EPA 812/B-92-009
MAY 1992
Monitoring Requirements
for Lead and Copper Rules
Water Systems Serving
> 100,000 Persons
for
Office of Ground Water and Drinking Water
U.S. Environmental Protection Agency
Washington, D.C.
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Table of Contents
Definitions Applicable to the Lead and Copper Rules ; iii
Monitoring Protocols 1
Additional Monitoring Data 2
Demonstrating Optimal Control Treatment with Tap Water
and Source Water Samples 2
Lead 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 19
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
Walcr Quality Parameter Analyses 23
Number and Frequency of WQP Sampling 27
WQP Sampling Before Installing Optima] Corrosion Control Treatment 27
WQP Sampling After Installing Optimal Corrosion Control Treatment and
After the Slate Specifies Numerical Values 27
Reduced WQP Sampling 28
Reporting WQP Sampling 28
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 31
Cessation of Lead and Copper Source Water Sampling 31
Analytical Methods — §141.89 32
Quality Assu ranee/Quality Control Programs 32
Tap Water Monitoring Schedules 35
Source Water Monitoring Schedules 45
Sample Forms 52
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List of Tables
Table 1. Timeframe for Large PWS Corrosion Control Submissions to the State 3
Table 2. Sample Handling Requirements for Lead, Copper, and Water Quality Parameters 16
Table 3. Pipe Volume Table 18
Table 4. Determination of 90th Percentile Values for Lead and Copper Monitoring Results 20
Table 5. Summary of Approved Analytical Methods for the Lead and Copper Rule 34
List of Figures
Figure 1. Preferred Sampling Pool Categories for Targeted Sampling Sites 12
Figure 2. Analytical Scheme for Differentiation of Phosphorus Forms 26
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•^•i's^---l-y.&&jw
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.
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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.
• NTNCWSs 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.
• WQP 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.
• WQP-DIS means lead and copper measured at representative locations throughout the distribution system.
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Monitoring Requirements
The U.S. Environmental Protection Agency
promulgated National Primary Drinking Water
Regulations (NPDWRs) for lead and copper on
June 7, 1991 (56 FR 26460).
Three monitoring protocols are included in
the final rule: (1) tap water monitoring for lead
and copper; (2) water quality parameter (WQP)
monitoring; and (3) source water monitoring
for lead and copper. 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 biannually. 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 for pH, 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 biannually
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 biannually at
representative sites in the distribution system.
Once a system reduces monitoring, WQP
samples are collected biannually, and ultimately,
annually at representative sites in the distribution
system. A PWS may not reduce the frequency
with which it collects WQP samples at entry
points to the distribution system. 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,
biennially, 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 man 0.005
mg/L. To make this demonstration the system
must collect tap water samples for lead at the
required number of sites (100), 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 , - ' j
Justification for Insufficient Number
of LSI Sites and/or Expansion to Tier
II or Tier III Sites in Sample Plan
First Six-Month Initial Monitoring
Period Results
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-A and 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 wish
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 §141.86(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 Data—Water
quality data for lead and copper levels in
home tap samples and service line samples
can be used to indicate problem areas.
They may also be used to confirm the
presence of lead- and copper-containing
materials in areas where insufficient
information exists. Site visits and verifi-
cation checks on individual sites should
be performed to confirm the site's
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 part of the monitoring for corrosivity
required under Section 141.42 (d) of the
Code of Federal Regulations—This section
refers to previous requirements set by the
EPA, that all community water suppliers
(1) determine corrosivity characteristics
by measuring water quality parameters for
corrosion indices, and (2) perform a
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materials survey to identify lead, copper,
galvanized iron, and asbestos cement as
being present in the system.
2. Distribution Maps and Record Drawings-
Maps and drawings of the distribution
system should be a primary source for
service line and connection information
including materials, line sizes, and dates.
Even with a lack of detail such sources
may be useful in indicating the historical
growth of the system. The maps would
also provide a visual aid in developing the
materials survey.
3. Maintenance Records—Maintenance
records often identify such information
as (1) existing materials; (2) replacement
materials; (3) date of event; and (4)
particular site conditions of note. LSLs
may be specifically identified when
encountered during maintenance activities.
4. Historical Documentation—Every u tility
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 Daw—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 contractors or develop-
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yffffiagi^^
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 begins, the same
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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 -
-------
&%^SS$Z3X3$$^^
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 I sites before initial monitoring begins
on January 1, 1992. Form 141-A on page 52
should be submitted to the state to justify the
use of Tier 2 and/or 3 sites.
Illegally Installed Lead
Plumbing Materials
The rule does not require PWSs to target sites
with illegally installed lead solder (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 more than 100,000
people can only confirm 30 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
50 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 the date that
the lead ban went into effect in the PWS
- 9 -
-------
service 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 or copper pipe with lead
solder installed after 1982, then the entire
sample pool should consist of these sites.
TIER 2
Category D
If a PWS cannot identify enough SFRs with
LSLs to fill 50% of the sample pool, and does
not have enough SFRs meeting the criteria in
Categories A through C to fill the 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.
TIERS
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 -
-------
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 -
-------
111
Figure 1. Preferred Sampling Pool Categories for
Targeted Sampling Sites
SAMPLE POOL DESCRIPTION
Most preferred sampling sites pool would consist of all Single Family
Residences (SFRs)*, with 50% of the sample sites consisting of LSLs and
50% consisting of either internal lead pipe or copper pipe with lead
solder installed after 1982.
If CATEGORY A sampling pool cannot be achieved, the pool should consist
of all SFR where all identified LSI sites are included and the remainder
of the required samples should consist of tap samples from homes with
lead pipe or copper pipe with lead solder installed after 1982.
If CATEGORIES A and B cannot be met and the utility can prove that there
are no LSLs in SFRs, 100% of the sample pool should be tap samples
collected from homes with lead pipe or copper pipe with lead solder
installed after 1982.
If enough SFRs with LSLs and lead or copper pipe with lead solder
installed after 1982 cannot be identified to fill the required number of
sample sites, the'utility may supplement the pool with sites from Multi-
Family Residences(MFRs) and/or public and private buildings (BLDGs)
supplied by LSLs or lead or copper pipe with lead solder installed after
1982.
If the above categories cannot be fully met, then the remainder of the
sites required must be filled with SFRs having copper pipe with lead
solder installed prior to 1983.
LEGEND
Tap Sample Sites from SFRs. > 1982
LSLJ LSL Sample Sites from SFRs
MFR/8LDG Tap (> 1982) and LSL Sample Sites
Tap Sample Sites from SFRs, < 1983
•Not*: IIMFTUoompnuitluttJtTlfcadrwMmocaanfMcaaranti* -1
wxur syium. t>M MFFU rrvty b* oduMO in CATEGORIES A.S. and C lamping '
poott if Si«y fflMt tM r«qur«d oiuru.
-------
&^tt&XttXWX&&^
Figure 1. Preferred Sampling Pool Categories for
Targeted Sampling Sites (Continued)
SAMPLE POOL
DESCRIPTION
F
F.1
EXCEPTIONAL CASES
Category F.1 consists of those PWSs that only have plastic interior plumbing
but cannot demonstrate'lead-free* conditions due to the presence of brass
faucets. These systems should monitor at SFRs with brass faucets.
F.2
Category F.2 includes those PWSs that only have sites where water
softeners have been installed. These systems should select the highest
risk sites (SFRs>82, SFRs_Pb, SFRs_LSL) and monitor at these locations
even though the water softener is present.
LEGEND
Plastic interior plumbing but not
•Lead-Free*.
Water softeners at all available sites.
- 13 -
-------
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 turn off the water.
4. Tightly cap the sample bottle and place in the sample kit provided. Please review the sample kit label
at this time to ensure that all information contained on the label is correct.
5. IF ANY PLUMBING REPAIRS OR REPLACEMENT HAS BEEN DONE IN THE HOME SINCE
THE PREVIOUS SAMPLING EVENT, NOTE THIS INFORMATION ON THE LABEL AS PROVIDED.
6. Place the sample kit outside of the residence in the location of the kit's delivery 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 -
-------
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,
particulate, or as a dissolved constituent but
adsorbed onto a particle. The analyses for total
metals include steps which make each form of
the metal available for measurement. This is
accomplished by first acidifying the sample to
approximately a pH 2 through the addition of
nitric acid (see third footnote of Table 5).
Particulate lead and copper dissolve and enter
solution under these low pH conditions. The
sample is then subjected to a digestion step
which applies elevated temperatures and
agitation to further dissolve particulate 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 -
-------
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. HNO3 to pH <23
Cone. HNO3to pH <23
None
Cool, 4°C
Cone. HN03to pH <25
Cool, 4°C
Cool, 4°C
Cool, 4°C
None
Container1
PorG
For G
PorG
PorG
PorG
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 Immediately4
P = Plastic, hard or soft; G = Glass, hard or soft.
In all cases, samples should be analyzed as soon after collection as possible.
If HN03 cannot be used because of shipping restrictions or is not used because homeowners are collecting samples, the sample
for analysis can be shipped to a laboratory where it must be acidified (generally to pH < 2) with concentrated HN03 as soon
as possible but not later than 1 4 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 HN03 will result in a pH < 2. Therefore, all samples can be automatically preserved with 1.5 mL of the acid, and all
standards can be made with the same acid concentration. In some extreme, high-alkalinity cases, more acid may be necessary.
"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 water is poorly
buffered.
If HNO3 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 HNO3 to pH < 2.
16 -
-------
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.H. Laxen, 1980, Nature (August 21):791-
793; deMora, S.J. et ah, 1987, Water Res. 21(l):83-94;
Brach, R.A., et ah, 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 -
-------
Table 3. Pipe Volume Table (Volumes Listed in Liters)
Pipe 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.)
3/8
.06
.09
.11
.14
.17
.20
.23
.26
.28
.31
.34
.37
.40
.43
.46
.49
.51
.54
.57
.71
.86
1.00
1.14
1.43
1/2
.09
.14
.18
.23
.27
.32
.36
.41
.45
.50
.55
.59
.64
.68
.73
.78
.82
.86
.91
1.14
1.36
1.59
1.82
2.27
5/8 -
.14
.21
.27
.34
.41
.48
.55
.62
.69
.75
.82
.89
.96
1.03
1.10
1.16
1.23
1.30
1.37
1.71
2.06
2.40
2.74
3.43
3/4
• 19
.29
.38
.48
.57
.67
.76
.86
.95
1.05
1.14
1.24
1.33
1.43
1.52
1.62
1.71
1.81
1.90
2.38
2.85
3.33
3.80
4.76
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
14/4
.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 -
-------
-?ftt^^^
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 sites and the behavior of the high lead levels
is inconsistent. The nature of lead and copper
monitoring results does not lend itself to the
typical data analyses used by utilities.
Consequently, the average concentration is not
a very useful measurement of the behavior of
lead and copper levels experienced in the
distribution system because it can be overly
influenced by a large number of low
concentrations and a few extremely high
concentrations. For this reason, distribution
frequency or the percent of samples below or
above a specified value proves most useful in
analyzing lead and copper data. This is the basis
for the ALs being based on a certain frequency
of samples which have lead and copper levels
less than 0.015 mg/L and 1.3 mg/L,
respectively.
Action levels are exceeded if the "90th
percentile" value is greater than 0.015 mg/L
for lead and 1.3 mg/L for copper. To determine
whether the monitoring results meet the action
levels stipulated for lead and copper, list the
collected data from the highest value recorded
to the lowest value recorded. The 90th percentile
values for lead and copper can be determined
by multiplying the number of samples taken by
0.9. This number is the position of the 90th
percentile value. Starting from the bottom
(lowest value) count up until the calculated
number (0.9 x # samples) is reached. The
sample value in this number position is the 90th
percentile value. The 90th percentile values for
lead and copper can be determined by moving
down the listed values the number of positions
indicated in Table 4 for each water system size.
Interpolation of lead and copper levels may
be necessary in some cases to determine system
performance at the desired frequency. If the
90th percentile value is represented by a sample
position other than an integer, (e.g. 0.9 x
# samples = 17.3), then the 90th percentile
value must be found by interpolating the results
of the lower and higher samples (e.g., the 17th
and 18th results in this case). The rounding
convention to be used when interpolating
between two analytical results is as follows:
all results greater than or equal to 0.5 units
round to the next unit, and results less than 0.5
units round down.
- 19 -
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Table 4. Determination of 90th Percentile Values
for Lead and Copper Monitoring Results
System Size
> 100,000
Minimum No. Samples
Required
Initial, Follow-Up,
and Routine
Monitoring
100
f •
Reduced
Monitoring i
50
90% Vaf ue Position from
Bottom of list
Initial, Follow-Up,
and Routine'
Monitoring
90
Reduced
Monitoring
45
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 100 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 100 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.
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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 100 to 50, 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 50 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
mat 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
, iParameter
Conductivity
PH
Temperature
Calcium
Orthophosphate
Silica
Alkalinity
Minimum Sample i
Volume .
50 mL
25 mL
1000 mL
100 mL
50 mL
50 mL
100 mL
Since temperature and pH are to be measured
in the field, a single sample may be used for
their analysis. PWSs with poorly buffered water
supplies may consider performing pH analyses
under a "closed system" to reduce measurement
shift and increase the accuracy of the pH
analyses [Schock, M.t etal., I9W,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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ftasggg^ftwassai^^
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 the
bottle with the probe inside until the pH reading
stabilizes; this could take several minutes. When
stable, record the measurement, rinse the
electrode with deionized water and replace it
in its holding bottle. When the temperature and
pH measurements are completed, discard the
sample. Recalibrate the pH probe if not used
over an extended period of time to adjust any
measurement shift which may have occurred
and record this information.
While small changes in the levels of
conductivity, alkalinity, calcium, orthophos-
phate, and silica may occur between the time
of a sample's original collection and its analysis
in the laboratory, the error introduced by the
delay should be negligible as long as the sample
bottles are fully filled, kept cool throughout the
day, and the handling practices summarized in
Table 2 are followed. If these parameters are
measured as part of the normal operating
practices of the utility, then the distribution
system and entry point water samples should
be analyzed in exactly the same fashion and by
the same personnel. This will allow the data
collected to be directly comparable to water
quality data collected throughout the water
treatment plant.
For those PWSs which apply a phosphate-
based corrosion inhibitor, measurement of
orthophosphate is required. These samples must
be 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 and stored in
- 25
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Figure 2. Analytical Scheme for Differentiation
of Phosphorus Forms
TOTAL SAMPLE (NO FILTRATION)
SAMPLE
F
I
L
T
R
A
T
I
O
N
Direct
Colorimetry
I
H2S04
Hydrolysis
and
Colorimetry
Orthophosphate
Persulfate
Digestion
Colorimetry
Hydrolyzable
plus
Orthophosphate
Total
Phosphorus
Residue
Filtrate
Direct
Colorimetry
Hydrolysis
and
Colorimetry
Dissolved
Orthophosphate
Persulfate
Digestion
Colorimetry
Hydrolyzable
plus
Orthophosphate
Total
Dissolved
Phosphorus
- 26 -
-------
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 25 sampling sites in the distribution system
and at each entry point to the distribution
system:
pH
alkalinity
calcium
conductivity
water temperature
orthophosphate, when a phosphate
inhibitor is used
• silica, when a silicate inhibitor is used
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 25 sampling
sites in the distribution system during each six-
month monitoring period:
• pH
• alkalinity
• calcium, when calcium carbonate
stabilization is used
• orthophosphate, when a phosphate
inhibitor is used
• silica, when a silicate inhibitor is used
EPA believes that these samples, collected
in conjunction with the lead and copper 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 two weeks:
- 27 -
-------
• 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 oforthophosphate 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 25 to 10.
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.
Stales 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
point(s) 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 specifies 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 state 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 me 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
<«ng/L)
0.001
0.020
0.001
0.002**
0.001
0.001
0.001
0.001
Practical
Quantitation Level
(mg/L)
0.050
0.005
Minimum
Accuracy
± 10% at
^0.050 mg/L
± 30% at
SO. 005 mg/L
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
- 32 -
-------
:x>:;^>*^fta?£^^
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
LSL.
(b) Initial, Follow-Up, Routine, Reduced,
Ultimate Reduced, or LSL Replacement
Program.
5. Sample Site Identifier: (3 Fields)
(a) Region ofDistribution System (Suggest that
Region 0 be assigned for each entry point
location.)
(b) Subregion ofDistribution 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 orpH 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 -
-------
Table 5. Summary of Approved Analytical Methods for the Lead and Copper Rule
Parameter
Lead
Copper
pH
Conductivity
Calcium
Alkalinity
Orthophosphate,
unfiltered, no
digestion or
hydrolysis
Silica
Temperature
Methodology9
Atomic absorption; furnace technique
Inductively-coupled plasma; Mass spectrometry
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
Eloclromolric
Conductance
EDTA titrimetric
Atomic absorption; direct aspiration
Inductively-coupled plasma
Titrimetric
Electrometric titration
Colorimetric, automated ascorbic acid
Colorimetric, ascorbic acid, two reagent
Colorimetric, ascorbic acid, single reagent
Colorimetric, phosphomolybdate; automated-segmented flow;
automated discrete
Ion chromatography
Colorimetric, molybdate blue;
automated segmented flow
Colorimetric
Molybdosilicate
Heteropoly blue
Automated method for molybdate-reactive silica
Inductively-coupled plasma
Thermometric
Reference (Method Number)
EPA*
239.2
200.8"
200. 9 7
220.2
220.1
200.76
200.8"
200.9'
150.1
150.2
120.1
215.2
215.1
200.76
310.1
365.1
365.3
365.2
300.08
370.1
200.7*
ASTM*
D3559-85D
01688-90C
D1688-90A
01293-84B
D1125-82B
D511-88A
D511-88B
D1067-88B
D515-88A
04327-88
D859-88
SM3
3113
3113
3111-B
3120
4500-H '
2510
3500-Ca-D
3111-B
3120
2320
4500-P-F
4500-P-E
4110
4500-Si-D
4500-Si-E
4500-Si-F
3120
2550
USGS*
•1601-85
-2601-85
-2598-"85
-1700-85
-2700-85
"Methods of Chemical Analysis of Water and Wastes," EPA Environmental Monitoring and Support Laboratory, Cincinnati, OH (EPA-600/4-79-020), 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 19103.
"Standard Methods for the Examination of Water and Wastewater," 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 Speetrometry," Revision 3.2, August 1990, U.S. EPA,
EMSL, Cincinnati, OH 45268.
"Determination of Trace Elements in Water and Wastes by Inductively-Coupled Plasma-Mass Spectrometry," Revision 4.3, August 1990, U.S. EPA, EMSL, EMSL, Cincinnati,
OH 45268.
"Determination of Trace Elements by Stabilized Temperature Graphite Furnace Atomic Absorption Spectrometry," August 1990, U.S. EPA, EMSL, Cincinnati, OH 45268.
"Determination of Inorganic Ions in Water by Ion Chromatography," December 1989, U.S. EPA, EMSL, Cincinnati, OH 45268.
For analyzing lead and copper, tho technique applicable to total metals must be used and samples cannot be filtered.
-------
Tap Water Monitoring Requirements For Large Water Systems (> 100,000)
Pb/Cu
[5nnr[l; _[|og|] 120071
Follow-up
Monitoring
Initial
Monitoring 1 Conduct
Treatment
Studies
Follow-up'
Monitoring
• Reduce number of samplng sites
Lotge systems must continue to monitor wSPs at each entry
point to the distribution system every two (2) weeks forever.
- 35 -
-------
INITIAL MONITORING REQUIREMENTS
FOR SYSTEMS SERVING > 100,000 PERSONS
FIRST MONITORING PERIOD January 1, 1992 to July 1, 1992
SECOND MONITORING PERIOD July 1, 1992 to January 1, 1993
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 100 sites during each of 2 consecutive 6-month
monitoring periods ;; /
5°
S°
ISJ
WATER QUALITY PARAMETER (WOP) SAMPLING
WQP 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 WQP SAMPLES COLLECTED AT REPRESENTATIVE SITES
IN THE DISTRIBUTION SYSTEM
• 2 samples at 25 sites during each of 2 consecutive 6-month
monitoring periods
NUMBER OF WQP 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 PERIOD
• January 1, 1992 to July 1, 1992 (submit by July 11,
SECOND MONITORING PERIOD
• July 1, 1992 to January 1, 1993 (submit by January
1992)
11, 1993)
- 36 -
-------
FOLLOW-UP MONITORING REQUIREMENTS
FOR SYSTEMS SERVING > 100,000 PERSONS
CO
FIRST MONITORING PERIOD
SECOND MONITORING PERIOD
January 1, 1997 to July 1, 1997
July 1, 1997 to January 1, 1998
LEAD AND COPPER TAP WATER SAMPLING
NUMBER AND FREQUENCY OF SAMPLING
« 1 sample at 100 sites during each of 2 consecutive €-montfei
monitoring periods .. "
WATER QUALITY PARAMETER (WQPJ SAMPLING
AT REPRCSENTAlTte $IT£$ II* THE DIStRlBUtlON $Y$1$M
* 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 25 sites during each of 2 consecutive 6-month
monitoring periods
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
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
STATE REVIEW
January 1, 1998 to July 1, 1998
5°
&
Oo
STATE ESTABLISHES WQPs
State establishes WOP values measured at representative sites fo the
distribution system; - - - >
• pH level ' „,.. -, f , , ,
• Alkalinity concentration, when alkalinity adjusted '-- * ''
• Calcium concentration, when calcium adjusted -' "
• Orthophosphate concentration, when & phosphatei-fcased inhibitor is
used " ' - "-- ,''„"'
• Silica concentration,-when a «flfeat£-ba$ed Inhibitor i$ os^d ,
State establishes chemical dosage fates measure^ at entry points to -
thedistrlbuliorstent?^'v ^***^ 'v''v ' ;
• 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
adj'usted
• 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 -
-------
MONITORING REQUIREMENTS FOR SYSTEMS
SERVING > 100,000 PERSONS AFTER
STATE ESTABLISHES WQPs
00
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 1OG sites every € months
WATER QUALITY PARAMETER fWQPJ SAMPLING
AT REPRESENTATIVE SITES \H 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 25 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, 1 998 to January 1, 1999 (submit by January 11,1999)
SECOND MONITORING PERIOD
• January 1, 1999 to July 1, 1999 (submit by July 11, 1999)
- 39 -
-------
REDUCED MONITORING REQUIREMENTS
FOR SYSTEMS SERVING > 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:
5°
to
LEAD AND COPPER TAP WATER SAMPLING
NUMBER AND FREQUENCY OF SAMPLING
• 1 sample et00^$ites annually , " 5
REQUESTING REDUCED SAMPLING - ^ ,, r * : ^
• System must submit a written request asking the state to reduce the
number and frequency Df |ead and copper tap water sampling {see
Form 141-B on page 55}
• State must review Jead and copper data submitted by the system
and provide a written response
WATER QUALITY PARAMETER fWQPJ 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
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 1», 2000} :
* July 1f 2001 (submit by July 11, 2001]
* July 1« 2002 (submit by July 11» 2002)
WQPs A/lust Be Sampled at Representative 'Sites in the Distribution
System Every 6 Months - ' ' ',' ' - ' '
• January 1. 2000 {submit by January 11, 2000J
* July 1,2000 (submit by Jury 1V200QJ - .
• January 1,2001 (submit by January 11,2001) '
• July 1,2001 (submit by 4ufy 11,2001)
• January 1^ 2002 {submit by January 11, 2002J
• July 1, 2002 (submit by July 11, 2002J
WQPs A/lust Be Sampled at Each Entry Point id the Distribution System
Every 2 Weeks , = .
- 41 -
-------
REDUCED MONITORING REQUIREMENTS
FOR SYSTEMS SERVING > 100,000 PERSONS
K)
O
Beginning July 1, 2002
f
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 50 sites fcvery 3 years
REQUESTING SEDUCED SAMPLING -W, >< > f.~/X-
• 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
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
o Silica, when silicate-based inhibitor used
• NUMBER AND FREQUENCY OF SAMPLING
o 2 samples at 10 sites annually
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
- 42 -
-------
REDUCED MONITORING PERIODS
Lead and Copper Must 8e Sampled Every 3 Year?
» July^f, 2005 '{sofamlt by'duly 11,2005*
* July 1, 2008 {submit by July 11; 2008J
* July 1.2011 {submH by 4uly 11« 20111
• Every 3 years thereafter ' ' - " - /"""''
WQPs Most *te Sampled; at Representative Sites in the Distribution
System Annually
• July 1,2003 {submit by July 11,2003} , ; .- - - ,-,: - >
* July 1, 2004 {submit by J«fy * 1T 2004)
• July 1, 200S {Submit by July II, 2005) .
• Annually thereafter
WQPs Must Be Sampled at Each Entry PoJnt to fee Distribution System
Every 2 Weeks ~-', .. , ^
- 43 -
-------
Number oHBFrequency of Tap Water Monitoring For Systems Demoi^pbting Optimal Corrosion Control Treatment Installed
(^Systems ServingT>
501)03.000
Serving?]]?
3.301 to 10.000
10,001 to 60.000
a stems Serving^.
jOl to lOO.OOO^x
• Number of sites in distribution system where PWS must collect two (2) samples for applicable WQPs.
1 ' Systems collect two (2) samples at each site for: pH, alkalinity, calcium, conductivity, water temperature, orlhophosphate
(when phosphate Inhibitor used), and silica (when silicate Inhibitor used).
' State establishes discrete set of WQPs monitored in distribution system and at each entry point.
tt Large water systems demonstrating OCCT with samples showing that the difference betv/een tap water and source water
lead levels are < 5 ppb; must collect WQP samples so the state can set values that reflect optimal corrosion control.
' " '.
60
10"
100
25"
^M
4)
60
60
10"
100
25"
40
.
60
,•
•
State
Review
T
State
Review
ft
5
10
20
.
•
2
3
.
.
•
'
3
7'
-
5i
10 '
:
.
5
10
20
0
0
0
7'
0
10'
3
3
7'
5
10 '
0
id
0
0
7'
0
10'
1
3
•
3
7'
51
10*
0
0
0
0
7'
3
10'
1
10
5
0
T
r
3
3
5
1
>0
0
0
'
0
'
1
7
1
5
0
T
'
7
10
••
-
t
T
•M
2
3
3
7
51
10
•••
5
5
10
0
0
0
t
'
«^^_
••••
- 44 -
-------
Source Water Monitoring For Lead and Copper For Large Systems (>50,000)
Surtaco Watei
or Both
1.
i
1 "• - .1 " •
1
li
uj2)
w
*!
• C
P
- 1
i i
1 " | .
1 |-
•1
o-
.-
System
Source
Treat
I
retail
Wote
nent
1
i
I
Follow-up
Monitoring
i
-Jmm
•
i ! i
si
a J
M.
'
1
l_^ __,
i , I . .
1 ' 1 ' 1 ]. 1 '
.
i i
i
• .
1 1 '
i
I
I
1 I
t 1
|
(
nr
, i 1 i
i
i i
i
i
i
(\a Cycle)
Second Compliance
Period
(1st Cycle)
Third Compliance Period
(2nd Cycle)
First Compliance Period
Reduce Monitoring to Once Per 9 Year Compliance Cycle
Reduce Monitoring to Once Per 9 year Compliance cycle
(1st Cycle)
Second Compliance Period
(1st Cycle)
Third Compliance Period
(1st Cycle)
First Compliance Period
Reduce Monitoring to Once Per 9 Year Compliance Cycle
No Monitoring Required
Reduce Monitoring to Once Per 9 Year Compliance Cycle
Begins in Third 9 year compliance cycle
-45 -
-------
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 level 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
5141.23(a)(1)to(4}",
MONITORING PERIODS
FIRST SOURCE WATER MONITORING
• July 1,1992 to January 1, 1993 feobmit by January 11,1993} .
• System must submit source water treatment recommendation with
lead and copper source water samples
- 46 -
-------
SOURCE WATER MONITORING REQUIREMENT
AFTER THE STATE SETS MAXIMUM PERMISSIBLE
LEAD AND COPPER LEVELS FOR SYSTEMS NOT
INSTALLING SOURCE WATER TREATMENT
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 wffl
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:
1st 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:
1 st 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, ft 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 «ntry
system during each of 2 consecuiiye 6-month f
tne distribution
nfortno periods -..:
MONITORING PERIODS
FIRST MONITORING PERIOD
• July 1,1995 to January t, 1996 {submit by January 11,1996)
SECOND MONITORING PERIOD
• January 1, 1996 to July 1, 1996 {submit by July 11, 1996)
- 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
PERIOD FOR
STA TE DETERMINA TION
July 1. 1996 to January 1, 1997
After a system installs source water treatment, collects follow-up samples,
and submits the results to the state, the state wffl set maximum permissible
lead and copper levels.
System must continue delivering finished water to each entry point to the
distribution system with lead and copper concentrations below the levels set
by the state to remain in compliance.
LEAD AND COPPER SOURCE WATER MONITORING
GROUNDWATER SYSTEMS
• System must collect 1 sample at each entry pofrrt to the distribution
system during the 3-year compliance period in effect when the state
sets maximum permissibfe 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 sets maximum permissible
lead and copper levels
MONITORING PERIODS
GRpUNDWATER SYSTEMS
• System must collect source water samples and submit the results to
the state by the following dates:
1st Compliance Period January 1, 1999 January 11, 1999
2nd Compliance Period January 1, 2002 January 11, 2002
3rd Compliance Period January 1, 2005 January 11, 2005
SURFACE WATER SYSTEMS
• System must collect source water samples and submit the results to
the state by the following dates:
1st Year January 1, 1998 January 11, 1 998
2nd Year January 1, 1999 January 11, 1999
A-:' January 1, 2000 January 11, 2000
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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
• System that maintains tead and copper concentrations below the
levels set by the state fbr3 consecutive 3-year compliance periods
may reduce source water monitoring to once per 9-year compliance
cycle
SURFACE WATER SYSTIMS _ / , „- ' ,,,,,':
• System that ma1nta|nl Jea^ and cppper concer»tratlons below the
levels «et t»y ^e*wtrw^'«d«$^fcujlwei years'tnay*&&«
water monitoring to ahee per S^year compliance cycle
1
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 «ach entry point to the distribution
system and submit the results to the state by January 1 \, 2011
- 50 -
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REDUCED MONITORING REQUIREMENTS FOR
LARGE SYSTEMS INSTALLING TREATMENT
GROUNDWATER SYSTEMS
SURFACE WATER SYSTEMS
Beginning January 1, 2011
s.
Beginning January 1, 2002
LEAD AND COPPER SOURCE WATER MONITORING
GROUNDWATER SYSTEMS , , \
« System that maintains fead and copper concentrations betow ttte
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 belowe..
levels set fcy'ifte stats for 3 consecutive years pfcay reduce
water monitoring to once per 9-year compliance cyde
REDUCED MONITORING PERIODS
GROUNDWATER SYSTEMS
• Reduced monitoring would take place 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 pofnt 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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Form 141-A
Page 1 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
System's Name:
Address:
Telephone number:
System ID #:
Contact Person:
' Type: D
Size: D
D
D
D
D
D
CWS D NTNCWS
> 100.000
10.001 to 100.000
3.301 to 10.000
501 to 3,300
101 to 500
£100
OF SAMPLING SUES
LEAD SOLDER SITES
# of single-family structures with copper pipes with lead solder installed
after 1982 or lead pipes and/or lead service lines (Tier 1)
# of multi-family structures with copper pipes with lead solder installed
after 1982 or lead pipes and/or lead service lines (Tier 1)
# of buildings containing copper pipes with lead solder installed
after 1982 or lead pipes and/or lead service lines (Tier 2)
# of sites that contain copper pipes with lead solder installed before 1983
(to be used only if first condition has been exhausted) (Tier 3)
TOTAL
The following sources have been explored to determine the number of structures which have interior
lead pipe or copper pipe with lead solder.
Plumbing and/or building codes
Plumbing and/or building permits
Contacts within the building department, municipal clerk's office, or state regulatory agencies
for historical documentation of the service area development
Water Quality Data
Other Resources Which PWS May Utilize
Interviews with building inspectors
, Survey of service area plumbers about when and where lead solder was used from 1982 to
present
Survey residents in sections of the service area where lead pipe and/or copper pipe with lead
solder is suspected to exist
Interviews with local contractors and developers
Explanation of Tier 2 and Tier 3 sites (attach additional pages if necessary)
- 52 -
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Form 141-A (continued)
Page 2 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
CERTIFICATION OF SAMPLINGSITES
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):
CERTIFICA T1ON OF COLLECTION METHODS
I certify that:
Each first draw tap sample for lead and copper is one liter in volume and has stood motionless in the
plumbing system of each sampling site for at least six hours.
Each first draw sample collected from a single-family residence has been collected from the cold
water kitchen tap or bathroom sink tap.
Each first draw sample collected from a non-residential building has been collected at an interior tap
from which water is typically drawn for consumption.
Each first-draw sample collected during an annual or triennial monitoring period has been collected
in the months of June, July, August or September.
Each resident who volunteered to collect tap water samples from his or her home has been properly
instructed by [insert water system's name]
in the proper methods for collecting lead and copper samples. I do not challenge the accuracy of those
sampling results. Enclosed is a copy of the material distributed to residents explaining the proper
collection methods, and a list of the residents who performed sampling.
- 53 -
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Form 141-A (continued)
Page 3 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
RESULTS
THE RESULTS OF LEAD AND COPPER TAP WATER SAMPLES MUST BE ATTACHED TO THIS
DOCUMENT
# of samples submitted 90th Percentile Pb
90th Percentile Cu
# of samples required
THE RESULTS OF WATER QUALITY PARAMETER SAMPLES MUST BE ATTACHED TO THIS
DOCUMENT
# of samples required # of tap samples submitted
# of entry point samples required # of entry point samples submitted
CHANGE OF SAMPLING $JTE$
Original site address:
New site address:
Distance between sites (approximately):
Targeting Criteria: NEW:
OLD:
Reason for change (attach additional pages if necessary):
SIGNATURE
NAME
TITLE
DATE
- 54 -
-------
Form 141-B
Page 1 of 1
REQUEST FOR REDUCED LEAD AND COPPER TAP WATER
System's Name:
Address:
Telephone number:
System ID if:
Contact Person:
Type: D
Size: D
D
D
D
D
D
CWS D IMTNCWS
> 100.000
10,001 to 100.000
3.301 to 10.000
501 to 3.300
101 to 500
5100
The
water system has:
D maintained tap water levels below the lead/copper action level(s); or
D operated in accordance with the state-specified water quality parameters during
each of the following six-month monitoring periods:
The above named water system hereby requests that the state permit the system
to reduce lead and copper tap water monitoring from:
D Biannual to Annual
D Annual to Triennial
D
D
D
D
D
100 to 50
60 to 30
40 to 20
20 to 10
10 to 5
The results of all water quality parameter samples and lead and copper tap water
samples collected during each of the monitoring periods are summarized and
attached.
SIGNATURE
NAME
TITLE
DATE
- 55 -
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BKSHEET #1
MATERIALS SURVEY INVESTIGATION RESULTS
MftfcmfflA^^
PWS FRDS NUMBER
POPULATION SERVED BY PWS
Type of
Structure
Location
Contact Person
Name
Phone
LSI
Homo
Plumbing:
Material
Verified
Voturt*
leered
Selected
Routine
Optional
Received
Training
Materiel
- 56 -
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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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WORKSHEET #3
SUMMARY OF MATERIALS SURVEY RESULTS
PWS FRDS NUMBER
POPULATION SERVED BY PWS
PJumbing Material
Interior Plumbing
Lead Pipe
Copper Pipe With Lead Solder >1982
Copper Pipe With Lead Solder < 1 983
Service Lines
LSLs
Entire Line
Partial Line
Total Available Sites
Type of Structure
SFR
MFR
BLDG
-- Number of Service Connections
- 58 -
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