Annually thereafter
• WOJH Must Be Sampled at Each EntoyPo^ to the Dittrflxrtfejn
System Every 2 Wseks
SYSTEMS CONDUCTING STUDtES
• Lead and Copper Must Be Sampfad Every 3 Yean
o July 1,2006 {submit by July 11, 2006)
o July 1, 2009 {submit by July 11, 2009}
o July 1,2012 (submit by July 11 ,201 2)
o Every 3 yes» thereafter
* WCU^ Must Be SemotsdetftsfOTMemativeSitM in tr»Dlstr (button
System Annuaftfr
o July 1, 2004 (submtt by July 1 1 , 2004)
2005 (submit by JulV 11, 2005}
o jj^l 2006 (submit by Juiyl 1,2 006)
Semoted at Each Entry Point to the Distribution
System Every 2 Weeks
-43 -
-------
Source Water Monitoring For Lead and Copper For Medium Systems (3,301 to 50,000)
1
_l
1
1
1
I*
__
1
El
i — —
i 1 i
1 —
i
r
1
*
X«C«
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—
Irak*
Walv
m*nt
f
T —
, 1
1 1
-
.
.
'"."
(IHCycto)
FM Comp*anc*
PMod
Annual
P"P"
i
i
i
i
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P"^
1
: J
1
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Ff
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P
! !
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ill ill ill L
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tl ill
1 1 1 II .!.._! 1 1 1 1
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: V ! ! !
•• '.'•• •• -I?i ';•••• ;!:-
r : ! i i
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taduco Moniodng to One* Pw t »*at Comolanc* C»cl«'
at Annual ""^Jjjjj" B*duc* Monlodng lo One* Pot f v*o> Complanc* Crete
llriCycte)
Second Constance fertod
Annual
! ' ' '
: : : :
., . [i.;;. i . i
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Dng to One* p« t Y*ai Complane* Cycto
;l i i 1 i i i i i i i
•••••• ii •; •;} • i > « I ' . .!
• B*gira m Itwd 9 y«af campianc* c
-------
Number and Frequency of Tap Water Monitoring For Systems Demonstrating Optimal Corrosion Control Treatment Installed
I I MonaKuno]
. \Motartanparahm. orihaphoiphato
•' Sy»tom§ cotect |M» a) torotot at «aeh Ut« tor: pR
« StatoMlabW^dbcratoi^orWQPimortloradlndittiunont^lamandalMchmkypoht
toadto«Mkara
-------
INITIAL SOURCE WATER MONITORING
REQUIREMENTS FOR MEDIUM SIZE SYSTEMS
FIRST MONITORING PERIOD January 1, 1993 to July 1, 1993 <*>
The schedule dhcutsed in this section assumes the water system exceeds an action
level in the first monitoring period.
LEAD AND COPPER SOURCE WATER SAMPLING
if tne^eed or copper actto twel is exceeded vi tap water samples &e
system must collect 1 sample at each entry point to the distrttwtkxi
system « accordance with 4t« coBection methods specified in
§141.23(8X1) to (4>
MONITORING PERIODS
HAST SOURCE WATER MONITORING PERIOD
• January 1, t993 to July 1,1993 (submit by July 11,
• System most submit source water treatment recommendation with
toad and copper satire* wtair sampfe»
-46 -
-------
SOURCE WATER MONITORING REQUIREMENT
AFTER THE STATE SETS MAXIMUM PERMISSIBLE
LEAD AND COPPER LEVELS FOR SYSTEMS NOT
INSTALLING SOURCE WATER TREATMENT
to
8
PERIOD FOR STA TE DETERMINA TION
July 1, 1993 to January 1, 1994
If a system is not required to install source water treatment the state wil establish
maximum permissfcle lead and copper levels with which the system must continue
to comply.
The system must continue to deliver finished water to each entry point to the
distribution system with lead and copper concentrations below those levels set
by the state.
LEAD AND COPPER SOURCE WATER MONITORING
GROUNDWATER SYSTEMS
• System must collect 1 sample at each entry poirit to^ distribution
system during th* 3-year compliance period in effect when the state
d^emririeetfeatmem Is nc* needed, and it sets maximum
permissattt toad and copper level*
* System must collect 1 sampieateachentiy pointtoth»o1»^b«fe)a
system during eacfe subsequent 3~year compliance period
SURFACE WATER SYSTEMS
• System must collect 1 sampfe at each smry poirt to tf* Distribution
system anmiaBy
• The first y«arb«a^ on th« date the stat»o^tflrmHtectreatrtMnt1c
not needed and it set* maximum permissible teed and copper fevete
MONITORING PERIODS
GROUNDWATER SYSTEMS
• Systeroiitiftt collect a8 source water samples and submit the results
to to'-ijjjt-itiPt the flowing dates;
1«tCof|ience Period January 1,1996 January 11,1996
2nd CiSjianrs Period January 1, 1999 January 11,1999
3rd Colfcace Period January 1, 2002 January 11, 2002
SURFACE WATER SYSTEMS
• System must collect alt source water samples and submit the results
to the state by the following dates:
1st Year January 1,199S January 11,1998
2nd Year January 1,1996 January 11,1998
3rd Year January 1,1997 January 11,1997
-47 -
-------
FOLLOW-UP SOURCE WATER MONITORING
FOR MEDIUM-SIZE SYSTEMS INSTALLING
SOURCE WATER TREATMENT
FIRST MONITORING PERIOD January 1, 1996 to July 1, 1996
SECOND MONITORING PERIOD July 1. 1996 to January 1, 1997
H a system 'm not required to instal source water treatment ft has 24 months to
instal and operate the treatment and 12 months to coiect and submit foaow-up
source water samples.
LEAD AND COPPER SOURCE WATER MONITORING
NUMBER AND FREQUENCY
* System must collect 1 sample at each entry point to the Distribution
system during each of 2 consecutive 6-month monitoring period*
MONITORING PERIODS
FIRST MONITORING PERIOD
• January 1, T996 to July 1r T996tsuboiit by July tl, 1996)
SECOND MONITORING PERIOD
• July 1, 1996 to January 1,1997 (submit by January It, 1997*
-48 -
-------
SOURCE WATER MONITORING REQUIREMENT
AFTER THE STATE SETS MAXIMUM PERMISSIBLE
LEAD AND COPPER LEVELS FOR SYSTEMS
INSTALLING SOURCE WATER TREATMENT
<0
vj
PERIOD FOR STA TE DETERMINA TION
January 1, 1997 to July 1, 1997
After a system installs source water treatment, collects follow-up samples, and
submits the results to the state, the state wBI set maximum permissible lead and
copper levels.
System must continue delivering finished water to each entry point to the distribution
system with lead and copper concentrations below the levels set by the state to
remain in compliance.
LEAD AND COPPER SOURCE WATER MONITORING
GROUNDWATER SYSTEMS
• System most collect 1 sample at each entry poim to tto distributfe
*ytt»m durfno the 3-year compliance period in effect when the «*»
sett maximum pefmiasibie lead and copper ieveia
System must collect t sampta at each entry point to the dlstrioutJor*
system during «** subsequent 3-year compliance period
SURFACE WATER SYSTEMS
* System must oottect t sa^npfa4te«^emiv point ^trM
system anmtatty
• The flrat year beams on the data the- state sets maximum permissible
toad and copper levels
MONITORING PERIODS
GROUNDWATER SYSTEMS
* System «*us* collect source water samples and submit th» results to
the sta||:|^: the foltowinfl date«:
Till ri||||ijii mil lit January t, 1999 January 11,1399
2nd ^jiiilf • Perfod January 1 r 2002 January 11,2002
3fdri||||nri Period January 1, 2005 January 11,2005
SURFACE WATER SYSTEMS
* System must collect source water samples and submit the results to
the state by the followina dates;
1st Year January 1,1998 January 11,1998
2nd Year January 1,1999 January 11,1999
3rd Year January 1, 2000 January 11, 2000
-49 -
-------
REDUCED MONITORING REQUIREMENTS FOR I
MEDIUM-SIZE SYSTEMS NOT INSTALLING TREATMENT
GROUNDWATER SYSTEMS
SURFACE WATER SYSTEMS
Beginning January 1, 2002
Beginning January 1, 2002
s
LEAD AND COPPER SOURCE WATER MONITORING
GROUNDWATER SYSTEMS
« System thatmantem* toad and copper ojncemrations below the
levels set by the state for 3 consecutive 3«year compliance period*
may reduce source water monitoring to once per 9-year compliance
cycle
SURFACE WATER SYSTEMS
• System that maintains lead and copper concentrations below the
levels set by the state for 3 consecutive years may reduce source
water monitoring to once per 9-year compliance eyde
REDUCED MONITORING PERIODS
GROUNDWATER AND SURFACE WATER SYSTEMS
• Reduced monftorins would take place l» the second 3~year
compliance cycte> which begin* January 1 , 2002 and ends January
* System must collect 1 sample at each entry point to the distribution
system and submit the result to the state by January 11, 2011
- 50 -
-------
REDUCED MONITORING REQUIREMENTS FOR
MEDIUM SIZE SYSTEMS INSTALLING TREATMENT
GROUNDWATER SYSTEMS
SURFACE WATER SYSTEMS
Beginning January 1, 2011
Beginning January 1, 2002
LEAD AND COPPER SOURCE WATER MONITORING
GROUNDWATER SYSTEMS
• System that manitaJn* lead and copper concentrations below tfce
level* sec by th* state for 3 consecutive 3-yww compliance periods
may reduce sourc* water rnonftorfog to one* per 3-year comptfance
cyd«
SURFACE WATER SYSTEMS
• System that maintains lead and copper concentrations below ffce
tevets set by tfw state for 3 consecutive years may reduce source
water monitoring to once per 9-year compliance cycle
REDUCED MONITORING PERIODS
GROUNDWATER SYSTEMS
• Reduced m
piBC^
, which beo&*»JamM»y 1> 2011 and ends January 1, 2020
System moat collect I sample at each entry point to tf» dijgriby&tn
ay stem and submit the restdts to ttw state by January 11, 2020
SURFACE WATER SYSTEMS
* Reduced monitoring would take place irt the second t-year
compilanc* cycle* wWcti beojhs January i, 2002 and end* January
1,2011
System most cottect I tampieat each emry point to the
system and suixftft*»resotts to the state by January 11, 2011
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Form 141-A
Page 1 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
System's Name:
Address:
Telephone number:
System ID #:
Contact Person:
•
Type: D
Size: D
D
D
D
D
D
CWS D NTNCWS
> 100,000
10,001 to 100,000
3,301 to 10.000
501 to 3,300
101 to 500
3100
CEKTtflCATTON 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 first condition has 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)
- 52 -
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Form 141-A (continued)
Page 2 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
CERTIFICATION OF SAMPLING SITES
LEAD SERVICE LINE SITES
# 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):
CERTtFtCATION 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.
- 53 -
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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 # 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 SAMPLING 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
- 54 -
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Form 141-B
Page 1 of 1
REQUEST FOR REDUCED LEAD AND COPPER TAP WATER
System's Name:
Address:
Telephone number:
System ID #:
Contact Person:
•
Tvoe: D
Size: D
D
D
D
D
D
CWS D NTNCWS
> 100.000
10,001 to 100,000
3.301 to 10,000
501 to 3,300
101 to 500
S100
REQUEST FOR REDUCTION
The
water system has:
D maintained tap water levels below the lead/copper action ievel(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:
D Biannual to Annual
D Annual to Triennial
D
D
D
D
D
100 to 50
60 to 30
40 to 20
20 to 10
10 to 5
The results of all 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
- 55 —
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WORKSHEET #1
MATERIALS SURVEY INVESTIGATION RESULTS
en
0>
PWS FRDS NUMBER
POPULATION SERVED BY PWS
Structure
Location
Contact Paw*
Nam*
Pfiona
•
LSI
•
Horn*
Verfflad
taarad
Safoctad
Routfna
Optional
Rtcalvad
Training
Matartal
-------
WORKSHEET #2
MATERIALS SURVEY RESULTS BY NUMBER OF SERVICE CONNECTIONS
FOR EACH PLUMBING MATERIALS TYPE
PWS FRDS NUMBER
POPULATION SERVED BY PWS
Type of Structure
SFRs
MFRs
BLDGs
TOTAL
type of dumbing Material
Interior Plumbing
Lead Plpa
Copper
>1982
Copper
<1983
Number of Sendee Connections
Distribution System Piping
LSLs
Entire Line
Partial Line
Number of Service Connections
-------
WORKSHEET #3
SUMMARY OF MATERIALS SURVEY RESULTS
PWS FRDS NUMBER
POPULATION SERVED BY PWS
Plumbing Material
Interior Plumbing
Lead Pipe
Copper Pipe With Lead Solder > 1 982
Copper Pipe With Lead Solder < 1 983
Service Lines
LSLs
Entire Line
Partial Line
Total Available Sites
Type of Structure
SFR
MFR
BLDQ
Number of Service Connection*
- 58 -
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