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

-------
   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

-------
                                     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

-------
                                      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
                                             - ii -

-------
                      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.
                                           - Hi -

-------
•   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.
                                              — IV  —

-------
                  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.

-------
  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.
                                      - 2 -

-------
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
                       - 3 -

-------
          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.
                                           - 4 -

-------
          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
                                       - 5 -

-------
     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
                                        - 6 -

-------
    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-
                                        - 7 -

-------
    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
                                        - 8 -

-------
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 -

-------
                                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 -

-------
  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 -

-------
              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  -

-------
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  -

-------
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.
                                        -  20 -

-------
              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
                                     - 21 -

-------
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.
- 22 -

-------
             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 -

-------
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 -

-------
   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 -

-------
   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 -

-------
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 -

-------
   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.
                                      - 28 -

-------
          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 -

-------
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«
Il*0)
—

Irak*
Walv
m*nt
f

T 	 —
, 1
1 1

-
.
.
'"."
(IHCycto)
FM Comp*anc*
PMod
Annual
P"P"
i
i
i
i
Amual
P"^
1
: J
1
1
Ff
1 • T;.
P
! !
!
|


i
i
i
i

	 1 	
1 1
• '
!
V' •
'•
,;;.]


(MCycM2nd
CacnpHanc*
Period
I -
• :,l;- v.
it. ill
! j
i i i
i i-l J.
. J ! ••:•••! ••
I ': :l': -,-4 ' 1
i r i :
1 1 1
(X 1
'., [
InM Cotnplane* Podod
ill ill ill 	 L
'. < • ' I
; : : : :
. I- ! j
1 ! 1
i i i
BndCyO.)
No) Canvknc* Pxtod
tl ill
1 1 1 II .!.._! 1 1 1 1
^
: V ! ! !
•• '.'•• •• -I?i ';•••• ;!:-
r : ! i i
i i ! i
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
i--, f i
i r i .
•i--;
(IdCycl*)
TnM Cempianc* P*rtod
	 1 	 ' ' '


: . 1 -: 1 1 .1 : ..1
' ; 1 1 1 1 1
! ! ! ! J !


I-, ! 1 i 1 i ••>...-. t: ••

I-: i- I i 1 ! i ! tfc;t 1 j V'"V
!:;.'• I • J : * ! • ! ! 1 !


i 1 1 	 j i j i i i i
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
                                    - 51 -

-------
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 -

-------
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  -

-------
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 -

-------
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 —

-------
    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 -

-------