Lead and Copper
Monitoring and
Reporting Guidance for
Public Water Systems
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Office of Water
(4606M)
EPA-816-R-02-009
www.epa.gov
February 2002
Printed on Recycled Paper
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Disclaimer
The SDWA provisions and EPA regulations described in this document contain
legally-binding requirements. This document does not substitute for those
provisions or regulations, nor is it a regulation itself. Thus, it does not impose
legally-binding requirements on EPA, States, or the regulated community, and
may not apply to a particular situation based upon the circumstances. EPA and
State decisionmakers retain the discretion to adopt approaches on a case-by-case
basis that differ from this guidance where appropriate. Any decisions regarding a
particular facility will be made based on the applicable statutes and regulations.
Therefore, interested parties are free to raise questions and objections about the
appropriateness of the application of this guidance to a particular situation, and
EPA will consider whether or not the recommendations or interpretations in the
guidance are appropriate in that situation. EPA may change this guidance in the
future. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
Lead and Copper Monitoring Guidance February 2002
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TABLE OF CONTENTS
CHAPTER I: INTRODUCTION 1
What Is the Purpose of this Guidance Document? 1
How Is This Document Organized? 2
What Is the Purpose of the Lead and Copper Regulations? 3
What Systems Are Affected by the Lead and Copper Regulations? 3
What Are the Requirements of the Lead and Copper Regulations? 4
What Are the Corrosion Control Treatment Requirements? 6
What Are the Source Water Treatment Requirements? 8
What Are the Public Education Requirements? 10
What Are the Lead Service Line Replacement Requirements? 11
CHAPTER II: LEAD AND COPPER TAP MONITORING AND REPORTING
REQUIREMENTS 12
What Is The Purpose of Collecting Lead and Copper Tap Samples? 12
Is My System Required to Collect Lead and Copper Tap Samples? 12
When Do I Collect Lead and Copper Tap Samples? 12
Am I Eligible for Reduced Lead and Copper Tap Monitoring? 15
Where Must I Collect My Samples? 19
How Do I Collect Lead and Copper Tap Water Samples? 22
What Are the Approved Methods for Analyzing Water Samples for Lead and Copper? 23
How Do I Evaluate My Results? 28
What If the State Determines that My Samples Are Invalid? 31
What Should I Do If I Exceed an Action Level While I am Monitoring at 6-month intervals? 32
What Should I Do If I Exceed the Lead or Copper Action Level During Reduced Monitoring? 33
Can I Ever Discontinue Lead and Copper Tap Monitoring? 33
What Lead and Copper Tap Monitoring Information Must I Report to the State? 34
What Should I Do If I Sell Water To, or Buy Water From, Another Water System? 35
What Happens If I Do Not Fulfill My Lead and Copper Tap Monitoring And Reporting Requirements36
What Provisions of the LCRMR Pertain to Lead and Copper Tap Monitoring and Reporting? 38
What Key Points Should I Remember About Lead and Copper Tap Monitoring? 40
CHAPTER HI: WATER QUALITY PARAMETER MONITORING AND REPORTING
REQUIREMENTS 41
What Is The Purpose of Collecting Water Quality Parameter Samples? 41
Which Systems Must Collect Water Quality Parameter Samples? 41
When Do I Collect Water Quality Parameter Samples? 42
How Do I Select My Sampling Sites? 47
How Do I Collect Water Quality Parameter Samples? 48
How Does the State Determine If I Am In Compliance With My Optimal Water Quality Parameter Va4Qes?
Can I Ever Reduce My WQP Monitoring? 52
Can I Ever Discontinue Water Quality Parameter Monitoring? 54
What Water Quality Parameter Monitoring Information Must I Report to the State? 54
What If I Do Not Fulfill My WQP Requirements? 55
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What Provisions of the LCRMR Pertain to Water Quality Parameter Monitoring and Reporting? ... 56
What Key Points Should I Remember About Water Quality Parameter Monitoring? 58
CHAPTER IV: LEAD AND COPPER SOURCE WATER MONITORING AND
REPORTING REQUIREMENTS 59
What Is The Purpose of Collecting Source Water Samples? 59
Which Systems Must Collect Source Water Samples? 59
When Do I Collect Source Water Samples? 59
Where Are These Samples Collected? 62
How Does the State Evaluate My Source Water Monitoring Results? 63
Can I Ever Discontinue Source Water Monitoring? 64
What Source Water Monitoring Information Must I Report to the State? 65
What If I Do Not Fulfill My Source Water Monitoring And Reporting Requirements? 65
What Provisions of the LCRMR Pertain to Source Water Monitoring and Reporting Requirements?
66
What Key Points Should I Remember About Lead and Copper Source Water Monitoring? 67
CHAPTER V: LEAD SERVICE LINE MONITORING AND REPORTING
REQUIREMENTS 68
What Is The Purpose of Collecting Lead Service Line Samples? 68
Which Systems Must Collect Lead Service Line Samples? 68
When Do I Collect Lead Service Line Samples? 69
How Do I Collect Lead Service Line Samples? 69
Can I Ever Discontinue Lead Service Line Monitoring? 71
What Lead Service Line-Related Information Must I Report to the State? 71
What If I Do Not Fulfill My Lead Service Line Replacement Requirements? 72
What Provisions of the LCRMR Pertain to Lead Service Line Monitoring and Replacement? 73
What Key Points Should I Remember About Lead Service Line Monitoring and Reporting? 74
APPENDIX A
List of LCRMR Outreach Materials for Water Systems A-l
APPENDIX B
Definitions B-l
APPENDIX C
Monitoring Timelines C-l
APPENDIX D
Summary of Monitoring and Reporting Violations D-l
APPENDIX E
Worksheet and Instructions E-l
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LIST OF TABLES
Table 1-1: Corrosion Control Treatment Steps 7
Table 1-2: Source Water Monitoring and Treatment Requirements 9
Table 2-1: Schedule for Initial Monitoring1 13
Table 2-2: Minimum Number of Lead and Copper Tap Samples for Systems on Standard Monitoring
13
Table 2-3: Minimum Number of Lead and Copper Tap Samples for Systems on Reduced Monitoring
15
Table 2-4: Reduced Lead and Copper Tap Monitoring Criteria 17
Table 2-5: Tiering Classification 19
Table 2-6: Approved Analytical Methods for the Lead and Copper Rule 23
Table 2-7: Sample Handling Requirements for Lead, Copper, and Water Quality Parameters 27
Table 3-1: Initial WQP Requirements for Systems Serving 50,000 and Fewer People 43
Table 3-2: Standard Number of WQP "Tap" Sites and Samples 44
Table 3-3: Daily Value Calculation Based on Monitoring Frequency 51
Table 3-4: Reduced Number of WQP Tap Sites and Samples 52
Table 3-5: Reduced WQP Tap Monitoring Criteria 53
Table 5-1: Pipe Volume Table (Volumes Listed in Liters) 70
Lead and Copper Monitoring Guidance iii February 2002
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List of Acronyms and Abbreviations
AL
ALE
CCT
Cu
CWS
EP
GUDI
HN03
LCR
LCRMR
LSL
MCL
MDL
MFR
mg/L
MPL
NTNCWS
OCCT
OWQP
Pb
ppb
PQL
PSA
PWS
QA/QC
SFR
SMF
SOWT
WQP
Action level
Action level exceedance
Corrosion control treatment
Copper
Community water system
Entry point
Ground water under the direct influence of surface water
Nitric Acid
Lead and Copper Rule
Lead and Copper Rule Minor Revisions
Lead service line
Maximum contaminant level
Method detection limit
Multi-family residence
Milligrams per liter
Maximum permissible level
Non-transient, non-community water system
Optimal corrosion control treatment
Optimal water quality parameter
Lead
Parts per billion
Practical quantitation level
Public service announcement
Public water system
Quality assurance/Quality control
Single family residence
Standardized monitoring framework
Source water treatment
Water quality parameter
Lead and Copper Monitoring Guidance
February 2002
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Lead and Copper Rule Monitoring and Reporting
Guidance for Public Water Systems
CHAPTER I: INTRODUCTION
What Is the Purpose of this Guidance Document?
On June 7, 1991, the United States Environmental Protection Agency or EPA, published in the
Federal Register, a regulation to control lead and copper in drinking water. This regulation is known
as the Lead and Copper Rule (also referred to as the LCR or 1991 Rule throughout this
document).
On January 12, 2000, EPA published minor revisions to the 1991 Rule. The purpose of the Lead
and Copper Rule Minor Revisions (LCRMR) is to eliminate unnecessary requirements,
streamline and reduce monitoring and reporting burdens, and promote consistent national
implementation. In some cases, EPA has added language which clarifies requirements and
corrects oversights in the original rule. EPA calls the revisions "minor" because they do not affect
the lead and copper maximum contaminant level goals, action levels, or other basic regulatory
requirements to monitor for lead and copper at the tap and to optimize corrosion control.
This guidance document has been developed for you, the water system owner and operator of
community water systems (CWSs) and non-transient, non-community water systems (NTNCWSs).
It provides a comprehensive discussion of the monitoring and monitoring-related reporting
requirements of the LCR, as amended by the LCRMR. Some of the LCRMR provisions are
clarifications to the LCR while other provisions are more stringent than the LCR. These are
revisions for which you and your States were required to begin implementation on April 11, 2000.
Some of the revisions are less stringent than the LCR (e.g., allow a reduction in monitoring if
specific criteria are met) and you may not be able to implement them because your State has
chosen not to adopt these provisions or has not yet incorporated these provisions into its State's
drinking water regulations. Therefore, you should first check with your State before following any
of these "less stringent" provisions. For water systems on Tribal lands, or located in Wyoming or
the District of Columbia, the Federal version of the entire LCRMR applies. Therefore, you were
able to take advantage of the burden reduction requirements of the LCRMR on April 11, 2000.
EPA recognizes that the majority of systems already have their monitoring programs underway
but believes that systems will find this document useful in understanding the modifications to the
monitoring and reporting requirements resulting from the LCRMR.
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How Is This Document Organized?
The document contains five chapters, including this introduction and a discussion of the four
monitoring protocols contained in the LCR. These chapters are listed below.
iV Chapter I: Introduction
iV Chapter II: Lead and Copper Tap Water Monitoring and Reporting Requirements
iV Chapter III: Water Quality Parameter Monitoring and Reporting Requirements
iV Chapter IV: Lead and Copper Source Water Monitoring and Reporting
Requirements
iV Chapter V: Lead Service Line Monitoring and Reporting Requirements
Chapter I includes a discussion of the purpose of the lead and copper regulations, and an overview
of the corrosion control treatment, source water treatment, public education, and lead service line
replacement requirements. Chapters II through V address the following topics:
• The purpose of the sample collection;
• Which systems are subject to the monitoring requirements;
• When, where, and how to conduct the monitoring;
• How to evaluate the results;
• What happens if the system does not meet its requirements;
• Criteria that allows a system to reduce and/or eliminate its monitoring requirements;
• Information that must be reported to the State;
• How the LCRMR have impacted monitoring and reporting requirements; and
• Key points to remember.
Chapter II also contains a detailed discussion on how to calculate 90th percentile levels and an
explanation of monitoring requirements for systems that purchase water from another system.
Please note that parenthetical references to the Code of Federal Regulations, Chapter 40 (i.e.,
EPA's regulations) are included throughout the document so that system owners and operators
can consult the federal regulations for further details. Note also that the term "State" is used
throughout the guidance document to refer to the government agency that enforces compliance
with drinking water regulations and assists you in understanding and implementing these
regulations. For most systems, this is an organization within the State government (e.g.,
Department of Natural Resources, Department of Environmental Quality, Department of
Health). For the District of Columbia, Wyoming, and Native American Lands, the contact is
often from the respective EPA Regional Office.
This guidance document focuses on those revisions that impact monitoring and reporting
requirements. Those revisions that are unrelated to monitoring and reporting requirements are
Lead and Copper Monitoring Guidance 3 February 2002
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discussed in more detail in separate guidance documents. For example, the guidance document,
entitled, Lead and Copper Rule: Summary of Revisions, April 2000, EPA 815-R-99-020, contains a
discussion of each of the important changes made to the 1991 Rule by the LCRMR by major rule
section (e.g., §141.81, §141.82, etc.), and identifies when you must begin complying with the new
requirements. It also contains an appendix which compares the rule language of the LCR against
the minor revisions. All available guidance documents, can be obtained by contacting the Safe
Drinking Water Hotline at (800) 426-4791 or via the EPA website:
www.epa.gov/safewater/leadcop.html. A list of key documents is provided as Appendix A.
Also included are five appendices to this document:
iV Appendix A: List of LCRMR Outreach Materials for Water Systems.
iV Appendix B: Definitions that explain the terms used in this guidance.
iV Appendix C: Timelines that illustrate the schedule for corrosion control treatment (if
applicable), lead and copper tap monitoring, and water quality
parameters (if applicable).
iV Appendix D: Summary of Monitoring and Reporting Violations.
iV Appendix E: Worksheets and instructions to assist in identifying sampling sites,
sample collection, and the documentation and justification of decisions.
What Is the Purpose of the Lead and Copper Regulations? (See §141.80 &
§141.81(b))
The purpose of the lead and copper regulations is to protect public health by minimizing lead and
copper levels in drinking water. Most regulations require sampling at entry points to the
distribution system. Because lead and copper in drinking water is primarily due to the corrosion
of distribution and household plumbing materials, tap water samples are collected at kitchen or
bathroom taps of residences and other buildings. This requirement significantly complicates
sample collection, requiring you, the water system, to coordinate with the people you serve.
What Systems Are Affected by the Lead and Copper Regulations? (See
§141.80(a))
Lead and copper tap monitoring applies to all community water systems (CWSs) and non-
transient, non-community water systems (NTNCWSs). The regulations divide these systems into
three broad size categories (large, medium, and small). System size is a factor in determining the
number of samples that must be collected, as well as the applicability and timing of some of the
provisions.
Size
Small
Medium
No. of people served I
•
25-3,300 1
3,301 - 50,000 1
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Large over 50,000 I
What Are the Requirements of the Lead and Copper Regulations? (See
§§141.80-141.91)
Tap monitoring results are the primary factor for determining your ongoing monitoring
requirements and whether you need to undertake any of the following treatment technique
requirements:
• Corrosion control treatment;
• Source water treatment;
• Public education; and/or
• Lead service line replacement.
There is no maximum contaminant level (MCL) for lead or copper. However, if your lead and
copper tap monitoring results are higher than the lead action level of 0.015 milligrams per liter
(mg/1) and/or the copper action level of 1.3 mg/L, corrosion control treatment is required. To
determine whether an action level has been exceeded, the value at the 90th percentile of all lead or
copper samples collected is compared against its respective action level. This means that no more
than 10 percent of your samples can be above either action level. An explanation of how to
calculate the 90th percentile levels is provided in Chapter II.
If your 9ffh percentile level exceeds the lead action level ofO. 015 mg/L, you must:
• Begin corrosion control treatment steps which include water quality parameter (WQP)
monitoring during the same monitoring period in which the exceedance occurs;
• Conduct source water monitoring within 6 months of the exceedance and install source
water treatment, if needed;
• Deliver public education within 60 days of the exceedance that informs your users
about the health effects of lead and measures that will reduce their exposure to lead;
and
• Replace lead service lines if you still exceed the lead action level after installing
treatment.
If your 90th percentile level exceeds the copper action level of 1.3 mg/L, you must:
• Begin corrosion control treatment steps which include WQP monitoring during the
same monitoring period in which the exceedance occurs; and
• Conduct source water monitoring within 6 months of the exceedance and install source
water treatment, if needed.
Note: Public education and lead service line replacement are
not required if only the copper action level is exceeded.
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A basic requirement of the lead and copper regulations is for systems to optimize corrosion
control. This means that the water system is delivering water that is minimally corrosive, thereby
reducing the likelihood that lead and copper will be introduced into the drinking water from the
corrosion of lead and copper plumbing materials. Some systems have naturally non-corrosive
water and would not benefit from installing treatment. Others installed corrosion control
treatment prior to the effective date of the original LCR (i.e., December 7, 1992). Still other
systems must install corrosion control to reduce the corrosivity of their water and thereby, their
lead and copper levels.
A State can deem a system to have optimized corrosion control in one of the three ways that are
listed below. For some systems, this can happen without installing treatment. As discussed in
more detail later in this document, systems that have optimized corrosion control have fewer
monitoring and/or treatment requirements.
You can be deemed to have optimized corrosion control if:
1. You are a small or medium system (i.e., serve 50,000 or fewer people) and your 90th
percentile levels are at or below both the lead and copper action levels for 2,
consecutive, 6-month monitoring periods. EPA also refers to these systems as "(b)(l)
systems" because they meet the requirements of §141.81(b)(l) of the federal version of
the lead and copper regulations.
2. You already have treatment in place, prior to the effective date of the 1991 LCR (i.e.,
prior to 12/7/92) and have conducted activities equivalent to those outlined in
§141.81(b)(2). EPA also refers to these systems as "(b)(2) systems".
3. You demonstrate that the difference between the 90th percentile tap water lead level
and the highest source water lead level is less than 0.005 mg/L. To make this
demonstration, you must collect tap water samples for lead at the standard number of
sites (see Table 2-2), and source water samples for lead at each entry point to the
distribution system during each of 2, consecutive, 6-month monitoring periods. EPA
also refers to these systems as "(b)(3) systems" because these criteria are specified in
§141.81(b)(3) of the regulations.
4. You demonstrate that for 2, consecutive, 6-month periods your source water lead levels
are below the method detection limit (MDL) and your 90th percentile lead levels are
less than or equal to the practical quantitation level (PQL) of 0.005 mg/L. This new
criterion was added in the LCRMR because systems with undetectable source water
lead levels and low 90th percentile lead levels could be precluded from qualifying as a
(b)(3) system under the 1991 LCR. This is because source water levels that are below
the MDL must be reported as 0; whereas, levels above the MDL, but less than 0.005
mg/L must be reported as 0.0025 mg/L which is half the PQL. This point is more
clearly illustrated in the following two examples.
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Example 1: A system with source water lead levels just below a MDL of 0.001 mg/L and a 90th
percentile tap level of 0.005 mg/L would not be deemed to be optimized using the 1991 LCR
(b)(3) criteria, which requires the difference to be less than 0.005 mg/L. The difference here
would be 0.005 mg/L, as shown in the following equation: 0.005 mg/L - 0 mg/L = 0.005 mg/L.
Example 2: With a lead MDL of 0.001 mg/L, a system with source water levels of 0.002 mg/L
and a 90th percentile of 0.0050 mg/L would be optimized under the 1991 LCR criteria because
the source levels could be reported as 0.0025 mg/L. The difference here would be 0.0025 mg/L,
as shown in the following equation: 0.0050 mg/L - 0.0025 mg/L = 0.0025 mg/L.
Note: The LCRMR also clarify that a (b)(3) system's 90th percentile
cannot exceed the copper action level of 1.3 mg/L. The 1991 LCR
did not include copper levels as part of the (b)(3) criteria. A (b)(3)
system that exceeds the copper action level after July 12, 2001 (i.e., 18
months after the date of rule promulgation) will no longer qualify as a
(b)(3) system. Such a system must begin corrosion control treatment
steps, unless such treatment is already in place.
What Are the Corrosion Control Treatment Requirements? (See §§141.81
& 141.82)
You must conduct the corrosion control treatment steps described below if: 1) you serve more
than 50,000 people and you do not qualify as a (b)(2) or (b)(3) system; or 2) you serve 50,000 or
fewer people and you exceed either the lead or copper action level.
Step 1: System serving 50,000 or fewer people submit a recommendation regarding the
type of corrosion control to be installed (for large systems, the recommendation is
included as part of the corrosion control study referred to in Step 2).
Step 2: The State decides if systems serving 50,000 or fewer people must conduct a
corrosion control study to help evaluate the most effective type of corrosion
control treatment for the system. For systems serving more than 50,000 people,
the study is required.
Step 3: The system submits the corrosion control study, if required.
Step 4: The State determines the type of corrosion control treatment to be installed.
Step 5 The system installs corrosion control treatment.
Step 6: The system collects follow-up lead and copper tap and WQPs after the
installation of corrosion control treatment. Note: Systems serving < 50,000people are
only required to collect WQP samples if they continue to exceed the lead or copper action level.
Step 7: The State sets WQPs ranges or minimums (called optimal water quality
parameters or OWQPs) that indicate that a system is operating corrosion control
treatment at a level that most effectively minimizes the lead and copper
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February 2002
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Step 8:
concentrations at users' taps. Note: The State is not required to set OWQPs for systems
serving < 50,000 people if they are at or below the lead and copper action levels, although the State
may opt to do so.
The system conducts periodic lead and copper tap and WQP monitoring. Note:
Systems serving < 50,000 people are only required to collect WQP samples during any monitoring
period in which they exceed the lead or copper action level.
Notes: Systems serving 50,000 or fewer people can discontinue these steps
whenever their 90th percentile levels are at or below both action levels for 2,
consecutive, 6-month monitoring periods. In addition, (b)(2) systems are not
required to conduct a study, install corrosion control treatment, or conduct
follow-up monitoring. The LCRMR clarify that (b)(2) systems must
conduct lead and copper tap and WQP monitoring after the State sets
OWQPs. Further, a system that meet the (b)(3) criteria based on initial
monitoring is not subject to the corrosion control treatment requirements.
Table 1-1 shows the schedule for completing corrosion control treatment steps for those systems
that are subject to these requirements.
Table 1-1: Corrosion Control Treatment Steps
Requirement
System recommends the type
of treatment to be installed
State decides whether study is
required
System completes study
State determines the type of
treatment to be installed
System installs treatment
System conducts follow-up
monitoring
State designates OWQPs1
System conducts continued
monitoring
Timetable for Completing Corrosion Control Treatment
for Systems Serving:
50,000 or fewer people2
6 months after the lead and/or copper action
level exceedance (ALE)
12 months after the ALE
18 months after State decision to conduct study
If study is required:
6 months after study completed
If no study is required:
- for < 3,300: 24 months after ALE
- for 3,301 - 50,000: 18 months after ALE
24 months after State decision regarding the
type of treatment to be installed
12 months after treatment installation (2
consecutive, 6-month periods)
6 months after follow-up monitoring
More than 50,000
N/A (Part of the corrosion
control study)
N/A (System must conduct
study)
July 1, 1994
January 1, 1995
January 1, 1997
January 1, 1998
July 1, 1998
The schedule based on whether an action level is exceeded and/or compliance
with OWQP ranges or minimums
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Table 1-1: Corrosion Control Treatment Steps
Requirement
Timetable for Completing Corrosion Control Treatment
for Systems Serving:
50,000 or fewer people2
More than 50,000
Notes:
'The State is not required to designate OWQPs if a system no longer exceeds both action levels after installing
treatment. However, some States have opted to do so.
2A system whose population exceeds 50,000 after July 1, 1994 must follow the schedule for medium-size systems,
beginning with the requirement to complete a corrosion control study.
Form 141-C, Optimal Corrosion Control Treatment/Water Quality Parameters, has been provided in
Appendix E. This form can help you to document: the results of corrosion control treatment
studies, your optimal corrosion control treatment recommendation, certification that optimal
corrosion control treatment has been installed, and request for modification of State decisions
regarding current corrosion control treatment or WQPs. You need only complete those boxes
that apply.
Lead and copper tap monitoring and WQP monitoring requirements are discussed in detail in
Chapter II and III, respectively. In addition, Appendix C contains several lead and copper tap
and WQP monitoring timelines that illustrate how these monitoring requirements are impacted by
a system's size category and whether a system exceeds an action level.
For more information on corrosion control treatment
refer to:
Lead and Copper Rule Guidance Manual, Volume II: Corrosion Control
Treatment, September 1992.
What Are the Source Water Treatment (SOWT) Requirements? (See
§141.83)
Systems that exceed the lead or copper action level are triggered into source water treatment
requirements. In general, these requirements will be limited to source water monitoring. EPA
anticipates that few systems have high source water lead or copper levels and will require SOWT.
The SOWT steps are as follows:
Step 1: The system conducts source water monitoring at each entry point (EP) to the
distribution system and submits a recommendation to the State regarding source
water treatment (required of all systems that exceed the lead and/or copper action
level).
Step 2: The State decides if source water treatment is needed.
Lead and Copper Monitoring Guidance 9 February 2002
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Step 3: The system installs source water treatment (if required).
Step 4 The system collects follow-up lead and copper samples at the tap and at each EP
(only required if treatment is installed).
Step 5: The State sets maximum permissible levels (MPLs) of lead and copper in source
water (generally only specified by the State for systems installing source water
treatment).
Step 6: The system conducts periodic lead and copper source water monitoring (required
regardless of whether source water treatment is installed).
Table 1-2 indicates the timing of these SOWT requirements. Please note that Steps 3 through 5
only apply to those systems that are required to install SOWT.
Table 1-2: Source Water Monitoring and Treatment Requirements
Action
System monitors at
each EP & submits
recommendation
State determines if
SOWT is required
System installs
SOWT
System conducts
follow-up monitoring
State sets MPLs for
lead & copper1
System conducts
routine source water
monitoring 2
System conducts
reduced source water
monitoring 3
Deadline for Completing Action
SOWT
Required
SOWT Not
Required
6 months after exceeding the lead and/or
copper action level
6 months after receipt of results &
recommendation
24 months after
State requires
SOWT
12 months after
installing treatment
Within 6 months
after follow-up
monitoring
N/A
N/A
N/A
Annually for surface water/combined
sources
Triennially for ground water systems
Once during each 9-year compliance cycle
Total Number of Months from
ALE
SOWT
Required
SOWT Not
Required
6 months
12 months
36 months
48 months
54 months
66 months
Depends on 3-yr com
effect
N/A
N/A
N/A
24 months
pliance period in
Depends on 9-yr compliance cycle in effect
Lead and Copper Monitoring Guidance
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February 2002
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Action
Deadline for Completing Action
SOWT
Required
SOWT Not
Required
Total Number of Months from
ALE
SOWT
Required
SOWT Not
Required
Table 1-2: Source Water Monitoring and Treatment Requirements
State will set MPLs for both lead and copper even if the system exceeded only one action level.
The 1st year of annual monitoring begins on the date the State set MPLs or determined that SOWT was not
needed. Triennial monitoring begins with the 3-year compliance period in effect when the State set MPLs or
determined that SOWT was not needed.
Systems can qualify for reduced monitoring, at a frequency of once every 9-year compliance cycle, if they are in
compliance with their MPLs for 3 consecutive compliance periods (i.e., 3 annual periods for surface
water/combined sources; 3, 3-year periods (equals 9 years) for ground water systems).
Note: Unlike corrosion control treatment, systems that are at or below both
action levels must complete the source water treatment steps once begun.
However, once the State sets MPLs or determines that source water
treatment is not needed, the system is not required to collect source water
samples during any source water monitoring period in which its 90th
percentile lead and copper tap water levels are at or below their action levels.
Source water monitoring requirements are discussed in more detail in Chapter IV of this guidance.
Detailed information regarding source water treatment is provided in Lead and Copper Rule Guidance
Manual, Volume II: Corrosion Control Treatment, September 1992.
What Are the Public Education Requirements? (See §141.85)
If you exceed the lead action level, you must deliver public education to your customers to inform
them of the health effects of lead, measures you are taking to correct the problem, and what they
can do to minimize their exposure to lead. The public education requirements are different for
CWSs and NTNCWSs. An overview of the requirements are provided below.
Within 60 days of exceeding the lead action level (either for the first time or again after having
monitoring periods at or below the lead action level), a CWS must:
• Insert notices in each customer's water utility bill;
• Deliver pamphlets and/or brochures that contain the public education materials to
facilities and organizations that provide services to pregnant women and children;
• Submit information to the editorial departments of the major daily and weekly
newspapers circulated throughout the community; and
• Deliver public service announcements (PSAs) to radio and television stations.
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A CWS must repeat delivery every 6 months for PSAs, and every 12 months for other forms of
delivery, for as long as the system exceeds the lead action level.
Within 60 days of exceeding the lead action level (either for the first time or again after having
monitoring periods at or below the lead action level), an NTNCWS must distribute public
education by:
• Posting informational posters in public places or in common areas of buildings served by
the system; and
• Distributing informational pamphlets and/or brochures to each person served by the
NTNCWSs.
An NTNCWS must repeat this information annually for as long as it exceeds the lead action level.
Any system can stop delivering public education whenever its 90th percentile lead level is at or below
the action level for one monitoring period. If it again exceeds the lead action level, it must
recommence public education within 60 days of the exceedance.
^ Please note, the LCRMR offer some flexibility in making revisions to the
mandatory public education language and the distribution of public education
materials.
For more information on public education, refer
to the updated guidance: Lead in Drinking Water
Regulation: Public Education Guidance, EPA 816-R-02-010.
What Are the Lead Service Line Replacement Requirements? (See §141.84)
If treatment is not effective in reducing lead levels, systems with lead service lines must replace at
least 7 percent of their lines annually (the State can require a higher rate). The State can also
require systems to begin lead service line replacement if they do not meet their deadline for
installing corrosion control or source water treatment. Systems can discontinue lead service line
replacement if they are at or below the lead action level for 2 consecutive monitoring periods.
The monitoring requirements that are associated with lead service line replacement are discussed
in Chapter V A detailed discussion of the lead service line replacement requirements is provided
in Lead and Copper Rule Guidance Manual, Volume II: Corrosion Control Treatment, September 1992.
Lead and Copper Monitoring Guidance 12 February 2002
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CHAPTER II: LEAD AND COPPER TAP MONITORING
AND REPORTING REQUIREMENTS
What Is The Purpose of Collecting Lead and Copper Tap Samples?
The tap water monitoring protocol for lead and copper is designed to identify those residences or
sampling locations with lead service lines, lead interior plumbing, or copper pipes with lead solder.
Samples collected from these locations are most likely to have high levels of lead and/or copper
caused by the contact of corrosive water with lead- and copper-containing plumbing materials.
You are required to monitor at these "high-risk" locations, whenever possible (versus collecting a
random sample) to better ensure that high levels of lead or copper are detected and that you
institute treatment that provides uniform and adequate levels of health protection throughout the
distribution system. Tap water monitoring for lead and copper not only allows you to determine
the lead and copper concentrations in drinking water, but if you have installed treatment,
monitoring allows you to assess the effectiveness of corrosion control treatment and/or source
water treatment.
Is My System Required to Collect Lead and Copper Tap Samples? (See
§§140.80(a) & 141.86(c)&(d))
All CWSs and NTNCWSs must collect lead and copper tap samples. Transient, non-community
water systems are not subject to the lead and copper regulations. The frequency of the monitoring
and number of samples to be collected and analyzed is based primarily on how many people you
serve and your tap water monitoring results.
When Do I Collect Lead and Copper Tap Samples? (See §§141.86(c) & (d))
Lead and copper monitoring can be divided into four phases:
• Initial monitoring that is required of all systems.
• Follow-up monitoring that corresponds to the 2, consecutive 6-month periods after
a system completes the installation of corrosion control and is only required for systems
that install treatment.
• Routine monitoring applies both to systems that are required to install treatment
and to (b)(2) systems. For these systems, this monitoring occurs after the State sets
OWQPs.
• Reduced monitoring corresponds to monitoring that occurs at a reduced frequency
and a reduced number of sample locations. This reduction is based on a system's lead
and copper 90th percentile levels or compliance with OWQPs.
Lead and Copper Monitoring Guidance 13 February 2002
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Each type of monitoring is discussed in greater detail below. In addition, refer to the monitoring
timelines in Appendix C which help illustrate how lead and copper tap monitoring requirements
are impacted by a system's size category and whether the system exceeds an action level.
Initial Lead and Copper Tap Monitoring
The LCR specifies dates by which you were required to begin monitoring. The date was
dependent on the number of people that you served as shown in Table 2-1 below, and was
specified for discrete 6-month monitoring periods of January through June and July through
December.
Table 2-1: Schedule for Initial Monitoring1
System Size
(No. of People Served)
3,300 and under
3,301 - 50,000
50,001 and more
1st Initial
Monitoring Period
7/1/93 - 12/31/93
7/1/92 - 12/31/92
1/1/92 - 6/30/92
2nd Initial
Monitoring Period
1/1/94 - 6/30/942
1/1/93 - 6/30/932
7/1/92 - 12/31/92
^ NOTES:
'If you are a new system, consult with your State LCR Coordinator to find out when you
should begin lead and copper monitoring.
2Required if you do not exceed either action level during the 1st initial monitoring period,
or if your State specifies that you must conduct this monitoring.
If you serve more than 50,000 people, you were required to conduct both 6-month rounds of
initial lead and copper tap monitoring at the standard number of sites, required for your system
size (see Table 2-2).
If you serve 50,000 or fewer people, you were required to conduct a minimum of one, 6-
month round of initial monitoring at the standard number of sites (see Table 2-2). The
requirement for you to conduct a second round of
initial lead and copper tap monitoring was based
on your 90th percentile lead and copper levels
during the first round of monitoring as follows:
You were not required to collect a
second round of initial monitoring if you
exceeded the lead or copper action level
(unless required by your State). Instead,
you were triggered into corrosion
control treatment steps (refer back to the
corrosion control treatment discussion in
Chapter I). You also had the option to
continue lead and copper tap
monitoring while conducting corrosion
Table 2-2: Minimum Number of
Lead and Copper Tap Samples for
Systems on Standard Monitoring
System Size
> 100,000
10,001 - 100,000
3,301 - 10,000
501 - 3,300
101-500
< 100
No. of Samples
100
60
40
20
10
5
Lead and Copper Monitoring Guidance
14
February 2002
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control treatment steps to determine if you were eligible to stop these steps (i.e., you
had 2, consecutive, 6-month periods in which your 90th percentile lead and copper
levels were at or below their respective action levels).
Note: If you are triggered into corrosion control treatment requirements,
some lead and copper tap monitoring will be needed to evaluate the type of
corrosion control to be installed and/or fine-tune your treatment. These
samples are not part of your monitoring requirements. However, some
States may require systems to submit these data for compliance purposes.
In this event, the lead and copper samples must be used by systems and
States in calculating 90th percentile levels [See§141.86(e)J.
You were required to conduct a second round of initial monitoring during the next 6
months, if you were at or below the lead and copper action levels during the first round
of monitoring.
Note: If you serve 50,000 or fewer people and never exceed an action level, you
only have to conduct periodic lead and copper tap monitoring.
~ No other requirements apply to you ~
Follow-up Lead and Copper Tap Monitoring
If you are required to install corrosion control treatment, you must conduct 2, consecutive, 6-
month rounds of follow-up lead and copper tap monitoring at the standard number of sites. If
you serve more than 50,000 people and you did not meet either the (b)(2) or (b)(3) criteria, this
monitoring was required to be conducted by January 1, 1998. If you serve 50,000 or fewer
people, this monitoring must be completed within one year of installing corrosion control
treatment.
Routine Lead and Copper Tap Monitoring
If you serve more than 50,000 people and you do meet the (b)(3) criteria, you must
monitor semi-annually at the standard number of sites until you qualify for reduced monitoring by
being in compliance with your OWQP specifications for 2, consecutive, 6-month monitoring
periods.
If you serve 50,000 or fewer people and you continue to exceed either action level after
installing corrosion control treatment, you must monitor semi-annually at the standard
number of sites until you qualify for reduced monitoring by being in compliance with your
OWQP specifications for 2, consecutive, 6-month monitoring periods.
Lead and Copper Monitoring Guidance 15 February 2002
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Am I Eligible for Reduced Lead and Copper Tap Monitoring? (See
§§141.86(d)(4) & (g))
Reduced Lead and Copper Tap Monitoring
Criteria for Annual Monitoring: You can reduce the frequency of your monitoring to
annually and collect from a reduced number of sites, as shown in Table 2-3, if:
1. You serve 50,000 or fewer people, and you are
at or below both action levels during 2,
consecutive, 6-month monitoring periods. The
earliest that you could qualify for reduced
monitoring is after initial monitoring. You do
not need prior approval from the State.
OR
2. For any size system, you operate in accordance
with State-specified OWQPs during 2,
consecutive, 6-month monitoring periods.
The LCRMR no longer require you to request reduced
monitoring status from the State. However, you must
receive written permission to proceed to reduced
monitoring.
Table 2-3: Minimum Number of
Lead and Copper Tap Samples for
Systems on Reduced Monitoring
System Size
> 100,000
10,001 - 100,00
3,301 - 10,000
501 - 3,300
101-500
< 100
No. of Samples
50
30
20
10
5
5
Note: The number of samples for systems serving <
100 people is the same under standard and reduced
monitoring.
REMEMBER: If you do not have the required number of
sampling sites, it may be necessary to collect more than one
sample from the same location, on different days, in order to
collect the minimum number of required samples.
Criteria for Triennial Monitoring: You can reduce the frequency of sampling to once every
3 years and collect the reduced number of samples if you are:
1.
2.
A system that serves 50,000 or fewer people and your 90th percentile lead and copper levels
are at or below both action levels for 3 consecutive years. You do not need prior approval from the
State). Two, consecutive, 6-month periods at or below both action levels (such as the two
initial monitoring periods) can count as the first year of the 3 years needed to qualify for
triennial monitoring.
Any size system that operates in accordance with State-specified OWQPs during, 3
consecutive years, even if you exceed one or both action levels. You must receive written
permission to proceed to reduced monitoring.
Lead and Copper Monitoring Guidance
16
February 2002
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3. Any size system that demonstrates that it meets the (b)(3) criteria. The LCRMR clarify
that (b)(3) systems must conduct one round of monitoring at the reduced number of sites
between September 1, 1997 and September 30, 2000 and collect lead and copper tap
samples at least once every 3 calendar years, thereafter (Note: Some States may not allow
triennial monitoring for certain size systems). If you no longer meet the (b) (3) criteria for any of the
following reasons, you must begin corrosion control treatment steps, beginning with the
study:
• The difference between your 90th percentile lead level at the tap and the lead level in
your source water is 0.005 mg/L or higher; or
• You exceed the lead action level; or
• You exceed the copper action level on or after July 12, 2001.
4. Any size system with 90th percentile lead levels of less than or equal to 0.005 mg/L and 90th
percentile copper levels of less than or equal to 0.65 mg/L, for 2, consecutive, 6-month
periods (also known as accelerated reduced lead and copper tap monitoring). This
provision is newly allowed under the LCRMR and is less stringent than the original LCR.
/ You must first check with your State to determine if it has adopted this provision.
Criteria for a Monitoring Waiver: Under the LCRMR, if you serve 3,300 or fewer people,
you may be eligible for a lead and/or copper monitoring waiver, that allows you to collect lead
and copper samples at 9-year intervals at the reduced number of sites if you meet specific
materials and monitoring criteria.
• To meet the materials criteria for lead, you must certify that the plumbing materials in
your system contain no plastic pipes which contain lead plasticizers, or plastic service
lines which contain lead plasticizers, and are free of lead service lines, lead pipes, lead
soldered pipe joints, and leaded brass or bronze alloy fittings and fixtures, unless the
fittings and fixtures meet the specifications of any standard established by SDWA
section 1417(e). To meet the materials criteria for copper, you must certify that the
plumbing materials in your system do not contain any copper pipes or copper service
lines.
• The monitoring criteria specify that your 90th percentile lead level cannot be greater
than 0.005 mg/L and your 90th percentile copper level cannot be higher than 0.65
mg/L.
Full waivers may be granted if you meet the materials and monitoring criteria for both lead and
copper. Partial waivers for lead or copper may be granted if you demonstrate to the State that
you meet the materials and monitoring criteria for either lead or copper, but not both. States may
elect not to grant full or partial monitoring waivers. Note: Some States are not planning on adopting this
waiver provision.
A few States granted waivers prior to the April 11, 2000, effective date of the LCRMR. If you
were granted a "pre-existing waiver" and were not required to monitor, the LCRMR specify that
Lead and Copper Monitoring Guidance 17 February 2002
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you had to conduct at least one set of lead and copper samples at the tap at the standard number
of sites by September 30, 2000.
For more information on monitoring waivers, refer
to: Monitoring Waivers under the Lead and Copper Rule Minor
Revisions for Systems Serving 3,300 or Fewer People, April 2000,
EPA815-R-99-021.
Table 2-4 below summarizes the criteria that you must meet to qualify for reduced monitoring.
For systems serving more than 100 people, monitoring is conducted at a reduced number of sites.
Table 2-4: Reduced Lead and Copper Tap Monitoring Criteria
System Size
(No. of people
served)
Criteria
Monitoring
Frequency
50,000 and fewer
Any size
At or below both action levels for 2 consecutive 6-month monitoring
periods.
Meet OWQP specifications for 2 consecutive 6-month monitoring
periods.
Annual
50,000 and fewer
Any size
Any size
Any size
At or below both action levels for 3 consecutive years of monitoring.
Meet OWQP specifications for 3 consecutive years of monitoring.
90th percentile lead level is < 0.005 mg/L and 90th percentile copper
level is < 0.65 mg/L for 2, consecutive, 6-month periods. <^Note: This
is newly allowed under the LCRMR and the State must adopt it before it can be
implemented.
Meet (b)(3) criteria:
1. the 90th percentile lead level minus the highest source water level is
< 0.005 mg/L for 2 consecutive, 6-month monitoring periods.
or
2. source water lead levels are below the MDL a/ft/the 90th percentile
lead level is < 0.005 mg/L for 2 consecutive, 6-month monitoring
periods.
and
3. after July 12, 2001, 90th percentile copper levels are at or below the
copper action level.
Triennial
Lead and Copper Monitoring Guidance
18
February 2002
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Table 2-4: Reduced Lead and Copper Tap Monitoring Criteria
System Size
(No. of people
served)
25 to 3,300
Criteria
Meet monitoring waiver criteria:
1. 90th percentile levels are < 0.005 mg/L for lead and/or < 0.65
mg/L for copper.
and
2. plumbing materials meet certain criteria that indicate negligible risk
from lead and/or copper exposure.
and
3. waiver is approved by the State.
Monitoring
Frequency
Once every 9
years
Note: 2 consecutive, 6-months at or below both action levels can count as the first year of the 3 years needed to
qualify for triennial monitoring.
Under the LCR, you were required to conduct reduced lead and copper tap monitoring (i.e.,
annual or triennial monitoring) during the months of June through September. Under the
LCRMR, the State may require you to collect your tap samples during months other than June
through September, if it believes that another time period better represents a time of normal
operation where the highest lead levels are likely to occur (e.g., seasonal system that is closed
during the summer months). The LCRMR specify a one-time transition period for switching
to the new monitoring period, including systems granted monitoring waivers.
If you monitor:
Annually
Triennially
Every 9 years
Then the next round of samples is due no later than:
21 months after the previous round
45 months after the previous round
The end of the 9-year cycle
For example, assume a system is on annual monitoring and last sampled on July 7, 2001. The
system is typically closed during the summer months and the State requires the system to collect its
samples during October through December. The LCRMR allow a maximum of 21 months for
a system on annual monitoring to transition to the new monitoring schedule or April 7, 2003 in
this example. However, since this system must collect its samples during October through
November, it only has until December 31, 2002 to complete this monitoring (a little under 18
months).
Lead and Copper Monitoring Guidance
19
February 2002
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Where Must I Collect My Samples? (See §141.86(a))
The lead and copper regulations require you to sample at locations that may be particularly
susceptible to high lead or copper concentrations. The LCR establishes a tiering system for
prioritizing sampling sites. A materials evaluation is required to help classify sampling sites into
tiers. You must perform a materials evaluation before you begin lead and copper tap monitoring
(refer back to Table 2-1). Table 2-5, below, defines the tiering system for prioritizing sampling
sites.
Table 2-5: Tiering Classification
If you are a CWS
Tier 1 sampling sites are single family structures:
• with copper pipes with lead solder installed
after 1982 (but before the effective date of your State's
lead ban) or contain lead pipes; and/or
• that are served by a lead service line.
% Note: When multiple-family residences (MFRs)
comprise at least 20% of the structures served by a
water system, the system may count them as Tier 1
sites.
Tier 2 sampling sites consist of buildings, including
MFRs:
• with copper pipes with lead solder installed
after 1982 (but before effective date of your State 's lead
ban) or contain lead pipes; and/or
• that are served by a lead service line.
Tier 3 sampling sites are single family structures
w/ copper pipes having lead solder installed before
1983.
If you are an NTNCWS
Tier 1 sampling sites consist of buildings:
• with copper pipes with lead solder installed
after 1982 (but before the effective date of your
State's lead ban) or contain lead pipes; and/or
• that are served by a lead service line.
Tier 2 sampling sites consist of buildings with
copper pipes with lead solder installed before
1983.
Tier 3: Not applicable.
^ Note: All States were required to ban the use of lead solder in all public water systems, and all homes and
buildings connected to such systems by June 1988 (most States adopted the ban in 1987 or 1988). Contact the
Drinking Water Program in your State to find out the effective date.
Once monitoring begins, you must use the same sites, unless a site is no longer accessible to you or
no longer fits the requirements of a priority site (e.g., the lead service lines that served the site have
been replaced).
The LCRMR specify that sites that are chosen for reduced monitoring (i.e., monitoring that is
conducted at a 1-year, 3-year, or 9-year frequency) must be representative of those sites that were
used during standard monitoring. The LCR did not contain language regarding which sites
should be used for reduced monitoring. You may wish to randomly select the reduced number of
sites from the larger pool used during standard monitoring. The intent of the rule is that you do
Lead and Copper Monitoring Guidance
20
February 2002
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not use only those sampling locations with the lowest lead or copper levels. The revised rule also
gives States the choice to determine which sample locations you must use. Before proceeding,
check with your State to find out what method the State uses in selecting reduced monitoring
sampling sites.
Sources of Information That You Should Review
To identify enough sites that meet targeting criteria, you should survey all records documenting
the materials used to construct and repair your distribution system and buildings connected to
your distribution system. Relevant information can be attained through the following sources:
• Plumbing Codes;
• Plumbing Permits;
• Distribution Maps and Drawings;
• Inspection and Maintenance Records;
• Meter Installation Records;
• Capital Improvement and Master Plans;
• Standard Operating Procedures;
• Operation and Maintenance Manuals;
• Permit Files;
• Existing Water Quality Data;
• Interviews with Senior Personnel, Building Inspectors, and Retirees; and
• Community Survey.
EPA recommends that you identify more sampling sites than the number of samples you are
required to collect during each monitoring period, in case volunteers drop out. The regulations
specify the minimum number of tap samples that you must collect each monitoring period, as are
shown in Tables 2-2 and 2-3. For example, if you serve 3,301 to 10,000 people, you are required
to collect 40 tap water samples during each of (at least) 2, consecutive, 6-month monitoring
periods. You should try to maintain a list of about 60 to 80 sampling sites that meet the Tier 1
targeting criteria. If you cannot identify 60 to 80 sites meeting the Tier 1 targeting criteria, then
you should complete your list with sites meeting Tier 2 criteria, followed by those meeting Tier 3
criteria (for CWSs only). If you do not have enough Tier 1, 2, and 3 sites, the LCRMR clarify
that you must complete your sampling pool with representative sites. A site is representative if its
plumbing is similar to that of other sites in your system. EPA encourages you to use sites with
copper plumbing installed subsequent to the local implementation if the lead ban (typically 1988
or 1989), provided these sites can be considered representative.
If your system contains lead service lines, then, if possible, half of the required sampling sites
should be served by a lead service line. Using the medium system example: your sampling plan
should include 20 sites that are served by a lead service line, and you should try to maintain a list
of about 30 to 40 sampling sites served by lead service lines to ensure access to enough sites.
Lead and Copper Monitoring Guidance 21 February 2002
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The preamble of the LCRMR (see page 1970) also clarifies that you may need to collect more
than one sample from the same location, on different days, in order to meet your minimum
sampling requirements. For example, if you are required to collect a minimum of five samples,
but you only have one sampling site, you must collect five samples from this sampling site on
different days.
Three worksheets for organizing the information collected during the materials evaluation are
included in Appendix E as follows:
• Worksheet 1: Materials Survey Investigation Results
• Worksheet 2: Materials Survey Results by Number of Service Connections for each
Plumbing Materials Type
• Worksheet 3: Summary of Material Survey Results
These worksheets can help you determine the sites that contain the highest priority materials.
You do not have to send them to the State, unless requested. In addition, you may want to
conduct some site surveys to be sure you have identified sites with lead.
If You Cannot Find Enough Sampling Sites with High Risk
If you are unable to collect all your samples from Tier 1 sites, then you must follow the procedures
discussed below:
• When a sufficient number of Tier 1 sites do not exist or are inaccessible, you should
complete your sampling pool with Tier 2 sites.
• For CWSs, when a sufficient number of Tier 1 and 2 sites do not exist or are
inaccessible, you should complete your sampling pool with Tier 3 sites.
• According to the LCRMR, any water system that cannot complete its sampling at sites
that meet the applicable tiering criteria must complete sampling at representative sites
throughout the distribution system.
• You are not required to target buildings with lead solder installed after the effective
date that the lead ban was adopted in your State.
• You should not monitor at sampling sites that have water softeners; however, if all of
your available sampling sites have water softeners, you should identify the highest risk
sites (Tier 1) and monitor at those locations (such as a kitchen or bathroom tap).
• If you are not able to draw at least half of your samples from taps served by lead service
lines, you must collect a sample from each site that is served by a lead service line.
For example, a system serving 3,301 to 10,000 people does not qualify for reduced
monitoring and is required to collect tap water samples from a total of 40 sites, 20 of
which must be from sites served by a lead service line. If, after reviewing all of the
records listed on the previous page, the system can identify only 12 sites served by a
lead service line, it must collect a tap water sample from each of those sites. The
remaining 28 samples would be collected from other Tier 1 sites. If an insufficient
number of Tier 1 sites are available, the system must use Tier 2 sites, followed by Tier
Lead and Copper Monitoring Guidance 2 2 February 2002
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3 sites, and lastly by representative sites. Refer back to Tables 2-2 (standard monitoring) and 2-
3 (reduced monitoring) to identify the appropriate number of sites for your system size.
If you have no lead service lines, but you have lead goosenecks or pigtails, you can
collect tap water samples at the sites with the goosenecks and/or pigtails.
How Do I Collect Lead and Copper Tap Water Samples? (See §141.86(b))
When collecting lead and copper tap samples, you must follow the procedures listed below:
• Always collect a 1-liter sample in one container only (e.g., do not split the sample
between two containers).
• Always collect a first-draw sample from a tap where the water has stood in the pipes for
at least 6 hours (e.g., no flushing, showering, etc.), except where noted below in the box titled:
"RelatedLCRMR Provisions". However, make sure it is a tap that is used regularly, and
not an abandoned or infrequently used tap.
• First-draw samples collected at single-family residences should always be drawn from
the cold-water kitchen tap or bathroom tap.
• First-draw samples collected from buildings other than single-family homes should
always be drawn from an interior tap from which water is typically taken for
consumption.
• You may allow residents to collect sample, but you must supply the residents with
instructions as to the sample collection procedures. You can use the instruction form
provided as page E-5 of Appendix E. Be sure to properly label sample bottles prior to
distributing them to residents.
• As a general rule, you should collect your lead and copper tap water samples early in
the monitoring period in case you exceed the lead or copper action level. This is
because you will be required to also collect WQP samples during the same monitoring
period (refer to Chapter III for a more detailed discussion of WQP monitoring).
• After the sample is drawn, 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 homeowner nor the sample collector should handle the
nitric acid used for sample acidification.
• If you cannot gain access to an original sampling site during any repeat sample
collections, you should collect a tap water sample from another site which meets the
same targeting criteria as the original site. The replacement site should be located
within reasonable proximity of the original site. (Note: Some States require prior notification or
approval of any changes in sampling sites.) Form 141-A in Appendix E provides you with an
easy-to-follow format for tracking sample site identification and certification.
Lead and Copper Monitoring Guidance 2 3 February 2002
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Related LCRMR Provision
If you are an NTNCWS or CWS (such as a prison or hospital) that does not
have enough inside taps where the water stands unused for at least 6 hours, the
LCRMR allow you to use inside taps that are the most likely to have remained
unused for the longest period of time. Your State contact will tell you whether
you must submit a sampling plan for State approval prior to sampling at non-
first-draw sample locations or if you can proceed with sampling and submit the
plan with your sampling results.
/ Please check with your State before collecting any non-first dra w
samples.
What Are the Approved Methods for Analyzing Water Samples for Lead
and Copper? (See §141.23(1))
The approved analytical methods for lead, copper, and all WQPs (pH, calcium, alkalinity, silica,
orthophosphate, conductivity, and temperature) are shown in Table 2-6. A summary of the
preservation protocols, sample containers, and maximum holding times for analysis is provided in
Table 2-7.
Table 2-6: Approved Analytical Methods for the Lead and Copper Rule
Contaminant
Methodology 8
EPA
ASTM3
SM4
Other
Alkalinity
Titrimetric
Electrometric titration
D1067-92B
2320 B
I-1030-855
Calcium
EDTA titrimetric
Atomic absorption; direct aspiration
Inductively-coupled plasma2
200.7
D511-93A
D511-93B
3500-CaD
3111B
3120 B
Copper
Atomic absorption; furnace
Atomic absorption; direct aspiration
Inductively Coupled Plasma (ICP)2
ICP-Mass spectrometry2
Atomic absorption; platform2
200.7
200.8
200.9
D1688-95C
D1688-95A
3113B
3111B
3120 B
Lead and Copper Monitoring Guidance
24
February 2002
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Table 2-6: Approved Analytical Methods for the Lead and Copper Rule
Contaminant
Conductivity Conductance
Methodology 8
EPA
ASTM3
D1125-95A
SM4
2510 B
Other
Lead
Atomic absorption; furnace
ICP-Mass spectrometry2
Atomic absorption; platform2
Differential pulse anodic stripping
voltammetry
200.8
200.9
D3559-95D
3113B
Method
10019
Orthophosphate7
Colorimetric, automated, ascorbic acid6
Colorimetric, ascorbic acid, single reagent
Colorimetric, phosphomolybdate
Colorimetric, automated-segmented flow
Colorimetric, automated discrete
Ion Chromatography6
365.1
300.0
D515-88A
D4327-91
4500-P F
4500-P E
4110B
I-1602-855
I-2601-905
I-2598-855
PH
Electrometric1
150.1, 150.2
D1293-95
4500-H+B
Silica
Colorimetric: molybdate blue
Colorimetric: automated-seg. flow
Colorimetric
Colorimetric: molybdosilicate
Colorimetric: heteropoly blue
Colorimetric: automated method for
molybdate-reactive silica
Colorimetric: inductively-coupled plasma
200.7
D859-95
4500-Si D
4500-Si E
4500-Si F
3120 B
1-1700-85
1-2700-85
Temperature
Thermometric
2550
Notes
1 "Methods for Chemical Analysis of Water and Wastes", EPA/600/4-79/020, March 1983. Available at NTIS, PB84
128677.
2 "Methods for the Determination of Metals in Environmental Samples — Supplement I", EPA/600/R 94/111, May 1994.
Available at NTIS, PB95 125472.
Lead and Copper Monitoring Guidance
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Table 2-6: Approved Analytical Methods for the Lead and Copper Rule
Methodology'
Contaminant
EPA ASTM3 SM4
3 Annual Book of ASTM Standards, 1994 and 1996, Vols. 11.01 and 11.02, American Society for Testing and Materials.
The previous versions of D1688 95A, D1688 95C (copper), D3559 95D (lead), D1293 95 (pH), D1125-91A (conductivity)
and D859 94 (silica) are also approved. These previous versions D1688 90A, C; D3559 90D, D1293 84, D1125 91A and
D859 88, respectively are located in the Annual Book of ASTM Standards, 1994, Vols. 11.01. Copies may be obtained from
the American Society for Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, PA 19428.
418th and 19th editions of Standard Methods for the Examination of Water and Wastewater, 1992 and 1995, respectively,
American Public Health Association; either edition may be used. Copies may be obtained from the American Public Health
Asso ciation, 1015 Fifteenth Street NW, Washington, DC 20005.
5 Method I 2601 90, Methods for Analysis by the U.S. Geological Survey National Water Quality Laboratory
Determination of Inorganic and Organic Constituents in Water and Fluvial Sediments, Open File Report 93 125, 1993; For
Methods I 1030 85; I 1601 85; I 1700 85; I 2598 85; I 2700 85; and I 3300 85 See Techniques of Water Resources
Investigation of the U.S. Geological Survey, Book 5, Chapter A 1, 3rd ed., 1989; Available from Information Services, U.S.
Geological Survey, Federal Center, Box 25286, Denver, CO 80225 0425.
6 "Methods for the Determination of Inorganic Substances in Environmental Samples", EPA/600/R 93/100, August 1993.
Available at NTIS, PB94 120821.
7Unfiltered, no digestion or hydolysis.
8 Because MDLs reported in EPA Methods 200.7 and 200.9 were determined using a 2X preconcentration step during
sample digestion, MDLs determined when samples are analyzed by direct analysis (i.e., no sample digestion) will be higher.
For direct analysis of cadmium and arsenic by Method 200.7, and arsenic by Method 3120 B sample preconcentration using
pneumatic nebulization may be required to achieve lower detection limits. Preconcentration may also be required for direct
analysis of antimony, lead, and thallium by Method 200.9; antimony and lead by Method 3113 B; and lead by Method
D3559 90D unless multiple in furnace depositions are made.
9The description for Method Number 1001 for lead is available from Palintest, LTD, 21 Kenton Lands Road, P.O. Box
18395, Erlanger, KY 41018. Or from the Hach Company, P.O. Box 389, Loveland, CO 8053.
Laboratory certification will only be required for lead and copper analyses, and is based on the
performance requirements included with the method detection limits. The use of the approved
analytical methods for all of the WQPs as well as lead and copper is necessary to assure consistent
results and high quality data. However, sample collection and analysis procedures in the field can
contribute to errors in measurement. A quality assurance/quality control (QA/QC) program for
field sampling/analysis and laboratory analysis should be developed and implemented by all
water systems. If a commercial or State laboratory performs the laboratory analyses, it is still
important that quality control measures be taken for the field sampling portion of the monitoring
program.
A complete 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 successful QA/QC
program is the ability to properly track a sample from its collection through analysis and ultimate
recording in either the State or your database. The QA/QC program requirements for sample
tracking include: (1) sample identification; (2) complete sample labeling; (3) training sample
collectors and field data collectors; (4) parallel construction of laboratory record keeping and
database format to sample labeling and identification; and, (5) periodic self-audits of the QA/QC
procedures.
Lead and Copper Monitoring Guidance 2 6 February 2002
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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 your database) needed to fully identify a sample
are:
1. Water System Identification Number.
2. Applicable Water System Entry Point Identification Numbers. (There may be multiple
entry points to a distribution system which should be identified 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 WQPs, or Lead service line.
b. Initial, Follow-Up, Routine, Reduced, or Lead Service Line.
5. Sample Site Identifier: (3 Fields)
a. Region of Distribution System. (Suggest that Region 0 be assigned for each entry
point location.)
b. Subregion of Distribution System. (Suggest that Subregion 0 be assigned for each
entry point location.)
c. Sample Site Specific Identifier.
6. Sample Collection Date.
7. Sample Collection Time.
8. Sample Period.
9. Sample Collector Identifier: Public Water System (PWS) Staff, Resident, State, or
Other.
10. Parameters for Analysis: Lead, Copper, Water Quality Parameters or pH and
Temperature (field measurements).
11. Sample Site Street Address - for water system use.
12. Sample Collection Route - for water system use.
13. Water system Name.
14. Water system Contact Person and telephone number.
You should include data fields to identify those samples delivered to the laboratory representing
travel blanks and blind spikes. As part of your 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. Additionally, for lead and copper
analyses, at least three blind spike samples should be included during every 6-month monitoring
period for medium and large water systems, and at least one such sample for small water systems.
Lead and Copper Monitoring Guidance 2 7 February 2002
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Table 2-7: 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. HNO3 to pH <23
None
Cool, 4°C
Cone. HNO3 to pH <25
Cool, 4°C
Cool, 4°C
Cool, 4°C
None
Container
PorG
PorG
PorG
PorG
PorG
PorG
PorG
Ponly
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 nitric acid (HNO3) cannot be used because of shipping restrictions or is not used because homeowners are
collecting samples, the sample for analysis can be snipped to a laboratory where it must be acidified (generally
to pH < 2) with concentrated HNO3 as soon as possible but not later than 14 days after sample collection.
Sample must stand in the original container used for sampling for at least 28 hours after acidification.
Laboratories should match the acid matrix of their samples, quality control, and calibration standards for
accurate results. The latter two sets of solutions will have the same, fixed concentration of acid. It is
recommended that good laboratory practice would be to determine by prior tests the amount of acid
necessary to achieve some pH <2, and make it consistent with the standards used. For instance, for most
waters, the previous EPA recommendation of 0.15% v/v of HNO3 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 closed 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.
Lead and Copper Monitoring Guidance
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How Do I Evaluate My Results? (See §§141.80(c)(3) & 141.86(f))
Lead and copper analytical results are evaluated against an action level, not an MCL. The lead
action level is exceeded if the concentration of lead in more than 10 percent of tap water samples
collected during any monitoring period is greater than 0.015 mg/L (i.e., if the 90th percentile level
lead level is greater than 0.015 mg/L). The copper action level is exceeded if the concentration of
copper in more than 10 percent of tap water samples collected during any monitoring period
conducted is greater than 1.3 mg/L (i.e., if the 90th percentile level copper level is greater than 1.3
mg/L). All samples that meet the proper site selection and sample collection procedures are used
to determine the 90th percentile calculation, even if you collect samples from more sites than
required.
The 90th percentile is calculated separately for lead and copper. The procedure for determining
the lead 90th percentile value is as follows:
If you are required to collect more than 5 samples:
Step 1: Place lead results in ascending order (from lowest to highest value).
Step 2: Assign each sample a number, 1 for lowest value.
Step 3: Multiply the total number of samples by 0.9.
Step 4: Compare the 90th percentile level to the action level of 0.015 mg/L(i.e., 15 parts
per billion (ppb)). If your 90th percentile value is higher than 0.015 mg/L, you
have an exceedance.
Repeat this procedure for copper sample results, except compare the 90h percentile copper level against its action
level of 1.3 mg/L. If your 90h percentile value is greater than 1.3 mg/L, you have an exceedance.
If you are required to collect 5 samples:
Step 1: Place lead or copper results in ascending order.
Step 2: Take the average of the 4th and 5th highest sample. This is your 90th percentile
level.
Step 3: Compare the 90th percentile level against the lead or copper action level.
REMEMBER: All sample results taken during the monitoring
period must be included in your 90th percentile calculations, unless a
result has been invalidated (refer to the section in this chapter,
entitled, What If The State Determines That My Samples Are
Invalid?). If a sample is invalidated, its replacement sample must be
included in the 90th percentile calculation. Further, a 90th percentile
level cannot be calculated if the system has collected less than the
minimum required number of samples.
M
Lead and Copper Monitoring Guidance
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Below are two examples to help demonstrate the 90th percentile calculation for systems that are
required to collect more than 5 samples. The first example explains how to determine whether
you have exceeded an action level when your 90th percentile level is a whole number. The second
example shows how to make this determination, using either rounding or interpolation, when your
90th percentile level contains a decimal. This may happen when you collect more than the
minimum required number of samples.
Example 1 : Determining Whether An Action Level Has Been
Exceeded When the 90th Percentile Level is A Whole Number
Sample Rank
1
2
3
4
5
6
7
8
9 (90th %)
10
Sample Value (mg/L)
0.000
0.000
0.002
0.005
0.005
0.006
0.006
0.010
0.015
0.020
The system does not exceed the lead action level because its 90th percentile level (the 9* sample)
is 0.015 mg/L which equals the lead action level. To have an exceedance, the 90* percentile
level must be greater than 0. 01 5 mg/L.
In Example 2 below, the system is required to collect a minimum of 10 valid samples. It collects
12 valid samples and thus, all 12 are used in the 90th percentile calculation. In this example, the
90th percentile level is 10.8 (i.e., 12 samples x 0.9 = 10.$.
Example 2: Determining Whether An Action Level Has Been
Exceeded When the 90th Percentile Level Contains A Decimal
Sample Rank
1
2
3
4
5
6
7
8
9
10
11
12
Sample Value (mg/L)
0.000
0.000
0.002
0.005
0.005
0.005
0.006
0.006
0.010
0.014
0.018
0.020
Lead and Copper Monitoring Guidance
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Either rounding or interpolation can be used to determine the 90th percentile level when the
sample that represents the 90th percentile value is not a whole number. Your State may specify
which method you should use.
Using Rounding: EPA's policy is to:
1. Round down to the nearest whole number if your decimal is 0.4 or lower.
2. Round up to the nearest whole number if your decimal is 0.5 or higher.
In this example, the 90th percentile sample is 10.8, and you would round up to 11. So, the sample
that is ranked 11th in the list represents the 90th percentile value that you compare to the relevant
action level.
Using rounding, the 9ffh percentile result is 0.018 mg/L and the
system exceeds the lead action level ofO. 015 mg/L.
Using Interpolation: To determine the 90th percentile level, using interpolation, you would:
1. Subtract the difference between the two samples between which your 90th percentile
falls. In this example you subtract the 10th sample result of 0.014 mg/L from the 11th
sample result of 0.018 mg/L, for a difference of 0.004 mg/L.
2. Multiply the difference of 0.004 mg/L by 0.8 because the 90th percentile level is 0.8
higher than the 10th sample result: 0.004 x 0.8 = 0.0032 mg/L (or 0.003 when rounded
to the number of significant figures).
3. Add 0.003 to the lower of the two sample results, in this example to the 10th sample
result of 0.014 mg/L: 0.003 + 0.014 = 0.017 mg/L.
Using interpolation, the 90th percentile lead level is 0.017 mg/L
and the system exceeds the lead action level.
i Note: The LCRMR allow the State to perform the 90th percentile calculation
for you if:
• your State has notified you that it will perform this calculation;
• you provide your sampling results and sampling site information by the
State-specified date; and
• your State gives you the results of the 90th percentile calculation before
the end of the monitoring period.
However, if you do not meet all three of these criteria, you must calculate
the 90th percentile results yourself, and provide them to the State.
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What If the State Determines that My Samples Are Invalid? (See
§141.86(f))
Under the LCRMR the State can invalidate a lead or copper tap water sample if any one of the
following are true:
1. The laboratory establishes that improper analysis caused errors;
2. The State determines that the sample site did not meet the site selection criteria;
3. The sample container was damaged in transit; or
4. Substantial reason exists to believe that the sample was tampered with.
In order for the State to make this determination, you must report to the State all sample results
and documentation of the reasons that the samples should be invalidated. Samples may not be
invalidated solely on the grounds that a follow-up sample result is higher or lower than the
original sample. /^ Please check with your State before requesting sample invalidation,
because your State may be unable to implement this provision until it has been
incorporated into its drinking water regulations.
Replacement Samples: If the State invalidates your sample(s), you only need to collect a
replacement sample if the number of valid samples is below the minimum number of required
samples. For example, assume you are on standard monitoring and only collect the required
number of samples (use 40 as an example). If one of these samples is invalidated, you only have
39 valid samples, and therefore, must collect 1 replacement sample. Conversely, if you initially
collected 41 samples and 1 was invalidated, you would still have 40 valid samples and would not
need to collect a replacement sample. Note that if a replacement cannot be taken at the same
location, it should be taken at a location other than one already used for sampling during the
monitoring period.
Replacement samples must be taken as soon as possible, but within 20 days of the date of
invalidation, or by the end of the applicable monitoring period, whichever is later. Note that if
these samples are taken after the end of the applicable monitoring period, they cannot be used to
fulfill the sampling requirements of a subsequent period. For example, assume a replacement
sample is collected in July 2001 for one invalidated sample that was collected during the January
through June 2001 monitoring period. You cannot include this replacement sample as part of
your samples for the July through December 2001 monitoring period.
Please note that you may find yourself in a situation where the State invalidates your sample(s) on
a date that does not allow you to collect a replacement sample during the months in which you
are required to conduct monitoring (i.e., June through September or an alternate period
designated by the State). In this event, you can collect this sample outside this time period, as long
as you collect the sample(s) no later than 20 days after the date the sample(s) was(were) invalidated
or by the end of the monitoring period, whichever occurs later. For example, assume you are
required to conduct monitoring during June through September and the State invalidates one of
Lead and Copper Monitoring Guidance 3 2 February 2002
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your samples on October 15, 2000. You have until November 4, 2000 (i.e., 20 days after the
State's invalidation decision) to collect the replacement sample.
REMEMBER: If a sample is determined to be invalid, you cannot
include it in your 90th percentile calculations. However, the
replacement sample must be included in the calculation.
What Should I Do If I Exceed an Action Level While lam Monitoring at 6-
month intervals? (See §141. 80)
If the 90th percentile lead level exceeds 0.015 mg/L or if the 90th percentile copper level exceeds
1.3mg/L, you must:
• Conduct WQP monitoring in each monitoring period in which you exceed an action
level, if you serve 50,000 or fewer people. If you are a large system, you are required
to collect WQPs regardless of whether you exceed an action level (unless you meet the
(b)(3) criteria) (see §141.87). Refer to Chapter III which discusses WQP requirements
in more detail.
• Collect lead and copper source water samples and submit a source water treatment
recommendation to the State, if you have not already done so within 6 months of the
exceedance (see §141.83(b)). Form 141-D, Source Water Monitoring and Treatment,
in Appendix E has been provided to assist you with compiling the information needed
to support and provide your recommendation. You do not need to complete the boxes
entitled "Certification that Source Water Treatment Has Been Installed" or "Request
for Modification of State Treatment Decisions and/or Maximum Permissible Lead and
Copper Levels".
• Submit an optimal corrosion control treatment recommendation to the State, if you
have not already done so within 6 months of the exceedance for systems serving 50,000
or fewer people. Systems serving more than 50,000 people were required to provide
this recommendation as part of their corrosion control study by July 1, 1994 (see
In addition, for lead action level exceedances, you must:
• Deliver the public education program described in Lead in Drinking Water Regulation:
Public Education Guidance, EPA 816-R-02-010. If your system has never exceeded, or if
the exceedance occurred after a monitoring period without a lead exceedance, then
delivery is due within 60 days. If it is a continued exceedance, then delivery is every 6
months or annually depending on whether you are a CWS or NTNCWS and
depending on the form of public education delivery required (see §141.85).
• If you exceed the lead action level after installing optimal corrosion control treatment
and/or source water treatment (whichever occurs later), you must replace 7 percent of
Lead and Copper Monitoring Guidance 3 3 February 2002
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your lead service lines within 12 months of the exceedance. You also must replace an
additional 7 percent every 12 months thereafter for as long as you continue to exceed
the lead action level. However, the State may require that more than 7 percent be
replaced each year (see §141.84). Chapter V provides an overview of the lead service
line replacement requirements and a more detailed discussion regarding the related
monitoring and reporting requirements.
What Should I Do If I Exceed the Lead or Copper Action Level During
Reduced Monitoring? (See §§141.80 & 141.86(d)(4)(vi)(A))
If the 90th percentile lead level exceeds 0.015 mg/L or 90th percentile copper level exceeds 1.3
mg/L, you must:
• Stop monitoring at a reduced number and frequency and, 6 months from the date of
the exceedance, begin collecting the standard number of samples every 6 months (see
§141.86(d)(4)(vi)). Refer back to Table 2-2 to find the correct number of sites for your
system size.
• Conduct WQP monitoring in each monitoring period in which you exceed an action
level, if you serve 50,000 or fewer people. If you are a large system, you are required
to collect WQPs regardless of whether you exceed an action level (unless you meet the
(b)(3) criteria) (see §141.81(b)(3) & §141.87).
• If you have not collected source water samples or submitted a source water treatment
recommendation to the State, do so within 6 months of the exceedance (see §141.83(b)).
As mentioned previously, you can use Form 141-D to assist you with preparing and
documenting your source water treatment monitoring results and recommendation.
• If you exceed the lead action level after installing optimal corrosion control treatment
and/or source water treatment (whichever occurs later), you must begin lead service
line replacement (see §141.84).
• Within 60 days of a lead action level exceedance, deliver the public education program
described in EPA's Lead in Drinking Water Regulation: Public Education Guidance, EPA 816-R-
02-010 (see §141.85).
Can I Ever Discontinue Lead and Copper Tap Monitoring?
No, the lead and copper regulations do not allow you to discontinue lead and copper tap
monitoring; only to reduce the number and frequency of this monitoring.
Lead and Copper Monitoring Guidance 3 4 February 2002
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What Lead and Copper Tap Monitoring Information Must I Report to the
State? (See §§141.90(a) & (h))
Within 10 Days of the End of the Monitoring Period
Within 10 days of the end of the monitoring period (i.e., 6 months, 1 year, 3 years, or 9 years), you
must report the following information to the State:
• All tap sample results, including any samples which meet the lead and copper
monitoring protocol and are above the minimum required number of samples for
standard or reduced monitoring.
• Documentation for any tap sample for which you are requesting sample invalidation (if
applicable).
• 90th percentile calculations. Under the LCRMR, the State may elect to do this for you.
However, if the State has not contacted you about this, you are responsible for these
calculations.
• Written explanation for any changes in sampling location (e.g., if homeowners no
longer allow sampling from their taps).
Newly Required by the LCRMR
If you are on a reduced monitoring schedule (i.e., collect lead and copper tap samples less
frequently than semi-annually), the LCRMR require you to submit notification of any change in
source water or treatment within 60 days of the change or sooner if required by the State. The
State may return you to a standard monitoring schedule or take other appropriate steps, if needed.
Less Stringent LCRMR Reporting Provisions:
The following provisions are generally less stringent than the LCR and your State may not be able
to implement them until the provisions are incorporated into its regulations. Your State may also
elect not to incorporate these revisions into its regulations. / Please check with your State
before following through on any of these provisions.
• Under the LCRMR you may no longer be required to provide a:
- certification showing that residents who took samples were informed of proper
sampling procedures;
- certification that each sample represents a first-draw sample;
- justification for using sites that do not meet the Tier 1 criteria; or
- written request for moving to a reduced tap monitoring schedule when you meet
your optimal WQPs (under §141.86(d)(4)).
• If you are an NTNCWS or CWS (such as a prison or hospital) that does not have
enough inside taps where the water stands unused for at least 6 hours, the LCRMR
allow you to use inside taps that are the most likely to have remained unused for the
longest period of time. The State will determine whether you must receive prior
approval to collect non-first draw samples, or whether you can submit documentation
Lead and Copper Monitoring Guidance 3 5 February 2002
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that identifies each site and length of standing time for the samples collected at these
sites when you submit your sample results. Unless you make additional changes to
your sampling plan during subsequent monitoring periods, this is a one-time reporting
requirement.
What Should I Do If I Sell Water To, or Buy Water From, Another Water
System? (See §141.29)
EPA's position on the consolidation of sampling requirements under the Lead and Copper Rule
was stated in a January 10, 1992 memorandum, entitled " Consecutive Systems Regulated under the
National Primary Drinking Water Regulations for Lead and Coppef. Highlights and excerpts from this
memorandum are presented below.
EPA believes it is reasonable to reduce monitoring in consecutive systems if the systems can
demonstrate they are interconnected in a manner that justifies treating them as a single system, in
accordance with §141.29.
Prior to allowing consecutive systems to consolidate their sampling, the State should submit to its
EPA Regional office a written explanation of how the monitoring, treatment, and reporting
requirements will be administered and enforced in consecutive systems that consolidate their
operations for lead and copper. These proposals should clearly identify which systems will be held
accountable for violations of any of the rule's requirements. Should enforcement actions ever
become necessary, it is vital that the party responsible for monitoring, or, if needed, subsequent
treatment and/or other activities (including public education or lead service line replacement) be
clearly identified and accept responsibility for any rule violations.
The key elements that should be contained in the proposal are:
1. Rationale for reduced monitoring;
2. Explanations of the responsibilities among systems involved, including which water
system(s) is (are) responsible for:
• Collecting and reporting to the State the results of the lead and copper tap
monitoring and all WQP monitoring;
• Completing corrosion control requirements under §§141.81 and 141.82; and
• Lead service line replacement.
Lead and Copper Monitoring Guidance 3 6 February 2002
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Note: EPA expects that the parent water system will take
responsibility for corrosion control throughout the entire area served.
Depending on contractual agreements, the size and configuration of
the satellite system(s), and the distance from the parent treatment
facility, individual corrosion control treatment may need to be installed
at a point or points other than the parent plant.
3. How the following provisions will be modified:
• Determination of 90th percentile lead and copper concentrations in the consolidated
system; and
• WQP monitoring to determine baseline values and ensure that optimal corrosion
control treatment is properly installed and maintained.
4. If applicable, how the responsibility for public education, source water monitoring, and
source water treatment will differ from the responsibilities as assigned in the preamble
to the LCR.
Note: In the preamble to the 1991 LCR, EPA has stated that
responsibility for public education delivery resides with the retailer (i.e.,
the consecutive or "satellite" system) and responsibility for source water
monitoring and treatment resides with the wholesaler or "parent" system.
What Happens If I Do Not Fulfill My Lead and Copper Tap Monitoring
And Reporting Requirements? (See §141.80(k))
If you do not meet all of the following monitoring and reporting requirements within the time
frame specified by the rule, you are in violation of these requirements:
• Use appropriate sampling procedures in accordance with §§141.86(a) and (b);
• Collect the required number of samples during the specified time frame in accordance
with §§141.86(c) and (d);
• Ensure samples are analyzed properly in accordance with §141.89(a);
• Submit all required monitoring information on time in accordance with §141.90(a); or
• Report a change in treatment, or an addition of a new source, within 60 days or within
the time frame specified by the State, if you are on reduced monitoring, have a waiver,
or are a (b)(3) system, as required by §141.90(a)(3).
Lead and Copper Monitoring Guidance
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Depending on whether the State adopts the less stringent provisions of the LCRMR into its
revised drinking water regulation, you may also be in violation if you do not meet the following
requirements within the timeframe specified by the rule:
• Meet replacement sample requirements for invalidated samples as described in
§141.86(f)(4) where these samples are needed to meet minimum sampling requirements;
• Meet the conditions of your monitoring waivers in §141.86(g) or provide the required
information in §§141.90(a)(4)(ii)-(iv);
• Provide sample information needed for your State to perform the 90th percentile
calculation as outlined in §141.90(h);
• Collect non-first draw samples that did not meet the criteria in §141.86(b)(5); or
• Meet the monitoring deadline for transitioning to an alternate period (i.e., months
other than June through September) for collecting reduced lead and copper tap
samples, as specified in §141.86(d)(4)(iv)(B).
If you are out of compliance, you must:
1. Report the violation to the State within 48 hours of determining the noncompliance
(see§141.31(b)).
2. Deliver public notification to your customers. If your State has not adopted the new
public notification requirements, refer to §141.32. Otherwise, refer to §141.201 &
§§141.203 -141.206 or to EPA's Public Notification Handbook (EPA 816-R-00-010, June
2000). The Handbook is available on EPA's website at
www.epa.gov/safewater/pn.html.
3. If you are a CWS, include a discussion of the violation in your consumer confidence
report, including potential adverse health effects and actions taken to address the
violation. Refer to §§141.153 & 141.154 or to EPA's Preparing Your Drinking Water
Consumer Confidence Report (EPA 816-R-99-002, March 1999). This document is
available on EPA's website at www.epa.gov/safewater/ccrl.html.
Also keep in mind that:
1. An action level exceedance is not a violation and does not trigger public notification
requirements. However, if you exceed the lead action level, you must deliver public
education to your customers. In addition, if you are a CWS, you must include in your
consumer confidence report, the 90th percentile value for the most recent sampling (if it
is a value greater than 0) and the number of sites that exceeded the action level.
2. If you have been granted a monitoring waiver and do not conduct your lead and
copper monitoring properly or on-time, you no longer meet the conditions of your
waiver and the State may revoke your waiver. You can reapply at a later date when
you again meet the eligibility requirements for a waiver.
Lead and Copper Monitoring Guidance 3 8 February 2002
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3. Consecutive rounds of monitoring are needed to qualify for reduced lead and copper
tap monitoring. Thus, noncompliance with your lead and copper tap monitoring
requirements can impact how quickly you can qualify for reduced monitoring.
What Provisions of the LCRMR Pertain to Lead and Copper Tap
Monitoring and Reporting? (See §141.86 & §141.90(a))
The table below summarize those lead and copper tap monitoring and related reporting
provisions that have been discussed throughout Chapter II. The table distinguishes between those
provisions that you were required to begin implementing on April 11, 2000 and those less
stringent provisions with which you must first check with your State before implementing.
Remember, if you own or operate a water system on Tribal lands, in Wyoming, or the District of
Columbia, the Federal version of the LCRMR applies to you. Therefore, you were required to
implement all of the following provisions beginning April 11, 2000.
You Were Required to Comply with
These Monitoring Requirements Beginning April 11, 2000
If you do not have enough Tier 1, 2, or 3 sites, you must use representative sites to meet
minimum sampling requirements.
If you are on reduced lead and copper tap monitoring, you must collect from sites that are
representative of the ones you used during standard monitoring. (Your State entity may specify where
to collect these samples.)
If you are on reduced lead and copper tap monitoring, are a (b)(3) system, or have a monitoring
waiver, you must notify your State in writing no later than 60 days after changing treatment or
adding a new source.
You Must First Check With Your State Before Implementing the Following
Provisions
Your State may allow you to conduct reduced lead and copper monitoring during months other
than June through September.
If you operate 24 hours a day and you do not have enough taps that can supply first-draw lead
and copper samples, you may be able to collect samples from the taps that have the longest
standing times.
You can collect lead and copper tap water samples once every 3 years after monitoring for only
2 consecutive, 6-month monitoring periods, if your 90th percentile levels are < 0.005 mg/L for
lead and < 0.65 mg/L for copper.
Lead and Copper Monitoring Guidance 3 9 February 2002
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You Must First Check With Your State Before Implementing the Following
Provisions
(Continued)
You can ask your State to invalidate lead and copper tap water samples if the samples meet at
least one of the criteria below and you provide documentation that supports your request:
• There is a laboratory error;
• The sample was damaged in transit;
• The State determines that the sample was taken from an inappropriate site; or
• The State believes the sample was tampered with.
Note: If you do not have enough valid samples after the State invalidates your sample (s), you must collect enough
replacement samples to meet the minimum sampling requirements.
You may request a 9-year monitoring waiver for lead and/or copper tap monitoring if:
• You serve 3,300 or fewer persons;
• Your 90th percentile levels are < 0.005 mg/L for lead and/or < 0.65 mg/L for copper;
and
• Your plumbing materials meet certain criteria that indicate negligible risk from lead
and/or copper exposure.
You may no longer be required to:
1. Calculate and report your 90th percentile lead and copper levels if:
• Your State has notified you that it will perform this calculation;
• You provided your sampling results and sampling site information to your State no
later than the date specified by your State (Note: this date will be sometime before the end of
the monitoring period); and
• Your State gave you the results of the 90th percentile calculation before the end of
the monitoring period.
2. Submit certifications that you followed proper sampling procedures or that homeowners
collected samples after receiving proper instructions.
3. Provide justifications if your sampling pool contains Tier 2 or Tier 3 sites or an
insufficient number of sites served by lead service lines.
4. Request in writing your State's permission to monitor for lead and copper on a reduced
schedule after you meet your OWQPs. (You still must receive written approval from
your State be fore you begin reduced monitoring.)
Lead and Copper Monitoring Guidance 4 0 February 2002
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What Key Points Should I Remember About Lead and Copper Tap
Monitoring? (See §§141.81 & 141.86)
You must sample at Tier 1 sites. If an insufficient number exist, use Tier 1, followed by Tier 2,
Tier 3, and representative sites. (Note: Tier 3 sites only apply to CWSs.)
If you have lead service lines in your distribution system, you should collect at least half of your
samples from sites served by lead service lines. If you have no lead service lines, but you have lead
goosenecks or pigtails, you can collect tap water samples at the sites with the goosenecks and/or
pigtails.
You should identify more sampling sites than the number of samples you are required to collect
during each monitoring period, in case volunteers drop out.
If you do not have the required number of sampling sites, it may be necessary to collect more than
one sample from the same location, on different days, in order to collect the minimum number of
required samples.
Samples must be 1-liter in volume and be taken from an interior tap where the water has stood in
the pipes for at least 6 hours (except as noted below).
If you are an NTNCWS or CWS that does not have enough inside taps where the water stands
unused for at least 6 hours, your State may allow you to use inside taps that have remained unused
for the longest period of time.
You should collect samples early enough in the monitoring period in case WQP samples are
required (e.g., small or medium systems that exceeds the lead or copper action level).
You must initiate corrosion control treatment steps if you exceed the lead or copper action level or if
you serve more than 50,000 people and you are not a (b)(2) or (b)(3) system.
You must collect source water samples if you exceed lead and copper action levels.
If you serve 50,000 or fewer people, you can stop corrosion control treatment steps whenever your
90th percentile lead and copper levels are at or below their action levels for 2, consecutive, 6-month
monitoring periods. You must recommence these steps if you again exceed either action level.
If you serve 50,000 or fewer people, you qualify for reduced annual monitoring if you have 2,
consecutive, 6-month periods at or below both action levels. You can qualify for triennial
monitoring if you have 3 consecutive years of monitoring at or below both action levels.
Regardless of the number of people that you serve, you can qualify for reduced monitoring if you are
in compliance with your OWQP specifications for a minimum of 2, consecutive, 6-month periods
and you receive written approval from the State.
Regardless of the number of people that you serve, you can qualify for triennial monitoring at the
reduced number of sites, if your 90th percentile lead level is < 0.005 mg/L and90th percentile copper
level is < 0.65 mg/L, for 2, consecutive, 6-month periods (if the State has adopted this provision).
If you serve 3,300 or fewer people, you can monitor once every 9 years at the reduced number of
sites, if you qualify for a monitoring waiver, and the State has adopted this provision.
Lead and Copper Monitoring Guidance 41 February 2002
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CHAPTER III: WATER QUALITY PARAMETER
MONITORING AND REPORTING REQUIREMENTS
What Is The Purpose of Collecting Water Quality Parameter Samples? (See
§141.87)
WQPs are used to determine the corrosivity of the water, and if needed, to help the system and
State determine the type of corrosion control that the system should install and how the treatment
should be operated. For most water systems that require treatment, corrosion control treatment is
the primary mechanism for reducing their lead and copper levels.
WQP samples include analysis for:
• pH;
• Alkalinity;
• Calcium;
• Conductivity;
• Water temperature;
• Orthophosphate, if an inhibitor containing phosphate is used; and
• Silica, if an inhibitor containing silica is used.
WQP samples are collected at two separate locations:
• At entry points to the distribution system; and
• At representative taps throughout the distribution system (approved coliform sampling sites
may be used).
Which Systems Must Collect Water Quality Parameter Samples? (See
§141.87)
If you serve more than 50,000 people, you must conduct some WQP monitoring. However, if
you meet the (b)(3) criteria based on initial lead and copper tap monitoring, you are only required
to conduct WQP monitoring during the same 2, consecutive, 6 months in which you conducted
initial lead and copper tap monitoring.
If you serve 50,000 or fewer people, you do not have to collect WQP samples unless you
exceed an action level. During any monitoring period in which you exceed the lead or copper
action level, WQP samples must be collected from entry points to the distribution system and
from a set of representative sites located throughout the distribution system.
Lead and Copper Monitoring Guidance 4 2 February 2002
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When Do I Collect Water Quality Parameter Samples? (See §§141.87(b)-(e))
Water quality parameter monitoring can be divided into three phases:
• Initial WQP monitoring;
• Follow-up monitoring that occurs in the year following the installation of corrosion
control treatment; and
• Monitoring that occurs after the State sets OWQPs.
Each of these is discussed in greater detail below. In addition, refer to the timelines in
Appendix C which illustrate how WQP monitoring requirements are impacted by a system's size
category and whether it exceeds an action level.
Initial WOP Monitoring
Initial WQP monitoring is conducted during the same monitoring period(s) as initial lead and
copper tap monitoring. During initial monitoring, WQP samples are collected at representative
sites in the distribution system (also referred to as tap samples) and at each entry point to the
distribution system for:
• pH;
• Alkalinity;
• Calcium;
• Conductivity;
• Temperature;
• Orthophosphate, when a phosphate-based corrosion inhibitor is used; and
• Silica, when a silicate-based corrosion inhibitor is used.
If you serve more than 50,000 people, you were required to conduct WQP monitoring during
the same 2, consecutive, 6-month monitoring periods as initial tap monitoring. Thus, for systems
that were in existence prior to 1992, WQP monitoring was required to be conducted during the
monitoring periods of January 1 through June 30, 1992 and July through December 31, 1992.
If you serve 50,000 or fewer people, and you exceeded the lead and/or copper action level,
you must monitor before the end of the 6-month initial tap monitoring period(s) during which the
action level is exceeded. Because WQP samples must be collected in the same monitoring period
in which you exceed an action level, you should collect lead and copper tap water samples early in
the monitoring period. If you exceed during the first round of initial tap monitoring, you are
immediately triggered into corrosion control treatment requirements. If your State requires you
to collect a second set of lead and copper tap samples or you elect to conduct this monitoring and
you exceed the action level, you will also be required to collect WQP samples during this 6-month
monitoring period. Table 3-1 below illustrates the timing for systems serving 50,000 or fewer
people that were in existence prior to January 1992.
Lead and Copper Monitoring Guidance 4 3 February 2002
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REMEMBER: For systems of any size, while you are
conducting a corrosion control study and installing corrosion control
treatment, you are not required to collect WQP samples, unless
required by the State. Samples that are required as part of the study
or during treatment installation are not counted towards compliance
with your normal WQP sampling requirements.
Table 3-1: Initial WQP Requirements for Systems Serving 50,000 and Fewer
People
If you serve...
3,301 to 50,000 people
25 to 3,300 people
And you exceeded during the. . .
1st monitoring period of July - December 1992
2nd monitoring period of January - July 1993
1st monitoring period of July - December 1993
2nd monitoring period of January - July 1994
You were required to
collect WQP samples
during...
July - December 1992
January - July 1993
July - December 1993
January - July 1994
<%> Note: If you are a new system, the State will specify when you must begin initial lead and copper tap
monitoring. WQP samples must be collected before the end of the 6-month initial tap monitoring period(s)
during which an action level is exceeded.
REMEMBER: A small or medium system that does not
exceed an action level does not have to conduct any WQP
monitoring unless required by the State.
During each initial monitoring period in which you are required to conduct WQP monitoring,
you must collect:
• 2 samples at each of the number of tap sites specified in Table 3-2; and
• 2 sample at each entry point to the distribution system.
Lead and Copper Monitoring Guidance
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February 2002
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Table 3-2: Standard Number of WQP "Tap" Sites and Samples
System Size
(No. of People Served)
> 100,000
10,001 to 100,000
3,301 to 10,000
501 to 3,300
< 500
No. of Sites
(Standard)
25
10
3
2
1
No. of Samples
(2 per site)
50
20
6
4
2
As an example, assume a system serving 9,000 people has 3 entry points. The regulation requires
the system to collect 2 distribution samples at 10 sites and 2 samples at each entry point to the
distribution system. Therefore, during January through June 1992, these systems would have
collected 20 WQP tap samples and 6 entry point samples. During July through December 1992,
the system would have collected the same number of entry point and WQP samples.
Follow-up WQP Monitoring
Follow-up monitoring occurs in the 12 months immediately following the installation of corrosion
control treatment. These samples are collected during the same 2, consecutive, 6-month
monitoring period(s) as follow-up lead and copper tap monitoring.
If you serve more than 50,000 people, you were required to conduct this monitoring during 2,
consecutive, 6-month monitoring periods of January through June 1997 and July through
December 1997, unless the State determined you met the criteria of a (b)(2) or a (b)(3) system. As
previously discussed, (b)(2) systems have already installed treatment that is equivalent to that
required under the lead and copper regulations. These systems are not required to conduct initial
or follow-up WQP monitoring.
If you serve 50,000 or fewer people, WQP monitoring is only required during each of the 6-
month follow-up monitoring periods in which you exceed the lead or copper action level.
Therefore, if you install corrosion control treatment and are at or below both action levels, you
are not required to conduct follow-up WQP monitoring. However, your State may require you to
continue WQP monitoring to demonstrate that you are properly operating corrosion control
treatment.
You must collect 2 samples at each of the number of WQP sites specified in Table 3-2, during
each of 2, consecutive, 6-month monitoring periods for:
• pH;
• Alkalinity;
• Calcium, when calcium carbonate stabilization is used;
• Orthophosphate, when a phosphate-based inhibitor is used; and
• Silica, when a silicate-based inhibitor is used.
Lead and Copper Monitoring Guidance
45
February 2002
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These samples should be collected evenly throughout the year to reflect seasonal variability.
You also must immediately begin taking / set of the following WQP samples at each entry point
at least once every 2 weeks:
• pH;
• When alkalinity is adjusted, a reading of the dosage rate of the chemical used to adjust
alkalinity and the concentration of alkalinity; and
• When an inhibitor is used, a reading of the dosage rate of the inhibitor used and the
concentration of orthophosphate or silicate (whichever is used).
Note: Once treatment has been installed, entry point monitoring
changes from 2 samples per entry point at 6-month intervals to 1
sample per entry point at least every 2 weeks.
After corrosion control treatment has been installed, the LCRMR allow ground water systems to
limit sampling points to those representative of the water quality and corrosion control treatment
conditions throughout the system. If this option is used, prior to sampling, the system must
demonstrate to the State that the selected sites are indeed representative. Please note that this
option does not apply to initial monitoring and can only apply if the State incorporates this
provision into its drinking water regulations. / First check with your State to determine if
you can take advantage of this provision.
Monitoring after the State sets OWQPs
The State uses the lead and copper tap and WQP data collected before and after the installation
of corrosion control treatment to set WQP ranges or minimums (called optimal water quality
parameters or OWQPs) that indicate that a system is operating corrosion control treatment at a
level that most effectively minimizes the lead and copper concentrations at users' taps. The State
sets ranges or minimums for the following OWQPs at entry points and within the distribution
system (i.e., tap samples) within 6 months of receiving lead and copper and WQP follow-up
monitoring results:
• pH;
• Alkalinity (when alkalinity is adjusted);
• Orthophosphate (when a phosphate inhibitor is used);
• Silica (when a silicate inhibitor is used); and
• Calcium (when calcium carbonate stabilization is used as part of corrosion control).
For example, the State might require you to maintain pH between 7.8 and 8.2 at each entry point
and a pH of 7.0 to 8.0 at all sampling sites in the distribution system. Similarly, the State might
require you to install sodium bicarbonate at a dosage rate of 10 mg/L (measured at each entry
Lead and Copper Monitoring Guidance 4 6 February 2002
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point) to maintain alkalinity above 20 (measured at all distribution system sites). The State can
also designate values for additional water quality control parameters.
The concentration of each applicable WQP is measured at entry points and at a specified number
of sites within the distribution system (refer back to Table 3-2). Measurements at the entry points
also include a reading of the dosage rate of the chemical used to adjust the alkalinity (if applicable)
and a reading of the dosage rate of the inhibitor used (if applicable).
After OWQPs are set, the frequency of WQP tap monitoring remains semi-annually (unless you
qualify for reduced monitoring), and the frequency for entry point monitoring remains every 2
weeks.
If you serve more than 50,000 people and do not qualify as a (b)(3) system, you must
collect WQP samples and operate in compliance with the OWQPs designated for your system. If
you installed corrosion control treatment prior to the effective date of the rule (i.e., are a (b)(2)
system), the LCRMR clarify that the State will designate OWQPs and that you must conduct
WQP monitoring. Prior to the LCRMR, the regulation was unclear regarding the continuing
monitoring requirements for (b)(2) and (b)(3) systems.
If you serve 50,000 or fewer people, you are only required to collect WQP samples during
those monitoring periods in which an action level exceedance occurs, unless required by the State.
You must collect 2 samples every 6 months at the standard number of WQP tap sampling sites
that is specified in Table 3-2 for:
• pH;
• Alkalinity;
• Calcium, when calcium carbonate stabilization is used;
• Orthophosphate, when a phosphate-based inhibitor is used; and
• Silica, when a silicate-based inhibitor is used.
You must collect 1 set of samples at each entry point (except those ground water systems that can
limit entry point monitoring to representative sites) at least once every 2 weeks for:
• pH;
• When alkalinity is adjusted, a reading of the dosage rate of the chemical used to adjust
alkalinity and the concentration of alkalinity; and
• When an inhibitor is used, a reading of the dosage rate of the inhibitor used and the
concentration of orthophosphate or silicate (whichever is used).
Lead and Copper Monitoring Guidance 4 7 February 2002
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Note: The LCRMR also clarify that for those systems with treatment
in place, the State must take measures to ensure that systems are
operating treatment properly. Thus, the State could require you to
collect WQP samples, even if you serve 50,000 or fewer people, or
qualify as a (b)(3) system.
-Refer to the section entitled, "Can I Ever Reduce My WQP Monitoring?",
for a discussion of the criteria that allow you to reduce the frequency of WQP tap monitoring-
How Do I Select My Sampling Sites? (See §141.87(a))
Distribution Samples
You must identify sampling sites in your distribution system representative of the water quality
throughout the distribution system. These samples are also referred to as WQP tap samples. The
number of tap WQP sampling sites are specified in Table 3-2. For ease, you may want to sample
from sites used for coliform monitoring. The advantages associated with using these sites are: (1)
access is available since the sites are already being used as 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 Coliform Rule. You also can use the
taps from which you collect lead and copper tap samples.
In order to ensure that your distribution sampling sites (or "tap" samples) are representative of
water quality throughout the distribution system, you should consider the following:
• Size of the population you serve and where the population is located;
• All of the different sources of water you currently use;
• All of the different treatments installed and operating;
• The effects of seasonal variability on treatment and water quality;
• The proximity of WQP sites to lead and copper tap water sampling sites;
• The proximity of WQP sites to supplemental chlorination feed points;
• The proximity of WQP sites to ground or elevated storage locations;
• The sampling sites' representativeness of typical detention times of water in the
distribution system;
• The sampling sites' representativeness of distinct pressure zones located throughout
the distribution system; and
• The sampling sites' representativeness of distribution system materials.
Also, avoid areas in the distribution system where maintenance or flushing is conducted because
water quality upsets are more likely to occur in these places. Remember, you are trying to collect
data that is representative of typical water quality conditions in the distribution system.
Lead and Copper Monitoring Guidance 4 8 February 2002
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Entry Point Samples
You must sample from each entry point to the distribution system to obtain a sample that is
representative of the source after treatment. If 2 or more sources are combined before
distribution, your sample must be representative of all sources used.
How Do I Collect Water Quality Parameter Samples? (See §141.87(a))
To Keep in Mind at the Sampling Site
Unlike lead and copper tap samples, WQP samples should be fully flushed. Samples collected at
entry points to the distribution system must be collected at locations representative of each source
of water after treatment.
If your system draws water from more than one source, and the sources are combined before
distribution, you must collect samples at sites in the distribution system where the water is
representative of all sources being used.
If you collect the WQP samples in the distribution system from the same location as coliform and
disinfectant residual samples, you should collect the WQP samples in the following manner:
• Fully flush the tap and collect the coliform sample;
• Collect a sample to measure disinfectant residual;
• Collect and analyze sample for temperature and pH; and
• Collect the samples for the other WQPs.
When you collect WQP samples, you should always record your observations about color,
suspended solids, and the flushing time required prior to achieving acceptable sampling
conditions. During collection of the WQP samples, care should be taken to avoid the introduction
of air bubbles into the sample which can affect the pH, conductivity, and dissolved oxygen content
of the water sample.
Plastic or glass containers can be used when collecting WQP samples unless silica analyses are
required, in which case, plastic must be used. All samples should be stored in a cool environment
until analyzed. During transportation, care should be taken to avoid breakage of the sample.
Lead and Copper Monitoring Guidance 4 9 February 2002
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Parameter-specific procedures to keep in mind
Temperature and pH: Temperature analyses must be conducted in the field to ensure
accuracy. Measure temperature using either a hand-held thermometer or a combined
temperature/pH electrode and meter. pH measurements must also be conducted in the field and
must be made with a pH electrode and meter within 15 minutes of sample collection. The meter
should be capable of measuring to 1/10 of a unit. The pH probe should be placed in a holding
bottle and secured during transport. The probe's membranes are very delicate and should not
come in contact with hard surfaces or be allowed to dry out. Pack a replacement probe just in
case. In addition:
• Before collecting the pH sample, 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.
• Before collecting the sample, remove the faucet aerator and run the water gently to
flush the line.
• Fill the sample bottle to slightly overflowing.
• Use a closed-system bottle — which allows you to insert the thermometer or pH
probe—to reduce measurement error.
• If you use a hand-held thermometer, insert it in the sample and record the reading
when it stabilizes. Insert the pH electrode immediately after removing the
thermometer.
• If you use a combined electrode and meter, insert it in the sample immediately after
filling the bottle and measure temperature. Change the meter to measure pH levels
and gently rotate the bottle until the pH reading stabilizes (may take several minutes).
• Record the pH measurement, rinse the electrode with deionized water and replace it in
the holding bottle.
Other WQPs: When you collect WQP samples for alkalinity, calcium, conductivity,
orthophosphate, and silica, you should take two, 500 mL samples at each sampling location. Two
samples are needed because the calcium analysis is conducted using a separate sample in order to
acidify the sample prior to measurement. The two, 500 mL samples counts as one set of samples;
thus, you must repeat this for each of your 2 entry point sample sets during initial monitoring, as
well as your 2 distribution ("tap") samples sets that are required during each WQP monitoring
period.
How Does the State Determine If I Am In Compliance With My Optimal
Water Quality Parameter Values? (See §141.82(g))
Prior to the LCRMR, you would incur a violation if the WQP value of any sample or the
average of the original sample and confirmation sample was below the minimum value or outside
the range designated by the State. If you elected to collect a confirmation sample, you were
required to collect it within 3 days of collecting the original sample.
Lead and Copper Monitoring Guidance 5 0 February 2002
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In each monitoring period in which you did not meet your OWQP specifications, you would incur
a violation. For entry point monitoring, compliance was determined every 2 weeks. For tap
WQP monitoring, compliance was determined for the monitoring period in effect (i.e., 6 months,
1 year, or 3 years).
Under the LCRMR, EPA revised the procedure for calculating compliance with OWQPs based
on concerns raised by several States and water systems. A major concern was that the 1991
compliance approach created a significant disincentive for sampling WQPs more frequently than
required, since the more frequently measurements are taken, the greater the potential that some of
the results will be outside the OWQP ranges or below the OWQP minimums set by the State.
Another concern was the "averaging" of results was not the best approach from an effective
corrosion control perspective. A system might have to increase pH scale and cause other
problems simply to set the average within range.
Under the LCRMR, compliance determinations are always based on a 6-month period,
regardless of the system's monitoring schedule (e.g., daily, biweekly, semi-annually annually,
triennially) or whether the WQP results are from an entry point or the distribution system. The
start of the first 6-month period begins on the day the State has designated OWQPs.
You cannot be outside the OWQP ranges or below the OWQP minimum (also known as an
excursion) for more than a total of 9 days at a specific sampling point or combination of sampling
points, or for a specific WQP or combination of WQPs during a 6-month period. The 9 days can
occur anytime during the 6-month period and do not have to be consecutive. The 9 days allow
you to make necessary repairs that may be causing your system to not meet its OWQP
specifications.
Confirmation samples are no longer used. You must use the results of all WQP samples collected
during the 6-month period at a sampling location to determine OWQP compliance and report
these results to the State. However, States have discretion to delete results of obvious sampling
errors from this calculation.
Daily values are calculated for each WQP at each sampling location. The procedure for
determining the daily value is based on the sampling frequency for that WQP and sampling point.
It is quite possible for you to collect several samples a day for a given WQP at one sampling
location and to conduct annual monitoring at another. Although the term "daily values" contains
the word "daily", in many instances, the daily value represents a measurement that was collected
more or less frequently than once per day. Table 3-3, below, explains how to calculate the daily
value based on the sampling frequency for a given WQP.
Please note that the State is not required to use this new OWQP compliance procedure.
/ First check with your State to determine when and if you should use this new
procedure for assessing compliance with your OWQPs.
Lead and Copper Monitoring Guidance 51 February 2002
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Table 3-3: Daily Value Calculation Based on Monitoring Frequency
If you are monitoring
for a specific WQP at
a sampling site:
Then the daily value is:
More frequently than
Daily
Daily
Biweekly
Semi-annually
Annually or Triennially
Calculated by averaging all the results measured at the sampling location
for that WQP during the day. If both continuous monitoring results and
grab samples are collected on the same day, both must be included in the
calculation of the daily value. States can specify the frequency with which
continuous monitoring results should be recorded.
A State can also require systems to determine the "daily value" using
another formula when they monitor more frequently than daily at the
same sampling location. / First check with your State regarding the frequency of
recording values and procedures for aggregating results.
Results of each daily sample for that WQP at that location.
Results of each sample collected during the 2-week period for that WQP
at that location.
Results of each sample collected during the 6-month period for that WQP
at that location.
The most recent measurements) taken, even if the measurements) was
(were) collected during a previous monitoring period.
Example: A system is on annual WQP tap monitoring during January -
December 2000. It measures pH at the tap on January 10, 2000 (pH =
7.5) and June 20, 2000 (pH = 7.6). For the 6-month period of January -
June 2000, there are two daily values because both measurements were
collected during the 6-month period being evaluated. For the 6-month
period of July - December 2000, only the most recent value of 7.6 is used.
For more information on the new OWQP compliance
procedure, refer to: How to Determine Compliance with Optimal
Water Quality Parameters as Revised by the Lead and Copper Rule Minor
Revisions, February 2001, EPA 815-R-99-019.
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Can I Ever Reduce My WQP Monitoring? (See §141.87(e))
After the State sets OWQPs, you can qualify for a reduction in the amount of monitoring
conducted at tap locations only if you are in compliance with your OWQPs (i.e., do not have
excursions for more than 9 days in a 6-month period). This reduction does not apply to entry
point WQP monitoring. Entry point monitoring remains at a frequency of every 2 weeks.
Criteria for Reducing the Number of WQP Tap Samples
If you are in compliance with your OWQPs after 2, consecutive, 6-month monitoring periods and
you serve more than 10,000people, you can reduce the number of sample sites at which you
collect tap WQP samples from the standard number to the reduced number as shown in Table 3-
4 below. However, 2 samples are still required at each location and the frequency remains at
semi-annually.
Table 3-4: Reduced Number of WQP Tap Sites and Samples
System Size
(No. of People Served)
> 100,000
10,001 to 100,000
3,301 to 10,000
501 to 3,300
25 to 500
No. of Sites
(Reduced)
10
7
3
2
1
No. of Samples
(2 per site)
20
14
6
4
2
^ Note: The number of WQP tap samples for systems serving < 10,000 people is the same under
standard and reduced monitoring.
Criteria for Annual Monitoring
If you are in compliance with your OWQP specifications for 3 consecutive years of monitoring
(beginning on the date the State sets WQP values), you may also reduce the frequency with which
you collect your distribution WQP samples from once every 6 months to once per year and collect
from the reduced number of sites.
Criteria for Triennial Monitoring
If you are on an annual WQP tap monitoring frequency and you are in compliance with your
OWQPs for 3 consecutive years of monitoring, you may reduce the frequency with which you
collect WQP tap samples from annually to once every 3 years. Systems serving more than 10,000
people would continue to collect from the reduced number of sites.
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Note: Unlike lead and copper tap monitoring, the first year of
semi-annually monitoring does not count toward the first year of
meeting the triennial monitoring criteria. Instead, you must
collect WQP tap samples at the annual frequency for 3
consecutive years to qualify for triennial WQP tap monitoring.
The LCRMR has added an accelerated reduced monitoring provision for tap WQPs. You can
now reduce the frequency of WQP monitoring at the tap to once every 3 years more rapidly than
before. In order to qualify, you must demonstrate for 2 consecutive monitoring periods (either 6-
month or annual periods):
1. Your 90th percentile lead level does not exceed 0.005 mg/L;
2. Your 90th percentile copper level does not exceed 0.65 mg/L; and
3. You are in compliance with your OWQP requirements.
In general, this provision will apply to large systems because unless required by the State, small
and medium systems that are at or below both action levels are not subject to WQP monitoring
requirements. S First check with your State to determine if you can take advantage of
this provision.
Table 3-5 below summarizes the criteria that you must meet to qualify for reduced WQP tap
monitoring. For systems serving more than 10,000 people, WQP tap monitoring is conducted at a
reduced number of sites. Remember, this reduction does not apply to entry point samples; once
corrosion control treatment is installed, these samples are collected at least every 2 weeks.
Table 3-5: Reduced WQP Tap Monitoring Criteria
Criteria1
(Required time period in which system is in
compliance with its OWQP Specifications)
2 consecutive 6-month periods
3 consecutive years (equals six, 6-month periods)
3 consecutive years of annual monitoring2
2 consecutive monitoring periods:
1. 90th percentile lead level < 0.005 mg/L;
2. 90th percentile copper level < 0.65 mg/L; and
3. in compliance with OWQP specifications.
Monitoring Frequency
Every 6 months
Annual
Triennial
Number of Years
Since State Set OWQPs
One
Three
Six
As early as One Year
1 Compliance with OWQPs must occur in consecutive periods to qualify for reduced monitoring.
2 Unlike lead and copper tap monitoring, semi-annual monitoring cannot count as the first year toward the triennial
monitoring criteria. A system must be in compliance with its OWQP specifications for 3 years in which it collects
WQP tap samples at the annual frequency before qualifying for triennial monitoring.
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February 2002
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REMEMBER: If your State is using the new OWQP compliance
procedure, you are in compliance with your OWQPs if you have
excursions on no more than 9 days in a 6-month period (at any
entry point or WQP tap sampling site or combination of sites). As
long as this is the case, you can count this monitoring period
toward qualifying for reduced monitoring.
Can I Ever Discontinue Water Quality Parameter Monitoring?
(See§§141.81(b)(3), 141.82(g), & 141.87(b)-(e))
If you serve 50,000 or fewer people and you no longer exceed an action level, you can discontinue
WQP monitoring. However, if you meet these criteria after installing treatment, your State may
require you to continue WQP monitoring. The LCRMR clarify that systems with treatment in
place must continue to properly operate it. Systems will also be required to undertake any
additional measures that the State deems necessary to ensure treatment is operated properly. This
may mean continued WQP monitoring even if you are at or below both action levels.
Similarly, if you are a large system and the State deems you to be a (b)(3) system, you are not
required to continue WQP monitoring. However, if the State makes this determination after you
have installed treatment, the State may require you to continue to conduct some WQP
monitoring.
REMEMBER: If you serve 50,000 or fewer people, if you again
exceed the lead or copper action level, you will be required to resume
WQP monitoring. Similarly, if you are a large system and no longer
meet the (b)(3) criteria, you also will be required to collect WQPs.
What Water Quality Parameter Monitoring Information Must I Report to
the State? (See §§141.90(a)(l)(vi)-(viii) & (5))
The LCRMR clarify that you must report WQP monitoring results within the first 10 days
following the end of each 6-month compliance period. This reporting requirement still applies even if your
State has not adopted the new OWQP compliance procedure. For example, during the year of 2001, any
WQP samples that you collected during January through June 2001 would be due to the State by
July 10, 2001. Those samples that you collected during July through December 2001 would be
due to the State by January 10, 2001. If you are on annual or triennial WQP tap monitoring,
there will be some 6-month monitoring periods in which you will not have any tap WQP results to
report.
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If you are a ground water system and you are requesting approval to limit entry point monitoring
to representative sites, you must provide a demonstration that selected sites represent water quality
and treatment conditions. / Please check with your State before providing this
demonstration to be sure this provision is included in the State's regulations.
What If I Do Not Fulfill My WQP Requirements? (See §§141.80(k),
141.82(g), &141.87(e)(4))
If you do not meet all of the following monitoring and reporting requirements within the
timeframe specified by the rule, you are in violation of these requirements:
• Use appropriate sampling procedures in accordance with §§141.87(a)(l);
• Collect the required number and type of samples in accordance with §§141.87(a)(2),(b)-
(e);
• Ensure samples are analyzed properly in accordance with §141.89(a);
• Submit all required monitoring information on time in accordance with §141.90(a)(vi)-
(viii); or
• Meet the State-approved sampling plan for collecting WQPs at representative entry
point locations in accordance with §§141.87(c)(3) (this criterion would only apply if you are a
ground water system and your State's regulation allows you to limit entry point WQP monitoring to
representative sites).
In addition, you are in violation if you do not meet your OWQP ranges or minimums set by the
State. If your State assesses compliance using the 1991 LCR procedure, you are out of
compliance if the results of any WQP sample, or the average of the original sample and a
confirmation sample, does not meet the State-designated OWQP ranges or minimums. Under
the LCRMR, you are in violation of your requirements if you have OWQP excursions for more
than 9 days in a 6-month compliance period.
If you are out of compliance with your monitoring, reporting, or OWQP requirements, you must:
1 . Report the violation to the State within 48 hours of determining the noncompliance (see
2. Deliver public notification to your customers (see §141.32 if your State has not adopted
the new public notification requirements or §141.201 & 141.203 - 141.206 if your State
has adopted these new requirements).
3. Include a discussion of the violation in your consumer confidence report if you are a
CWS, (see §§141. 153).
4. Return to semi-annual WQP tap monitoring and lead and copper tap monitoring at the
standard number of sites, if you are on reduced monitoring and you are in violation of
your OWQP requirements. Note: A monitoring and reporting violation does not impact your
WQP monitoring schedule.
Lead and Copper Monitoring Guidance 5 6 February 2002
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EPA has also defined the timing of a 6-month monitoring period for small and medium systems
on reduced lead and copper tap monitoring that are triggered into WQP monitoring because of
an action level exceedance. For these systems, the end of the 6-month period for WQP
monitoring is synchronized with the end of the reduced lead and copper tap monitoring period
during which an action level was exceeded. This revision was made to correspond to the new
OWQP compliance procedure which is based on 6-month monitoring periods. For example, if
you are on annual lead and copper tap monitoring during the time period of January 1 through
December 31, 2001 and you exceed an action level, the corresponding WQP monitoring period
would be July 1 through December 31, 2001.
What Provisions of the LCRMR Pertain to Water Quality Parameter
Monitoring and Reporting? (See §141.82(g), §§141.87(c)(3) & (e)(ii), &
§141.90(a))
The table below summarizes those provisions that directly impact your WQP monitoring and
reporting requirements. It distinguishes between those provisions that you were required to begin
implementing on April 11, 2000 and those less stringent provisions with which you must first
check with your State before implementing. For water systems owned or operated on Tribal
lands, in Wyoming, or the District of Columbia, all of the provisions listed below became
applicable on April 11, 2000.
You Were Required to Comply with
These Monitoring Requirements Beginning April 11, 2000
If you have installed corrosion control treatment but are not required to conduct WQP
monitoring, you must continue to properly operate and maintain corrosion control treatment at
all times.
You must report WQP monitoring results within the first 10 days following the end of the 6-
month OWQP compliance period.
Lead and Copper Monitoring Guidance 5 7 February 2002
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You Must First Check With Your State Before Implementing the Following
Provisions
The LCRMR revises the OWQP compliance procedure as follows:
• "Daily values" are now used to determine compliance. Daily values are the sample
results for each WQP and are calculated for each WQP at each sampling location.
They are based on the sampling frequency for that WQP and sampling point.
• You are only out of compliance if you have an "excursion" for more than a total of 9
days during a 6-month period. An excursion is any "daily value" for a WQP that is
below the minimum value or outside the range set by the State.
• Compliance determinations are always based on 6-month periods, regardless of your
monitoring schedule (e.g., daily, biweekly, semi-annually, annually, triennially) or
whether the sample is from an entry point or tap.
• Confirmation samples are no longer used. You must report the results of all samples
collected during the 6-month period.
You can proceed to triennial WQP tap monitoring if you:
• Qualify for accelerated reduced lead and copper tap water monitoring (your 90th
percentile levels are < 0.005 mg/L for lead and < 0.65 mg/L for copper), and
• Are in compliance with your OWQPs for 2 consecutive monitoring periods (either 6-
month or annual).
You may limit biweekly WQP entry point monitoring to representative locations if:
• You are a ground water system; and
• You can demonstrate that these sites are representative of your system's water quality
conditions.
Lead and Copper Monitoring Guidance 5 8 February 2002
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What Key Points Should I Remember About Water Quality
Parameter Monitoring? (See §§141.82(g) & 141.87)
If you serve more than 50,000 people, you must conduct some WQP monitoring.
If you serve 50,000 or fewer people, you do not have to collect WQP samples unless you
exceed an action level or are required to by the State. However, you must collect WQP
samples during any monitoring period in which you exceed the lead or copper action level.
Samples must be collected from entry points to the distribution system and from a set of
representative sites located throughout the distribution system (coliform sites may be used).
Unlike lead and copper tap samples, WQP samples should be fully flushed. Samples
collected at entry points to the distribution system must be collected at locations
representative of each source of water after treatment.
After you install corrosion control treatment, entry point monitoring changes from 2 samples
per site every 6 months to 1 sample per site every 2 weeks.
You can collect WQP tap samples from a reduced number of sites and/or a reduced
frequency by meeting your OWQP requirements for a specified number of consecutive
monitoring periods for both WQP entry points and distribution samples. Entry point
monitoring remains biweekly.
Unlike lead and copper tap monitoring, you cannot count semi-annual monitoring toward
meeting the triennial monitoring criteria. You must have conducted WQP tap monitoring
annually for 3 consecutive years and be in compliance with your OWQPs for these 3 years
to qualify for triennial WQP tap monitoring.
If your State adopts the new procedure for OWQP compliance, you are in compliance with
your OWQP requirements if you have excursions for no more than a total of 9 days at
specific sampling point or combination of sampling points, or for a specific WQP or
combination of WQPs during a 6-month period.
If you are on reduced monitoring for lead and copper tap monitoring or WQP tap
monitoring, you must return to standard monitoring if you have excursions on more than 9
days in a 6-month period (based on the LCRMR compliance approach).
Lead and Copper Monitoring Guidance 5 9 February 2002
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CHAPTER IV: LEAD AND COPPER SOURCE WATER
MONITORING AND REPORTING REQUIREMENTS
What Is The Purpose of Collecting Source Water Samples? (See
§§141.81(b)(3) & 141.88(a))
The purpose of requiring lead and copper sampling at the entry points to the distribution system is
to:
1. Determine the contribution from source water to total tap water lead and copper levels.
2. Assist you and the States in designing an overall treatment plan for reducing lead and
copper levels at the tap.
3. Assist the State in determining whether source water treatment is necessary to reduce
lead and copper levels at the tap.
Source water samples are also required if you are trying to demonstrate that you have optimized
corrosion control by meeting the criteria under §141.81(b)(3). Refer to the section entitled, What
Is the Purpose of the Lead and Copper Regulations?, in Chapter I for a discussion of the (b)(3)
criteria.
Which Systems Must Collect Source Water Samples? (See §141.88(a))
For systems of any size, source water monitoring for lead and copper is required if a system
exceeds the lead or copper action level based on the 90th percentile lead or copper level in tap
water samples. Source water monitoring is also required for systems electing to demonstrate
that they qualify as (b)(3) systems. Therefore, if a system never exceeds the lead or copper action
level or is not trying to demonstrate that it qualifies as a (b)(3) system, lead and copper source
water monitoring is not required.
Note: If you are a (b)(3) system, your State may require you to
collect source water samples every 3 years when you conduct
lead and copper tap monitoring to confirm your (b)(3) status.
When Do I Collect Source Water Samples? (See §§141.88(a)-(e))
If This Is The First Time You Have Exceeded The Lead Or Copper Action Level
When you exceed the lead or copper action level for the first time, you must collect a sample at
each entry point to the distribution system. Each sample must be analyzed for both lead and
copper and the results must be submitted to the State within 6 months of the exceedance. The
State will use these sample results to determine if source water treatment is needed. In addition to
submitting source water samples, you must also submit a source water treatment recommendation
to the State for review and approval within 6 months of exceeding an action level. This
recommendation is based on source water monitoring results. You are not required to conduct a
source water treatment study. As part of your recommendation, you should consider: ion
Lead and Copper Monitoring Guidance 6 0 February 2002
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exchange, reverse osmosis, lime softening, and coagulation/filtration. You can also recommend
that no source water treatment is needed. EPA's guidance document Lead and Copper Rule Guidance
Manual Volume II: Corrosion Control, September 1992 (see page 3-34), recommends source water
treatment when the concentration of lead in the source water is greater than 0.010 mg/L or the
concentration of copper in source water is greater than 0.800 mg/L.
Form 141-D in Appendix E may be used to report your source water monitoring results and your
source water treatment recommendation. If you use this form, you must also attach a copy of the
analytical results from the laboratory. The State will make a decision regarding source water
treatment and notify you within 6 months of its receipt of your sample results.
If The State Requires You To Install Source Water Treatment
If the State requires you to install source water treatment, you have 24 months to complete
installing this treatment. You are not required to conduct source water monitoring while
installing this treatment other than samples that you may elect to take to evaluate the performance
of your treatment. You are not required to report these results to the State.
Once you have installed source water treatment, you must collect one sample from each entry
point during 2, consecutive, 6-month periods, and analyze this sample for both lead and copper
even if you exceed only one of the action levels. With the "before and after treatment" lead and
copper results, the State will designate maximum permissible levels (MPLs) for lead and copper.
These MPLs represent the highest lead and copper concentrations that are allowed in water
entering the distribution system after source water treatment. The State will set MPLs for both
lead and copper even if you exceeded the action level of only one of these contaminants.
After the State sets MPLs, your monitoring requirements are based on your source type as follows:
• If you use ground water as your only source, you must monitor during 3-year
compliance periods. The first 3-year compliance period is the one in effect when the
State specified MPLs for lead and copper. These are the same compliance periods that
were established under the Standardized Monitoring Framework (SMF) for Phase II/V
contaminants (e.g., 1993 -1995, 1996 -1998, 1999 - 2001, 2002 - 2004, etc.). This was
done to allow you to coordinate your source water monitoring for lead and copper with
other monitoring requirements.
• If you use surface water, ground water under of the direct influence of
surface water (GVDI), or any combination of these sources with ground
water, you must monitor annually. The first annual monitoring period begins on the
date that the State set your MPLs.
You can further reduce your source water monitoring frequency to once every 9 years based on
the SMF compliance cycle (i.e., 1993 - 2001, 2002 - 2010, etc). The number of sites from which
you must collect source water samples remains at one sample per entry point.
You can reduce your monitoring frequency to once every 9 years if you meet the criteria listed
below.
Lead and Copper Monitoring Guidance 61 February 2002
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• If you use ground water exclusively, you can collect source water samples once
every 9 years if you do not exceed either the lead or copper MPL for 3 consecutive, 3-
year compliance periods (i.e., 9 years).
• If you use surface water, ground water under of the direct influence of
surface water (GVDI), or any combination of these sources with ground
water, you can collect source water samples once every 9 years if you do not exceed
either MPL for 3 consecutive years.
If You Are Not Required To Install Source Water Treatment
If you continue to exceed the lead or copper action level but the State determines that source
water treatment is not needed, your continued monitoring requirements are based on the date that
the State made this determination and your source type as follows:
• If you use ground water as your only source, you must monitor during 3-year
compliance periods. The first 3-year compliance period is the one in effect when the
State determines that source water treatment is not needed.
• If you use surface water, GVDI, or any combination of these sources with
ground water, you must monitor annually. The first annual monitoring period begins
on the date that the State determines that source water treatment is not needed.
Note: Some States may have set MPLs for systems that were not required
to install source water treatment. For these systems, the monitoring
schedule is based on when the State set MPLs. More specifically, systems
using ground water exclusively would begin triennial monitoring with the 3-
year period in effect when the State set MPLs. All other systems would
begin annual monitoring on the date that the State set MPLs.
The LCRMR expand the universe of systems that can conduct source water monitoring at a
frequency of once every 9 years. The 1991 LCR did not allow systems that exceeded an action
level, but for which the State did not set MPLs, to reduce the frequency of source water
monitoring. /^ Please check with your State to determine if they have adopted the
provision described below.
If you exceed an action level after the State has determined that source water treatment is not
needed, you can reduce the frequency of source water monitoring if:
• your source water lead concentrations are < 0.005 mg/L; and
• your source water copper concentrations are < 0.65 mg/L; and
• you maintains these levels for 3 consecutive compliance periods.
Ground water systems would qualify for reduced monitoring after 3 consecutive, 3-year
compliance periods or after 9 years. Surface water systems (or those using a combined source)
would qualify after 3 consecutive years.
Lead and Copper Monitoring Guidance 6 2 February 2002
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REMEMBER: You cannot qualify for reduced source water
monitoring unless the 3 compliance periods in which you meet
the reduced monitoring criteria are consecutive.
Once you qualify for reduced source water monitoring (regardless of whether you install source
water treatment or not), you are not required to return to standard monitoring. In other
words, an exceedance of an action level or of an MPL does not impact your source water
monitoring schedule.
Where Are These Samples Collected? (See §141.88(a))
The sample location, collection methods, and number of samples required are the same as for
Phase II/V contaminants, as explained below.
Sampling Requirements Based on Your Source
If you use ground water as your only source, you must take at least one sample at every
entry point to the distribution system which is representative of each well after treatment. If there
are separate entrances to your distribution system from either individual wells or wellfields, a
sample must be collected from each discrete entry point. If you use multiple wells that draw from
the same aquifer, the State can identify an individual well for monitoring, as long as there is no
treatment or blending.
If you use surface water, GVDI, or any combination of these sources with ground
water, you must take at least one sample at every entry point to the distribution system after the
application of treatment or in the distribution system at a point which is representative of each
source after treatment. These samples may be collected after storage during normal operating
conditions or at the high service pumps.
Other Considerations for All Systems Conducting Source Water Monitoring
You must have your samples analyzed for both lead and copper even if you have only exceeded
the action level for one of these contaminants.
If you are drawing from sources that are combined, samples should be taken during normal
operations so that the water is representative of all sources being used.
Some States allow a maximum of 5 samples to be combined together and analyzed as one sample
(known as compositing). The LCRMR require that compositing be done by a certified laboratory.
There are two types of compositing: (1) compositing of samples collected within the same system
(intra-system compositing) and (2) compositing among different systems (inter-system
compositing). Inter-system composting is only allowed for systems serving 3,300 or fewer people.
/ First check with your State to determine whether compositing of source water
samples is allowed.
Lead and Copper Monitoring Guidance 6 3 February 2002
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If the lead concentration in a composite sample is greater than or equal to the lead resampling
trigger of 0.001 mg/L, or if the copper concentration is greater than or equal to the copper
resampling trigger of 0.160 mg/L, then a follow-up sample for the contaminant which exceeded
the trigger should be taken at each site and analyzed within 14 days of when the original sample
was collected. If duplicates of or sufficient amounts are available from the original samples from
each sampling point, these may be used instead of resampling.
Note: The LCRMR increased the copper resampling trigger from greater
than 0.020 mg/L or 0.001 mg/L (depending on the analytical method) to
greater than or equal to 0.160 mg/L and the changed the lead resampling
trigger from greater than 0.001 mg/L to greater than or equal to 0.001 mg/L.
You must take each repeat sample at the same sampling site unless conditions make sampling at
another site more representative of each source or treatment plant.
REMEMBER: Compositing allows you to save on analytical
i aw- ! costs. It does not reduce the number of samples that you must
collect. Also remember to first check with your State to
determine if compositing of samples is allowed.
How Does the State Evaluate My Source Water Monitoring Results?
(See §§141.83(b)(4) & 141.88(a)(2))
If the State sets MPLs for lead and copper, it will compare your source water results to these
levels. If you exceed the lead or copper MPL, you can take a confirmation sample within 14 days
of collecting the original sample. If the average of these results are still higher than the MPL, you
are in violation. The State may require you to make changes to your source water treatment. If
the State does not set these levels, it will review your results to determine if there are any
significant fluctuations in your source water levels, indicating a possible need for source water
treatment.
Note: 90th percentile levels are never calculated for source water samples.
Lead and Copper Monitoring Guidance 6 4 February 2002
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Can I Ever Discontinue Source Water Monitoring? (See §141.88(d)(2))
Once you exceed either the lead or copper action level, you are always subject to source water
monitoring requirements. However, after the State has designated MPLs or determined that you
are not required to install source water treatment, you are not required to collect any source
water samples during any monitoring period in which your 90th percentile lead or copper levels
of tap water samples are at or below their action levels for the entire source water monitoring
period in effect. If your lead and copper tap and source water monitoring periods do not overlap,
then source water monitoring is not required if your 90th percentile lead and copper levels from
the last monitoring period were at or below their respective action levels. These points are
illustrated in the three examples below.
EXAMPLE 1:
A system qualifies for reduced source water monitoring for the compliance cycle of 2002 through
2010. During this time period, the system is on triennial lead and copper tap monitoring. It
conducts lead and copper tap monitoring during 2001 through 2003, 2004 through2006, 2007
through 2009, and 2010 through2012. Both the lead and copper 90th percentile levels are below
the lead and copper action levels for all four monitoring periods. The system is not required to
conduct source water monitoring because it was below both action levels during the entire source
water monitoring period in effect (i.e., the 9-year compliance cycle of 2002 through 2010).
EXAMPLE 2:
Another system qualifies for reduced source water monitoring for the compliance cycle of 2002
through 2010. It conducts lead and copper tap monitoring during 2001 through2003, 2004
through 2006, 2007 through 2009, and 2010 through 2012. During the compliance period of
2010 to 2012, it exceeds the lead action level. These lead and copper tap samples were collected
during 2011. This system is not required to conduct source water monitoring during 2001
through 2010, but it would be required to conduct this monitoring during 2011 through 2019
because of the exceedance that occurred in 2011.
EXAMPLE 3:
Beginning January 1, 2000, a surface water system is on an annual source water monitoring
schedule, and a triennial lead and copper tap monitoring schedule. The system collects lead and
copper samples during 2001 for the compliance period of 2000 through 2002. It continues to
exceed the copper action level, but still qualifies for triennial tap monitoring because it is in
compliance with its OWQPs. The next time the system collects samples is in 2004 (for the 3-year
tap monitoring period of 2003 through 2005) and for the first time, it is below both action levels.
The source water monitoring period in effect in this example is one year. This system must
conduct source water monitoring in 2000, 2001, and 2002 because the system exceeded the
copper action level. The system is also required to conduct monitoring in 2003 although no lead
and copper tap monitoring occurred because it exceeded the copper action level during the last
monitoring period. It is not required to conduct source water monitoring during 2004 and 2005
because the system was below both action levels.
Lead and Copper Monitoring Guidance 6 5 February 2002
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REMEMBER: Once the State sets MPLs or determines that you are
not required to install source water treatment, you can discontinue
source water monitoring if you no longer exceed the lead or copper
action level during the entire source water monitoring period in effect.
The State does not set MPLs until after follow-up monitoring has been
completed. Therefore, if you are required to install source water
treatment, you must complete the 2 consecutive, 6-month rounds of
follow-up source water monitoring even if you no longer exceed the
lead or copper action level in your tap water samples.
What Source Water Monitoring Information Must I Report to the State?
(See§141.90(b))
You must provide the following information within 10 days of the end of the monitoring period
(based on your source water lead and copper sampling schedule — 6 months, 1 year, 3 years, or 9 years):
• All source water sample results; and
• With the exception of your first round of source water monitoring, the identification of
any new sampling location(s) and an explanation for any changes in your sampling
site(s).
What If I Do Not Fulfill My Source Water Monitoring And Reporting
Requirements? (See §§141. 80(k) & 141.83(b)(5))
If you do not meet all of the following monitoring and reporting requirements within the
timeframe specified by the rule, you are in violation of these requirements:
• Use appropriate sampling procedures (see §§141.88(a)(l) and (2));
• Collect the required number of source water samples (see §§141.88(a)(l) - (e));
• Ensure samples are analyzed properly (see §141.89(a)); or
• Submit all required sampling information on time (see §141.90(b)).
You are also in violation if you do not meet your State-designated or approved MPLs. If you are
above either MPL, you can take a confirmation sample within 2 weeks of the original sample, if
allowed by the State. The results of the original and confirmation samples are averaged to
determine whether you are in compliance with your MPLs (see §§141.88(a)(2)).
If you are out of compliance with your monitoring, reporting, or MPLs, you must:
1 . Report the violation to the State within 48 hours of determining the noncompliance (see
2. Deliver public notification to your customers (see §141.32 or if the State has adopted the
new public notification requirements, see §141.201 & §§141.203 - 141.206.)
Lead and Copper Monitoring Guidance 6 6 February 2002
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3. Include a discussion of the violation in your consumer confidence report if you are a
CWS (see §§141.153).
~ Also keep in mind that consecutive rounds of monitoring are needed to qualify for reduced lead and copper
source water monitoring. Thus, noncompliance with your monitoring requirements will impact ho w quickly
you can qualify for reduced monitoring. ~
What Provisions of the LCRMR Pertain to Source Water Monitoring and
Reporting Requirements? (See §§141.88(a)(iv) & 141.88(e)(2)(ii))
The table below summarizes those provisions that directly impact your source water monitoring
requirements. The LCRMR did not change your source water reporting requirements. The table
distinguishes between those provisions that you were required to begin implementing on April 11,
2000 and those less stringent provisions with which you must first check with your State before
following. For water systems owned and operated on Tribal lands, Wyoming, or the District of
Columbia, all of the provisions listed below became applicable on April 11, 2000.
You Were Required to Comply with
These Monitoring Requirements Beginning April 11, 2000
EPA has clarified that compositing (if permitted by the State) must be conducted by certified
lab personnel.
EPA has revised the resampling trigger for composite samples to:
• > 0.001 mg/L for lead; and
• > 0.160 mg/L for copper. (This one for copper is less stringent because the resampling trigger was
increased from 0.020 mg/L to 0.160 mg/L}
You Must First Check With Your State Before Implementing the Following Provisions
You may conduct source water monitoring on a reduced schedule even though you exceed an
action level, it.
• your source water levels are < 0.005 mg/L for lead and < 0.65 mg/L for copper; and
• your State has determined that source water treatment is unnecessary.
Lead and Copper Monitoring Guidance 6 7 February 2002
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What Key Points Should I Remember About Lead and Copper Source
Water Monitoring? (See §§141.83 & 141.88)
Source water lead and copper monitoring is not required if you do not exceed the lead or copper
action level based on tap water monitoring or you are not trying to qualify as a (b)(3) system.
You must analyze for both lead and copper even if you exceed only one of the action levels in lead or
copper tap monitoring.
You must collect a set of samples at each entry point and provide a source water treatment
recommendation (that can include no treatment needed) within 6 months of exceeding an action
level. No source water treatment study is required.
Source water samples are compared against the lead and copper MPLs. 90th percentile levels are
not calculated for source water samples and compared against the action level.
If you are required to install source water treatment, you must complete follow-up source water
monitoring regardless of whether your 90th percentile lead and copper tap monitoring results are at
or below the lead and copper action levels. If you are required to install source water treatment, the
State will establish MPLs for both lead and copper even if you only exceeded one of the action levels
in tap water monitoring.
Once the State sets MPLs or determines that source water treatment is not needed, ground water
systems must monitor every 3 years beginning with the SMF compliance period in effect when the
State made the applicable decision.
Once the State sets MPLs or determines that source water treatment is not needed, surface water
systems or ones using a combined source must monitor annually. The first year begins on the date
the State made the applicable decision.
You can collect source water samples once every 9 years based on SMF compliance cycles, if for 3
consecutive compliance periods you do not exceed your MPLs (equals 9 years for ground water
systems and 3 years for all other systems).
Your State may allow you to collect source water samples once every 9 years if:
- you continue to exceed the lead or copper action level and are not required to install source
water treatment, but
- for 3 consecutive compliance periods your source water lead and copper levels do not exceed
0.005 mg/L and 0.65 mg/L, respectively.
Once you are on reduced source water monitoring, an exceedance of an action level in lead or
copper tap monitoring or an exceedance of an MPL does not alter your monitoring schedule.
After the State has designated MPLs or determined that you are not required to install source water
treatment, you are not required to collect any source water samples during any monitoring period in
which your 90th percentile lead or copper levels of tap water samples are at or below their action
levels for the entire source water monitoring period in effect.
Lead and Copper Monitoring Guidance 6 8 February 2002
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CHAPTER V: LEAD SERVICE LINE MONITORING
AND REPORTING REQUIREMENTS
What Is The Purpose of Collecting Lead Service Line Samples?
(See §§141.84(a) - (d)(l))
You must begin replacing lead service lines if you continue to exceed the lead action level after
installing corrosion control treatment and/or source water treatment (in whichever sampling
occurs later). The State can also require you to begin lead service line replacement if you are
required to install corrosion control treatment or source water treatment and have not installed
such treatment.
There are two reasons for collecting lead service line samples.
1. To determine if a lead service line must be replaced. You are not required to replace an
individual lead service line if the lead concentration of all samples from the line is less
than or equal to 0.015 mg/L. This line counts as a replaced line. You are required to
replace a minimum of 7 percent of your lead service lines annually for as long as you
continue to exceed the lead action level. This monitoring is optional, but it may
save you the expense of replacing a lead service line.
2. To determine the impact of partial lead service line replacement on lead levels. Partial
lead service line replacement occurs when you do not replace the privately-owned
portion of the line, because of legal restrictions or the owner decides not to pay for the
replacement of the privately-owned portion. In this event, you must collect a sample
that is representative of the water in the service line that you partially replaced and have
the sample analyzed for lead within 72 hours after the partial lead service line
replacement. This monitoring is required.
Which Systems Must Collect Lead Service Line Samples? (See §§141.84(a)
& fd)(l))
Only those systems that are required to replace lead service lines may be required to conduct
some lead service line monitoring. As stated above, monitoring to determine whether a line needs
to be replaced is optional. However, the cost of a lead analysis is less expensive than the cost to
replace a line.
If you replace a line, but do not replace the privately-owned portion of the line, then you must
collect a sample that is representative of the water in the service line. This sample is not required
if you replace the entire lead service line, or if you only replaces a gooseneck, pigtail, or other
fittings and these are the only lead components in your service line.
Lead and Copper Monitoring Guidance 6 9 February 2002
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When Do I Collect Lead Service Line Samples? (§§141.84(b) & (e)(3))
The first required year of lead service line replacement begins on the date you exceed the lead
action level in tap samples collected after installing corrosion control or source water treatment,
whichever is later, or as specified by the State.
You are required to replace at least 7 percent (or more if required by the State) of the initial number of
lead service lines in your distribution system. The initial number of lead service lines is the
number in place at the time the replacement program began. You must continue replacing the
required percentage of lead service lines each year until you no longer exceed the lead action level
during 2 consecutive monitoring periods of any duration.
How Do I Collect Lead Service Line Samples? (See §141.86(b)(3))
You can collect these samples using one of the following procedures. For each method, collect a
1-liter sample from the tap by filling the sample bottle to the 1-liter mark, then cap immediately.
• Flushing a Specified Volume - The sample should be collected from the building tap which is
closest to the portion of the lead service line that was not replaced (i.e., the first tap in the
building, most likely a kitchen or bathroom tap on the first floor). Flush the estimated
volume of water between the service connection and the sample tap. You can estimate
the volume of water by using Table 5-1, Pipe Volume Table. EPA recommends
selecting the pipe diameter that is one size larger than the actual pipe size, since pipe
material thickness can vary, affecting the interior diameter and the actual volume of
water. You can also estimate the volume by measuring the length and diameter of
piping from tap to connection and the length and diameter of the service connection
itself into a graduated beaker or cylinder to ensure that you have collected the correct
volume, then close the tap.
• Direct Service Line Samples - In communities where the meters are located outside the
buildings (or unmetered areas) service line taps may already exist. Prior to sampling,
water should be run to flush the pipe that connects the faucet and the service line. If no
tap exists, but the lead service line can be made accessible, a tap constructed of lead-free
materials can be installed directly into the line for sample collection purposes. However,
because installation of a tap directly into the lead service line could induce additional
corrosion activity and is an expensive process as well, this option is not recommended
when there are no existing service line taps.
• Temperature Variation - This method is recommended if the temperatures of lead service
line and interior piping are easily distinguishable (for example in a single-family home).
A tap sample should be collected by gently opening the tap and running the water at a
normal flow rate, keeping a hand/finger under the flowing water. When a change in
water temperature is detected, a 1-liter sample should be collected by filling the sample
bottle to the appropriate level and capping.
Lead and Copper Monitoring Guidance 7 0 February 2002
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Table 5-1: 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 (Inches)
3/8
0.06
0.09
0.11
0.14
0.17
0.20
0.23
0.26
0.28
0.31
0.34
0.37
0.40
0.43
0.46
0.49
0.51
0.54
0.57
0.71
0.86
1.00
1.14
1.43
1/2
0.09
0.14
0.18
0.23
0.27
0.32
0.36
0.41
0.45
0.50
0.55
0.59
0.64
0.68
0.73
0.78
0.82
0.86
0.91
1.14
1.36
1.59
1.82
2.27
5/8
0.14
0.21
0.27
0.34
0.41
0.48
0.55
0.62
0.69
0.75
0.82
0.89
0.96
1.03
1.10
1.16
1.23
1.30
1.37
1.71
2.06
2.40
2.74
3.43
3/4
0.19
0.29
0.38
0.48
0.57
0.67
0.76
0.86
0.95
1.05
1.14
1.24
1.33
1.43
1.52
1.62
1.71
1.81
1.90
2.38
2.85
3.33
3.80
4.76
1
0.32
0.49
0.65
0.81
0.97
1.14
1.30
1.46
1.62
1.78
1.95
2.11
2.26
2.43
2.60
2.76
2.92
3.08
3.24
4.06
4.87
5.68
6.49
8.11
1%
0.50
0.74
0.99
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.
3. EPA recommends selecting the pipe diameter that is one size larger than the actual pipe size,
since pipe material thickness can vary, affecting the interior diameter and the actual volume of
water.
Can I Ever Discontinue Lead Service Line Monitoring? (See §141.84(t))
Lead and Copper Monitoring Guidance 71 February 2002
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You can discontinue lead service line replacement and thus eliminate any need to conduct lead
service line monitoring whenever your 90th percentile lead levels are at or below the lead action
level for 2, consecutive monitoring periods. You must start replacement again if you
subsequently exceed the lead action level during any monitoring period.
REMEMBER: It takes 2, consecutive monitoring periods
to stop replacement, but only 1 monitoring period to be
triggered back into lead service line replacement.
What Lead Service Line-Related Information Must I Report to the State?
(See§141.90)(e))
Within 12 Months of When You Exceed the Lead Action Level
You must provide the State with written demonstration that your materials evaluation was
completed, including the evaluation to identify the initial number of lead service lines in your
distribution system, as follows:
• Schedule for replacing at least 7 percent each year of the initial number of lead service
lines in your distribution system.
• Letter stating for the previous year:
- the number of lines scheduled that were to be replaced;
the number and location of lines actually replaced; and
if measured, the water lead concentration and location of each lead service line
sampled, the sampling method, and the date of sampling.
This letter is due every 12 months until you complete lead service line replacement or no longer exceed the lead
action level during 2, consecutive rounds of tap monitoring.
Newly Required Under the LCRMR
If you do not replace the entire length of the lead service line (i.e., partial replacement), you must
provide the following information to the State.
• The analytical results of lead service line samples collected in response to partial lead
service line replacement:
- the results are due within 10 days following the month in which you received these
analytical results; and
the State can also eliminate the requirement to report these sample results.
Lead and Copper Monitoring Guidance 7 2 February 2002
-------
• Any additional information as specified by the State, and in a time and manner
prescribed by the State, to verify that all partial lead service line replacement activities
have taken place.
No Longer Required under LCRMR
Under the LCRMR you are no longer need to provide evidence that you do not control the entire
lead service line if you are only replacing a portion of the line. Under the 1991 LCR, you were
required to replace the entire line unless you could demonstrate that you did not "control" the
entire line. The LCRMR require you to replace the portion that you own versus control, thereby,
making this demonstration unnecessary.
What If I Do Not Fulfill My Lead Service Line Replacement Requirements?
(See§141.80(k))
You are in violation if you fail to:
• Replace the required number of lead service lines by the annual deadline (i.e., at least
7% annually) (see §§141.84(a) & (b)); or
• Report the required lead service line information on time that demonstrates that the
replacement rate was met (see §141.90(e)).
You are also in violation if you do not meet the following partial lead service line replacement
requirements (only applicable if you do not replace the entire lead service line) (see §141.84(d)):
• Provide notice and guidance to residents at least 45 days before lead service line
replacement begins (unless the State allows a shorter notification period);
• Collect a tap sample within 72 hours of completing the partial lead service line
replacement;
• Mail and/or post results of the analysis to the owner and residents within 3 days of
receipt of the results; or
• Report information that the State requires to assess whether you met your partial lead
service line replacement monitoring and notification requirements.
If you are in violation for any of the above reasons you must:
1 . Report the violation to the State within 48 hours of determining the noncompliance (see
2. Deliver public notification to your customers (see §141.32 if your State has not adopted
the new public notification requirements or §141.201 & 141.203 - 141.206 if your State
has adopted these new requirements).
3. Include a discussion of the violation in your consumer confidence report if you are a
CWS (see §141. 153).
Lead and Copper Monitoring Guidance 7 3 February 2002
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What Provisions of the LCRMR Pertain to Lead Service Line Monitoring
and Replacement? (See §141.88(d) & §141.90(e))
The table below summarize each of the LCRMR provisions that impact your lead service line
monitoring and replacement requirements. You were required to begin implementing these
requirements on April 11, 2000.
You Were Required to Comply with
These Monitoring and Reporting Requirements Beginning April 11, 2000
Under the LCRMR, you:
• Must replace the portion of the lead service line that you own. Under the LCR you were
required to replace the portion of the line that you controlled, unless you could
demonstrate that you controlled less than the entire line.
• Must notify the owner (or owner's authorized agent) about the replacement, and offer to
replace the owner's portion of the line.
• Are not required to pay for replacing the privately-owned portion of the line.
• Are not required to replace the privately-owned portion of the line if precluded by law, or
where the owner chooses not to pay the cost of replacing the privately-owned portion.
In those instances where you do not replace the privately-owned portion of the line, you must:
• Notify all residents served by the line you are replacing, at least 45 days prior to partial
replacement. The State can allow you to provide less advanced notice if the line is being
replaced in conjunction with emergency repairs.
• Collect at your expense one representative service line sample for each replaced lead
service line within 72 hours of removing the line. Under the LCR, you were required to
collect a sample from each resident (if the residents) so desired) within 14 days of the
partial replacement.
• Report sample results to the building owner(s) and the residents) served by the partially
replaced line within 3 business days of receiving these results. You must notify residents
by mail. However, for multi-family dwellings you can post the notification in a
conspicuous common-use area of the building.
• Submit these monitoring results to the State within the first 10 days of the month
following that in which you receive the results. However, the LCRMR give States the
option to modify reporting requirements, so you need to check with your State to be sure
of your specific requirements.
Lead and Copper Monitoring Guidance 7 4 February 2002
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What Key Points Should I Remember About Lead Service Line
Monitoring and Reporting? (See §§141.84 & 141.86(b)(3))
Lead service line replacement is not required unless:
- You continue to exceed the lead action level in monitoring conducted after you install
corrosion control treatment or source water monitoring (whichever occurs later); or
- The State requires it because you have missed your deadline for installing corrosion
control treatment or source water treatment.
You are not required to replace an individual lead service line if the lead concentration of all
samples from the line is less than or equal to 0.015 mg/L. This line counts as a replaced
line.
If you do not replace the privately-owned portion of a lead service line (also known as partial
lead service line replacement), you must collect a sample that is representative of the water in
the service line within 72 hours of the replacement.
There are 3 methods for collecting a lead service line sample: 1) Flushing a specified volume;
2) Direct service line samples; and 3) Using temperature variation.
You can discontinue lead service line replacement and thus, any need to conduct lead service
line monitoring whenever your 90th percentile lead levels are at or below the lead action level
for 2, consecutive monitoring periods.
You must recommence lead service line replacement if you subsequently exceed the lead
action level during any monitoring period.
For more information on partial lead service line
replacement, refer to: Notification and Reporting
Requirements for Partial Lead Service Line Replacement under the
Lead and Copper Rule, April 2000,
EPA815-R-99-022
Lead and Copper Monitoring Guidance
75
February 2002
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APPENDICES
Appendix A: List of LCRMR Outreach Materials for Water
Systems
Appendix B: Definitions
Appendix C: Monitoring Timelines
Appendix D: Summary of Monitoring and Reporting Violations
Appendix E: Worksheets and Instructions
Lead and Copper Monitoring Guidance February 2002
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APPENDIX A
List of LCRMR Outreach Materials for Water Systems
Below is a comprehensive list of outreach materials that were developed to help you
understand and implement the minor revisions to the Lead and Copper Rule.
Guidance Documents
/ How to Determine Compliance with Optimal Water Quality Parameters as Revised by the Lead and Copper
Rule Minor Revisions, February 2001, EPA 815-R-99-019.
/ Lead and Copper Rule: Summary of Revisions, April 2000, EPA 815-R-99-020.
/ Monitoring Waivers under The Lead and Copper Rule Minor Revisions for Systems Serving 3,300 or Fewer
People, April 2000, EPA 815-R-99-021.
/ Notification and Reporting Requirements for Partial Lead Service Line Replacement under the Lead and Copper
Rule, April 2000, EPA 815-R-99-022.
/ Lead and Copper Rule: Minor Revisions Compared to the 1991 Rule, April 2000, EPA 816-
R-00-009
/ Lead in Drinking Water Regulation: Public Education Guidance (revised), EPA 816-R-02-010
Fact Sheets
/ Fact Sheet Lead and Copper Rule Minor Revisions, December 1999, EPA 815-F-99-010.
/ Fact Sheet for Public Water Systems that Serve 3,300 or Fewer Persons, February 2001,
EPA816-F-00-007.
/ Fact Sheet for Public Water Systems that Serve 3,301 to 50,000 Persons, February 2001,
EPA816-F-00-008.
/ Fact Sheet for Public Water Systems that Serve More Than 50,000 Persons, February
2001, EPA 816-F-00-009.
/ Fact Sheet for Tribal Water System Owners and Operators, February 2001, EPA 816-F-
00-010.
Training
/ Comprehensive Lead and Copper Rule Training, January 2001.
You can obtain any of these documents from the Safe Drinking
Water Hotline, or the Office of Ground Water and Drinking
Water web page at www.epa.gov/safewater/leadcop.html.
Lead and Copper Monitoring Guidance A-l February 2002
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Lead and Copper Monitoring Guidance B-1 February 2002
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APPENDIX B
Definitions
Term
Definition
^Note: New terms introduced under the LCRMR are shown in italics.
90th Percentile
Accelerated Reduced
Lead and Copper Tap
Monitoring
Accelerated Reduced
Water Quality
Parameter (WQP)
Monitoring
Action Level (AL)
(b)(l) system
(b)(2) system
(b)(3) system
Community Water
System (CWS)
Corrosion Control
Treatment
Cu
Daily values
Deemed to have
optimized
corrosion control
Entry Point
Exceedance
The highest concentration of lead or copper in tap water that is exceeded by 10 percent of
the sites sampled during a monitoring period. This value is compared to the lead or copper
action level (AL) to determine whether an AL has been exceeded.
Allows water systems with very low levels of lead and copper in their tap water to be placed on a triennial
monitor schedule after only 2, consecutive, 6-month monitoring periods. 90* percentile lead level must be <
0. 005 mg/L, and 90* percentile copper levels must be < 0. 65 mg/L.
Allows water systems to proceed more quickly to a triennial WQP monitoring schedule. Systems must meet the
requirement for accelerated reduced lead and copper levels and be in compliance with their optimal water quality
parameter specifications for 2, consecutive monitoring periods (either 6-month or annual periods).
The concentration of lead or copper in tap water which determines whether a system may be
required to install corrosion control treatment, collect WQP samples, collect lead and copper
source water samples, replace lead service lines, and/or deliver public education about lead.
The action level for lead is 0.015 mg/L or 15 ppb. The action level for copper is 1.3 mg/L
or 1300 ppb.
A small or medium system that is at or below both action levels during 2, consecutive, 6-
month rounds of lead and copper tap monitoring.
A systems that is deemed to have optimized corrosion control after demonstrating that it has
completed corrosion control treatment steps prior to 12/7/92 that are equivalent to those
described in §141.81(b)(2) of the regulation.
A system that is deemed to have optimized corrosion control by demonstrating that it has
minimal levels of corrosion entering the distribution system based on lead and copper source
and tap water samples.
A public water system that services at least 15 service connections used by year-round
residents or regularly serves at least 25 year-round residents.
A treatment designed to reduce the dissolving of lead and/or copper in plumbing materials
during water delivery to consumers.
The chemical symbol for copper.
The sample results of WQPs. They are calculated for each WQP at each sampling location. They are based on
the sampling frequency for that WQP and sampling point.
Systems that are delivering minimally corrosive water (i.e., (b)(l), (b)(2), or (b)(3) systems).
These systems are subject to fewer monitoring and treatment technique requirements.
Refers to points of entry to the drinking water distribution system from which samples will be
representative of each source of supply after treatment.
Occurs when the 90th percentile lead or copper sample is above its respective action level.
Lead and Copper Monitoring Guidance
B-2
February 2002
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Term
Definition
^Note: New terms introduced under the LCRMR are shown in italics.
Excursion
First-Draw Sample
Follow-up
Monitoring
Full Waiver
GUDI
Initial Tap
Monitoring
Large Water
System
LCR
LCRMR
Lead Service Line
(LSL)
Materials Survey
Maximum
Permissible Levels
(MPLs)
Medium Water
System
Method Detection
Limit (MDL)
Monitoring Waiver
Refers to a "daily value " for a WQP at a sampling location that is below the minimum optimal water quality
parameter (OWQP) value or outside the range of values designated by the State.
Refers to a 1-liter sample of tap water that has been standing motionless in plumbing pipes at
least 6 hours and is collected without flushing the tap.
Refers to the lead and copper tap water and WQP (tap and entry point) monitoring that takes
place after corrosion control treatment is in place and before the State determines OWQP
ranges or minimums. The samples are taken during the 2, consecutive 6-month monitoring
periods immediately following the installation of corrosion control treatment.
This waiver allows a small system to collect both lead and copper tap samples at a frequency of once every 9
years at a reduced number of sites. To receive this waiver a system must meet the monitoring and materials
criteria for both lead and copper.
An acronym for systems that have been determined to be ground water under the direct
influence of surface water.
For systems serving 50,000 or fewer people, refers to the first set(s) of lead and copper tap
water samples that are taken at 6-month intervals until which point the system exceeds either
action level, or is at or below both action levels for 2, consecutive, 6-month monitoring
periods. For systems serving more than 50,000 people, refers to tap samples collected during
the first 2, consecutive, 6-month periods of monitoring.
A water system that serves more than 50,000 people.
An acronym for the Lead and Copper Rule. Also referred to in this document as the 1991
Rule.
The acronym for the Lead and Copper Rule Minor Revisions.
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.
Refers to a system's initial evaluation of materials that are contained in its pipes and
distribution system in order to identify sites with a high risk of lead and copper occurrence.
The highest allowable lead and copper concentrations after treatment for source water that is
entering a water system's distribution system. These levels are determined by the State after
it has reviewed source water samples from before and after a system has installed source
water treatment, and are set to reflect lead and copper levels from a properly operated and
maintained treatment system.
A water system that serves 3,301 to 50,000 people.
The minimum concentration of a substance that can be measured and reported with 99%
confidence that the analyte concentration is greater than zero.
This waiver allows a small system (those serving 3,300 or fewer people) to collect lead and copper tap samples
at a frequency of once every 9 years at a reduced number of sites. To receive this waiver a system must meet the
monitoring and materials criteria for lead and copper.
Lead and Copper Monitoring Guidance
B-3
February 2002
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Term
Definition
^Note: New terms introduced under the LCRMR are shown in italics.
Non-transient,
Non-Community
Water System
(NTNCWSs)
Optimal Corrosion
Control Treatment
(OCCT)
Optimal Water
Quality Parameters
(OWQPs)
Partial Wavier
Pb
Practical
Quantitation Level
(PQL)
Public Water
System (PWS)
Reduced
Monitoring
Representative Site
Service Line
Sample
Single Family
Residences (SFRs)
Single Family
Structure
Small Water
System
A public water system that is not a community water system and regularly serves at least 25 of
the same persons during a minimum of 6 months of each year.
The corrosion control treatment that minimizes the lead and copper concentrations at users'
taps while ensuring that the treatment does not cause the water system to violate any national
primary drinking water regulations.
Specific ranges or minimums that are determined by the State for each relevant WQP.
OWQPs represent the conditions under which systems must operate their corrosion control
treatment to most effectively minimize the lead and copper concentrations at their users' taps.
This type of waiver may be granted if a small system meets the materials and monitoring criteria for either lead
or copper, but not both. It allows the system to monitor once every 9 years at a reduced number of sites for the
contaminant for which it receives the waiver. The State may elect not to grant partial waivers.
The chemical symbol for lead.
The lowest concentration of an analyte that can be reliably measured within specified limits
of precision and accuracy during routine laboratory operating conditions. For lead, the PQL
equals 0.005 mg/L; for copper it equals 0.050 mg/L.
A system that provides piped water for human consumption, which has at least 15 service
connections or regularly serves an average of at least 25 individuals daily for at least 60 days
of the year. It includes: 1) the collection, treatment, storage, and distribution facilities
operated and used by the system, and 2) any collection or pretreatment storage facilities not
under the control of the system, but which it primarily uses.
Refers to the sampling frequency and number of monitoring sites from which a system must
collect lead and copper tap samples or WQP distribution samples after it has met the criteria
that is specified under §141.86(d)(4) or §141.97(e), respectively. After meeting any one of
these criteria, systems are allowed to sample from a reduced number of monitoring sites
and/or at a reduced frequency.
A sampling site that is connected to plumbing materials which are similar to materials used at other sites in the
water system.
A 1-liter sample of water, collected in accordance with §141.86(b)(3), that has been standing
for at least 6 hours in a lead service line.
Single family residence structures which can include for purposes of identifying targeted
sampling locations: (1) Non-Residential structures; and (2) Multi-Family Residences (MFRs) if
they constitute more than 20% of the service connections within the system's service area.
A building constructed as a single-family residence that is currently used as either a residence
or a place of business.
A water system that serves 25 to 3,300 people.
Lead and Copper Monitoring Guidance
B-4
February 2002
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Term
Definition
^Note: New terms introduced under the LCRMR are shown in italics.
Solder
Source Water
Sample
Source Water
Treatment
Special-Case CWS
Standard
Monitoring
Tier 1 Site
Tier 2 Site
Tier 3 Site
Water Distribution
System
Water Quality
Parameters (WQPs)
A metallic compound used to seal joints in plumbing. Until the lead ban took effect, most
solder contained about 50 percent lead.
A sample collected at entry point(s) to the distribution system representative of each source of
supply after treatment.
Treatment designed to remove lead and/or copper from the source of the water supply.
A facility, such as a prison or a hospital, where the population served is not capable of or is prevented from
making improvements to plumbing or installing point of use treatment devices; and the water system supplies
water as part of the cost of services provided and does not separately charge for water consumption. For certain
monitoring and public education requirements, these systems may be treated like an NTNCWS.
Refers to the monitoring frequency and number of monitoring sites from which a system
must collect samples before a system has qualified to go to a reduced monitoring schedule.
Standard monitoring is conducted at 6-month intervals.
For a CWS, it is a single family structure that contains lead pipes, or copper pipes with lead
solder installed after 1982, and/or is served by lead service lines. For an NTNCWS, it is a
building that contains copper pipes with lead solder installed after 1982, and/or is served by
lead service lines.
For a CWS, it is a building and multiple-family residence that contains lead pipes, or copper
pipes with lead solder installed after 1982, and/or is served by lead service lines. For an
NTNCWS, it is a building that contains copper pipes with lead solder installed before 1983.
Applies only to a CWS, and is a single family structures that contain copper pipes with lead
solder installed before 1983.
Refers to the piping, devices, and related fittings that are used to carry a system's drinking
water to its users. It includes the treatment plant, distribution system, water meter, water
meter setting equipment, piping and plumbing that conveys drinking water, and individual
fixtures.
Used to help systems and States determine what levels of corrosion control treatment would
work best for the system and whether this treatment is being properly operated and
maintained over time. WQPs include: pH, temperature, conductivity, alkalinity, calcium,
orthophosphate, and silica.
Lead and Copper Monitoring Guidance
B-5
February 2002
-------
APPENDIX C
Monitoring Timelines
Lead and Copper Tap and WQP Monitoring Schedule for Large Water
Systems (> 50,000)
This timeline illustrates the schedule for corrosion control treatment (CCT), lead and copper
tap monitoring, and WQP monitoring for (b)(3) and non-(b)(3) large systems.
Lead and Copper Tap Schedule for Medium Water Systems (3,301 -
50,000) that Do Not Exceed An Action Level
This timeline shows the lead and copper monitoring requirements for medium water systems
that do not exceed an action level.
Lead and Copper Tap and WQP Monitoring Schedule for Medium
Water Systems (3,301 - 50,000) that Exceed An Action Level (No Longer
Exceed After Installing Treatment)
This timeline illustrates the CCT and monitoring schedule for medium systems that no longer
exceed an action level after treatment.
Lead and Copper Tap and WQP Monitoring Schedule for Medium
Water Systems (3,301 - 50,000) that Exceed An Action Level (Continue
to Exceed After Installing Treatment)
This timeline shows the CCT and monitoring schedule for medium water systems that
continue to exceed an action level after CCT.
Lead and Copper Tap Schedule for Small Water Systems (<, 3,300) that
Do Not Exceed An Action Level
This timeline shows the lead and copper monitoring requirements for small water systems that
do not exceed an action level.
Lead and Copper Tap and WQP Monitoring Schedule for Small Water
Systems (< 3,300) that Exceed An Action Level (No Longer Exceed After
Installing Treatment)
This timeline illustrates the CCT and monitoring schedule for small systems that no longer
exceed an action level after treatment.
Lead and Copper Tap and WQP Monitoring Schedule for Small Water
Systems (< 3,300) that Exceed An Action Level (Continue to Exceed
After Installing Treatment)
This timeline illustrates the CCT and monitoring schedule for small systems that continue to
exceed an action level after installing CCT.
Lead and Copper Monitoring Guidance C-l February 2002
-------
Lead and Copper Tap and WQP Monitoring Schedule for Large Water Systems (> 50,000)
Non-(b)(3)
Systems
f \
( Pb/Cu )
X^ ^N.
f WOP )
^\^^J
(b)(3) Systems
( Pb/Cu )
\ /
^^
I WQP j
1992
bfl
G
0
3
0
b£
G
O
o
3
G
Momtori
;•£
bfl
0
G
0
-
bfl
G
0
G
0
bfl
G
•G
o
G
o
s
s
Momtori
;-§
0
S
0
^
"^
'£
1993
1994
Conduct
Studies
U
U
OJ
O-i
CO
CO
1995 1996
1997
Q.M
Folio w-i.
momtori
%s
» °
S'S
0 0
fc g
&G°
Folio w-i
momtori
%g
'? °
S'S
II
1998
0
o
-M
ul
CO
u
Standar
u
u
c
1999
-n
Standar
u
1
CO
2000
Reduce
Annua
-V 3
u G
-3.2
iy
"V a
^ 1
2001
Reduce
Annua
ul
IS
^y
"V a
^ 1
2002
2003
2004 2005 2006 2007 2008
Reduced Triennial
H
1991 LCR was unclear on the system's continuing
monitoring requirements
One round of monitoring is
conducted between 9/1/97 -
9/30/00
(LCRMR requirement)
1991 LCR was unclear on the system's continuing
monitoring requirements
H
•o-
II
c^^
Reduced Triennial
Reduced Triennial
Reduced
Triennial
7/1/07-
6/30/09
Reduced
Triennial
7/1/07-
6/30/09
Reduced Triennial
Reduced Triennial
Reduced Triennial 10/1/06 —
9/30/09
WQP monitoring is no longer required
Notes:
1. If a water system exceeded the lead or copper action level, it must conduct initial source water monitoring within 6 months of the exceedance (Timeline for source water monitoring to be developed.)
2. The diagram assumes that (b)(3) systems meet these criteria based on initial lead and copper tap and source water samples.
3. Reduced lead and copper tap monitoring and WQP tap monitoring (shown in the shaded boxes) is conducted at the reduced number of sites.
4. Depending on when and if the State adopts the accelerated reduced lead and copper tap provision and the system meets the criteria of this provision, it can omit some or all of the annual monitoring rounds
and proceed directly to triennial monitoring.
5. Similarly, depending on when and if the State adopts the accelerated reduced WQP tap monitoring provisions and if a non-(b)(3) system meets these provisions, it can omit some or all of the annual WQP tap
monitoring and proceed directly to triennial monitoring.
Lead and Copper Monitoring Guidance
C-2
February 2002
-------
Lead and Copper Tap Schedule for Medium Water Systems (3,301 - 50,000)
that Do Not Exceed An Action Level
Systems Serving
3,301 - 50,000
1992
1993
1994
Reduced
A i
/innuai
1995
Reduced
A i
/innuai
1996
1997
1998
Reduced irienmal
1999
2000
2001
Reduced 1 nennial
2002
2003
2004
Reduced 1 nennial
2005
2006
2007
2008
Reduced 1 nennial
Reduced
Triennial
7/1/07-
6/30/09
WQP monitoring does not apply to these systems
Notes:
1. Corrosion control treatment is not required for systems serving 50,000 and fewer people that remain at or below both action levels.
2. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites.
Lead and Copper Monitoring Guidance
C-3
February 2002
-------
Lead and Copper Tap and WQP Monitoring Schedule for Medium Water Systems (3,301 - 50,000)
that Exceed An Action Level
(No Longer Exceed After Installing Treatment)
Systems
Conducting
Studies
x- \
( Pb/Cu )
\^^ ,/
/ \
f \
| I WQP J
\< J
Systems Not
Conducting
Qi-i A '
otudies
X" "X
I Pb/Cu j
V J
s
/" N\
( WQP )
\y
1992
bfl
C
0
'S
0
'S
1 '
w)
G
O
'S
o
S
'-0
'S
1993
13
13
OJ
h^2
13
3
CO
-g
u
OJ
Q
-M
CO
1994
1995
Conduct
Treatment
Study
u
u
OJ
u
O-i
CO
-M
CO
1996
1997
Install Treatment
1998
-( ^i
Follow-i
monitor]
^c?
^ 0
S'S
0 0
fc g
-( ^i
Follow-i
monitor]
g-^
^ 8
~5 o
fc g
1999
,
&
^
o
3o
-M
CO
13
13
c
CO
2000 2001 2002 2003 2004 2005 2006 2007 2008
13
-n Reduced Reduced „, in--- -1 T-,1 1 T-- • -1
^ Annual Annual Reduced 1 nennial Reduced 1 nennial
-d
CO
WQP monitoring is no longer required
d
•3
o
'S
o
13
'S
bfl
c
0
'S
0
'S
State
Specifies
corrosion
Contro
Treatment
Tnc
inSLa.ii i icauiiciiL
§^
s-a
Follow-up
monitoring
0,^
^1
"o o
fc g
Follow-up
monitoring
C^
cy
o
OJ
OJ
-M
CO
-u
T>
-d
13
13
C
-d
CO
Reduced
Annual
Reduced
Triennial
Annual Reduced Triennial Reduced Triennial 1/1/07 —
12/31/09
WQP monitoring is no longer required
Notes:
1. This diagram assumes that the system exceeded the lead or copper action level in the first round of initial monitoring and no longer exceeds after the installation of corrosion control treatment.
2. Initial source water monitoring is due within 6 months of the lead or copper exceedance (Timeline for source water monitoring to be developed.)
3. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites. Depending on when and if the State adopts the accelerated reduced lead and copper tap
monitoring provisions and the system meets these criteria, it can omit some of the annual monitoring rounds and proceed directly to triennial tap monitoring.
Lead and Copper Monitoring Guidance
C-4
February 2002
-------
Lead and Copper Tap and WQP Monitoring Schedule for Medium Water Systems (3,301 - 50,000)
that Exceed An Action Level
(Continue to Exceed After Installing Treatment)
Systems
Conducting
Studies
Systems Not
Conducting
Studies
1992
b£
C
•G
O
'3
o
s
'S
1 '
be
c
o
'£
o
^
•-£
'S
1993
13
OJ
^
"d"1
B
CO
OJ
u
OJ
Q
-M
CO
1994
1995
Conduct
Treatment
Study
be
G
o
o
s
•g
"
M
C
0
'S
0
'S
State
Specifies
corrosion
Contro
Treatment
Tnc
H
u
OJ
Lfl
U
OJ
-M
-M
CO
1996
1997
Install Treatment
1998
. .
O-i g
Follow-t
mo niton:
a^
il
"o o
[X, g
. .
O-i 2]
Follow-t
mo niton:
g,_g>
& o
_O • g
"o o
IX g
1999
a
^
O
£3
OJ
-M
CO
13
|
CO
13
rt
13
C
rt
2000
n
Standan
"^
13
-M
2001
Reduced
Annual
,
a; G
u C
13. JH
M
, ,
"SB
u C
13. JH
So
2002 2003
Reduced
Annual
13 3
a; C
u ^
c^ 'G
M
13 3
-§ ^
c^ 'G
w
2004
2005 2006
Reduced Triennial
13 _
rt
II
inSLa.ii i ica.Liiiciii.
bfl
£ 0
^'a
0 0
G
O-i ^
Folio w-i
momtori
bfl
7ollow-i
10 niton
I-M g
O-I ^
Folio w-i
momtori
&
o
"OJ
OJ
-d
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13
Standar
-^
13
C
-M
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13
Standar
13
Standar
Reduced
Annual
_^
^
13 3
Reduce
semi-ann
_
13 3
Reduce
semi-ann
Reduced
Annual
^
^
13 3
Reduce
semi-ann
_
13 3
Reduce
semi-ann
13 _
rt
II
Reduced Triennial
13 _
OJ (^
u 3
13 _ 13
u 3 u
"S G "5
C
13
1
P^
13
C
2007 2008
Reduced Triennial
7/1/06-6/30/09
Reduced Triennial
Reduced Triennial
Reduced Triennial
Reduced
Triennial
1/1/07-
12/31/09
Triennial
1/1/07-
12/31/09
Notes:
1. This diagram assumes that the system exceeded the lead or copper action level in the first round of initial monitoring.
2. This diagram also assumes that the system continued to exceed an action level after installing treatment and qualifies for reduced lead and copper tap and WQP tap monitoring because it is in
compliance with its OWQPs.
3. Initial source water monitoring is due within 6 months of the lead or copper exceedance (Timeline for source water monitoring to be developed,)
4. Reduced lead and copper tap monitoring and WQP tap monitoring (shown in the shaded boxes) is conducted at the reduced number of sites.
Lead and Copper Monitoring Guidance
C-5
February 2002
-------
Lead and Copper Tap Schedule for Small Water Systems (• »3,300)
that Do Not Exceed An Action Level
Systems
Serving 25 -
3,300
1992
1993
1994
1995
Reduced
Annual
1996
Reduced
Annual
1997
1998
1999
Reduced Triennial
2000
2001
2002
Reduced Triennial
2003
2004
2005
Reduced Triennial
2006
2007
2008
Reduced Triennial
WQP monitoring does not apply to these systems
Notes:
1. Corrosion control treatment is not required for systems serving 25 — 50,000 people that remain at or below both action levels.
2. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites.
Lead and Copper Monitoring Guidance
C-6
February 2002
-------
Lead and Copper Tap and WQP Monitoring Schedule for Medium Water Systems (• "3,300) that
Exceed An Action Level
(No Longer Exceed After Installing Treatment)
Systems
Conducting
Studies
I Pb/Cu J
\. ^/
S ,.
I \
| 1 WQP I
V )
Systems Not
Conducting
Qi-i A '
otudies
t^^^\
1 Pb/Cu j
\ /
\^ S
S> "N.
/ \
/ \
1 WQP J
\^ ^/
1992 1993
bO
•G
o
'S
o
S
•g
1 — '
bO
G
0
1
. £H
'G
1994
T)
OJ
OJ
h3
-o"
3
c^)
OJ
' u
Q
OJ
s
CO
1995
1996
Conduct
Treatment
Study
U
OJ
u
OJ
-M
rt
CO
1997
1998
Install Treatment
1999
Follow-u
momtorir
3
||
"o o
fc a
Follow-u
momtorir
3
E* S
"o o
2000 2001 2002 2003 2004 2005 2006 2007 2008
a
^
o
S
CO
c c
CO CO
Reduced
Annual
Reduced Reduced Triennial
&„„,,„] Reduced Triennial
7/1/06-6/30/09
WQP monitoring is no longer required
bO
C
0
0
^
. £3
,-S
bO
C
' d
o
o
^
1
State Specifies
Corrosion
Control
Treatment
Install Treatment
3
& o
"o o
fc g
bO
3 ^
& 2
"o o
fc 6
3
E* S
_o • ^
"o o
bO
S^ G
& 2
"o o
fc g
P^
cv
o
OJ
-S
s
CO
"S
1
4-J
CO
^
C
4-J
CO
Reduced
Annual
Reduced
Annual
Reduced Triennial Reduced Tnennia
WQP monitoring is no longer required
Notes:
1. This diagram assumes that the system exceeded the lead or copper action level in the first round of initial monitoring and no longer exceeds after installing corrosion control treatment.
2. Initial source water monitoring is due within 6 months of the lead or copper exceedance (Timeline for source water monitoring to be developed,)
3. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites. Depending on when and if the State adopts the accelerated reduced lead and copper tap
monitoring provisions and the system meets these criteria, the system can omit some of the annual monitoring rounds and proceed directly to triennial tap monitoring.
'Lead and Copper Monitoring Guidance
C-7
February 2002
-------
Lead and Copper Tap and WQP Monitoring Schedule for Medium Water Systems (• "3,300) that
Exceed An Action Level
(Continue to Exceed After Installing Treatment)
Systems
Studies
[ Pb/Cu J
/^ ^\
/ \
| I WQP J
\^ J
Systems Not
Conducting
^^^^
/* \
I Pb/Cu J
\y
/^^
( WQP J
1992
1993
d
Initial Momtori
bo
c
•G
o
o
^
3
1994
CO
V
Q
-M
1995
1996
Conduct
Treatment
Study
esCCT
u
O-i
CO
rt
CO
1997
1998
Install Treatment
1999
Follow-up
monitoring
,
3 ^
0 0
fc g
Follow-up
monitoring
,
¥-G
J.-§
0 0
IX g
2000
&
-d
CO
Standard
13
13
C
CO
2001
Standard
13
13
C
•M
CO
2002
Reduced
Annual
— H
c
g
— H
g
rt
G
2003
Reduced
Annual
— H
c
g
— H
g
rt
G
2004
2005
2006 2007 2008
Reduced Triennial
Annual
Annual
Annual
Reduced Triennial
7/1/06-6/30/09
Triennial
7/1/06 -6/30/09
c
o
3
o
s
c
al Monitor
3
State Specifies
Corrosion
Control
Treatment
3 ^
Follow-
monitor
^ollow-up
nomtoring
e^^
Follow-
monitor
^ollow-up
nomtoring
cy
o
OJ
-M
CO
13
13
C
-M
CO
Standard
13
13
C
-M
CO
Standard
Reduced
Annual
emi-annua
emi-annua
Reduced
Annual
emi-annua
emi-annua
Reduced Triennial
Annual
Annual
Annual
Reduced Trienma
Triennial
Notes:
1. This diagram assumes that the system exceeded the lead or copper action level in the first round of initial monitoring.
2. This diagram also assumes that the system continued to exceed an action level after installing treatment and qualifies for reduced lead and copper tap and WQP tap monitoring because the system it is in
compliance with its OWQPs.
3. Initial source water monitoring is due within 6 months of the lead or copper exceedance (Timeline for source water monitoring to be developed.)
4. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites.
'Lead and Copper Monitoring Guidance
February 2002
-------
APPENDIX D
Summary of Monitoring and Reporting Violations
Monitoring and Reporting (M/R) violations fall into four major categories as described below.
1. M/R for lead and copper at customers' taps
You are in violation if you do not meet all of the following monitoring and reporting requirements
within the time frame specified by the rule:
Use appropriate sampling procedures in accordance with §§141.86 (a) and (b);
Collect the required number of samples during the specified time frame in accordance with
§§141.86(c)and(d);
Ensure samples are analyzed properly in accordance with §141.89(a);
Submit all required monitoring information on time in accordance with §141.90(a); or
Report a change in treatment, or an addition of a new source, within 60 days or within the time
frame specified by the State, if you are on reduced monitoring, have a waiver, or are a (b)(3)
system, as required by §141.90(a)(3).
Depending on whether the State adopts the less stringent provisions of the LCRMR into its revised
drinking water regulation, you may also be in violation if you do not meet the following requirements
within the timeframe specified by the rule:
Meet replacement sample requirements for invalidated samples as described in §141.86(f)(4)
where these samples are needed to meet minimum sampling requirements;
Meet the conditions of your monitoring waivers in §141.86(g) or provide the required
information in §§141.90(a)(4)(ii)-(iv);
Provide sample information needed for your State to perform the 90th percentile calculation as
outlined in §141.90(h);
Collect non-first draw samples that did not meet the criteria in §141.86(b)(5); or
Meet the monitoring deadline for transitioning to an alternate period (i.e., months other than
June through September) for collecting reduced lead and copper tap samples, as specified in
§141.86(d)(4)(iv)(B).
2. M/R for WQPs at entry points and taps in the distribution system
You are in violation if you do not meet all of the following monitoring and reporting requirements
within the time frame specified by the rule:
Use appropriate sampling procedures in accordance with §§141.87(a)(l);
Collect the required number and type of samples in accordance with §§141.87(a)(2),(b)-(e);
Ensure samples are analyzed properly in accordance with §141.89(a);
Submit all required monitoring information on time in accordance with §141.90(a)(vi)-(viii);
Meet the State-approved sampling plan for collecting WQPs at representative entry point
locations in accordance with §§ 141.87 (c) (3) (this criterion would only apply if you are a ground water system
and your State's regulation allows you to limit entry point WQP monitoring to representative sites).
J V J J I *- V I '
5. M/R for WQPs at entry points and taps in the distribution system (continued)
Lead and Copper Monitoring Guidance D-l February 2002
-------
Summary of Monitoring and Reporting Violations
Monitoring and Reporting (M/R) violations fall into four major categories as described below.
In addition, you are in violation if you do not meet your OWQP ranges or minimums set by the State
as follows:
If your State assesses compliance using the 1991 LCR procedure, you are out of compliance if
the results of any WQP sample, or the average of the original sample and a confirmation
sample, does not meet the State-designated OWQP ranges or minimums.
If your State assesses compliance using the LCRMR, you are in violation of your requirements
if you have OWQP excursions for more than 9 days in a 6-month compliance period.
3. M/R for lead and copper in source water
You are in violation if you do not meet all of the following monitoring and reporting requirements
within the time frame specified by the rule:
Use appropriate sampling procedures (see §§141.88(a)(l) and (2));
Collect the required number of source water samples (see §§141.88(a)(l) - (e));
Ensure samples are analyzed properly (see §141.89(a)); or
Submit all required sampling information on time (see §141.90(b)).
In addition, you are in violation if you do not meet your State-designated or approved MPLs (see
§141.8 8 (a) (2)) (Note: If you are above either MPL, you can take a confirmation sample within 2 weeks of the original
sample, if allowed by the State. The results of the original and confirmation samples are averaged to determine whether you are
in compliance with your MPLs)
4. M/R for lead and other requirements associated with lead service line
replacement
You are in violation if you do not:
Replace the required number of lead service lines by the annual deadline (i.e., at least 7%
annually) (see §§141.84 (a) & (b)); or
Report the required lead service line information on time that demonstrates that you replaced
the required number of lead service lines by the annual deadline (see §141.90(e))
You are also in violation if you do not meet the following partial lead service line replacement
requirements (only applicable if you do not replace the entire lead service line) (see §141.84(d)):
Provide notice and guidance to residents at least 45 days before lead service line replacement
begins (unless the State allows a shorter notification period);
Collect a tap sample within 72 hours of completing the partial lead service line replacement;
Mail and/or post results of the analysis to the owner and residents within 3 days of receipt of
the results; or
Report information that the State requires to assess whether you met your partial lead service
line replacement monitoring and notification requirements.
\
Lead and Copper Monitoring Guidance D-l February 2002
-------
APPENDIX E
Worksheet and Instructions
Worksheet 1: Materials Survey Investigation Results
This worksheet can be used to record information about sampling sites based on your materials
investigation (e.g., presence of lead service lines (LSLs), contact information).
Worksheet 2: Materials Survey Results by Number of Service Connections for
each Plumbing Materials Type
This worksheet allows you to record the number of service connections by type of structure (i.e., single
or multi-family residence, or public/commercial buildings) and the type of interior and distribution
system plumbing materials (e.g., copper pipe with lead solder, LSL).
Worksheet 3: Summary of Material Survey Results
This worksheet allows you to tally the number of service connections by type of structure and type of
plumbing material.
Suggested Directions for Homeowner Tap Sample Collection Procedures
This page provides suggested language that you can use when instructing homeowners on the proper
procedure for collecting lead and copper tap samples.
Form 141-A: Sample Site Identification and Certification
This form is used to identify: the number of sites that meet the tiering criteria; a certification that each
sample was collecting using proper sampling procedures; your 90th percentile calculations and the
number of samples upon which these levels are based; the number of WQPs sample collected vs. the
number of required samples; and an explanation of any changes in sampling locations.
Amended Form 141-A: Sample Site Identification and Certification
This version of Forml41-A deletes those certifications which are no longer required under the LCRMR.
However, you must first check with your State before using this form.
Form 141-B: Request for Reduced Lead and Copper Tap Monitoring
This form can be used to request permission from the State to collect lead and copper tap samples at a
reduced number and frequency based on your continued compliance with your OWQPs. The LCRMR
no longer require you to submit a formal request for reduced monitoring; however, first check with your
State to determine if this requirement still applies.
Form 141-C: Optimal Corrosion Control Treatment Recommendation
This 2-page form has several applications. It can be used to: 1) document the results of monitoring used
to evaluate various corrosion control treatment (CCT) options and to provide your study
recommendation, 2) certify that you have properly installed CCT, or 3) request a modification to your
State's decision regarding CCT and/or OWQPs.
Form 141-D: Source Water Monitoring and Treatment
This form is similar to Form 141-C. It can be used to: 1) document your initial source water monitoring
and source water treatment (SOWT) recommendation; 2) certify that you have properly installed
SOWT; or 3) request a modification to the State's decision regarding SOWT or MPLs.
Lead and Copper Monitoring Guidance E- 2 February 2002
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WORKSHEET #3
SUMMARY OF MATERIALS SURVEY RESULTS
PWS ID NUMBER
POPULATION SERVED BY PWS
Plumbing Material
Interior Plumbing
Lead Pipe
Copper Pipe With Lead Solder >19824
Copper Pipe With Lead Solder <19835
Service Lines
LSLs
Entire Line
Partial Line
Total Available Sites
Type of Structure
SFR1
MFR2
BLDG3
Number of Service Connections
1 SFR - single family residence
2 MFR - multi-family residence
3 BLDG - public or commercials buildings
4 Refers to buildings that contain copper pipes with lead solder installed after 1982.
5 Refers to buildings that contain copper pipes with lead solder installed before 1983.
Lead and Copper Monitoring Guidance
E-5
February 2002
-------
Suggested Directions for
Homeowner Tap Sample Collection Procedures
These samples are being collected to determine the lead and copper levels in your tap water. This sampling effort
is required by the U.S. Environmental Protection Agency and your State, and is being accomplished through the
cooperation of homeowners and residents.
Collect samples from a tap that has not been used for a minimum of 6 hours. Because of this requirement, the
best time to collect samples is either early in the morning or in the evening upon returning from work. Be sure to
use taps that have been in general use by your household for the past few months. 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. There must be a minimum of 6 hours during which there is no water used from the tap the sample is taken
from and any taps adjacent or close to that tap. 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. If you have water softeners on your
kitchen taps, collect your sample from the bathroom tap that is not attached to a water softener, if possible.
Place the opened sample bottle 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. ALSO IF YOUR SAMPLE WAS COLLECTED FROM A TAP WITH A WATER
SOFTENER, NOTE THIS AS WELL.
6. Place the sample kit outside of the residence in the location of the kit's delivery so that department staff
may pick up the sample kit.
7. Results from this monitoring effort will be provided to participating customers when reports are generated
for the State. However, if excessive lead and/or copper levels are found, 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.
Signature Date
Lead and Copper Monitoring Guidance E-6 February 2002
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Form 141-A
Page 1 of3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
System's Name:
Address:
System Type: D CWS
D NTNCWS
Number of People Served:
System ID:_
Contact
D >100,000
D 10,001 to 100,000
D 3,301 to 10,000
Telephone number:
D 501 to 3,300
D 101 to 500
D <100
CERTIFICATION OF SAMPLING SITES
LEAD SOLDER SITES
# of single-family structures with copper pipes with lead solder installed
after 1982 or lead pipes and/or lead service lines (Tier 1)
# of multi-family structures with copper pipes with lead solder installed
after 1982 or lead pipes and/or lead service lines (Tier 1)
# of buildings containing copper pipes with lead solder installed
after 1982 or lead pipes and/or lead service lines (Tier 2)
# of sites that contain copper pipes with lead solder installed before 1983
(Tier 3)
# of sites that do not meet Tier 1, 2, or 3 criteria (to be used only if other
conditions have been exhausted)
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)
Lead and Copper Monitoring Guidance
E-7
February 2002
-------
Lead and Copper Monitoring Guidance E-8 February 2002
-------
Form 141-A (continued)
Page 2 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
CERTIFICATION OF SAMPLING SITES
LEAD SERVICE LINE SITES
# of samples required to be drawn from lead service
line sites
# of samples actually drawn from lead service line sites
Difference (explain differences other than zero)
The following sources have been explored to determine the number of lead service lines in the
distribution system.
Distribution system maps and record drawings
Information collected for the presence of lead and copper as required under §141.42 of the Code
of Federal Regulations
Capital improvement plans and/or master plans for distribution system development
Current and historical standard operating procedures and/or operation and maintenance (O&M)
manuals for the type of materials used for service connections
Utility records including meter installation records, customer complaint investigations and all
historical documentation which indicate and/or confirm the location of lead service connections
Existing water quality data for indications of 'troubled areas'
Other Sources Which PWS Utilized
Interviews with senior personnel
Conduct service line sampling where lead service lines are suspected to exist but their presence is
not confirmed
Review of permit files
Community survey
Review of USGS maps and records
Interviews with pipe suppliers, contractors, and/or developers
Explanation of fewer than 50% LSL sites identified (attach additional pages if
necessary):
CERTIFICATION OF COLLECTION METHODS
Lead and Copper Monitoring Guidance
E-9
February 2002
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SAMPLE SITE IDENTIFICATION AND CERTIFICATION
I certify that:
• Each first draw tap sample for lead and copper is 1 liter in volume and has stood motionless in the
plumbing system of each sampling site for at least 6 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 or in the alternate period specified by
the State.
• 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.
Form 141-A (continued)
Page 3 of 3
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
RESULTS OF MONITORING
THE RESULTS OF LEAD AND COPPER TAP WATER SAMPLES MUST BE ATTACHED TO
THIS DOCUMENT
# of samples required
90th Percentile Pb
# of samples submitted
90th Percentile Cu
Note: If the State has informed you that it will calculate your 9ffh percentile levels, you do not need to
submit the 90th percentile calculations. However, you must still provide your sample results to the State
by the deadline that they have specified.
THE RESULTS OF WATER QUALITY PARAMETER SAMPLES MUST BE ATTACHED TO THIS
DOCUMENT
# of WQP tap samples required
# of entry point samples required
# of WQP tap samples submitted
# of entry point samples submitted
CHANGE IN SAMPLING SITES
Lead and Copper Monitoring Guidance
E-10
February 2002
-------
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
Original site address:
New site address:
Distance between sites (approximately):
Targeting Criteria: NEW:
OLD:
Reason for change (attach additional pages if
necessary)
SIGNATURE
PRINTED NAME
TITLE
DATE
%> Note: The LCRMR no longer require you to complete the certification of sampling sites, or
certification of collection methods. A modified version of Form 141-A is provided below. This
revised form deletes those certifications that are no longer required under the LCRMR. Please
check with your State before using the amended Form 141-A.
Amended Form 141-A Page 1 of 2
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
System's Name:
Address:
System Type: D CWS
D NTNCWS
Number of People Served:
Lead and Copper Monitoring Guidance
E-ll
February 2002
-------
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
System ID #:
Contact Person:
D >100,000
n 10,001 to
100,000
D 3,301 to 10,000
Telephone number:
D 501 to 3,300
D 101 to 500
D ^100
RESULTS OF MONITORING
THE RESULTS OF LEAD AND COPPER TAP WATER SAMPLES MUST BE ATTACHED TO
THIS DOCUMENT
# of samples required
90th Percentile Pb
# of samples submitted
90th Percentile Cu
Note: If the State has informed you that it will calculate your 90th percentile levels, you do not need to
submit the 90th percentile calculations. However, you must still provide your sample results to the State by
the deadline that they have specified.
THE RESULTS OF WATER QUALITY PARAMETER SAMPLES MUST BE ATTACHED TO
THIS DOCUMENT
# of WQP tap samples required
# of entry point samples required
# of WQP tap samples submitted
# of entry point samples submitted
Lead and Copper Monitoring Guidance
E-12
February 2002
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Amended Form 141-A (Continued)
Page 2 of2
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
CHANGE IN SAMPLING SITES
Original site address:
New site address:
Distance between sites (approximately):
Targeting Criteria: NEW:
OLD:
Reason for change (attach additional pages if
necessary)
SIGNATURE
PRINTED NAME
TITLE
DATE
Lead and Copper Monitoring Guidance
E-13
February 2002
-------
Note: The LCRMR no longer require a system, which is in compliance with its OWQPs, to submit a
written request to its State to allow it to collect lead and copper tap samples at a reduced number and
frequency. Therefore, this or a similar form may no longer be required by your State. Please note
that this form cannot be used to request a monitoring waiver. Monitoring waiver forms are provided
in the guidance document, Monitoring Waivers under the Lead and Copper Rule Minor Revisions for Systems
Serving 3,300 or Fewer People, April 2000, EPA 815-R-99-021.
Form 141-B
Page 1 of 1
REQUEST FOR REDUCED LEAD AND COPPER TAP WATER
System's Name:
Address:
System Type:
D CWS
D
NTNCWS
Number of People Served:
D >100,000
D 10,001 to
100,000
D 3,301 to 10,000
D 501 to 3,300
D 101 to 500
D ^100
System ID #:
Contact Person:
Telephone number:
The
water system has~operated in
accordance with the State-specified water quality parameters during each of the following
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
or
D Annual to Triennial
D 100 to 50
D 60 to 30
D 40 to 20
D 20 to 10
D 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
PRINTED NAME
TITLE
DATE
Lead and Copper Monitoring Guidance
E-14
February 2002
-------
Form 141 C
Page 1 of2
OPTIMAL CORROSION CONTROL TREATMENT RECOMMENDATION
System's Name:
Address:
System ID #:
Contact Person:
System T
—
D >100,0
D 10,001
100.000
vpe: D CWS D NTNCWS
Number of People Served:
00 D 501 to 3,300
to D 101 to 500
D ^100
D 3,301 to 10,000
Telephone number:
RESULTS OF MONITORING
The Results of Source Water, Tap \Vatei
# of tap water samples required
# of source water samples required
r, andWQPSam,
ales Must Be Att
£ of tap water sa
£ of source wate
ached to This Document
mples submitted
r samples submitted
RESULTS OF OPTIMAL CORROSION CONTROL TREATMENT STUDIES
(If the State requires you to conduct additional treatment analyses, copy this form and attach the
results.)
Test 1 — Alkalinity & pH Adjustment
Before
Parameters
Pb
Cu
pH
alkalinity
calcium
conductivity
orthophosphate
silicate
water
temperature
After
Test 3 — Addition of Corrosion Inhibitor
Test 2 — Calcium Hardness Treatment
Before
Test 4 —
Parameters After
Pb
Cu
pH
alkalinity
calcium
conductivity
orthophosphate
silicate
water
temperature
Lead and Copper Monitoring Guidance
E-15
February 2002
-------
Before
Parameters
Pb
Cu
pH
alkalinity
calcium
conductivity
orthophosphate
silicate
water
temperature
After
Before
Parameters
Pb
Cu
pH
alkalinity
calcium
conductivity
orthophosphate
silicate
water
temperature
After
Form 141-C (continued)
Page 2 of2
OPTIMAL CORROSION CONTROL TREATMENT RECOMMENDATION
CORROSION CONTROL TREATMENT RECOMMENDATION
1. Treatment recommendation and rationale:
2. Test methodologies used to evaluate each treatment (e.g., pipe rig loop tests, metal
coupon tests, etc.):
3. Identify any chemical or physical constraint that limits or prohibits the use of a particular
corrosion control treatment (attach all data indicating that a particular treatment has
adversely affected other water treatment processes or is ineffective for reducing
corrosion):
CERTIFICATION THAT OPTIMAL CORROSION CONTROL
TREATMENT HAS BEEN INSTALLED
The
water system certifies that optimal corrosion control
treatment has been installed and is being properly operated as agreed to between the above
named water system and the State of . Optimal corrosion control
treatment was required to be installed by
treatment was installed on
(date). Optimal corrosion control
(date).
Lead and Copper Monitoring Guidance
E-16
February 2002
-------
OPTIMAL CORROSION CONTROL TREATMENT RECOMMENDATION
CORROSION CONTROL TREATMENT RECOMMENDATION
REQUEST FOR MODIFICATION OF CURRENT CORROSION CONTROL TREATMENT
AND/OR WATER QUALITY PARAMETERS
Reason for
modification:
(Attach all supporting studies, data, treatment specifications, etc., that substantiate this
request for modification.)
SIGNATURE
PRINTED NAME
TITLE
DATE
Form 141-D
Page 1 of2
SOURCE WATER MONITORING AND TREATMENT
System's Name:
Address:
System ID #:
Contact Person:
System Type: D CWS D NTNCWS
Number of People Served:
D >100,000 D 501 to 3,300
D 10,001 to 100,000 D 101 to 500
D 3,301 to 10,000 D <100
Telephone number:
SOURCE WATER DATA
Attach all data collected at all entry points to the distribution system. List the highest values obtained
in sampling for this monitoring period and attach the results of all other samples collected at each entry
Entry Point Location
1.
2.
3.
4.
Lead Values
(in mg/L)
Copper Values
(in mg/L)
Lead and Copper Monitoring Guidance
E-17
February 2002
-------
SOURCE WATER MONITORING AND TREATMENT
5.
6.
7.
8.
9.
10.
Lead and Copper Monitoring Guidance
E-18
February 2002
-------
Form 141-D (continued)
Page 2 of2
SOURCE WATER MONITORING AND TREATMENT
SOURCE WATER TREATMENT RECOMMENDATION
Treatment recommendation:
Reason for treatment/no treatment recommendation: (Attach additional pages as needed.)
CERTIFICATION THAT SOURCE WATER
TREATMENT HAS BEEN INSTALLED
The
water system certifies that source water treatment has
been installed and is being properly operated as agreed to between the above named water
system and the State of . Water treatment was required to be installed
by (date). Source water treatment was installed on (date).
REQUEST FOR MODIFICATION OF STATE TREATMENT DECISION AND/OR MAXIMUM
PERMISSIBLE LEAD AND COPPER LEVELS
Reason for modification:
(Attach all supporting studies, data, treatment specifications, etc., that substantiate this
request for modification.)
SIGNATURE
PRINTED NAME
TITLE
DATE
Lead and Copper Monitoring Guidance
E-19
February 2002
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