United States
        Environmental Protection  Office of Water      EPA 812-B-92-008
        Agency         (WH-550)        May 1992
£EPA    MONITORING REQUIREMENTS
         for LEAD AND COPPER RULES

         WATER SYSTEMS SERVING
         50,001 to 100,000 PERSONS

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   Monitoring Requirements
    for Lead and Copper Rules
      Water Systems Serving
    50,001 to 100,000 Persons
                for
Office of Ground Water and Drinking Water
  U.S. Environmental Protection Agency
          Washington, D.C.
            December 1991

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                                      Table  of Contents
    Definitions  Applicable to the Lead and Copper Rules	        ^
    Monitoring  Protocols	         1
    Additional Monitoring Data	         2
    Demonstrating Optimal Control Treatment with Tap Water
      and Source Water Samples	         2
L«ad and Copper Tap Water Monitoring — §141.86	         4
    Conducting  a Materials Evaluation  	         4
    Identifying Interior Plumbing Materials  	         4
      Sources Required by Rule  	         4
      Suggested Sources  . •.	         5
    Identifying Distribution System and Service Line Materials  	         5
      Sources Required by Rule  	         5
      Suggested Sources	         6
    Organizing the Data  	         7
    Identifying and Certifying Targeted Sampling Sites  	         8
    When Tier  1 or Tier 2 Sites Cannot Be Found	         8
    Illegally Installed Lead Plumbing Materials	'.	         9
    When Lead Service Line Sites Cannot Be Found	         9
    Prioritizing  Sampling Sites  	         9
    Sample Collection Methods	        11
    Tap Water Samples	        11
    Lead Service  Line Samples  	        17
      Flushing  a Specified Volume   	-.'	        17
      Direct  Service  Line Samples	        17
      Temperature Variation  	•. . .-	        19
    Data Analysis and Interpretation	        '.9
    Number and Frequency of Sampling  	        20
    Initial Monitoring	        20
    Follow-up Monitoring  	        20
    Routine Monitoring	        20
    Reduced  Monitoring  	        21
    Reporting Samples  	        21
Water Quality Parameter Monitoring — §141.87	        22
    Selecting Representative Sampling Sites 	        22
    Sample Collection Methods	        23
    Water Quality Parameter Analyse*  	        23
    Number and Frequency of WQP Sampling  	        27
    WQP Sampling Before Installing Optimal Corrosion Control Treatment  	        27
    WQP Sampling After Installing Optimal Corrosion Control Treatment and
      After the State Specifies Numerical Value*  	        2"
    Reduced  WQP Sampling	        23
    Reporting WQP Sampling	        23
Lead  and Copper Source Water Monitoring — §141.88	        29
    Sample Collection Methods	        29
    Number and Frequency  of Lead and Copper Sampling	        30
    Lead and Copper Sampling After System Exceeds Lead or Copper Action Level	        30
    Lead and Copper Sampling After System Installs Source Water Treatment	        30
    Lead and Copper Sampling After State Specifies  Maximum  Permissible
      Lead and Copper Levels  	        30
    Reduced  Monitoring  	        31
    Reporting Source Water Samples  	        3!
    Cessation of Lead and Copper Source Water Sampling	        31
Analytical Methods — §141.89 	        32
    Quality Assurance/Quality Control Programs	        32
Tap Water Monitoring Schedules   	"*• •        35
Source Water Monitoring Schedules  	        -*
Sample Forms	        --

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                                       List of Tables
Table 1.  Tlmeframe for Large PWS Corrosion Control Submissions to the State  	
Table 2.  Sample Handling Requirements for Lead, Copper, and Water Quality Parameters
Table 3.  Pipe Volume Table  	,	
Table 4.  Determination of 90th Percentile Values for Lead and Copper Monitoring Results .
Table 5.  Summary of Approved Analytical Methods for the Lead and Capper Rule  	




                                      List of Figures

Figure 1. Preferred Sampling Pool Categories for Targeted Sampling Sites  	
Figure 2. Analytical Scheme for Differentiation of Phosphorus Forms	 .  .
PAGE

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                      Definitions Applicable to the
                          Lead  and Copper  Rules

                                          §141.2
•  ACTION  LEVEL  (AL) is the concentration of lead or copper in water specified in §141.80(c) which
   determines, in some cases, the treatment requirements contained in Subpart I of this part that a water system
   is required to complete.
•  BLDGs means public or commercial buildings served by the PWS.
•  BLDG>82 means a public or commercial building constructed after 1982 with copper plumbing using lead-
   based solder.
•  BLDG<82 means a public or commercial building constructed before or in 1982 with copper plumbing using
   lead-based solder.
•  BLDG-LSL means a public  or commercial building served by a lead service line connection.
•  BLDG-Pb means a public or commercial building which has lead interior plumbing.
•  CORROSION INHIBITOR means a substance capable of reducing the corrosivity of water toward metal
   plumbing materials, especially lead and copper, by forming a protective film on  the interior surface of those
   materials.
•  Cu is the symbol for copper.
•  EFFECTIVE CORROSION INHIBITOR RESIDUAL means a concentration sufficient to form a passivating
   film on the interior walls of a pipe.
•  FIRST DRAW SAMPLE means a one-liter sample of tap water,  collected in accordance with §141.86(b)(2),
   that has been standing in plumbing pipes at least 6 hours and is collected without flushing the tap.
•  LARGE WATER SYSTEM means a water system that serves more than 50,000 persons.
•  LEAD SERVICE LINE (LSL) means a service line made  of lead which connects the water main to the
   building inlet and any lead pigtail, gooseneck or other fitting which is connected to such lead line.
•  MAXIMUM CONTAMINANT LEVEL (MCL) means the maximum permissible level of a contaminant in
   water which is delivered to any user of a public water system.
•  MEDIUM-SIZE WATER SYSTEM means a water system that serves greater  than 3,300 and less than or
   equal to 50,000 persons.
•  MFR > 82 is the acronym for a multi-family residence constructed after 1982 with copper plumbing using lead-
   based solder.
•  MFR < 82 is the acronym for multi-family residences constructed before or in 1982 with copper plumbing using
   lead-based solder.
•  MFR-LSL is the acronym for multi-family residences served by a lead service line connection.
•  MFR-Pb is the acronym for multi-family residences which have lead interior plumbing.
                                            —  iii —

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•   MFRs is the acronym for multi-family residences.

•   NRs is the acronym for non-residential structures constructed as single-family residence.

•   OPTIMAL CORROSION CONTROL TREATMENT means the corrosion control treatment that minimizes
    the  lead and copper concentrations at users'  taps while insuring that the treatment does not cause the water
    system to violate any national primary drinking water regulations.

•   NTNCVVSs is the acronym for Non-Transient, Non-Community Water Supplies

•   Pb is the symbol for lead.

•   Pb/Cu-POE means lead  and copper samples collected at the  points of entry to the distribution system
    representative  of each source of supply after  treatment.

•   Pb/Cu-TAP means lead and copper samples  collected as  first-draw tap samples from targeted sample sites.

•   POE is the acronym for points of entry to the distribution system representative of each source of supply after
    treatment.

•   PQL is the acronym for the Practical Quantitation Level

•   PWS is the acronym for a Public Water Supplier

•   SERVICE LINE SAMPLE means a one-liter sample of water, collected in accordance with §141.86(b)(3),
    that has been standing for at least 6 hours in a service line.

•   SFRs is  the acronym for single family residences,  which can include for purposes of identifying targeted
    sampling locations: (1) Non-Residential structures (NRs); and (2) Multi-Family Residences  (MFRs) if they
    constitute more than 20%  of the  service connections within the PWS's service area.

•   SFR > 82 is the acronym for a single-family residence constructed after 1982 with copper plumbing using lead-
    based solder.

•   SFR < 82  is the acronym  for a single-family residence constructed before or  in  1982 with copper plumbing
    using lead-based solder.

•   SFR-LSL  is the acronym for a single-family residence served by a lead service  line connection.

•   SFR-Pb is the acronym for a single-family residence which have lead interior plumbing.

•   SINGLE FAMILY STRUCTURE means a  building constructed as a single-family residence  that is currently
    used as either a residence or a place of business.

•   SMALL WATER SYSTEM means a water system that serves 3,300 persons or fewer.

•   90%TL means the 90% lead and/or copper level.

•   90<%TL-POE means the difference between the 90% lead level for first-draw tap samples collected at targeted
    sample sites and the highest respective lead level measured at the points of entry to the distribution system.

•   VVQP means  water quality parameters, which  include pH,  temperature, conductivity, alkalinity, calcium,
    orthophosphate, and 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.

•   VVQP-DIS means  lead and copper measured at representative locations throughout the distribution system.
                                                — iv  —

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                  Monitoring  Requirements
  The U.S. Environmental Protection Agency
promulgated National Primary Drinking Water
Regulations (NPDWRs) for lead and copper on
June 7,  1991 (56 FR 26460).
  Three monitoring protocols are included in
the final rule: (1) tap water monitoring for lead
and copper; (2) water quality parameter (WQP)
monitoring;  and (3) source water monitoring
for  lead and copper. All large water systems
must  collect tap  water samples  for lead and
copper and WQP samples.
  The  monitoring  requirements  for  non-
transient,   non-community  water   systems
(NTNCWS) 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
contributions of different sources of lead and
copper corrosion by-products to drinking water.
These sources include: lead service lines, lead
and copper  interior piping, lead solder, and
fixtures and faucets. Tap water monitoring for
lead and copper allows  the water system to
determine the lead and copper concentrations
in drinking water to which their customers may
be  exposed,  as well as  the effectiveness of
corrosion   control  treatment  for  reducing
concentrations of those contaminants in -water
consumed by the public. Tap water samples for
lead and copper are collected biannuaily. A
large  system that installs and properly operates
optimal corrosion control treatment can collect
lead and copper tap water samples annually and
ultimately triennially. See pages 4 to 21 for a
discussion of lead  and copper  tap water
sampling.
  Water quality parameter samples must be
collected at each entry point to the distribution
system (WQP-POE) and at a set of sites in the
distribution  system   (WQP-DIS)   that  is
representative of water quality throughout the
distribution system.
  Initially systems must collect samples for pH,
alkalinity,   calcium,  conductivity,   water
temperature, and, if a corrosion inhibitor is
being used, orthophosphate or  silica, depending
upon  the  inhibitor in use.  After  optimal
corrosion control treatment has been installed,
the WQP samples collected by a PWS depend
upon the corrosion control treatment installed
by that PWS.  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).
These  samples  are  used  to  monitor  the
effectiveness of corrosion control treatment and
determine whether the  PWS is operating  in
compliance with the rule.
  Initially WQP samples are collected biannuaily
at each entry point to the  distribution system
and  at representative sites  throughout  the
distribution system. After optimal corrosion
control treatment is installed WQP samples are
collected biweekly  at each entry point to the
distribution   system  and   biannuaily   at
representative sites in the distribution system.
Once a system  reduces  monitoring,  WQP
samples are collected biannuaily, 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. See pages 22
to 28 for a discussion of WQP sampling.
   Source water monitoring for lead and copper
is only required of a PWS that exceeds the lead
or copper action level in tap water samples. The
purpose of requiring lead and  copper sampling

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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 large 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. See
pages 29 to 31 for a discussion of lead and
copper source  water sampling.

Additional Monitoring  Data
   Any system which 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
  While a large PWS is not required to monitor
lead  and  copper  at  entry  points to  the
distribution system  (Pb/Cu-POE)  unless it
exceeds an action level, a PWS that wishes to
demonstrate  that optimal corrosion control
treatment has already been installed may do so
by demonstrating that the difference between
the 90th percentile tap water lead level and the
highest source water lead level is less than 0.005
mg/L. 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 six month monitoring periods.
  Once a large PWS makes this demonstration,
the state will establish values for a set of water
quality parameters (WQP-POE and WQP-DIS)
for the system. The PWS must continue to
operate in accordance with the state-specified
WQPs to remain in compliance with the rules.
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       Table 1.  Timeframe for Large PWS Corrosion Control
                          Submissions to the State
PWS Action
Justification for Insufficient Number
of LSL Sites and/or Expansion to Tier
II or Tier III Sites in Sample Plan
First Six-Month Initial Monitoring
Period Results
Second Six-Month Initial Monitoring
Period Results
Corrosion Study and Treatment
Recommendations
Certification that the State
designated treatment has been
installed
First Six-Month Follow-Up Monitoring
Period Results
Second Six-Month Follow-Up
Monitoring Period Results
State Specifies Optima/ Water Quality
Parameters
First Six-Month Monitoring Period
After State Specifies Optimal Water
Quality Parameters — Routine
Monitoring
Second Six-Month Monitoring Period
After State Specifies Optimal Water
Quality Parameters — Routine
Monitoring
Reduced Monitoring
Ultimate Reduced Monitoring
Deadline
Jan. 1. 1992
July 11. 1992
Jan. 11. 1993
July 1. 1994
Jan. 1, 1997
July 11. 1997
Jan. 11, 1998
July 1. 1998
Jan. 11. 1999
July 11, 1999
See Appendix A
for Dates
See Appendix A
for Dates
Submission to State
LSL Site and/or Targeting. Criteria Sections of
Form 141 -A
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE; Pb/Cu-POE
submitted *
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE; Pb/Cu-POE
submitted *
Treatment study report and results as
discussed in Volume II
Letter of Certification
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE submitted
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE submitted
Based on Follow-Up Monitoring Results
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE submitted
Form 141 -A and Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE submitted
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 submitted
Form 141-B when state-specified WQPs have
been maintained for three consecutive years
Form 141-Aand Monitoring Results:
Pb/Cu-TAP; WQP-DIS; WQP-POE submitted
Pb/Cu-POE samples are not required unless the action level is exceeded. However, large systems that wisr.
to demonstrate optimization based upon the 90th percentile tap results and the entry point results must sample
concurrently with the targeted tap monitoring. Systems that do not wish to demonstrate corrosion control
optimization using this mechanism should follow the source water monitoring requirements in Appendix A.
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          Lead and Copper Tap Water Monitoring
                                      §141.86
  In establishing the tap water monitoring
requirements, EPA sought to ensure that they
would be  stringent enough  to identify water
systems with  significant  lead  and  copper
problems,  while insuring that water systems
could implement the monitoring 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 large 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 §U1.86(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 50 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 within
     a PWS service area. Plumbing codes are
     generally available from either the  building
     or public works department of the appro-
     priate governmental body. In cases where
     there is multi-jurisdictional control within
     the PWS service area, an investigation of
     each jurisdiction's code is necessary. In
     selecting potential targeted sites for further
     investigation,  it may be assumed  that
     plumbing materials  will conform to the
     code in effect at the time of construction.
 B.  Plumbing  Permits—Plumbing  permits
     should show the type of materials used,
     location of construction, and"the date of
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     the permit application. In many munici-
     palities, construction  permits  for  new
     construction   and    kitchen/bathroom
     remodeling are issued through the building
     department. Tracing the historical permits
     with the plumbing code provisions should
     indicate locations where copper plumbing
     with lead solder is likely to be found. The
     permits may also indicate those residences
     that have replaced lead- and/or copper-
     containing materials with other materials
     such as plastic.
 C.  Existing  Water  Quality Dora—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
     characterization.

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.  Interviews with Plumbers/Building Inspec-
     tors—These personnel, particularly senior
     personnel and retirees,  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 associated
     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 pan of the monitoring for corrosiviry
     required under Section 141.42  (d) of [he
     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
                                         - 5  -

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    materials survey to identify lead, copper,
    galvanized iron, and asbestos cement as
    being present in the system.
2.  Distribution Maps and Record Drawings—
    Maps and  drawings of the distribution
    system  should  be a primary source for
    service  line and connection information
    including materials,  line sizes, and dates.
    Even with  a lack of detail such sources
    may be useful in indicating the historical
    growth  of the system.  The maps  would
    also provide a visual aid in developing the
    materials survey.
3.  Maintenance  Records—Maintenance
    records often identify  such information
    as (1) existing materials; (2) replacement
    materials;  (3)  date of event; and (4)
    particular site conditions  of note. LSLs
    may  be  specifically  identified  when
    encountered during maintenance 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 & Maintenance Manuals (O&M)
     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 contractor^.pr develop-
                                        - 6  -

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    ers may have reliable information on the
    materials of construction for sections of
    the distribution system.
D.  Community Survey—A community survey
    may  be  helpful  in   identifying  LSL
    connections. A utility could perform this
    survey  by  mail  using  a  standard
    questionnaire. Many PWSs have indicated
    a preference for the use of some form of
    a community survey to assist in identifying
    potential targeted  sampling sites where
    owners or residents may be predisposed
    to   volunteering  their   participation.
    Selective mailings'to new billing  units
    identified since 1982 and/or those residents
    located in sections of town where LSLs
    are anticipated (perhaps, organized by zip
    code area) could reduce the total number
    of surveys to be distributed as well as the
    effort's associated costs.
E.  Other Sources—Any other sources that
    may be available to the utility that might
    be helpful in identifying the materials used
    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, this generalization may not
    be  applicable.
  Each  PWS  should  select  a method for
documenting the information obtained  from
these various 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 wide use of lead and copper materials or
elevated lead and copper levels in  tap water.

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 large  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 eliminates inappropriate 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
on an ongoing basis. 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
alternative  sites  are   available  for  repeat
sampling. Once monitoring begin*,., the same
                                        -  7 -

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sample sites must be used unless a location has
been dropped 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.
Tier 1:
  •  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
similar style and fashion as single-family resi-
dences, 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 Tier 1
sites do not exist or are 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.          ^
                                         - 8 -

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  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
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 January 1, 1992.  Form 141-Aonpage 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 (i.e., 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  by  the  rule  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 50,001 to 100,000
people can only confirm 20 specific SFRs served
by LSLs willing to participate in the monitoring
program, then this system would have to submit
to the State the reasons for not having at least
30 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 the distribution system (as well as the
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
     of the total connections served by the PWS,
     and if so, include them in the definition
     of a SFR.
  •  Where SFRs served by LSLs are located
     in the distribution system.
  •  Which SFRs installed copper pipe with lead
     solder after 1982.  Consider thje+date thai
     the lead ban wens into effect in the PWS

-------
     ser\'ice area. 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).
TIER 1
Category A
   All sample sites in Category A and B  are
considered high  priority sites to  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-family  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  .  :opper 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 sample 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.                         ,.,
                                        - 10  -

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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
 •  NTNCWS 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 the 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
lead 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 14. 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).
                                       - 11  -

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Figure 1.  Preferred Sampling Pool Categories for
            Targeted Sampling Sites
                     - 12 -

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Figure 1.  Preferred Sampling Pool Categories for
      Targeted Sampling Sites (Continued)
                   -  13 -

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                                Suggested Directions for
                  Homeowner Tap Sample  Collection Procedures.

    These samples are being collected to determine the contribution of faucet fixtures and household
pipes and/or solder to the lead and copper levels  in tap water.  This sampling effort is required
by the Environmental Protection Agency, and is being accomplished through the cooperation of
homeowners and residents.

    A sample is  to be collected after an extended period of stagnant water conditions (i.e., no
water use during this period) within the interior  piping.  Due  to this requirement,  either early
mornings or evenings upon returning from work are the best times for collecting samples.  The
collection procedure is described in more detail below.

    1.  Prior arrangements will be made with the customer to coordinate the sample collection event.  Dates
       will be set for sample kit delivery and pick-up by  water department staff.

    2.  A minimum of 6*8 hour period during which there  is no water use must be achieved prior to sampling.
       The water  department  recommends that either early mornings or evenings upon returning  home are
       the best sampling times to ensure that the necessary stagnant water conditions exist.

    3.  A kitchen or bathroom cold-water faucet is to be used for sampling. Place the sample bottle (open)
       below the faucet and gently open the cold water tap. Fill the sample bottle to the- line marked ' 1000-mL"
       and rum off the water.

    4.  Tightly cap the sample bottle and place in the sample kit provided.  Please review the sample kit label
       at this time to ensure that all information contained on the label is correct.

    5.  IF ANY PLUMBING REPAIRS OR REPLACEMENT HAS BEEN DONE IN THE HOME SINCE
       THE PREVIOUS SAMPLING EVENT, NOTE THIS INFORMATION ON THE LABEL AS PROVIDED.

    6.  Place the sample kit outside of the residence in the location of the kit's delivery in order that department
       staff may pick up the sample kit.

    7.  Results from this monitoring effort will be provided to participating customers when reports are generated
       for the State unless excessive lead and/or copper levels are found. In those cases, immediate notification
       will be provided (usually 10 working days from the time of sample collection).

Call	at	if you have any questions regarding
these instructions.
TO BE COMPLETED BY RESIDENT

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                                                                   *•«



                                           - 14  -

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  The procedure  for collecting samples  is
simple. A clean, plastic, one-liter sample bottle
should be placed below the spout of the cold
water tap in the kitchen (or bathroom). The cold
water tap should be turned on gently to maintain
low   flow  conditions  during  the  sample
collection. It  should take approximately 45
seconds to fill the bottle. The sample bottle
should be filled to the one-liter level marked
on the container, and then capped. To  avoid
problems  of residents  handling  nitric  acid,
acidification of first draw samples may be done
by laboratory personnel up to 14 days after the
sample is collected.  Neither the homeowners
nor the sample collectors should handle nitric
acid used for  sample acidification.  For those
systems  that  do not use disposable sample
bottles, care must be taken to assure that the
glassware used in each of the sample handling
steps is free of trace amounts of lead and copper
since it can introduce a significant degree of
analytic error. To reduce errors, especially in
cases where very low lead concentrations are
expected, acid soak all appropriate glassware
for 2 hours prior to use. The recommended
acid-soaking procedure is one part nitric acid,
two parts hydrochloric 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 follow-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).
Paniculate 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
and assessing treatment performance. Filtered
                                         -  15 -

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                  Table 2.   Sample  Handling  Requirements for  Lead,
                          Copper, and  Water  Quality Parameters
Contaminant or
Parameters
Lead
Copper
pH
Conductivity
Calcium
Alkalinity
Orthophosphate
Silica
Temperature
Preservative
Cone. HN03to pH <23
Cone. HN03to pH <23
None
Cool, 4°C
Cone. HN03 to pH <25
Cool, 4°C
Cool, 4°C
Cool, 4°C
None
Container1
PorG
PorG
PorG
PorG
P or G
PorG
PorG
P only
PorG
Maximum Holding
Time2
6 months
6 months
Test Immediately4
28 days
6 months
14 days
48 hours
28 days
Test Immediately'1
'   P = Plastic, hard or soft; G = Glass, hard or soft.

2   in all cases, samples should be analyzed as soon after collection as possible.

3   If HNO-, cannot be used because of shipping restrictions or is not used because homeowner* are collecting samples, the sample
   for analysis can be shipped to e laboratory where it must be acidified (generally to pH < 2) with concentrated HNO, as soon
   as possible but not later than 14 days after sample collection. Sample must stand in the original container used for sampling
   for at least 28 hours after acidification.  Laboratories should match the acid matrix of their samples, quality control, and calibration
   standards for accurate results. The latter two sets of solutions will have the same, fixed concentration of acid. It is recommended
   that good laboratory practice would be to determine by prior tests the amount of acid necessary to achieve some pH <2.
   and make it consistent with the standards used. For instance, for most waters, the previous EPA recommendation of 0.1 5%
   v.'v of KN03 will result in a pH  < 2.  Therefore, all samples can be automatically preserved with 1.5 mL of the acid, ana all
   standards can be made with the same acid concentration.  In some extreme, high-alkalinity cases, more acid may  be necessary.

4   "Test Immediately" generally means within 15 minutes of sample collection.  In the case of pH, the sample should be measured
   as soon as the sample  is taken and should be measured under closes  system conditions, particularly if the weter is poorly
   buffered.

4   If HNO, cannot be used 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.
                                                  -  16  -

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metal  analysis  requires  the  use  of special
procedures.  [References for dissolved metal analysis
are: Schock and Gardels, 1983, JAWWA, 75(2):87; Harri-
son, R.M. & P.M. Laxen, 1980, Nature (August 21):79l-
793; deMora, S.J. etal., 1987, Water Res. 21(l):83-94;
Brach, R.A., et al., 1991. Proc. AWWA Annual Conf.
(Philadelphia); Hulsmann, A.D., 1990, IWEM (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 and diameter of piping from the
kitchen tap to the service connection and  the
length and diameter 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, then 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.
                                         - 17 -

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Table 3.  Pipe Volume Table (Volumes Listed in Liters)
Pip« Length (Feet)
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 Diameter (In.)
3/g
.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
I
.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 can be added together for pipe lengths not listed.
2. Liters can be converted to gallons by dividing by 3.785.
                      - 18 -

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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 wanner 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 sues 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.
                                        -  19 -

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               Table 4.  Determination of 90th Percentile Values
                    for Lead and Copper Monitoring Results
System Size
50,001 to 100.000
Minimum No. Samples
Required
Initial, Follow-Up,
and Routine
Monitoring
60
Reduced
Monitoring
30
90% Value Position from
Bottom of List
Initial, Follow-Up,
and Routine
Monitoring
54
Reduced
Monitoring
27
Number and Frequency  of
Sampling

Initial Monitoring
   Initial monitoring  for large  PWSs begins
January 1, 1992 and ends on January 1, 1993.
Initial monitoring consists of two consecutive
six-month monitoring periods.  During each
monitoring period each large PWS must collect
at least 60 tap samples for lead and  copper
(Pb/Cu-TAP) at targeted sampling sites. A large
PWS will also collect WQP samples at repre-
sentative sites in the distribution system and at
each entry  point.  After  completing initial
monitoring (January  1, 1992 to January 1, 1993)
all large PWSs will conduct corrosion control
treatment studies (January 1, 1993 to July 1,
1994).  See page  35.

Follow-Up  Monitoring
   Follow-up monitoring for large water systems
begins  on January 1, 1997 and ends on January
1, 1998.  Follow-up monitoring consists of two
consecutive six-month monitoring periods.
During each monitoring period a large water
system must collect at least 60 tap samples for
lead and copper (Pb/Cu-TAP) at  targeted
sampling sites. A large water system will also
collect WQP samples at representative sites in
the distribution system and at each entry point.

Routine Monitoring
  Routine lead and copper tap water sampling
is conducted by each large PWS after the state
specifies the water quality parameter values that
reflect optimal  corrosion  control treatment
(WQP-DIS and WQP-POE). The lead and
copper tap water samples  are collected  to
measure the lead and copper concentration to
which consumers may be exposed after optimal
corrosion control treatment is 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  lead and copper  tap  water
samples are  collected  biannually.  Routine
WQP-DIS samples are collected biannually.
Routine WQP-POE  samples  are  collected
biweekly. Each PWS must continue to meet all
water quality para-meters established by the state
during subsequent monitoring periods to remain
in compliance with the  rule. After a system
complies with state specified WQPs for two
consecutive six month monitoring periods it may
request the state to reduce lead and copper tap
water sampling.
                                       - 20 -

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Reduced Monitoring
   A large PWS that operates in accordance with
state specified water quality parameters during
each of two consecutive six-month monitoring
periods may  request the state to reduce the
required number of lead and copper samples
from 60 to 30, and reduce the frequency for
collection from biannual to annual. A large
water system that operates in accordance with
state specified water quality parameters for three
years (six consecutive six-month monitoring
periods) may request the state to reduce the
frequency  for collecting 30 lead and copper tap
water samples from annually to triennially.  A
water system sampling less frequently than 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.
   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.

Reporting Samples
   All  large  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, triennially).
   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.
                                       - 21  -

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              Water Quality Parameter Monitoring
                                       §141.87
   Water quality parameters (WQP-DIS and
WQP-POE),  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 rule.  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 be limited in 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 sampling 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
that 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 the 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
                                        - 22 -

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locations representative of each source of water
after treatment. If a system draws water from
more than one  source  and the sources are
combined before distribution, the system must
sample at points in the 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 coliform 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, orthophosphate, and silica
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 coliform sample;
  •    Collect a sample to measure disinfectant
       residual;
  •    Collect  and  analyze  a sample for
       temperature and pH;
  •    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.
                                        - 23 -

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Temperature may be measured either by a hand-
held thermometer or by a combined temperature/
pH  electrode and meter. In  all cases,  pH
measurements must use a pH electrode 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: (1) each field sampler subjectively judges
the results,  such that 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, "Methods for Chemical Analysis of Water
and wastes".  EPA 600/4-79-020] are presented below.
Water Quality
Parameter
Conductivity
pH
Temperature
Calcium
Orthophosphate
Silica
Alkalinity
Minimum Sample
Volume
50 mJL
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., et ai., mo, JAWWA, 72(5):304;
Schock, M.  and S.C. Schock, 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.
                                         - 24  -

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   Before beginning the distribution system
sampling, the pH electrode should be calibrated
at pH 7.0 and a second pH level, either 4.0 or
10.0, depending on the pH range typically found
within  the  distribution  system.  For  most
systems, the second pH level for  calibration
should be pH 10.0. For more accurate results,
the pH standard solution used for  calibration
should be near the temperature anticipated for
the water in the distribution system even if the
pH meter is temperature compensated. In most
cases, the temperature of the finished water will
be representative of the temperature found in
the distribution system. To attain the desired
temperature, a small amount of buffer solution
could be placed in a closed container in a flow-
through water bath overnight.
   During transport, the pH probe should be
placed in a sample bottle and secured in the
vehicle.  The pH probe membranes are very
delicate, and they should not come in contact
with hard surfaces or be allowed to dry  out.
It may be a good idea to pack  a replacement
probe  (calibrated  prior to  leaving) in  case
problems are experienced  with the primary
probe.
   During sample collection for the water quality
parameters, care should be taken to avoid over-
agitation of the 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, designed 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 stabilizes. 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 this
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 unfiltered with no digestion or hydrolysis
step performed. The direct colorimetric approach
as highlighted in Figure  2 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 orthophosphate 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 anfi
-------

         Figure 2.  Analytical Scheme for Differentiation
                      of Phosphorus Forms
                             TOTAL  SAMPLE  (NO FILTRATION)
       SAMPLE
    F
    I
    L
    T
    R
    A
    T
    I
    O
    N
           H,S04
        Hydrolysis
           and
        Coloriaetry
Orthophosphate
J
                      Persulfate
                       Digestion
                      Colorimetry
 Hydrolyzable
     plus
Orthophosphate
  Total
Phosphorus
Residua
         Filtrate
                      Direct
                    Coloriaetry
        Hydrolysis
            and
        Coloriaetry
                    Dissolved
                  Orthophosphate
                      Persulfate    i
                       Digestion    !
                     Coloriaetry    |
       Hydrolyzable
           plus
      Orthophosphati
                         Total
                       Dissolved
                       Phosphorus
                            - 26 -

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a permanent data file by sampling location so
that they can be directly compared with lead
and copper results from nearby locations. The
average, maximum and 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 initial monitoring (January 1, 1992
to January 1, 1993), a large PWS must collect
two samples  for each of the following WQPs
at 10 sampling sites in the distribution system
and at each  entry point to the distribution
system:
      pH
       alkalinity
       calcium
       conductivity
       water temperature
       onhophosphate,  when   a phosphate
       inhibitor is used
  •    silica, when a silicate inhibitor is used
  The number of samples required for the
WQPs are fewer than for lead and copper
because these parameters do not vary to the
same extent as lead and copper as such, fewer
samples are required to accurately characterize
the values throughout the distribution system.
Systems  should attempt  to  collect the two
samples in the distribution system as far apart
in time as possible to capture any seasonal
changes that may occur. Water systems should
also collect tap samples and entry point samples
at the same approximate time within the moni-
toring 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 large PWS must collect two samples
for each of the following WQPs at 10 sampling
sites in the distribution system during each six-
month monitoring period:
  •     pH
  •     alkalinity
  •     calcium,  when  calcium   carbonate
       stabilization is used
  •     onhophosphate,  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 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.
  Each large PWS must collect one sample for
each of the following WQPs at each entry  point
to the distribution system every t^p weeks:
                                      - 27  -

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 •     pH
 •     the dosage rate of the chemical used to
       adjust  alkalinity  and  the  alkalinity
       concentration,  when  alkalinity   is
       adjusted
 •     the dosage rate of the inhibitor used and
       the concentration ofonhophosphate or
       silica (whichever is used)  when  an
       inhibitor is  used
   EPA believes  requiring biweekly measure-
ments  at each entry  point to the distribution
system is important to evaluate fluctuations in
these parameters and to assist in establishing
operational targets for  water systems to  maintain
optimal treatment.  To  reduce the burden of
collecting   daily    measurements,   EPA
recommends that systems install a continuous
pH monitoring device  and  dosage  meter  for
alkalinity  and  inhibitors. The devices can be
mounted to  provide easy access and  produce
accurate and reliable results for an extended
period of  time.
   A system may take a confirmation sample
for any WQP value within three days after
receiving  the results  of the first sample. If a
confirmation sample is collected the result must
be averaged for the  purpose of determining
compliance with the state-specified parameter.

Reduced  WQP  Sampling
   Each large PWS that maintains the range of
values for each state-specified WQP for two
consecutive six-month monitoring periods must
continue to  collect two WQP samples during
each six-month  monitoring  period,  but may
reduce the number  of sites from which samples
are collected from 10 to 7.
   Any water  system that maintains the range
of values for state-specified WQPs for  six
consecutive  six-month monitoring periods may
reduce the frequency with which it collects WQP
samples in the distribution system from biannual
to annual. Any water system that collects WQP
samples annually must collect these samples
throughout the year so as to reflect the seasonal
variability to which corrosion control treatment
is subject. Water systems may not reduce the
number or frequency of WQP samples collected
at entry points to the distribution system. A
water system that fails to operate within the
range of values established by the state for any
WQP must resume monitoring in accordance
with  the   initial  number  and  frequency
requirements.
  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 large PWSs must report several pieces
of information for all WQP samples within the
first 10  days  following  the  end of  each
monitoring period (i.e., semi-annually, annually,
triennially).
  Each PWS must report the results of all tap
water samples collected at representative sites
in the  distribution  system for all applicable
WQPs.
  Each PWS  must report the results of  all
source water samples collected at the entry
points) to the distribution system for all applica-
ble WQPs.
  With the exception of tap samples collected
during each water  system's  first monitoring
period, each PWS must  identify  any site(s)
which was not sampled during previous monitor-
ing periods, and include an explanation of why
the sampling site(s) has changed.
                                        -  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 tap water lead and 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 installed
and follow-up samples are submitted, the state
will establish maximum permissible lead and
copper levels. From that point on, the system
must monitor in accordance with the standard-
ized monitoring framework (SMF) established
for inorganic contaminants to  insure lead and
copper levels are maintained below the  state-
specified contaminant levels.
   In those instances where the state does not
require a water system to install source water
treatment,  the  state  will simply  establish
maximum permissible lead and copper levels
with which the system must continue to comply.
These systems, like those that  installed source
water treatment, must monitor in accordance
with  the  SMF  established  for   inorganic
contaminants to insure lead and copper levels
are maintained below state-specified 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 same 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
                                       - 29  -

-------
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
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 treatment 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 specif** maximum
                                     - 30 -

-------
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.
  Surface water systems that demonstrate to
the state that maximum 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 systems
meets the maximum permissible lead and copper
concentrations set by the stale for three consecu-
tive monitoring  periods.

Reporting  Source Water
Samples
  Each large 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.
   Any  large PWS requesting  that the State
reduce the frequency of source water monitoring
must submit several pieces of information, to
the state. For those large PWSs that have not
installed source water treatment, each system
must submit the  results  of all source water
samples demonstrating that source water does
not contribute in excess of the maximum permis-
sible lead and  copper levels set by the state.
For those large PWSs that have installed source
water treatment, each system  must submit the
results of all source water samples demonstrating
that source water does not contribute in excess
of the maximum permissible lead  and copper
levels set by the state.
   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  -

-------
                             Analytical Methods
                                       §141.89
   The approved analytical methods for lead,
copper, and all water quality parameters (pH,
calcium, alkalinity,  silica, orthophosphate,
conductivity, and temperature) are shown in
Table  5.  A summary  of the  preservation
protocols, sample containers, and maximum
holding times  for  analysis is  provided  in
Table 2.
   Laboratory certification will only be required
for lead and copper analyses, and is based on
the performance requirements included with the
method detection limits. In cases where sample
compositing is done, laboratories  must achieve
the method detection limits found below using
the procedure described in Appendix B to Part
136 of the  Code of Federal Regulations.
  The use of the approved analytical methods
for all of the water quality parameters as well
as lead  and copper  is necessary  to  assure
consistent  results  and  high  quality  data.
However, sample collection and analysis proce-
dures in the field  can contribute to errors in
measurement. A quality assurance/quality control
program  for  field  sampling/analysis  and
laboratory analysis should be  developed and
implemented by all PWSs. If a commercial or
State laboratory performs the laboratory anal-
yses, it is still important that quality control
measures be taken for the field sampling portion
of the monitoring  program.
Analyte and Method
Copper
Atomic Absorption, furnace
Atomic Absorption, direct aspiration
Atomic Absorption, platform furnace
Inductively Coupled Plasma
Inductively Coupled Plasma, Mass Spectrometry
Lead
Atomic Absorption, furnace
Atomic Absorption, platform furnace
Inductively Coupled Plasma, Mass Spectrometry
Method
Detection Limit
(mg/L)
0.001
0.020
0.001
0.002**
0.001
0.001
0.001
0.001
Practical
Qaantitttkra Lerd
(mg/L)
0.050
0.005
Minimum
Accuracy
± 10% at
S0.050 mg/L
± 30% at
iO.005 mg/L
II
  Using the 4X concentration technique which would not be required because the copper AL is much
  higher than the detection limits.
 Quality  Assurance/
 Quality  Control  Programs
   A  complete  Quality  Assurance/Quality
 Control  (QA/QC)  program  should contain
 components at each step in the data collection
 process,  including  sample  collection  and
 methods, laboratory  sample handling  and
analysis, and recording/reporting of the results.
An important element in implementing a success-
ful QA/QC program is the ability to properly
track a sample from  its collection through
analysis and ultimate recording in either the state
or  PWS  database. The QA/QC  program
requirements for sample  tracking include: (1)
sample identification; (2) complete sample
                              0-<
                                        -  32 -

-------
labeling; (3) training sample collectors and field
data collectors;  (4)  parallel  construction of
laboratory recordkeeping and database format
to sample labelling and identification; and, (5)
periodic self-audits of the QA/QC procedures.
   Significant benefits could be gained by the
implementation of a program to properly label
and identify samples to track their collection,
analysis, and results. Minimally, the data  fields
(i.e., variables defined within the laboratory
and/or PWS database) needed to fully identify
a sample are:
 1.  PWS Identification Number
 2.  Applicable PWS  Entry Point Identification
    Numbers (There may be multiple entry points
    to a disTribution system which should be  identi-
    fied for each  sample collected within it.)
 3.  Sample Identification Number
 4.  Sample Type  Identifier: (2 Fields)
    (a)  First-draw  Tap,  Distribution System,
        Source Water for Lead and Copper, Source
         Water for Water Quality Parameters, or
        LSI.
    (b)  Initial, Follow-Up,  Routine, Reduced,
         Ultimate  Reduced, or LSL Replacement
        Program.
 5.   Sample Site  Identifier: (3 Fields)
     (a)  Region of Distribution System (Suggest that
        Region 0 be assigned for each entry point
        location.)
     (b)  Subregion of Distribution System (Suggest
        that Subregion 0 be assigned for each entry
        point location.)
     (c)  Sample Site Specific Identifier
 6.   Sample  Collection Date
 7.   Sample Collection Time
 8.   Sample Period
 9.   Sample  Collector  Identifier:  PWS  Staff.
     Resident, State, or Other.
10.   Parameters for Analysis: Lead, Copper, Water
     Quality Parameters or pH and Temperature
     (field measurements).
11.   Sample Site Street Address -for PWS use
12.   Sample Collection Route -for PWS use
13.   PWS Name
14.   PWS Contact Person and telephone number
  The PWS should include data fields to identify
those samples delivered  to  the  laboratory
representing travel blanks and blind spikes.  As
part of a PWS's routine QA/QC program  for
analytical  results,  travel  blanks  should  be
included in at least 10 percent of the sampling
kits delivered to and returned from homeowners
performing tap monitoring. For lead and copper
analyses,  at  least three blind  spike  samples
should be included during every six-month
monitoring period for medium and large PWSs,
and at least one such  sample for small PWSs.
  When  first-draw tap samples  are to  be
collected, the sample bottles must be properly
labelled prior to distribution  if residents  are
collecting the samples. In addition to the sample
bottles, PWSs must supply the residents with
instructions as to the sample collection proce-
dures. The PWS must certify that residents were
informed of the sampling procedures  prior to
collecting  the samples.  If PWS  staff  are
collecting the first-draw tap samples, then they
are required to certify that to the best of their
knowledge, each sample represents first-draw
samples. PWSs will  be required to submit a
statement to  the state at the end of each six-
month monitoring period that these certificates
were obtained (see Form 141-A on page 52).
                                          - 33 -

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               Table  5.   Summary of Approved Analytical Methods  for the Lead and  Copper Rule
Parameter
Lead
Copper
PH
Conductivity
Calcium
Alkalinity
Orthophosphale,
unfilleiod, no
digestion 01
hydrolysis
Silica
Temperature
Methodology*
Atomic absorption; furnace technique
Inductively-coupled plasma; Mass spactrometry
Atomic absorption; Platform furnace technique
Atomic absorption; furnace technique
Atomic absorption; direct aspiration
Inductively-coupled plasma
Inductively-coupled plasma; Mass spectrometry
Atomic absorption; Platform furnace technique
Electrometric
Conductance
EDTA titrimatric
Atomic absorption; direct aspiration
Inductively-coupled plasma
Titrimetric
Electfometric titration
Colonmetric. automated ascorbic acid
ColonmoKic. ascorbic acid, two reagent
Colorimetric, ascorbic acid, singla reagent
Coloiimetric, phosphomolybdate; automated-segmented flow;
automated discrete
Ion chromatography
Colorimetric, molybdata blue;
automated segmented flow
Colorimetric
Molybdosilicate
Heteropoly blue
Automated method for molybdate-reactive silica
Inductively-coupled plasma
Thermometric
Reference (Method Number)
EPA1
239.2
200.8"
200.9'
220.2
220.1
200.7"
200.8"
200.9'
150.1
150.2
120.1
215.2
215.1
200. 76
310.1
365.1
365.3
365.2
300.0"
370.1
200.7'

ASTM2
D355985D
D168890C
D1688-90A
D129384B
D1125-82B
D511 88A
0511 88B
D106788B
D51588A
0432788
0859-88

SM1
3113
3113
3111 B
3120
4500 H*
2510
35OOCaO
3111 B
3120
2320
4500-P-F
4SOO-P-E
4110
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4 500 Si £
4500- SiF
3120
2550
uses4






1 1601 85
1 2601 85
1 2598 85
1-1700-85
1270085

"Methods of Chemical Analysis of Water and Wastes," EPA Environmental Monitoring and Support Laboratory, Cincinnati, OH (EPA-6OO/4-79-O20), Revised March 1983.
Available from ORD Publications, CERI, EPA, Cincinnati, OH 45268.
Annual Book of ASTM Standards, Vol. 11.01. American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 191O3.
"Standard Methods for the Examination of Water and Waste water." 17th Edition. American Public Health Association, American Water Works Association, Water Pollution
Control Federation, 1989.
"Methods for Determination of Inorganic Substances in Water and Fluvial Sediments," 3rd edition. U.S. Geological Survey, 1989.
"Determination of Metals and Trace Elements in Water and Wastes by Inductively-Coupled Plasma Atomic Emission Spectrometry," Revision 3.2. August 1990, U.S. EPA.
EMSL. Cincinnati. OH 45268.
"Determination of Tiuce Elements in Water and Wastes by Inductively Coupled  Plasma Mass Spectromelry." Revision 4.3. Auyust 1990, U.S. EPA, EMSL, EMSL, Cinciniinii
OH 45268.
"Dotaiminittiun <>l Tim:» Elements >>y Stutnluud Temperature Graphite furnuce Atomic Absorption Spectromelry," August  1990, U.S. EPA, EMSL, Cincinnati. OH 4S26U.
       ii.itiiin ol liu>my Ion Chromatoijruphy."  Decomhur 1989,J^^^£PA, EMSL, Cincinnati, OH 45268.
        /inu li:lo to lulul mctiils must Uu u»ud^^^^viiples cannot l>a lilluiud.

-------
TIMELINE
                                            -  35  -

-------
      INITIAL MONITORING REQUIREMENTS FOR
 SYSTEMS SERVING 50.001 TO 100.000 PERSONS
FIRST MONITORING PERIOD     January 1, 1992 to July 1.  1992
SECOND MONITORING PERIOD  July 1,  1992 to January 1,  1993
                                                                NO
         LEAD AND COPPER TAP WATER SAMPLING
     COLLECTION METHODS NEVER CHANGE
     •  One liter
     •  First draw
     •  6-hour standing time
     NUMBER AND FREQUENCY OF SAMPLING
     •  1 sample at 60 sites during each of 2 consecutive 6-month
       monitoring periods
      WATER QUALITY PARAMETER fWQP) SAMPLING
     WOP SAMPLES COLLECTED AT REPRESENTATIVE SITES IN THE
     DISTRIBUTION SYSTEM AND AT EACH ENTRY POINT
       pH
       Alkalinity
       Calcium
       Conductivity
       Temperature
       Orthophosphate, when phosphate-based inhibitor used
       Silica, when silicate-based inhibitor used
     NUMBER OF WOP SAMPLES COLLECTED AT REPRESENTATIVE SITES
     IN THE DISTRIBUTION SYSTEM
     •  2 samples at 10 sites during each of 2 consecutive 6-month
       monitoring periods
     NUMBER OF WOP SAMPLES COLLECTED AT EACH ENTRY POINT
     •  2 samples at each entry point during each of 2 consecutive 6-month
       monitoring periods
                   MONITORING PERIODS
     FIRST MONITORING PERJOD
     • January 1,1992 to July 1, 1992 (submit by July 11,1992)
     SECOND MONITORING PERIOD
     • July 1. 1992 to January 1, 1993 (submit by January 11,1993)
                                  - 36 -

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     FOLLOW UP MONITORING REQUIREMENTS FOR
   SYSTEMS SERVING 50.001 TO 100.000 PERSONS
FIRST MONITORING PERIOD    January 1. 1997 to July 1,  1997
SECOND MONITORING PERIOD  July 1. 1997 to January 1,  1998
         LEAD AND COPPER TAP WATER SAMPLING
     NUMBER AND FREQUENCY OF SAMPLING
     •  1 sample at 60 sites during each of 2 consecutive 6-month
       monitoring periods
                                                                      (O
                                                                      vj
      WATER QUALITY PARAMETER (WQP) SAMPLING
     AT REPRESENTATIVE SITES IN THE DISTRIBUTION SYSTEM
     •  PARAMETERS SAMPLED
       o   pH
       o   Alkalinity
       o   Calcium, when calcium carbonate stabilization used
       o   Orthophosphate, when phosphate-based inhibitor used
       a   Silica, when silicate-based inhibitor used
     •  NUMBER AND FREQUENCY OF SAMPLING
       o   2 samples at 10 sites  during each of 2 consecutive 6-month
           monitoring periods
     AT EACH ENTRY POINT TO THE DISTRIBUTION SYSTEM
     •  PARAMETERS SAMPLED
       o
       o
    PH
    When alkalinity is adjusted, the dosage rate of the chemical
    used to adjust it and the concentration of alkalinity
o   When an inhibitor is used, the dosage rate of the inhibitor and
    the concentration of orthophosphate or silicate (whichever is
    used)
NUMBER AND FREQUENCY OF SAMPLING
o   1 sample at each entry point every 2 weeks
                    MONITORING PERIODS
     FIRST MONITORING PERIOD
     • January 1, 1997 to July 1, 1997 (submit by July 11,1997)
     SECOND MONITORING PERIOD
     • July 1, 1997 to January 1, 1998 (submit by January 11,1998)
                                   - 37 -

-------
  STATE REVIEWS RESULTS OF FOLLOW-UP SAMPLES
STA TE REVIEW
January 1, 1998 to July 1,  1998
                                                                                 Co
                   STATE ESTABLISHES WQPs
     State establishes WOP values measured at representative sites in the
     distribution system:
     •  pH level
     •  Alkalinity concentration, when alkalinity adjusted
     •  Calcium concentration, when calcium adjusted
     •  Orthophosphate concentration, when a phosphate-based inhibitor is
        used
     •  Silica concentration, when a silicate-based inhibitor is used
     State establishes chemical dosage rates measured at entry points to
     the distribution system:
     •  Chemical used to adjust pH, when pH adjusted
     •  Dosage rate of the chemical used to adjust alkalinity, when alkalinity
        adjusted
     •  Dosage rate of chemical used to adjust calcium, when calcium
        adjusted
     •  Dosage rate of inhibitor used, when inhibitor used
                      STA TE REVIEW PERIOD
     State must establish WQP values that must be met at sampling sites in
     the distribution system and chemical dosages that must be maintained
     at each entry point to the distribution system

     State must inform the system of these WQP values in writing by
     July 1. 1998
                                       - 38 -

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     MONITORING REQUIREMENTS FOR SYSTEMS
         SERVING 50.001 TO  100.000 PERSONS
           AFTER STATE ESTABLISHES WQPs
FIRST MONITORING PERIOD     July 1, 1998 to January 1, 1999
SECOND MONITORING PERIOD  January 1,  1999 to July 1, 1999
         LEAD AND COPPER TAP WATER SAMPLING
     NUMBER AND FREQUENCY OF SAMPLING
     •  1 sample at 60 sites every 6 months
5°
&
Co
      WATER QUALITY PARAMETER (WOP) SAMPLING
     AT REPRESENTATIVE SITES IN THE DISTRIBUTION SYSTEM
     •  PARAMETERS SAMPLED
       o   pH
       o   Alkalinity
       o   Calcium, when calcium carbonate stabilization used
       o   Orthophosphate, when phosphate-based inhibitor used
       o   Silica, when silicate-based inhibitor used
     •  NUMBER AND FREQUENCY OF SAMPLING
       o   2 samples at 10 sites every 6 months
     AT EACH ENTRY POINT TO THE DISTRIBUTION SYSTEM
     •  PARAMETERS SAMPLED
       o   pH
       o   When alkalinity is adjusted, the dosage rate of the chemical
           used to adjust it and the concentration of alkalinity
       o   When an inhibitor is used, the dosage rate of the inhibitor and
           the concentration of orthophosphate or silicate (whichever is
           used)
     •  NUMBER AND FREQUENCY OF SAMPLING
       o   1 sample at each entry point every 2 weeks
                   MONITORING PERIODS
     FIRST MONITORING PERIOD
     •  July 1. 1998 to January 1, 1999 (submit by January 11, 1999)
     SECOND MONITORING PERIOD
     •  January 1, 19.99 to July 1, 1999 (submit by July 11,1999}
                                   - 39 -

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       REDUCED MONITORING REQUIREMENTS FOR
    SYSTEMS SERVING 50.001 TO 100.000 PERSONS
Beginning July 1. 1999

  System maintaining values for WQPs at representative sites in the
  distribution system for 2 consecutive 6-month monitoring periods, and
  at each entry point to the distribution system for 1 year, may reduce
  sampling as follows:
         LEAD AND COPPER TAP WATER SAMPLING
     NUMBER AND FREQUENCY OF SAMPLING
     • 1 sample at 30 sites annually
     REQUESTING REDUCED SAMPLING
     • System must submit written request asking the state to reduce the
       number and frequency of lead and copper tap water sampling (see
       Form 141-B on page 55)
     • State must review lead and copper data submitted by the system
       and provide a written response
       WA TER QUALITY PARAMETER fWQP) SAMPLING
     AT REPRESENTATIVE SITES IN THE DISTRIBUTION SYSTEM
     • PARAMETERS SAMPLED
       o   pH
       o   Alkalinity
       o   Caicium, when calcium carbonate stabilization used
       a   Orthophosphate. when phosphate-based inhibitor used
       o   Silica, when silicate-based inhibitor used
     • NUMBER AND FREQUENCY OF SAMPUNG
       o   2 samples at 7 sites every 6 months
     AT EACH ENTRY POINT TO THE DISTRIBUTION SYSTEM
     • PARAMETERS SAMPLED
        o   pH
        o   When alkalinity is adjusted, the dosage rate of the chemical
            used to adjust it and the concentration of alkalinity
        o   When an inhibitor is used, the dosage rate of the inhibitor and
            the concentration of orthophosphate or silicate (whichever is
            used]
     • NUMBER AND FREQUENCY OF SAMPLING
        o   1 sample at each entry point every 2 weeks
                                     - 40 -

-------
          REDUCED MONITORING PERIODS
Lead and Copper Must Be Sampled Annually
• July 1. 2000 (submit by July 11, 2000)
• July 1. 2001 (submit by July 11, 2001)
• July 1, 2002 (submit by July 11, 2002)
WQPs Must Be Sampled at Representative Sites in the Distribution
System Every 6 Months
• January 1, 2000 (submit by January 11, 2000)
• July 1, 2000 (submit by July 11. 2000)
• January 1, 2001 (submit by January 11, 2001)
• July 1, 2001  (submit by July 11, 2001)
• January 1, 2002 (submit by January 11, 2002)
• July 1, 2002 (submit by July 11, 2002)

WQPs Must Be Sampled at Each Entry Point to the Distribution System
Every 2 Weeks
                                 - 41 -

-------
       REDUCED MONITORING REQUIREMENTS FOR
    SYSTEMS SERVING 50,001 TO 100.000 PERSONS
Beginning July 1, 2002

  System maintaining values for WQPs at representative sites in the
  distribution system for 6 consecutive 6-month monitoring periods, and
  at each entry point to the distribution system for 3 years, may reduce
  sampling as follows:
         LEAD AND COPPER TAP WATER SAMPLING
     NUMBER AND FREQUENCY OF SAMPLING
     • 1 sample at 30 sites every 3 years
     REQUESTING REDUCED SAMPLING
     • System must submit written request asking the state to reduce the
       number and frequency of lead and copper tap water sampling (see
       Form 141-B on page 55
     • State must review lead and copper data submitted by the system
       and provide a written response
       WA TER QUALITY PARAMETER (WQP) SAMPLING
     AT REPRESENTATIVE SITES IN THE DISTRIBUTION SYSTEM
     • PARAMETERS SAMPLED
        o   pH
        o   Alkalinity
        o   Calcium, when calcium carbonate stabilization used
        o   Orthophosphate, when phosphate-based inhibitor used
        o   Silica, when silicate-based inhibitor used
     • NUMBER AND FREQUENCY OF SAMPLING
        o   2 samples at 7 sites annually
     AT EACH ENTRY POINT TO THE DISTRIBUTION SYSTEM
     • PARAMETERS SAMPLED
            pH
        o   When alkalinity is adjusted, the dosage rate of the chemical
            used to adjust it and the concentration of alkalinity
        o   When an inhibitor is used, the dosage rate of the inhibitor and
            the concentration of orthophosphate or silicate (whichever is
            used)
        NUMBER AND FREQUENCY OF SAMPLING
        o   1 sample at each entry point every 2 weeks
                                     - 42 -

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          REDUCED MONITORING PERIODS
Lead and Capper Must Be Sampled Every 3 Years
• July 1, 2005 (submit by July 11, 2005)
• July 1. 2008 (submit by July 11, 2008)
• July 1, 2011 (submit fay July 11. 2011)
• Every 3 years thereafter
WQPs Must Be Sampled at Representative Sites in the Distribution
System Annually
• July 1, 2003 (submit by July 11, 2003)
• July 1, 2004 (submit by July 11, 2004)
• July 1. 2005 (submit by July 11, 2005)
• Annually thereafter

WQPs Must Be Sampled at Each Entry Point to the Distribution System
Every 2 Weeks
                                 - 43  -

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Timeline
                                          - 44  -

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Timeline
                                        - 45 -

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       INITIAL SOURCE WATER MONITORING
       REQUIREMENTS FOR LARGE SYSTEMS
FIRST MONITORING PERIOD     July 1, 1992 to January 1.  1993

  The schedule discussed in this section assumes the water system exceeds an
  action level in the first monitoring period.
      LEAD AND COPPER SOURCE WATER SAMPLING
     If the lead or copper action levei is exceeded in tap water samples the
     system must collect 1 sample at each entry point to the distribution
     system in accordance with the collection methods specified in
     §141.23(a)(1) to (4>
                   MONITORING PERIODS
     FIRST SOURCE WATER MONITORING PERIOD
     •  July 1.. 1992 to January 1, 1993 {submit by January 11, 1993)
     •  System must submit source water treatment recommendation with
       lead and copper source water samples
                                   - 46 -

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    SOURCE WATER  MONITORING REQUIREMENT
  AFTER THE  STATE  SETS MAXIMUM PERMISSIBLE
   LEAD AND COPPER LEVELS FOR SYSTEMS NOT
      INSTALLING SOURCE WATER TREATMENT
                                        JO
                                        5°
                                        Co
PERIOD FOR
 STA TE DETERMINA TION
January 1. 1993 to July 1, 1993
  If a system is not required to install source water treatment the state wil
  establish maximum permissible 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 point to the distribution
       system during the 3-year compliance period in effect when the state
       determines treatment is not needed, and it sets maximum
       permissible lead and copper levels
     • System must collect 1  sample at each entry point to the distribution
       system during each subsequent 3-year compliance period
     SURFACE WATER SYSTEMS
     • System must collect 1 sample at each entry point to the distribution
       system annually
     • The first year begins on the date the state determines treatment is
       not needed and it sets maximum permissible lead and copper levels
                    MONITORING PERIODS
     GROUNDWATER SYSTEMS
     • System must collect all source water samples and submit the results
       to the state by the following dates:
       1 st Compliance Period  January 1, 1996     January 11, 1996
       2nd Compliance Period January 1, 1999     January 11, 1999
       3rd Compliance Period  January 1, 2002     January 11, 2002
     SURFACE WATER SYSTEMS
     • System must collect all source water samples and submit the results
       to the state by the following dates:
       1st Year             January 1, 1994     January 11, 1994
       2nd Year             January 1, 1995     January 11, 1995
       3rd Year             January 1, 1996     January 11, 1996
                                       47 -

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    FOLLOW-UP SOURCE WATER MONITORING
         FOR LARGE SYSTEMS  INSTALLING
            SOURCE WATER TREATMENT
FIRST MONITORING PERIOD    July 1. 1995 to January 1, 1996

SECOND MONITORING PERIOD  January 1. 1996 to July 1, 1996

  If a system is not required to install source water treatment h has 24 months
  to install and operate the treatment and 12 months to collect and submit
  follow-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 periods
                  MONITORING PERIODS
    FIRST MONITORING PERIOD
    • July 1, 1995 to January 1, 1996 (submit by January 1T, 1996)
    SECOND MONITORING PERIOD
    • January 1. 1996 to July 1, 1996 (submit by July 11, 19961
                                 - 48 -

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    SOURCE WATER MONITORING REQUIREMENT
  AFTER THE STATE SETS MAXIMUM PERMISSIBLE
      LEAD AND COPPER LEVELS FOR SYSTEMS
      INSTALLING SOURCE WATER TREATMENT
                                               
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     REDUCED MONITORING  REQUIREMENTS FOR
   LARGE SYSTEMS NOT INSTALLING TREATMENT
GROUNDWATER SYSTEMS

SURFACE WATER SYSTEMS
Beginning January 1, 2002

Beginning January 1, 2002
     LEAD AND COPPER SOURCE WATER MONITORING
     GROUNDWATER SYSTEMS
     •  System that maintains lead and copper concentrations below the
       levels set by the state for 3 consecutive 3-year compliance periods
       may reduce source water monitoring to once per 9-year compliance
       cycle
     SURFACE WATER SYSTEMS
     •  System that maintains fead 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 cycle •
              REDUCED MONITORING PERIODS
     GROUNDWATER AND SURFACE WATER SYSTEMS
     •  Reduced monitoring would take place in the second 9-year
       compliance cycle, which begins January 1, 2002 and ends
       January 1, 2011
     •  System must collect 1 sample at each entry point to the distribution
       system and submit the results to the state by January 11, 2011
                                   - 50 -

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   REDUCED MONITORING REQUIREMENTS FOR
    LARGE SYSTEMS INSTALLING TREATMENT
GROUNDWATER SYSTEMS
SURFACE WATER SYSTEMS
Beginning January 1, 2011
Beginning January 1, 2002
                                                                                    N
                                                                                    C
     LEAD AND COPPER SOURCE WATER MONITORING
     GROUNDWATER SYSTEMS
     •  System that maintains lead and copper concentrations betow the
       levels set by the state for 3 consecutive 3-year compliance periods
       may reduce source water monitoring to once per 9-year compliance
       cycle
     SURFACE WATER SYSTEMS
     •  System that maintains lead and copper concentrations betow the
       levels set by the state for 3 consecutive years may reduce source
       water monitoring to once per 9-year compliance cycle
              REDUCED MONITORING PERIODS
     GROUNDWATER SYSTEMS
     •  Reduced monitoring would take ptace in the third 9-year compliance
       cycle, which begins January 1, 2011 and ends January 1. 2020
     •  System must collect 1 sample at each entry point to the distribution
       system and submit the results to the state by January 11, 2020
     SURFACE WATER SYSTEMS
     •  Reduced monitoring would take place in the second 9-year
       compliance cycle, which begins January 1, 2002 and ends January
       1, 2011
     •  System must collect 1 sample at each entry point to the distribution
       system and submit the results to the state by January 11, 2011
                                   -  51  -

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        SAMPLE SITE IDENTIFICATION AND  CERTIFICATION
System's Name:
Address:


Telephone number:
System ID »:
Contact Person:

Type: D
Size: D
D
D
a
a
a



CWS D NTNCWS
> 100.000
10.001 to 100.000
3.301 to 10,000
501 to 3,300
101 to 500
£100
                         CERTIFICATION OF SAMPLING S/7FS
LEAD SOLDER SITES
n 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 1 982 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 arid where lead solder was used from 1982 to
       present
  	 Survey residents in sections of the service area where lead pipe and/or copper pipe with lead
       solder is  suspected to exist
       Interviews with local contractors and developers
 Explanation of Tier 2 and Tier 3 sites (attach additional pages if necessary)
                                           -  52 -

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Form 141-A (continued)
                                                                                    r-age
         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):
                     CERTIFICATION OF COLLECTION METHODS
 I certify that:
    Each first draw tap sample for lead and copper is one liter in volume and has stood motionless in the
 plumbing system of each sampling site for at least six hours.
    Each first draw sample collected from a single-family residence has been collected from the cold
 water kitchen tap or bathroom sink tap.
    Each first draw sample collected from a non-residential building has been collected at an interior tap
 from which water is typically drawn for consumption.
    Each first-draw sample collected during an annual or triennial monitoring period has been collected
 in the months of June, July, August or September.
    Each resident who volunteered to collect  tap water samples from his or her home has been properly
 instructed by [insert water system's name! 	
  in the proper methods for collecting lead and copper samples.  I do not challenge the accuracy of those
  sampling results.  Enclosed is a copy of the material distributed to residents explaining the proper
  collection methods, and a list of the residents who performed sampling.                *'*
                                           - 53 -

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Fcr.-n  : 41-A 'continued)
        SAMPLE SITE IDENTIFICATION AND CERTIFICATION
                          RESUL TS 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 entry point samples required_
            # of tap samples submitted
            # of entry point samples submitted.
                         CHANGE OF SAMPLING SITES
 Original site address:
 New site address:
 Distance between sites (approximately):
 Targeting Criteria: NEW:
                 OLD:
 Reason for change (attach additional pages if necessary):
 SIGNATURE
  NAME
       TITLE
       DATE
                                    - 54 -

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Form 1 41-B
                                                                   r'age
    REQUEST FOR REDUCED LEAD AND COPPER TAP WATER
System's Name:
Address:


Telephone number:
System ID #:
Contact Person:

Type: D
Size: D
D
a
a
a
a



CWS D NTNCWS
> 100.000
10.001 to 100.000
3.301 to 10.000
501 to 3.300
101 to 500
^100
                         REQUEST FOR REDUCTION
   The
                       water system has:
   D maintained tap water levels below the lead/copper action Jevel(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
          a
          a
          a
          a
          a
100 to 50
60 to 30
40 to 20
20 to 10
10 to 5
   The results of all water quality parameter samples and lead and copper tap water
   samples collected during each of the monitoring periods are summarized and
   attached.
 SIGNATURE
  NAME
TITLE
           DATE
                                   - 55 -

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WORKSHEET
                 MATERIALS SURVEY INVESTIGATION RESULTS
PWS FRDS NUMBER
POPULATION SERVED BY PWS
Type of
Structure











«

Location

















Contact Parson
Name













Phono













LSI














Homo
Plumbing
Material













Verified













Volun-
teered













Selected
Routine













Optional













Received
Training
Material














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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 Plumbing Material
Interior Plumbing
Lead Pipe
Copper
>1982
Copper
<1983
Number of Service Connections











•.
Distribution System Piping
LSLs
Entire Line
Partial Line
Number of Service Connections








                        57 -

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         SUMMARY OF MATERIALS SURVEY RESULTS
PWS FRDS NUMBER
POPULATION SERVED BY PWS
Plumbing Material
Interior Plumbing
Lead Pipe
Copper Pipe With Lead Solder > 1982
Copper Pipe With Lead Solder <1983
Service Lines
LSLs .
Entire Line
Partial Line
Total Available Sites
Type of Structure
SFR
MFR
BLDG
Number of Service Connections
























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                          - 58 -

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