v>EPA Lead and Copper Rule
United States B^ • . » •
Environmental Protection nOniCOrinS anO
Agency
Guidance for Public Water
Systems
(Original Document: Lead and Copper Rule Monitoring and Reporting Guidance for Public Water Systems:
EPA 816-R-02-009, February 2002)
(Revised Document: Lead and Copper Rule Monitoring and Reporting Guidance for Public Water Systems:
EPA 816-R-10-004, March 2010)
Office of Water (4606M)
EPA 816-R-10-004
March 2010
www.epa.gov/safewater
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TABLE OF CONTENTS
SECTION I: OVERVIEW 1
A. What Is the Purpose of this Guidance Document? 1
B. How Is this Document Organized? 2
C. What Is the Purpose of the Lead and Copper Regulations? 3
D. What Systems Are Affected by the Lead and Copper Regulations? 3
E. What Are the Requirements of the Lead and Copper Regulations? 4
F. What Are the Corrosion Control Treatment Requirements? 6
G. What Are the Source Water Treatment Requirements? 8
H. What Are the Public Education and Public Information Requirements? 9
Community Water Systems 10
Non-transient Non-community Water Systems 11
CWS and NTNCWS Consumer Notice of Lead Tap Results 12
Revised Consumer Confidence Report Rule Requirements 12
I. What Are the Lead Service Line Replacement Requirements? 13
SECTION II: LEAD AND COPPER TAP WATER MONITORING AND REPORTING
REQUIREMENTS 15
A. What Is the Purpose of Collecting Lead and Copper Tap Samples? 15
B. Is My System Required to Collect Lead and Copper Tap Samples? 15
C. When Do I Collect Lead and Copper Tap Samples? 15
Standard Lead and Copper Tap Monitoring 16
D. Am I Eligible for Reduced Lead and Copper Tap Monitoring? 17
Annual Monitoring Criteria 17
Triennial Monitoring Criteria 18
Monitoring Waiver Criteria 19
E. When Must I Collect My Samples If I Am on Reduced Monitoring 20
Transitioning to Less Frequent Monitoring 21
Transitioning to a State-specified Monitoring Schedule 24
F. Where Must I Collect My Samples? 24
Sources of Information That You Should Review 25
If You Cannot Find Enough Tier 1 Sampling Sites 27
If You Cannot Use Original Sampling Site 28
G. How Do I Collect Lead and Copper Tap Water Samples? 28
H. What Are the Approved Methods for Analyzing Water Samples for Lead and Copper? 29
I. How Do I Evaluate My Results? 34
J. What If the State Determines that My Samples Are Invalid? 37
K. What If I Exceed an Action Level While on a Six-Month Monitoring Schedule? 38
L. What Should I Do If I Exceed the Lead or Copper Action Level or Have an Optimal Water
Quality Parameter Excursion During Reduced Monitoring? 39
M. Can I Ever Resume a Reduced Monitoring Schedule? 40
N. Can I Ever Discontinue Lead and Copper Tap Monitoring? 40
Revised LCR Monitoring and Reporting Guidance
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O. Am I Required to Provide the Analytical Results to My Consumers? 40
P. What Lead and Copper Tap Monitoring and Related Information Must I Report to the State?
41
Reporting No Longer Required by the 2000 LCRMR 42
Requirements Modified or Added by the Short-Term Revisions 43
Q. What Should I Do If I Sell Water To, or Buy Water From, Another Water System? 45
R. What Happens If I Do Not Fulfill My Lead and Copper Tap Monitoring and Reporting or
Consumer Notice of Lead Tap Results Requirements? 46
S. What Provisions of the Short-Term Revisions Pertain to Lead and Copper Tap Monitoring
and Corrosion Control Treatment Requirements? 48
T. What Provisions of the Short-Term Revisions Pertain to Consumer Notice of Lead Tap
Results and CCR Requirements? 52
U. What Key Points Should I Remember About Lead and Copper Tap Monitoring? 52
SECTION III: WATER QUALITY PARAMETERS REQUIREMENTS 55
A. What Is the Purpose of Collecting Water Quality Parameter Samples? 55
B. Which Systems Must Collect Water Quality Parameter Samples? 55
C. When Do I Collect Water Quality Parameter Samples? 56
Initial WQP Monitoring 56
Follow-up WQP Monitoring 57
Monitoring after the State sets OWQPs 59
D. How Do I Select My Sampling Sites? 61
Distribution Samples 61
Entry Point Samples 62
E. How Do I Collect Water Quality Parameter Samples? 62
At the Sampling Site 62
Parameter-specific Procedures 63
F. How Does the State Determine If I Am In Compliance With My Optimal Water Quality
Parameter Values? 64
G. Can I Ever Reduce My WQP Monitoring? 66
Criteria for Reducing the Number of WQP Tap Samples 66
Criteria for Annual Monitoring 66
Criteria for Triennial Monitoring 67
H. Can I Ever Discontinue Water Quality Parameter Monitoring? 68
I. What Water Quality Parameter Monitoring Information Must I Report to the State? 69
J. What If I Do Not Fulfill My WQP Requirements? 69
K. What Provisions of the Short-Term Revisions Pertain to Water Quality Parameter
Monitoring and Reporting? 70
L. What Key Points Should I Remember About Water Quality Parameter Monitoring? 70
SECTION IV: LEAD AND COPPER SOURCE WATER MONITORING AND REPORTING
REQUIREMENTS 73
A. What Is the Purpose of Collecting Source Water Samples? 73
B. Which Systems Must Collect Source Water Samples? 73
C. When Do I Collect Source Water Samples? 73
If this Is the First Time You Have Exceeded an Action Level 73
Revised LCR Monitoring and Reporting Guidance ii
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Immediately Following Source Water Treatment Installation 74
After the State Sets MPLs or Determines Source Water Treatment Is Not Needed 74
Reduced Monitoring 75
D. Where Are These Samples Collected? 76
Sampling Requirements Based on Your Source 76
Other Considerations for All Systems Conducting Source Water Monitoring 77
E. How Does the State Evaluate My Source Water Monitoring Results? 77
F. Can I Ever Discontinue Source Water Monitoring? 78
G. What Source Water Monitoring Information Must I Report to the State? 79
H. What If I Do Not Fulfill My Source Water Monitoring and Reporting Requirements? 79
I. What Provisions of the Short-Term Revisions Pertain to Source Water Monitoring and
Reporting Requirements? 80
J. What Key Points Should I Remember About Source Water Monitoring and Reporting? 70
SECTION V: LEAD SERVICE LINE MONITORING AND REPORTING REQUIREMENTS 83
A. What Is the Purpose of Collecting Lead Service Line Samples? 83
B. Which Systems Must Collect Lead Service Line Samples? 83
C. When Do I Collect Lead Service Line Samples? 84
D. How Do I Collect Lead Service Line Samples? 84
E. Can I Ever Discontinue Lead Service Line Monitoring? 86
F. What Happens If I Have a Subsequent Lead Action Level Exceedance? 86
G. What Lead Service Line-Related Information Must I Report to the State? 87
All Systems Subject to Lead Service Line Replacement 87
Systems Conducting Partial Lead Service Line Replacement 87
H. What If I Do Not Fulfill My Lead Service Line Replacement Requirements? 88
I. What Provisions of the Short-Term Revisions Pertain to Lead Service Line Monitoring and
Replacement? 89
J. What Key Points Should I Remember About Lead Service Line Monitoring and Reporting? 91
APPENDIX A - List of LCR Outreach Materials for Water Systems A-l
APPENDIX B - Definitions B-l
APPENDIX C — Summary of Monitoring and Reporting Violation Definitions C-l
APPENDIX D - Worksheet and Instructions D-l
APPENDIX E — Lead Consumer Notice Certification Form E-l
Revised LCR Monitoring and Reporting Guidance
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EXHIBITS
Exhibit 1-1: Corrosion Control Treatment Steps 7
Exhibit 1-2: Source Water Monitoring and Treatment Requirements 8
Exhibit 1-3: Short Informational Statement 13
Exhibit 1-4: Follow up Actions Resulting from Lead and Copper Tap Monitoring 14
Exhibit II-l: Schedule for Initial Monitoring 16
Exhibit II-2: Minimum Number of Lead and Copper Tap Samples for Systems on Standard
Monitoring 16
Exhibit II-3: Minimum Number of Lead and Copper Tap Samples for Systems on Reduced
Monitoring 17
Exhibit II-4: Reduced Lead and Copper Tap Monitoring Criteria 19
Exhibit II-5. Three-Year Compliance Period for Systems on Reduced Triennial Monitoring 23
Exhibit II-6. Nine-Year Compliance Period for Systems on Monitoring Waivers 23
Exhibit II-7: Tiering Classification 25
Exhibit II-8: Approved Analytical Methods for the Lead and Copper Rule 30
Exhibit II-9: Sample Handling Requirements for Lead, Copper, and Water Quality
Parameters 33
Exhibit 11-10: Revisions to Lead and Copper Tap Monitoring and Reporting Requirements
and Corrosion Control Treatment Schedule 48
Exhibit 11-11: Consumer Notice of Lead Tap Results and Revisions to Consumer Confidence
Report Requirements 52
Exhibit III-l: Initial WQP Requirements for Systems Serving 50,000 and Fewer People 57
Exhibit III-2: Standard Number of WQP "Tap" Sites and Samples 57
Exhibit III-3: Daily Value Calculation Based on Monitoring Frequency 65
Exhibit III-4: Reduced Number of WQP Tap Sites and Samples 66
Exhibit III-5: Reduced WQP Tap Monitoring Criteria 68
Exhibit III-6: Revisions to Water Quality Parameters 70
Exhibit IV-1: Revisions to Source Water Requirements 80
Exhibit V-l: Pipe Volume Table (Volumes Listed in Liters) 85
Exhibit V-2: Revisions to Lead Service Requirements 89
Revised LCR Monitoring and Reporting Guidance iv
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LIST OF ACRONYMS AND ABBREVIATIONS
AL
ALE
CCR
CCT
CFR
Cu
cws
EP
EPA
FR
GWUDI
HNO3
LCR
LCRMR
LSL
LSLR
MCL
MCLG
MDL
MFR
mg/L
MPL
NPDWR
NTNCWS
OCCT
OWQP
Pb
ppb
PQL
PSA
PWS
QA/QC
SFR
Action level
Action level exceedance
Consumer Confidence Report
Corrosion control treatment
Code of Federal Regulations
Copper
Community water system
Entry point
United States Environmental Protection Agency
Federal Register
Ground water under the direct influence of surface water
Nitric acid
Lead and Copper Rule
Lead and Copper Rule Minor Revisions
Lead service line
Lead service line replacement
Maximum contaminant level
Maximum contaminant level goal
Method detection limit
Multi-family residence
Milligrams per liter
Maximum permissible level
National primary drinking water regulation
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
Revised LCR Monitoring and Reporting Guidance
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SMF Standardized monitoring framework
SOWT Source water treatment
WQP Water quality parameter
Revised LCR Monitoring and Reporting Guidance vi
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SECTION I: OVERVIEW
A. What Is the Purpose of this Guidance Document?
This guidance document has been developed for water system owners and operators of community
and non-transient, non-community water systems. It provides a comprehensive discussion of the
monitoring and monitoring-related reporting requirements of the Lead and Copper Rule (LCR).
The United States Environmental Protection Agency has updated this guidance from the February
2002 version to include the requirements of the October 10, 2007, Lead and Copper Rule Short-
Term Regulatory Revisions and Clarifications (hereafter referred to as the "Short-Term Revisions"
or "Revisions") under the Safe Drinking Water Act (SDWA).
EPA first promulgated maximum contaminant level goals (MCLGs) and national primary drinking
water regulations (NPDWRs) for lead and copper in 1991 (56 FR 26460, June 7, 1991). EPA
proposed minor revisions to the LCR (LCRMR) in 1996 (60 FR 16348) and finalized these minor
revisions on January 12, 2000 (65 FR 1950). These minor revisions streamlined the requirements of
the LCR, promoted consistent national implementation, and reduced the reporting burden for water
systems and States. EPA promulgated the Short-Term Revisions to strengthen implementation of
the LCR in the following seven targeted areas:
• Minimum number of samples required;
• Definitions for compliance and monitoring periods;
• Reduced monitoring criteria;
• Consumer notice of lead tap water monitoring results;
• Advanced notification and approval of long-term treatment changes;
• Public education requirements; and
• Reevaluation of lead service lines.
The compliance date for all of the provisions of this Rule is 180 days after publication in the Federal
Register (i.e., April 7, 2008), except if by that date, the State has not adopted this rule, in which case
compliance with this final rule is required the earlier of either the State's adoption of the rule, or two
years after December 10, 2007. Systems for which EPA is the Primacy Agency (i.e., Wyoming,
District of Columbia, and most Indian territories) and in States that incorporate EPA's drinking
water regulations by reference automatically or incorporate based on the Federal publication date
were required to begin complying with the Short-Term Revisions on April 7, 2008.
Most of the provisions of the Short-Term Revisions are clarifications to the LCR or are more
stringent than the current requirements. These revisions must be adopted by States to retain
primacy. This guidance document identifies those provisions that are not more stringent than the
current LCR but allow flexibility and improvements in implementation. States have the option to
incorporate these revisions into their drinking water regulations. Therefore, you should first check
with your State to determine if they apply to your water system.
Please note that the SDWA provisions and EPA regulations described in this document contain
legally-binding requirements. This document does not substitute for those requirements, nor is it a
regulation itself. It does not impose legally-binding requirements on EPA, States, Tribes, or the
regulated community and may not apply to a particular situation based upon the circumstances.
Revised LCR Monitoring and Reporting Guidance |
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EPA and State decision makers 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. EPA will then consider whether or not the recommendations or interpretations
in the guidance are appropriate in that situation based on the law and regulations. EPA may change
this guidance in the future.
B. How Is this Document Organized?
The document contains five sections, including this overview and a discussion of the four
monitoring protocols contained in the LCR. These sections are listed below.
• Section I: Overview
• Section II: Lead and Copper Tap Water Monitoring and Reporting Requirements
• Section III: Water Quality Parameter Monitoring and Reporting Requirements
• Section IV: Lead and Copper Source Water Monitoring and Reporting Requirements
• Section V: Lead Service Line Monitoring and Reporting Requirements
Section 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 public information
requirements, and lead service line replacement requirements. Sections II through V address the
following topics:
• The purpose of 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 allow systems to reduce and/or eliminate its monitoring requirements;
• Information that must be reported to the State;
• How the Short-Term Revisions have impacted monitoring and reporting requirements;
and
• Key points to remember.
Section 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 (CFR), Title 40 (i.e., EPAs
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, or Department of Health). For the District of Columbia,
Wyoming, and Native American Lands (except for the Navajo Nation), the contact is often from the
respective EPA Regional Office.
Revised LCR Monitoring and Reporting Guidance 2
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This guidance document focuses on those revisions that impact monitoring and reporting
requirements. Those revisions that are unrelated to monitoring and reporting requirements (e.g.,
public education requirements) are discussed in more detail in separate guidance documents. All
available LCR-related guidance documents can be obtained by visiting EPA's Web site:
www.epa.gov/safewater/lcrmr/compliancehelp.html or contacting the Safe Drinking Water Hotline
at (800) 426-4791. A list of these guidance documents and outreach materials is provided as
Appendix A and includes guidance and fact sheets to help utilities implement the new public
education and information requirements.
In addition to Appendix A, this document includes the following appendices:
• Appendix B: Definitions that explain the terms used in this guidance.
• Appendix C: Summary of Monitoring and Reporting Violation Definitions.
• Appendix D: Worksheets and instructions to assist in identifying sampling sites, sample
collection, and the documentation and justification of decisions.
• Appendix E: Lead Consumer Notice Certification Form.
C. What Is the Purpose of the Lead and Copper Regulations?
(40CFR 141.80 & I4l.8l(b))
The purpose of the lead and copper regulations is to protect public health by minimizing lead and
copper levels in drinking water, primarily by reducing water corrosivity. Most regulations require
sampling at entry points to the distribution system. Because lead and copper in drinking water is
mainly due to the corrosion of service lines 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 coordination with the people you serve.
D. What Systems Are Affected by the Lead and Copper
Regulations? (40 CFR I4l.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 requirements.
System Size Categories
Size
Small
Medium
Large
No. of people
served
25 - 3,300
3,301 - 50,000
over 50,000
Revised LCR Monitoring and Reporting Guidance
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E. What Are the Requirements of the Lead and Copper
Regulations? (40 CFR 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.
for lead or copper. However, if your lead and
higher than the lead action level of 0.015 milligrams
The Short-Term Revisions have modified the
calculation of the 90th percentile for systems
that are permitted to collect fewer than five
tap samples (if allowed by their State). A
detailed explanation of how to calculate the
90th percentile levels is provided in Section II.
There is no maximum contaminant level (MCL)
copper tap 90th percentile monitoring results are
per liter (mg/L) 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.
If your 90h percentile level exceeds the lead action level of 0.015 mg/L, you must:
• Conduct 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 at entry points to the distribution system, make a
treatment recommendation, and install source water treatment, if needed;
• Deliver public education that informs your users about the health effects of lead,
measures that will reduce their exposure to lead, and sources of additional information;
and
• Replace lead service lines if you still exceed the lead action level after installing treatment
or the State requires their replacement.
If your 9ffh percentile level exceeds the copper action level of 1.3 mg/L, you must:
• Conduct corrosion control treatment
steps which include WQP monitoring
during the same monitoring period in
which the exceedance occurs; and
• Conduct source water monitoring, make a treatment recommendation, and install source
water treatment, if needed.
s
Public education and lead service line
replacement are not required if only
the copper action level is exceeded.
Revised LCR Monitoring and Reporting Guidance
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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 must install corrosion control to reduce the
corrosivity of their water and thereby, their lead and copper levels. On the other hand, some
systems have naturally non-corrosive water and would not benefit from installing treatment or have
already installed corrosion control treatment.
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.
Your water system can be deemed to have optimized corrosion control if:
1. It is a small or medium system (i.e., serve 50,000 or fewer people) and its 90th percentile
levels are at or below both the lead and copper action levels for two consecutive six-
month monitoring periods. EPA also refers to these systems as "(b)(l) systems" because
they meet the requirements of 40 CFR 141.81(b)(l).
2. It already has treatment in place, prior to the effective date of the 1991 LCR (i.e., prior
to December 7, 1992) and has conducted activities equivalent to those outlined in 40
CFR 141.81(b)(2). EPA also refers to these systems as "(b)(2) systems."
3. It demonstrates 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 (refer to
Exhibit II-2), and source water samples for lead at each entry point to the distribution
system during each of
two consecutive six-
A (b)(3) system that exceeds the copper action level
after July 12, 2001 no longer qualifies as a (b)(3) system.
Such a system must begin corrosion control treatment
steps, unless this treatment is already in place.
month monitoring
periods. EPA also
refers to these systems
as "(b)(3) systems"
because these criteria
are specified in 40 CFR 141.81(b)(3) of the federal regulations.
4. It demonstrates that for two consecutive six-month periods, its source water lead levels
are below the method detection limit (MDL) and its 90th percentile lead levels are less
than or equal to the practical quantitation level (PQL) of 0.005 mg/L. These criteria
were added in the January 12, 2000, LCRMR and were optional for States to include in
their drinking water regulations. If you believe your water system meets these criteria,
first check with your State to determine if this provision applies.
Revised LCR Monitoring and Reporting Guidance
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F. What Are the Corrosion Control Treatment
Requirements? (40 CFR 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: A system serving 50,000 or fewer people submits 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 WQP samples 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 capper action level or
if required by the State.
Step 7: The State sets 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. 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.
Step 8: The system conducts periodic lead and copper tap and WQP monitoring. Note:
Systems serving < 50,000people are only required to collect WQP samples during any
monitoring period in which they exceed the lead or copper action level or if required by the State.
Systems serving 50,000 or fewer people can discontinue these steps whenever their 90th percentile
levels are at or below both action levels for two consecutive six-month monitoring periods.
However, if these systems exceed the lead or copper action level, they or their State must
recommence completion of the applicable corrosion control treatment steps, beginning with the
first step that was not previously completed. The State can also require the system to repeat any
previously completed steps if the State determines that this is necessary to properly implement the
corrosion control treatment requirements. In this instance, the State must notify the system in
writing of its determination and provide an explanation for its decision.
Water systems that meet the (b)(2) criteria are not required to conduct a study, install corrosion
control treatment, or conduct follow-up monitoring. However, (b) (2) systems must conduct lead
and copper tap and WQP monitoring after the State sets OWQPs. A system that meets the (b)(3)
criteria based on initial monitoring is not subject to the corrosion control treatment requirements.
Revised LCR Monitoring and Reporting Guidance
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Exhibit 1-1 shows the schedule for completing corrosion control treatment steps for those systems
that are subject to these requirements.
Exhibit l-l: Corrosion Control Treatment Steps
Requirement
Step 1: System recommends type
of treatment to be installed
Step 2: State decides whether study
is required
Step 3: System completes study
Step 4: State determines type of
treatment to be installed
Step 5: System installs treatment
Step 6: System conducts follow-up
monitoring
Step 7: State designates OWQPs 3
Step 8: System conducts continued
monitoring
1
1
Timetable for Completing Corrosion Control Treatment for Systems Serving: |
50,000 or fewer people 1
6 months 2
12 months 2
18 months after State decision to conduct
study
1. If study is required: 6 months after
study is completed
2. If no study is required:
Serves < 3,300: 24 months;
Serves 3,301 - 50,000: 18 months 2
24 months after State decision regarding
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 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
:A 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.
2 Indicates the number of months after the end of the monitoring period during which the lead and/or copper action level was
exceeded. Prior to the Short-Term Revisions, this was expressed as number of months after exceeding an action level.
3The State is not required to designate OWQPs for systems serving 50,000 or fewer people that no longer exceed both
action levels after installing treatment. However, some States have opted to do so.
Form 141-C, Optimal Corrosion Control Treatment/'Water Quality'Parameters, has been provided in
Appendix D. 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
Sections II and III, respectively.
For more information on corrosion control treatment, refer to the
technical guidances listed in Appendix A. These documents can be found
on EfiA's Web site:
httto://uww.etoa.sov/safewater/lcrmr/comtoliancehelto.html.
Revised LCR Monitoring and Reporting Guidance
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G. What Are the Source Water Treatment Requirements?
(40CFR 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 source
water treatment. The source water treatment steps are as follows:
Step 1: The system conducts source water monitoring for lead and copper 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.
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 source water 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).
Exhibit 1-2 indicates the timing of these source water treatment requirements. Please note that
Steps 3 and 4 only apply to those systems that are required to install source water treatment.
Exhibit 1-2: Source Water Monitoring and Treatment Requirements
Action
Step 1: System
monitors at each EP &
submits
recommendation
Step 2: State
determines if SOWT is
required
Step 3: System installs
SOWT
Step 4: System
conducts follow-up
monitoring
Step 5: State sets MPLs
"or lead & copper 3
Deadline for Completing Action
Source Water
Treatment (SOWT)
Required
SOWT Not Required
180 days after the end of the monitoring period
during which the lead and/or copper action level
was exceeded 2
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
Number of Months from ALE l
SOWT Required
SOWT Not Required
180 days
12 months
36 months
48 months
54 months
N/A
N/A
N/A
Revised LCR Monitoring and Reporting Guidance
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Exhibit 1-2: Sourc,
Action
Deadline for Completing Action
Source Water
Treatment (SOWT)
Required
SOWT Not Required
Number of Months from ALE
SOWT Required
SOWT Not Required
Step 6: System
conducts periodic water
monitoring 4
Annually for surface water/combined sources
66 months
24 months
Triennially for ground water systems
Depends on 3-year compliance period in
effect
Once during each nine-year compliance cycle
Depends on 9-year compliance cycle in effect
Indicates the number of months after the end of the monitoring period during which the lead and/or copper action level was
exceeded. Prior to the Short-Term Revisions, this was expressed as number of months after exceeding an action level.
State will set MPLs for both lead and copper even if the system exceeded only one action level. In some cases, the State
will set MPLs for systems that are not required to install source water treatment.
2 Prior to the Short-Term Revisions, initial monitoring and the source water treatment recommendation were due within
six months after the exceedance.
5 The Short-Term Revisions require the first year of annual monitoring to begin during the year the State set MPLs or
determined that SOWT is not needed versus the date the applicable determination was made. Triennial monitoring
Begins with the three-year compliance period in effect when the State makes the applicable determination.
4 Systems can qualify for reduced monitoring, at a frequency of once every nine-year compliance cycle, if they are in
compliance with their MPLs for three consecutive compliance periods (i.e., three annual periods for surface water/combined
sources; three, three-year periods (equals nine years) for ground water systems).
Unlike corrosion control treatment, systems that are at or below both action levels must
complete the source water treatment steps once begun (i.e., Steps I - 4). 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 Section IV of this guidance.
Detailed information regarding source water treatment is provided in Lead and Copper Ru/e Guidance
Manual, Volume II: Corrosion Control Treatment, September 1992, which is available on EPA's Web site
at httb: 11 www. eba. sov/ safewater/ Icrmrl combliancehelt). html.
H. What Are the Public Education and Public Information
Requirements? (40 CFR 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,
sources of lead, and what they can do to
minimize their exposure to lead. The Short-
Term Revisions modify the required content
of public education materials to provide
greater specificity on the health effects that can
result from exposure to lead and require CWSs and NTNCWSs to deliver the same mandatory
The Short-Term Revisions require that you
submit your public education language to
your State for review. Check with your State
to determine if this language must be
approved before you can use it in your
public education materials.
Revised LCR Monitoring and Reporting Guidance
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language that consists of an opening statement, health effects language, and sources of additional
information. In addition, the Revisions specify that you must provide information regarding the
sources of lead, steps to reduce lead exposure in water, why there are elevated levels of lead in the
system's drinking water, what the water system is doing to reduce lead levels, and where to go for
more information; however, they allow you to tailor much of the language to better fit your
community and/or situation. Further, the Revisions add a new set of delivery requirements for
CWSs to better reach "at-risk" populations (e.g., pregnant women, infants, and young children).
A system can stop delivering public
education whenever it no longer exceeds
the lead action level for one monitoring
period. If it subsequently exceeds the lead
action level, it must recommence public
education within 60 days after the end of
the monitoring period in which the lead
action level was exceeded.
The Short-Term Revisions also clarify that the
time frame for initiating or recommencing
public education delivery is within 60 days after
the end of the monitoring period in which the
lead action level was exceeded (as opposed to
within 60 days of the lead exceedance). In
addition, the Revisions allow the State
discretion to extend this 60-day delivery
deadline for CWSs and NTNCWSs, provided
that before the end of the 60-day deadline, the State has approved the extension in writing. The State
may grant an extension on a case-by-case basis if the system has initiated public education activities prior to the end of
the 60-day deadline.
The requirements for delivering public education are different for CWSs and NTNCWSs. An
overview of these requirements is provided below. To further assist you in implementing the new
public education requirements, EPA has developed CWS and NTNCWS fact sheets and guidance
documents. These documents explain the public education requirements and other public
information requirements that include consumer notice of lead tap results, and for CWSs, the
revised Consumer Confidence Report (CCR) Rule requirements. The public education guidances
also explain how to design and implement an effective public education program, and include public
education, lead consumer
notice, and CCR
templates (CWS guidance
only) that can be adapted
for use.
These public education documents are listed in Appendix A and
are available at EPA's Web site:
httto://www.etoa.sov/safewater/lcrmr/comtoHancehelto.html.
Community Water Systems
Within 60 days after the end of the monitoringperiod in which the lead action level was exceeded (either
for the first time or again after having a monitoring period at or below the lead action level), a CWS
must:
• Deliver printed materials (pamphlets and brochures) to all bill paying customers and put
new mandatory language on or in water bills.
• Deliver printed materials to local public health agencies, even if they are not located
within its distribution system. The printed materials must include an "informational
notice" that encourages the local health agencies to distribute materials to any potentially
affected customers; or CWS users.
• Contact its local health agencies via phone or in person to obtain a list of additional
community-based organizations that serve target populations and deliver public
education materials to these organizations.
Revised LCR Monitoring and Reporting Guidance 10
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• Contact at-risk customers by delivering printed materials to public and private schools or
school boards; women, infants and children (WIG), and Head Start programs; public and
private hospitals and medical clinics; pediatricians; family planning clinics; and local
welfare agencies. The printed materials must include the "informational notice"
described above.
• Make a good faith effort to locate and deliver printed materials to licensed childcare
centers, public and private pre-schools, and obstetricians-gynecologists and midwives.
The printed materials must include the "informational notice" described above.
• Post the printed material content on its Web site if it serves more than 100,000 people.
• Submit a press release to newspaper, television, and radio stations.
• Implement activities from the following (in consultation with its State): public service
announcements, paid advertisements, public area informational displays, e-mails to
customers, public meetings, household deliveries, targeted individual customer contact,
direct material distribution to all multi-family homes and institutions, or other methods
approved by your State.
Most public education requirements must be repeated annually until the system no longer exceeds
the lead action level. Some activities must be conducted more frequently as follows:
• CWSs must provide the mandatory informational statement on or in water bills with
each billing cycle but no less frequently than quarterly;
• CWSs must deliver press releases twice every 12 months on a schedule agreed upon with
the State; and
• CWSs serving more than 100,000 people must retain material on their publicly-accessible
Web site for as long they have an action level exceedance.
The Short-Term Revisions continue to allow small systems (those serving
3,300 or fewer people) to limit certain aspects of their public education
program. Refer to the public education guidances for specific requirements.
Non-transient Non-community Water Systems
The Short-Term Revisions do not modify the delivery requirements for NTNCWSs. Within 60 days
after the end of the monitoringperiod in which the lead action level was exceeded (either for the first time
or again after having monitoring
periods at or below the lead action
level), a NTNCWS must distribute
public education by:
The Short-Term Revisions continue to allow "special
CWSs", such as prisons and hospitals, to apply to the
State in writing (unless prior approval is waived) to
use the same delivery requirements as NTNCWSs.
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
NTNCWS.
Revised LCR Monitoring and Reporting Guidance | |
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A NTNCWS or "special CWS" must repeat this information annually for as long as it exceeds the
lead action level.
The Short-Term Revisions allow a State to extend this 60-day delivery deadline
if it has approved the extension before the end of the 60 days. This extension
may be granted on a case-by-case basis if the system has initiated public
education activities prior to the end of the 60-day deadline
CWS and NTNCWS Consumer Notice of Lead Tap Results
The Short-Term Revisions added a new consumer notice of lead tap results requirement to 40 CFR
141.85(d). CWSs and NTNCWSs must provide consumers who occupy homes or buildings that are
part of the utility's monitoring program with results when their drinking water is tested for lead
(including those who do not receive water bills). These requirements are discussed in detail in
Subsections II.O and II.P.
Revised Consumer Confidence Report Rule Requirements
The Short-Term Revisions modify the requirements of the CCR Rule in 40 CFR 141.154.
Previously, all CWSs that detected lead above the action level in more than 5 percent of the homes
sampled had to include a short informational notice about lead in their CCR. EPA is requiring all
CWSs to provide information in their CCRs on lead in drinking water irrespective of whether the
system detected lead in any of its samples.
EPA believes that exposure to lead can be a localized phenomenon and has revised the rule based
on concerns that exposure to lead may be taking place, even though the action level is not exceeded.
Consumers, therefore, currently may not receive sufficient information on how to reduce their
exposure to lead.
This short educational statement will help to ensure that all vulnerable populations or their
caregivers receive information (at least once a year) on how to reduce their risk to lead in drinking
water (refer to Exhibit 1-3 for this statement). EPA incorporated the National Drinking Water
Advisory Council's recommended changes to the informational notice, which clarify the risk of lead
in drinking water, include basic steps on how to reduce exposure to lead in drinking water, and
provide sources of additional information. Additionally, requiring all systems to have one statement
will simplify compliance with this provision of the rule for the systems and the States. However, the
CCR revisions allow you to write your own educational statement, but only in consultation with the
State. For example, you may wish to revise the flushing time of "30 seconds to 2 minutes" if it
conflicts with the flushing information in your public education materials.
Revised LCR Monitoring and Reporting Guidance 12
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Exhibit 1-3: Short Informational Statement
If present, elevated levels of lead can cause serious health problems, especially for
pregnant women and young children. Lead in drinking water is primarily from
materials and components associated with service lines and home plumbing. [NAME
OF UTILITY] is responsible for providing high quality drinking water, but cannot
control the variety of materials used in plumbing components. When your water has
been sitting for several hours, you can minimize the potential for lead exposure by
flushing your tap for 30 seconds to 2 minutes before using water for drinking or
cooking. If you are concerned about lead in your water, you may wish to have your
water tested. Information on lead in drinking water, testing methods, and steps you
can take to minimize exposure is available from the Safe Drinking Water Hotline or at
http:/1 www. epa.gov/ safewater/ lead.
You must begin to include this lead informational statement in CCRs that are
due to your consumers by July I, 2009 (i.e., the CCR for 2008), except in
those States that have not incorporated the requirements of the Short-Term
Revisions into their regulations by December 2008. Please check with your
State to determine when this CCR requirement takes effect
I. What Are the Lead Service Line Replacement
Requirements? (40 CFR 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 two consecutive month
The monitoring requirements that are associated with lead service line replacement are discussed in
Section V. A detailed discussion of the lead service line replacement requirements is provided in
Lead and Copper Ru/e Guidance Manual, Volume II: Corrosion Control Treatment, September 1992.
This and other guidance documents pertaining to the LCR and Short-Term Revisions are
listed in Appendix A of this document and are available on EPA's Web site at:
httb://www.eba.eov/safewater/lcrmr/combHancehelb.html.
Exhibit 1-4 illustrates how your lead and copper monitoring results and system size impact your
requirements under the LCR.
Revised LCR Monitoring and Reporting Guidance
13
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Exhibit 1-4. Follow up Actions Resulting from Lead and Copper Tap Monitoring
CWS or NTNCWS Collects Lead
and Copper Tap Samples
90th Percentile
Is At or Below
Both Action Levels1
Conduct
reduced lead
and copper
tap
monitoring
Begin LSLR
replace 7%
of LSLs per
year'1-
90th Percentile
Exceeds the Lead
Action Level (15 ug/L)
90th Percentile
Exceeds the Copper
Action Level (1.3 mg/L)
Conduct
public
education
due within
60 days3
Begin CCT
steps
includes
WQP
monitoring 4
Conduct
source water
monitoring
install
SOWT, if
needed j
Conduct
standard
lead and
coppertap
monitoring s
1 Includes systems servings 60,000 people and (b) (3) systems; (b)(2) systems also must conduct WQP monitoring.
2 Required if lead action level is exceeded after treatment.
3 Counted from the end of the monitoring period with the lead ALE.
' Includes non-(b)(3) systems serving more than 50,000 people, irrespective of their 3ffl percentile levels.
5 Systems that meet their OWQPs and do not exceed the lead action level can qualify for reduced lead and coppertap monitoring.
Revised LCR Monitoring and Reporting Guidance
14
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SECTION II: LEAD AND COPPER TAP WATER
MONITORING AND REPORTING REQUIREMENTS
A. 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 is used to assess the effectiveness of
corrosion control treatment and/or source water treatment.
See Exhibit 11-10 for a summary of Revisions that impact lead and copper tap
monitoring and reporting requirements and the corrosion control treatment schedule.
See Exhibit ll-l I for a summary of Revisions that impact lead consumer notice of tap
results and CCR requirements.
B. Is My System Required to Collect Lead and Copper Tap
Samples? (40 CFR I40.80(a) & I4l.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.
C. When Do I Collect Lead and Copper Tap Samples? (40 CFR
I4l.86(c)&(d))
Lead and copper monitoring can be divided into two broad categories:
• Standard monitoring encompasses all monitoring other than reduced monitoring.
Standard monitoring is conducted at six-month intervals. Both initial monitoring
(required of all systems) and follow-up monitoring (corresponds to the two consecutive
six-months after a system completes the installation of corrosion control and is only
required for systems that install treatment) are a type of standard monitoring. Refer to
Exhibit II-2 for the number of sampling locations for systems on standard monitoring.
• Reduced monitoring corresponds to monitoring that occurs at a reduced frequency
and a reduced number of sample locations. The criteria that a water system must meet
to qualify for reduced monitoring are discussed in Subsection D below.
Each type of monitoring is discussed in greater detail below.
Revised LCR Monitoring and Reporting Guidance 15
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Standard Lead and Copper Tap Monitoring
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 Exhibit II-l below, and was specified for discrete six-month monitoring periods of January
through June and July through December.
Exhibit II-l: Schedule for Initial Monitoring
System Size
(No. of People Served)
3,300 and under
3,301 - 50,000
50,001 and more
Ist 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- 6/30/94 2
1/1/93- 6/30/93 2
7/1/92-12/31/92
1 If you are a new system, consult with your State LCR Coordinator to find out when you
must begin lead and copper monitoring.
2 Required 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 six-month rounds of
initial lead and copper tap
monitoring at the standard number
of sites, required for your system
size (refer to Exhibit II-2).
If you serve 50,000 or fewer
people, you were required to
conduct a minimum of one, six-
month round of initial monitoring
at the standard number of sites
(refer to Exhibit II-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 Section I).
• You also had the option to continue lead and copper tap monitoring while conducting
the corrosion control treatment steps to determine if you were eligible to stop these
steps (i.e., you had two consecutive six-month periods in which your 90th percentile lead
and copper levels were at or below their respective action levels).
Exhibit 11-2: 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
If fewer than five tap sites are used for human consumption, the Revisions
clarify that you must collect more than one sample from the same location
on different days to obtain the minimum number of required samples.
Alternatively, your State may allow you to collect one sample per available
sample tap.
Revised LCR Monitoring and Reporting Guidance
16
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You were required to conduct a second round of initial monitoring during the next six
months if you were at or below the lead and copper action levels during the first round
of monitoring.
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 monitoring
(e.g., source water monitoring) or treatment requirements apply.
Follow-up Lead and Copper Tap
Monitoring: If you are required to install
corrosion control treatment, you must conduct two
consecutive six-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.
The State uses this information and any WQP data
to set OWQP ranges or minimums. 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.
Other Standard Monitoring: After the State sets OWQPs, systems must monitor semi-annually
and collect the standard number of samples until they qualify for reduced monitoring. Refer to
Subsection II.D below for a discussion of the reduced monitoring criteria. In addition, as explained
in detail in Subsection ILL, systems that no longer meet the reduced monitoring criteria must return
to standard monitoring until they re-qualify for reduced monitoring.
A (b)(2) system has completed
corrosion control treatment steps
prior to 12/7/92 that are equivalent
to those described in 40 CFR
141.81 (b)(2) of the federal
regulation.
A (b)(3) system has demonstrated that it has
minimal levels of corrosion entering the
distribution system based on lead and copper
source and tap water samples in accordance with
40 CFR I4l.8l(b)(3) of the federal regulation.
D. Am I Eligible for
Reduced Lead and Copper
Tap Monitoring? (40 CFR
I4l.86(d)(4)&(g))
Annual Monitoring Criteria
You can reduce the frequency of your
monitoring to annually beginning in the
calendar year immediately following the end
of the second consecutive six-month
monitoring period and collect from a reduced
number of sites, as shown in Exhibit II-3, if:
Exhibit 11-3: 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
aThe number of samples for systems s
people is the same under standard and
monitoring.
erving ;<100
reduced
Revised LCR Monitoring and Reporting Guidance
17
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1. You serve 50,000 or fewer people, and you are at or below both action levels during two
consecutive six-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 and do not
exceed the lead action level during two consecutive six-month monitoring periods. You must
receive written permission from your State to proceed to reduced monitoring.
The Short-Term Revisions no longer allow water systems to qualify for reduced monitoring
based on meeting their OWQP specifications if they have a lead action level exceedance.
Triennial Monitoring Criteria
You can reduce the frequency of sampling to once every three years and collect the reduced number
of samples if your water system meets any of the following criteria:
1. Serves 50,000 or fewer people and its 90th percentile lead and copper levels are at or
below both action levels for three consecutive years. You do not need prior approval from the
State. Two consecutive six-month periods at or below both action levels (such as the two
initial monitoring periods) can count as the first year of the three years needed to qualify
for triennial monitoring.
2. Serves a population of any size and for three consecutive years, operates in accordance
with State-specified OWQPs and is at or below the lead action level. Note that prior to
the Short-Term Revisions a water system could qualify for reduced lead and copper tap
monitoring if it had a lead action level exceedance but met its OWQP specifications. You
must receive written permission to proceed to reduced monitoring.
3. Serves a population of any size and demonstrates that it meets the (b)(3) criteria. These
systems were required to 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 three calendar years thereafter. 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 90 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 two consecutive six-
month periods (also known as accelerated reduced lead and copper tap monitoring).
These criteria were introduced under the January 2000 LCRMR and were optional for the State to
include in its regulations. Check with jour State to determine if this provision applies.
Revised LCR Monitoring and Reporting Guidance 18
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Monitoring Waiver Criteria
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 nine-year intervals at the reduced number of
sites if you meet specific materials and monitoring criteria.
• The lead materials criteria require you to certify that the plumbing materials in your
water system contain no plastic pipes that contain lead plasticizers, or plastic service lines
that 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).
• The copper material criteria require you to certify that the plumbing materials in your
water system do not contain any copper pipes or copper service lines.
• The monitoring criteria specify that your 90th percentile lead level cannot be higher 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. You must first check with your State to determine if it has
adopted this provision.
A few States granted waivers prior to the April 11, 2000, the effective date of the LCRMR. If you
were granted a "pre-existing waiver" and were not required to monitor, you were required to collect
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, EPA 8I5-R-99-021 on EPA's
Web site at: httb://www.eba.eov/safewater/lamr/combliancehelb.html.
Exhibit II-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.
For systems serving 100 or fewer people, the number of samples remains at five.
Exhibit 11-4: Reduced Lead and Copper Tap Monitoring Criteria
System Size
(No. of people
served)
50,000 and fewer
Any size
50,000 and fewer
Any size
Criteria
At or below both action levels for two consecutive six-month monitoring
periods.
Meet OWQP specifications and do not exceed the kad action kvel for two
consecutive six-month monitoring periods. 1
At or below both action levels for three consecutive years of monitoring.
Meet OWQP specifications and do not exceed the lead action level for three
Monitoring
Frequency
Annual
Triennial 2
Revised LCR Monitoring and Reporting Guidance
19
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opper i ap nomtonng criteria
System Size
(No. of people
served)
Criteria
Monitoring
Frequency
consecutive years of monitoring. l
Any size
90th percentile lead level is < 0.005 mg/L and 90th percentile copper level is
<. 0.65 mg/L for two consecutive, six-month periods. 1 Check with your State to
determine if you may reduce monitoring to once every third calendar year based on these
criteria.
Any size
Meet (b)(3) criteria:
1. 90th percentile lead level minus the highest source water level is < 0.005
mg/L for two consecutive six-month monitoring periods.
or
2. Source water lead levels are below the MDL andtht 90th percentile lead level
is < 0.005 mg/L for two consecutive six-month monitoring periods.
After July 12, 2001, jour 90th percentile copper levels cannot exceed the copper action level.
Meet monitoring waiver criteria: 1
1. 90th percentile levels are < 0.005 mg/L for lead and/or < 0.65 mg/L for
copper.
25 to 3,300
and
2. Plumbing materials meet specified criteria that indicate they are free of lead-
containing and/or copper-containing materials.
and
3. Waiver is approved by the State.
Once every
nine years
1 Requires State approval before proceeding to reduced monitoring.
2 Two consecutive six-month monitoring periods in which the 90th percentile is at or below both action levels can
count as the first year of the three years needed to qualify for triennial monitoring.
If you have fewer than five taps that are used for human consumption, the Short-Term
Revisions: I) clarify that you must collect multiple samples from the same location on
different days to collect the minimum number of required samples or; 2) allow you to
collect one sample from each tap that is used for human consumption if the State agrees
in writing. Check with your State to see which applies to your system.
E. When Must I Collect My Samples If I Am on Reduced
Monitoring (40 CFR I4l.86(d)(4))
Many of the Short-Term Revisions help clarify when monitoring must be conducted for systems
that qualify for or are on a reduced monitoring schedule. One of these clarifications is to define the
"monitoring period" as the specific period in which water systems must conduct their required
monitoring. For a system that is on reduced lead
and copper tap monitoring (i.e., annual, triennial, or
nine-year monitoring), samples must be conducted
during the summer months of June through
September because these are the months in which
the highest lead levels are expected to occur.
For systems on standard monitoring,
the monitoring period remains the six-
month period of January through June
or July through December.
Revised LCR Monitoring and Reporting Guidance
20
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Thus, for systems on reduced monitoring, the monitoring period is the four-month period of June
through September of the same calendar year.
The 2000 LCRMR introduced the provision that allows a State to establish an alternate monitoring
period (not to exceed four consecutive months in the same calendar year) in which water systems
may conduct reduced lead and copper tap monitoring if it believes that another time period better
represents a time of normal operation where the highest lead levels are likely to occur. For example,
a State may decide to set an alternate schedule for a system that is closed during the summer
months. The Short-Term Revisions further clarify the timing of monitoring requirements for
systems on these alternate schedules.
Although a water system has a four-month monitoring window, it should not wait until the end of
the monitoring period to collect its samples for two main reasons. First, medium and small systems
should allow time to collect WQPs should they have an action level exceedance (refer to Section III
for more detail regarding WQP monitoring requirements). Second, the Short-Term Revisions clarify
that for systems on reduced lead and copper tap monitoring, the end of the monitoring period is
September 30 or for systems on an alternate monitoring period, the last day of that period. Because
lead and copper monitoring information is due within 10 days after the end of the monitoring
period, a system that collects samples during June — September would be required to report these
data to the State by October 10 (refer to Subsection II.P for more information on reporting
requirements).
The remainder of this section discusses the timing of reduced monitoring requirements for systems
monitoring during June through September or a State-designated alternate monitoring period.
Transitioning to Less Frequent Monitoring
If you are transitioning to a less frequent monitoring schedule (e.g., semi-annually to annually,
annually to triennially), the Short-Term Revisions clarify when the new monitoring period must
begin or when samples must be collected during compliance periods.
For water systems that qualify for annual monitoring, the Short-Term Revisions clarify that the
first year of annual monitoring begins during the calendar year immediately following the end of the
second consecutive six-month monitoring period in which it met the criteria for annual monitoring.
This clarification is illustrated in the following example.
Revised LCR Monitoring and Reporting Guidance 21
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EXAMPLE: Annual Monitoring
A water system on standard monitoring is below both action levels and OWQPs
during July I - December 31, 2008, and January I - June 30, 2009.
It would begin annual monitoring in 2010 because it completed its 2nd six-month
monitoring period below the lead and copper action levels in 2009.
It would collect the annual samples during June - September 2010 or during the
State-designated alternate four-month period in 2010 if applicable.
It would report its lead and copper tap information to the State by October 10,
2010, or 10 days after the end of the State-designated period.
For water systems that qualify for triennial monitoring, the Short-Term Revisions clarify that
the first year of triennial monitoring begins during the calendar year immediately following the end
of the third consecutive year of monitoring in which it met the criteria for triennial monitoring. In
addition, the Revisions specify that triennial samples must be collected no later than every third
calendar year as illustrated in the example below and Exhibit II-5.
EXAMPLE: Triennial Monitoring
The PWS meets its OWQP specification and is below the lead action level for the
three consecutive years of 2006, 2007, and 2008.
The first year of triennial monitoring begins in 2009. Therefore, the system must
monitor during June - September (or State-designated alternate four-month
period) in 2009, 2010, or 201 I.
It samples in July 2010 and reports no later than October 10, 2010.
Because these samples must be collected every 3 years, the next set of samples
must be collected no later than June -September of 201 3 (or State-designated
alternate four-month period in 201 3).
Revised LCR Monitoring and Reporting Guidance 22
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Exhibit 11-5. Three-Year Compliance Period for Systems on
Reduced Triennial Monitoring
2009 m-t 2010 -• 2011
2012 - 2013 - 2014
3-year compliance periods
*Samples must be collected during this monitoring period or alternate State-designated period.
For small water systems that qualify for a nine-year monitoring waiver, the Short-Term
Revisions clarify that the first monitoring must occur at least every nine years (refer to the example
below and Exhibit II-6).
EXAMPLE: Nine-Year Monitoring Waiver
A small PWS with a monitoring waiver is required to collect samples
during 2001 -2009.
The PWS conducts monitoring during August 2004.
Because these samples must be collected every nine years, the next set
of samples must be collected no later than June -September of 2013 (or
State-designated alternate four-month period in 20! 3).
Exhibit II-6. Nine-Year Compliance Period for Systems on
Monitoring Waivers
'02 '03 '04 '05 '06
'10 '11 '12 '13 '14 '15 '16 '17 '18
'07 '08 '09
1st nine-year compliance 2"a nine-year compliance
*Samples must be collected during this monitoring period or alternate State-designated period.
Revised LCR Monitoring and Reporting Guidance
23
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Systems that are on reduced lead and copper tap monitoring must collect their samples
during June - September (or a State-designated alternate four-month period) of the same
calendar year. Samples collected outside this period (except proper replacement samples
for invalidated samples) cannot be counted toward compliance or used in your 90th
percentile calculation. Therefore, if you have an insufficient number of samples that were
collected on-time, you will be in violation of your monitoring requirements.
Transitioning to a State-specified Monitoring Schedule
The 2000 LCRMR specified a one-time transition period to enable water systems to facilitate their
transition from a June through September monitoring period to a State-specified reduced
monitoring period as follows:
If you monitor. Then the next round of samples is due no later than:
Annually 21 months after the previous monitoring period
Triennially 45 months after the previous monitoring period
Every nine years The end of the nine-year cycle
For example, assume a system is on annual monitoring and last sampled on July 7, 2007. The
system is typically closed during the summer months and the State requires the system to collect its
samples during October through December. The system is allowed a maximum of 21 months from
the end of the "previous round" (or from September 30, 2007, in this example) to transition to the
new monitoring schedule or June 30, 2009, in this example. However, since this system must collect
its samples during October through December, it only has until December 31, 2008, to complete
this monitoring (i.e., 15 months).
Although not explicitly stated in the Short-Term Revisions, EPA
interprets the regulation to begin the transition period from the
end of the reduced monitoring period (i.e., from September 30).
F. Where Must I Collect My Samples? (40 CFR I4l.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 Exhibit II-l). Exhibit II-7, below, defines the tiering system for prioritizing sampling
sites.
Revised LCR Monitoring and Reporting Guidance 24
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^P9H
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 jour 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 jour 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 with
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 jour 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.
Representative Sample: If a CWS or NTNCWS cannot collect enough samples from tiered sites, it must
collect them from sites where the plumbing is similar to that used at other sites served by the water system.
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 removed).
Sites chosen for reduced monitoring (i.e., monitoring that is conducted at a one-year, three-year, or
nine-year frequency) must be representative of those sites that were used during standard
monitoring and must follow tiering requirements. For example, if a system has 100 sites, of which
75 are Tier 1 and 25 are Tier 2, it must collect all 50 reduced sites from Tier 1 sites if they are
available. Otherwise, the rule does not specify which sites must be chosen 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 not use only those sampling locations
with the lowest lead or copper levels. Your State may 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;
Revised LCR Monitoring and Reporting Guidance
25
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• 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
shown in Exhibits II-2 and II-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) two consecutive six-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, 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 of the lead ban (typically 1988 or 1989), provided these sites can be considered
representative.
If your system has fewer than five drinking water taps, the Short-Term Revisions clarify that you
must collect at least one sample from each tap and additional samples from those taps on different
days during the monitoring period to meet the minimum number of required samples. For instance,
if you have only one sample site, you may be required to collect five separate samples from that
sample site on different days. Alternatively, under the Short-Term Revisions, your State may allow
you to collect fewer than five tap samples if you collect samples from all taps that can be used for
human consumption (e.g., kitchen or bathroom taps). Your State must approve this reduction in the
number of tap samples in writing, so check with your State to determine if you may further reduce
the number of samples required to be collected.
If your system contains lead service lines, then, if possible, half of the required sampling sites should
be served by a lead service line. For a system required to collect 40 tap samples, 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.
Three worksheets for organizing the information collected during the materials evaluation are
included in Appendix D as follows:
• Worksheet 1: Materials Survey Investigation Results
• Worksheet 2: Materials Survey Results by Number of Service Connections for each
Plumbing Materials Type
• Worksheet3: Summary of Material Survey Results
Revised LCR Monitoring and Reporting Guidance 26
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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 Tier 1 Sampling Sites
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 (e.g.,
homeowner denies permission for you to collect a sample), you must 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 must complete your sampling pool with Tier 3 sites.
• Any water system that cannot complete its sampling at sites that meet the applicable tier
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 available site that is served by a lead service
line.
• 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.
Revised LCR Monitoring and Reporting Guidance 27
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EXAMPLE: Selecting Tiered Sites
* A water system serving 3,301 to 10,000 people is on standard monitoring.
* It is required to collect tap samples for a total of 40 sites, 20 of which must be
from sites served by a lead service line.
* After reviewing its records (refer back to "Sources of Information that You Should
Review"), the water system can identify only 12 sites served by lead service lines.
* It must collect a tap sample from each of these available sites and the remaining 28
samples from other Tier I sites.
* If an insufficient number of Tier I sites are available, the system must use Tier 2
sites, followed by Tier 3 sites, and lastly by representative sites.
Note: Refer back to Exhibits 11-2 (standard monitoring) and 11-3 (reduced monitoring) to
identify the appropriate number of sites for your system size.
If You Cannot Use Original Sampling Site
If you cannot gain access to an original sampling site during any subsequent monitoring period (e.g.,
homeowner no longer wishes to participate in the sampling program), you must 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, and you must report any sampling site changes
when submitting data.) Form 141-A in Appendix D provides you with an easy-to-follow format for
tracking sample site identification and certification.
G. How Do I Collect Lead and Copper Tap Water Samples?
(40CFR I4l.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 six hours (e.g., no flushing, showering, etc). However, make sure it is a tap that is
used regularly, and not an abandoned or infrequently used tap.
• If your water system is a NTNCWS or CWS (such as a prison or hospital) that does not
have enough inside taps where the water stands unused for at least six hours, you are
allowed to use interior taps from which water is typically drawn for consumption and
which are the most likely to have remained unused for the longest period of time. Your
State 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 draw samples.
Revised LCR Monitoring and Reporting Guidance 28
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First-draw samples collected at single-family residences must always be drawn from the
cold-water kitchen tap or bathroom tap.
First-draw samples collected from buildings other than single-family homes must always
be drawn from an interior tap from which water is typically taken for consumption.
You may allow residents to collect samples, but you must supply the residents with
instructions as to the sample collection procedures. You can use the revised instruction
form provided in Appendix D (refer to FYI box below). Be sure to properly label
sample bottles prior to distributing them to residents.
This instruction form was revised as pan ofEPA's October 20, 2006, Memorandum: Management
of Aerators during Collection of Tap Samples to Comply with the Lead and Copper Rule. This
memorandum clarifies that water systems should not instruct customers to remove or clean
aerators prior to or during the collection of tap samples for lead. Aerators are part of some faucet
assemblies and are used to introduce air into the water flow. Although not intended to remove
inorganic contaminants, screens that are part of the aerator may trap paniculate matter or debris
within the faucet. Removal and cleaning of the aerator is advisable on a regular basis. However, if
customers are only encouraged to remove and clean aerators prior to drawing a sample to test for
lead, the water system could fail to identify typically available contribution of lead from the tap, and
thus, fail to take additional actions needed to reduce exposure to lead in drinking water. A copy of
this memorandum is available at http://www.epa.gov/safewater/lcrmr/compliancehelp.html.
• 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 Section III for a more detailed discussion of WQP monitoring). In addition,
you will need to submit your monitoring information to your State within 10 days after
the end of the monitoring period (e.g., by October 10 for systems that monitoring during
June - September).
• 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.
H. What Are the Approved Methods for Analyzing Water
Samples for Lead and Copper?
The approved analytical methods for lead, copper, and all WQPs (pH, calcium, alkalinity, silica,
orthophosphate, conductivity, and temperature) are shown in Exhibit II-8. A summary of the
preservation protocols, sample containers, and maximum holding times for analysis is provided in
Exhibit II-9.
Revised LCR Monitoring and Reporting Guidance 29
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Exhibit 11-8: Approved Analytical Methods for the Lead and Copper Rule
Contaminant
Methodology l3
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-Ca D
3111 B
3120 B
Copper
Atomic absorption; furnace
Atomic absorption; direct aspiration
Inductively Coupled Plasma (ICP)2
ICP-Mass spectrometry2
Atomic absorption; platform2
Conductivity Conductance
200.7
200.8
200.9
D1688-95C
D1688-95A
D1125-95A
3113 B
3111 B
3120 B
2510 B
Lead
Atomic absorption; furnace
ICP-Mass spectrometry2
Atomic absorption; platform2
Differential pulse anodic stripping voltammetry
200.8
200.9
D3559-95A
3113 B
Method 100115
Orthophosphate*2
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
Revised LCR Monitoring and Reporting Guidance
30
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• 1-8: Approved Analytical Methods for the Lead and Copper Rule
Contaminant
Methodology l3
EPA
ASTM3
SM4
Other
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.
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.
4 18th 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 Association, 1015
Fifteenth Street NW, Washington, DC 20005.
5 Method 1-2601-90, 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 1-1030-85; I-
1601-85; 1-1700-85; 1-2598-85; 1-2700-85; and 1-3300-85. See Techniques of Water Resources Investigation of the U.S. Geological
Survey, Book 5, Chapter A-l, 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.
***
12 Unfiltered, no digestion or hydolysis.
13 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-fumace depositions are made.
***
15 The 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 (MDLs). 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. Further, 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.
Revised LCR Monitoring and Reporting Guidance
31
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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: First-Draw Tap, Distribution System, Source Water for Lead
and Copper, Source Water for WQPs, or Lead Service Line.
5. Sample Site Identifier: (3 Fields)
• Region of Distribution System.
• Subregion of Distribution System.
• 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, WQPs, or pH and Temperature (field
measurements).
11. Sample Site Street Address - for Water System Use.
12. Sample Collection Route - for Water System Use.
13. Tier Assignment and Presence/Absence of a Lead Service Line - for Water System Use.
(This information may be useful in case the location needs to be replaced "on the fly"
and allows the water system to maintain the correct type of locations included in the tap
sampling program.)
14. Water System Name.
15. 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.
Revised LCR Monitoring and Reporting Guidance 32
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Exhibit 11-9: Sample Handling Requirements for Lead, Copper, and
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
Container1
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 days
28 days
Test Immediately4
1 P = Plastic, hard or soft; G = Glass, hard or soft.
2 In all cases, samples should be analyzed as soon after collection as possible.
3 If nitric acid (HNOj) cannot be used because of shipping restrictions or is not used because homeowners are collecting
samples, the sample for analysis can be shipped to a laboratory where it must be acidified (generally to pH < 2 with
concentrated HNOj as soon as possible but not later than 14 days after sample collection. Samples 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 HNOj 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.
4 "Test Immediately" generally means within 15 minutes of sample collection. In the case of pH, the sample should be
measured as soon as the sample is taken and should be measured under closed system conditions, particularly if the
water is poorly buffered.
5 If HNOj 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 HNOj to pH < 2.
Revised LCR Monitoring and Reporting Guidance
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I. How Do I Evaluate My Results? (40 CFR I4l.80(c)(3) & I4l.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 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 five 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 (can also be
expressed as 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 9 (f percentile copper level against its action level
of1.3 mg/L. If jour 9Cfh percentile value is greater than 1' .3 mg/i^,jou have an exceedance.
If you are required to collect five 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.
If you are allowed under the Short-Term Revisions to collect fewer than five samples:
Step 1: Place lead or copper results in ascending order.
Step 2: Compare the highest sample value (this is considered to be your 90th percentile
level) against the lead or copper action level.
All valid sample results taken during the monitoring period must be included in your 90th percentile
calculations, unless a result has been invalidated (refer to Subsection II.J). If a sample is invalidated,
its replacement sample must be included in the 90th percentile calculation, unless it is collected
more than 20 days after the State invalidates the sample or outside the monitoring period
(whichever is later). Late samples (regular or replacement samples) cannot be included in the
calculation. Refer to Section II.J for additional information on sample invalidation.
Below are two examples to help demonstrate the 90th percentile calculation for systems that are
required to collect more than five 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
Revised LCR Monitoring and Reporting Guidance 34
-------
90th percentile level contains a decimal. This may happen when you collect more than the minimum
required number of samples.
In Example 1, a system serving 150 people is on
standard monitoring, and collects the minimum
number of required samples for its size category
(i.e., 10 samples). The 90th percentile level
corresponds to the 9th highest sample (i.e., 10
samples x 0.9). It does not exceed the lead action
level because its 90th percentile level is 0.015 mg/L,
which equals the lead action level. To have an
exceedance, the 90th percentile level must be greater
than 0.015 mg/L.
In Example 2, 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. The 90th percentile level is
10.8 (i.e., 12 samples x 0.9 = 10.8). Either rounding
or interpolation can be used to determine the 90th
percentile level when the sample that represents it is
not a whole number (see explanation below). Your State may specify which method you should use.
Using Rounding: EPA's policy is to:
1.
___-
Fvamnlo 1* 90th
y^^" ^^^" bAttlllLJIG •• 7V
IE E Whole Number
Sample Rank
1
2
3
4
5
6
7
8
9 (90th percentile)
10
Percentile Is a
Sample Value
0.000
0.000
0.002
0.005
0.005
0.006
0.006
0.010
0.015
0.020
Round down to the nearest whole number if the
decimal is 0.4 or lower.
2.
Round up to the nearest whole number if the
decimal is 0.5 or higher.
In this example, the 90th percentile level is 10.8, and
you would round up to 11. So, the sample that is
ranked 11th in the list (0.018 mg/L) is the 90th
percentile value that you compare to the relevant
action level. Thus, the system exceeds the lead
action level of 0.015 mg/L.
Using Interpolation: To determine the 90th
percentile level, using interpolation, you would:
1. Subtract the difference of the two samples
between which your 90th percentile falls. In this
example, the 90th percentile level is 10.8 so you
would 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.
Subtract the difference between the 90th
2.
'- Example 2: 90th Percentile
- Contains a Decimal
Sample Rank
1
2
3
4
5
6
7
8
9
10
10.8 (90th percentile)
11
12
Sample Value
0.000
0.000
0.002
0.005
0.005
0.005
0.006
0.006
0.010
0.014
0.018
0.020
percentile level ranking of 10.8 and the lower of the two sample rankings between which the 90'
percentile level falls or 10, for a difference of 0.8.
Revised LCR Monitoring and Reporting Guidance
35
-------
3. Multiply the difference of 0.004 mg/L (from Step 2) by 0.8 (from Step 3): 0.004 x 0.8 = 0.0032
mg/L (or 0.003 when rounded to the number of significant figures).
4. 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.
Thus, the 90th percentile lead level is 0.017 mg/L and the system exceeds the lead action level.
Your State may 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.
If you do not meet all three of these criteria, you must calculate the 90th percentile results yourself, and provide
them to the State.
Example 3: 90th Percentile Based
- on Less than 5 Samples
Sample Rank
1
2
3 (9&h percentile)
Sample Value
0.006
0.008
0.020
Example 3 shows how the 90 percentile value
is calculated under the Short-Term Revisions.
Assume a system has only three valid tap sites
that are used for human consumption. The
system serves 105 people and receives written
approval from its State to collect one sample
from each of its three sites. For systems that
are allowed to collect fewer than five samples,
the highest test result is the 90 percentile level.
In this example, the 90th percentile lead level is equal to the third highest sample result of 0.020
mg/L. Therefore, this system has a lead action level exceedance.
Please note that the Short-Term Revisions supersede the March 9, 2004, memorandum from
Cynthia C. Dougherty, Office Director for EPA's Office of Ground Water and Drinking Water, and
the November 23, 2004, memorandum from Benjamin Grumbles, Assistant Administrator for
EPA's Office of Water related to the 90th percentile calculation when the system has fewer than five
taps and the State allows a reduction in the number of samples. These memoranda stated that when
the minimum number of samples is not collected, the 90' percentile level is based on the number of
samples collected. For example, if 3 samples were collected, the 90th percentile level would be the
2.7th sample (i.e., 0.9 multiplied by the number of samples). The 90th percentile could be calculated
by rounding to the nearest whole number (the 3rd or highest sample result in this example) or by
interpolation (using the 2nd and 3rd sample results in this example). In addition, the water system
would be assigned a lead and copper tap monitoring and reporting violation and be subject to Tier 3
public notification requirements.
A copy of these memoranda can be downloaded at
httto://www.etoa.sov/safewater/lcrmr/comtoHancehelto.html.
Revised LCR Monitoring and Reporting Guidance
36
-------
'f you receive Stote permission to collect fewer than five samples, you are not in violation of your
monitoring requirements. Therefore, you would not be subject to public notification requirements.
J. What If the State Determines that My Samples Are Invalid?
(40CFR I4l.86(f))
The State can invalidate a lead or copper tap water sample if any one of the following is 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.
For the State to make this determination, you must provide your State with 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 jour State before requesting sample invalidation to determine whether it applies in jour
State.
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.
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. 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 system is on a six-month
monitoring schedule. It collects a replacement sample in July 2009 for one invalidated sample that
was collected during the January through June 2009 monitoring period. It cannot include this
replacement sample as part of its samples for the July through December 2009 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 your samples on
Revised LCR Monitoring and Reporting Guidance 37
If a replacement cannot be taken at the
same location, it must be taken at a
location other than one already used for
sampling during the monitoring period.
-------
October 15, 2009. You have until November 4, 2009 (i.e., 20 days after the State's invalidation
decision) to collect the replacement sample. You also need to submit the results of that replacement
sample to the State, along with recalculated 90th percentiles for lead and copper. Your State may
give you specific instructions for reporting when it notifies you of the invalidation(s).
'^ ° somP'e 's determined to be invalid, you cannot include it in your 90th percentile
calculations. However, the replacement sample must be included in the calculation,
provided this sample was collected no later than 20 days after the sample was invalidated
or by the end of the monitoring period (whichever of the two dates occurs later).
K. What If I Exceed an Action Level While on a Six-Month
Monitoring Schedule? (40 CFR !4l.86(d)(4)(vi)(B))
If the 90th percentile lead level exceeds 0.015 mg/L or if the 90th percentile copper level exceeds 1.3
mg/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) (refer to 40 CFR 141.87). Also refer to Section 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 180 days of the end
of the monitoring period in which the exceedance occurred (refer to 40 CFR 141.83(b)).
Refer to Section IV of this document for detailed information regarding source water
monitoring requirements. Form 141-D, Source Water Monitoring and Treatment, in
Appendix D 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 six months of the end of the monitoring period in which the
exceedance occurred 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 (refer to 40 CFR 141.81(e)(l)).
In addition, for lead action level exceedances, you must:
• Conduct public education (refer to 40 CFR 141.85 and the updated public education
guidance documents for CWSs and NTNCWSs that are available at
http://www.epa.gov/safewater/lcrmr/compliancehelp.html).
• If your system has never previously exceeded, or if the exceedance occurred after a
monitoring period without a lead exceedance, then delivery is due within 60 days of the
end of the monitoring period. If it is a continued exceedance, then repeated delivery is
Revised LCR Monitoring and Reporting Guidance 38
-------
required, depending on whether you are a CWS or NTNCWS and depending on the
form of public education delivery required (refer to 40 CFR 141.85 or the revised public
education guidance documents).
The State may extend this 60-day delivery deadline if you have begun your
public education activities before the end of the 60 days.
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
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 (refer to 40 CFR 141.84). Section V provides an overview of the lead service
line replacement requirements and a more detailed discussion regarding the related
monitoring and reporting requirements.
L. What Should I Do If I Exceed the Lead or Copper Action
Level or Have an Optimal Water Quality Parameter
Excursion During Reduced Monitoring? (40 CFR 141.80 &
I4l.86(d)(4)(vi))
Water systems on reduced monitoring must
return to standard lead and copper monitoring
if they: 1) serve 50,000 or fewer people,
exceed the copper action level, and the State
has not set Optimal Water Quality Parameter
Excursion (OWQPs); 2) exceed the lead action
level regardless of whether they meet their
OWQP specifications (new requirement under the
Short-Term Revisions); or 3) do not meet their
OWQP specifications for more than nine days
in a six-month period (i.e., have an excursion).
The Short-Term Revisions clarify that standard
monitoring for systems for which OWQPs
have been established must begin no later than
1 of the calendar year following the lead action
III for more information on WQPs).
EXAMPLE: Resuming Standard
Monitoring
A PWS meets its OWQP specifications but
exceeds the lead action level based on
samples collected during July 2009.
This PWS must resume standard lead and
copper tap monitoring beginning with the
six-month monitoring period of January-
June 30, 2010.
the six-month monitoring period beginning January
level exceedance or WQP excursion (refer to Section
In addition, if you exceed the lead or copper action level, 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) (refer to 40 CFR 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 no later than 180 days after the end of the
monitoring period during which the exceedance occurred (refer to 40 CFR 141.83(b)).
Revised LCR Monitoring and Reporting Guidance
39
-------
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 (refer to 40 CFR 141.84).
• Within 60 days of a lead action level exceedance, you must begin delivering your public
education program (refer to 40 CFR 141.85).
M. Can I Ever Resume A Reduced Monitoring Schedule? (40
CFR I4l.86(d)(4)(vi))
Yes, you can requalify for annual reduced monitoring if you meet the criteria specified in Subsection
II.D (Am I Eligible for Reduced Lead and Copper Tap Monitoring?). The Revisions specify that
annual monitoring will begin during the calendar year immediately following the end of the second
consecutive six-month monitoring period in which the system meets the reduced monitoring
criteria. The timing of this requirement is illustrated in Subsection II.E (When Must I Collect My
Samples If I Am on Reduced Monitoring?).
N. 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 if you meet the specific
criteria outlined in Subsection II.D.
O. Am I Required to Provide the Analytical Results to My
Consumers? (40 CFR I4l.80(g) & I4l.85(d))
The Short-Term Revisions add a new consumer notification requirement to 40 CFR 141.85(d) that
requires all water systems to provide consumers who occupy homes or buildings that are part of the
utility's monitoring program with their individual sample result when their drinking water is tested
for lead (including those who do not receive water bills). This notification is required irrespective of
whether the utility exceeds the lead action level and applies to each valid lead sample result
regardless of whether it is below the action level or detection limit. The consumer notice of lead tap
results will help occupants determine what actions to take to reduce their exposure to lead in
drinking water. Although some water systems may have provided customers with testing results,
they were not previously required by EPA to notify occupants of the lead levels found in their
drinking water.
Specifically, you must:
ERA recommends that the consumer
notice of lead tap results include the
90th percentile level if known prior to
the delivery deadline.
• In addition to the lead results, provide an
explanation of the health effects of lead,
steps consumers can take to reduce
exposure to lead in drinking water,
contact information for the water utility, the MCLG and the action level for lead, and the
definitions for these two terms from 40 CFR 141.153(c) of the CCR Rule.
Revised LCR Monitoring and Reporting Guidance 40
-------
Short-Term Revisions also impact your CCR requirements. Refer to
Subsection H in Section I for a discussion of these revised requirements.
Send the notice by mail or other State-
approved method (e.g., NTNCWSs can
post the results on a bulletin board in the
tested facility, if approved by the State).
Provide the consumer notice of lead tap
results to your consumers within 30 days
of when you learn of the results.
Provide this notice to each individual unit
that was tested (i.e., notification does not
need to extend to the entire building), where testing occurs in buildings with many units:
Submit to the State a sample copy of the consumer notice of lead tap results and a
certification that you met your delivery requirements (refer to 40 CFR 141.90(f)(3)). For
example, if you sent out 10 notices, you only need to provide a copy of one of these
notices and one certification for these 10 notices. Appendix E provides a sample
consumer notice of lead tap results certification form that you can adapt for your use.
A separate lead consumer notice of
lead tap results must be provided for
each lead test result.
Thus, a water system that collects 10 samples
must provide 10 separate notices within 30
days of receiving each result This notice should
include the test result that is specific to that
home or building (i.e., do not provide all 10
lead results to each home/building).
Although the requirements to notify consumers of their lead tap results have been added to 40
CFR 141.85, they are distinct from other public education requirements. They apply to all
CWSs and NTNCWSs, including those with 90th percentiles at or below the lead action level of
0.015 mg/L. A violation of the consumer notice of lead tap results is a reporting violation and
does not trigger public notification. On the other hand, a public education violation is a
treatment technique violation and triggers Tier 2 public notification.
Templates for consumer notice of lead tap results are available in the CWS and NTNCWS
public education guidance documents. The suggested language includes both the individual
lead result and the 90th percentile level. A copy of these guidances can be downloaded at
httto://www.etoa.sov/safewater/lcrmr/comtoliancehelto.html
P. What Lead and Copper Tap Monitoring and Related
Information Must I Report to the State? (40 CFR I4l.90(a), (f), &
Within 10 days of the end of the monitoring period, you must report:
• 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. Your State may elect to do this for you. However, if the
State has not contacted you about this, you are responsible for these calculations.
Revised LCR Monitoring and Reporting Guidance
41
-------
Written explanation for any changes in sampling location (e.g., if homeowners no longer
allow sampling from their taps or if a location no longer qualifies as Tier 1 because of
plumbing renovations.)
The Revisions clarify that the end of the monitoring period for systems on reduced lead and
copper tap or reduced WQP tap monitoring is the last date on which samples can be collected
during that period. For most systems on reduced lead and copper tap monitoring, the last day
samples can be collected is September 30 (if the State has not designated an alternate period).
Therefore, the above reporting requirements are due to the State no later than October 10 of the
year in which the samples were collected (compared to January 10 of the following year).
Water systems that are subject to the public education requirements (i.e., they exceed the lead action
level during their most recent monitoring period), must provide the following written
documentation to the State. This information is due within 10 days after the end of each period in
which they are required to perform public education tasks.
• A demonstration that they have delivered public education materials that meet the
content and delivery requirements of the rule; and
• A list of all the newspapers, radio stations, television stations, and facilities and
organizations to which they delivered public education materials during the period in
which the system was required to perform public education tasks. Note: See "Reporting
No Longer Required by the 2000 LCRMR" be Ion1 for an explanation of when submitting this
distribution list may not be required.
Reporting No Longer Required by the 2000 LCRMR
To reduce reporting burden, the 2000 LCRMR removed some of the system reporting requirements
that EPA considered non-critical to the protection of public health. States were not required to
adopt the following provisions into their State regulations. Therefore, please check with your State
to determine whether the reporting requirements apply. Note that the Short-Term Revisions have
not modified any of these requirements.
The 2000 LCRMR removed the requirement for systems to provide the State with 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 lead and copper tap monitoring schedule when
you meet your optimal WQPs (under 40 CFR 141.86(d)(4)).
Revised LCR Monitoring and Reporting Guidance 42
-------
In addition, the 2000 LCRMR allowed NTNCWSs or CWSs (such as a prison or hospital) that do
not have enough inside taps where the water stands unused for at least six hours, to use inside taps
that are the most likely to have remained unused for the longest period of time. The State had the
option to determine whether these systems must receive prior approval to collect non-first draw
samples, or whether they can submit documentation that identifies each site and length of standing
time for the samples collected at these sites with their sample results. Unless a water system makes
additional changes to its sampling plan during subsequent monitoring periods, this was a one-time
reporting requirement.
For water systems that are delivering public education, the 2000 LCRMR allows them to forego
submittal of the distribution list if: they have previously submitted this information to the State, the
distribution list has not changed, they certify that the public education materials were distributed to
the same list submitted previously, and the State does not require this information.
Requirements Modified or Added by the Short-Term Revisions
:s
The lead consumer notice and certification
requirements apply to all systems regardless
of their lead levels.
Consumer Notice of Lead Tap Results:
As discussed in Subsection II.O, you must
provide a consumer notice of lead tap results
to people served at the specific sampling site
from which a lead and copper tap sample was collected, even if your lead 90th percentile did not
exceed the action level or the sample results are non-detects. In addition, the Short-Term Revisions
add a reporting requirement in 40 CFR 141.90(f)(3), which requires you to submit a sample copy of
the lead consumer notice of lead tap results and a certification to the State that you have met the
delivery requirements for this notice. This information is due to the State within three months
following the end of the monitoring period (i.e., by December 31 for systems on a reduced
monitoring schedule).
Change in Long-Term Treatment or Addition of a New Source: Previously, water systems on
reduced monitoring (including (b)(3) systems and those on monitoring waivers) were required to
report changes in treatment or addition of a new source but were not required to receive prior State
approval before implementing these changes or additions. The Short-Term Revisions modify this
requirement by specifying that these changes must be long-term in nature and that the State must
approve the treatment change or new source before it can be implemented. The Revisions require
that you notify your State in writing at a time specified by your State or if your State does not specify
a date, to notify your State as soon as possible prior to adding a new source or implementing the
change.
A change in treatment or source may necessitate a change in OWQP
specifications and corrosion control treatment plans.
40 CFR 141.90(a)(3) (of the Revisions) also provides examples of long-term treatment changes.
These examples include the addition of a new treatment process or modification of an existing
treatment process such as:
Revised LCR Monitoring and Reporting Guidance 43
-------
Switching secondary disinfectants (e.g.,
chlorine to chloramines),
Switching coagulants (e.g., alum to ferric
chloride),
Long-term treatment changes
would not include chemical dose
fluctuations associated with daily
raw water quality changes.
• Switching corrosion inhibitor products (e.g.,
orthophosphate to blended phosphate), and
• Changing the dosage of existing chemicals if the system is planning long-term changes to
its finished water pH or residual inhibitor concentration.
Additional examples of long-term treatment changes include the installation of membrane filters,
ozonation, and enhanced coagulation/enhanced softening to reduce disinfectant by-product
precursors. Other treatments to consider are those processes or combinations of processes that can
greatly affect the pH, oxidation-reduction potential, alkalinity, or the major composition of the ionic
background of the water. These include:
• Initiation of an aeration process (e.g., for radon removal).
• Initiation of disinfection.
• Installation of oxidation/removal process for iron, manganese, hydrogen sulfide,
ammonia, and other similar contaminants, in a system previously having minimal or no
disinfectant residual. Examples include aeration and filtration, permanganate addition,
breakpoint chlorination, greensand, or biologically-active filtration followed by
disinfection.
• Change from lime softening to ion exchange softening (alkalinity may increase greatly,
causing corrosivity), particularly in ground water systems (more likely to have high
alkalinities and thence, copper problems).
• Change from orthophosphate inhibition to pH/alkalinity adjustment as a corrosion
control treatment strategy, or vice versa.
• Installation of sorptive or ion-exchange media for arsenic, radionuclide, or other
contaminant removal that requires or is operated in such a way as to cause a pH
decrease.
Examples of source additions include, but are not limited to:
(1) Shifting from ground water to surface water supply.
(2) Adding any new source to a system that has different general background water quality.
Examples include:
• Switching source types.
• Adding a treated surface water to a ground water only system.
• Adding a new well from an aquifer with different water quality characteristics
pertinent to corrosivity (e.g., alkalinity, pH, chloride, sulfate) than the current supply.
Regularly changing among sources on a seasonal or interannual basis that
have been covered by previous LCR OCCT studies and sampling and are
covered within the OCCT designation framework, do not require notification.
Revised LCR Monitoring and Reporting Guidance 44
-------
The March 2007, "Simultaneous Compliance Guidance Manual for the Long Term 2 and
Stage 2 DBF Rules," can assist you in identifying those situations where optimal corrosion
control can be affected by long-term changes in treatment or source water. This
document is available at: httto://www.etoa.sov/safewater/lcrmr/comtoHancehelto.html.
Q. What Should I Do If I Sell Water To, or Buy Water From,
Another Water System? (40 CFR 141.29)
EPA's position on the consolidation of sampling requirements under the LCR was stated in a
January 10, 1992, memorandum, entitled "Consecutive Systems Regulated under the National Primary
Drinking Water Regulations for Lead and Copper" (EPA. water supply guidance 8 5A). 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 40 CFR 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 40 CFR 141.81 and 141.82; and
• Lead service line replacement.
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.
Revised LCR Monitoring and Reporting Guidance 45
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3. How the following provisions will be modified:
• Determination of 90' 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.
In the preamble to the 1991 LCR, EPA 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.
As previously discussed, the Short-Term Revisions add the consumer notice of lead tap monitoring
results (see Section I.H and II.P). The wholesaler and retailer(s) should coordinate to clearly identify
the role each party will have in fulfilling this requirement.
R. What Happens If I Do Not Fulfill My Lead and Copper Tap
Monitoring and Reporting or Consumer Notice of Lead Tap
Results Requirements? (40 CFR I4l.80(k))
If you do not meet all of the following lead and copper tap monitoring and reporting requirements
within the time frame specified by the rule, you are in violation:
• Use appropriate sampling procedures in accordance with 40 CFR 141.86(a) and (b);
• Collect the required number of samples during the specified time frame in accordance
with 40 CFR 141.86(c) and (d);
• Ensure samples are analyzed properly in accordance with 40 CFR 141.89(a);
• Submit all required monitoring information on time in accordance with 40 CFR
141.90(a);
• Report a change in long-term treatment or addition of a new source within the time frame
specified by the State or as soon as possible, or to receive State approval before
implementing the change or addition, as required by 40 CFR 141.90(a)(3). Note: This
requirement applies only to systems on reduced lead and copper tap monitoring including (b)(3) systems
and those on a monitoring waiver.
Depending on whether the State adopted the following provisions that were introduced under the
2000 LCRMR, 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 40 CFR
141.86(f)(4) where these samples are needed to meet minimum sampling requirements;
• Meet the conditions of your monitoring waivers in 40 CFR 141.86(g) or provide the
required information in 40 CFR 141.90(a)(4)(n)-(iv);
• Provide sample information needed for your State to perform the 90th percentile
Revised LCR Monitoring and Reporting Guidance 46
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calculation as outlined in 40 CFR 141.90(h);
• Collect non-first draw samples that did not meet the criteria in 40 CFR 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 40 CFR 141.86(d)(4)(iv)(B).
If you do not meet all of the following requirements for consumer notification of lead tap results
within the time frame specified by the rule, you are in violation:
• Provide the following information specified in 40 CFR 141.85(d)(3) to individuals whose
taps were used to collect lead and copper compliance samples: the results of lead tap
water monitoring for the tap that was tested an explanation of the health effects of lead,
steps consumers can take to reduce exposure to lead in drinking water, contact
information for the water utility, the MCLG and the action level for lead, and the
definitions for these two terms from 40 CFR 141.153(c) of the CCR Rule;
• Provide this notification within 30 days of learning the results, as specified in 40 CFR
141.85(d)(2);
• Send this notice by mail or other State-approved method, as required by 40 CFR
141.85(d)(4);and
• Submit to the State a sample copy of the notification and a certification that you met the
delivery requirements within 3 months following the end of the applicable monitoring
period, as required by 40 CFR 141.90(f)(3).
If you are out of compliance, you must:
1. Report the violation to the State within 48 hours of determining the noncompliance
(refer to 40 CFR 141.31 (b)).
2. Deliver public notification to your customers (refer to 40 CFR 141.201 & 141.203 -
141.206 and additional information, available at
(http://www.epa.gov/safewater/publicnotification/index.html).
3. Include a discussion of the violation in your CCR if you are a CWS, (refer to 40 CFR
141.153 and additional information, available at
(http://www.epa.gov/safewater/ccr/index.html). Note: This CCR requirement is unrelated
to the new 40 CFR 141.154 provision that requires all CWSs to provide a short informational notice
about lead in their CCR (also refer back to Subsection H in Section I for more information).
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
CCR 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
Revised LCR Monitoring and Reporting Guidance 47
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the State may revoke your waiver. You can reapply at a later date when you again meet
the eligibility requirements for a waiver.
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.
S. What Provisions of the Short-Term Revisions Pertain to
Lead and Copper Tap Monitoring and Corrosion Control
Treatment Requirements?
Exhibit 11-10 summarizes each of the revisions that impact your lead and copper tap monitoring
requirements and corrosion control treatment schedule. Those revisions that impact your WQP,
source water treatment, or lead service line replacement requirements can be found in Sections III -
V, respectively.
If you own or operate a water system on Tribal lands (other than the Navajo Nation), in Wyoming,
or the District of Columbia, the Federal version of the LCR applies to you. Therefore, you were
required to implement the following provisions beginning April 7, 2008. Water system owners or
operators in other States should check with their Primacy Agencies to determine when these
provisions will be in effect.
Exhibit 11-10: Revisions to Lead and Copper Tap Monitoring and Reporting
Requirements and Corrosion Control Treatment Schedule
CFR Citation
New Requirements under the
Short-Term Revisions
Previously Required under the 1991
Rule as Amended by LCRMR
Lead and Copper Monitoring and Reporting Requirements
§141.80(c)(3)(v)
§141.80®
§141.81(b)(3)(iii)
§141.86(c)
For systems permitted by their State to
collect fewer than five samples in
accordance with 40 CFR 141.86(c), the 90*
percentik value is the highest concentration.
Systems must provide notice of lead tap
sampling results to persons served at the
sites that are tested.
(b) (3) systems must report any upcoming
long-term change in treatment or addition of
a new source to the State and must receive
prior approval before implementing the
change or addition.
Systems with fewer than five drinking
water taps must collect at least one sample
from each tap and additional samples from
those taps on different days to meet the
required number of sites. Alternatively,
States may permit these systems to collect
Systems were required to collect a
minimum of five tap samples.
Systems were not required to notify
individual homeowners of their tap
monitoring results.
(b) (3) systems were required to report
changes in treatment or addition of a new
source but the Rule did not limit reporting
of treatment changes to those that were
"long-term" changes. Also, prior State
approval was not needed before
implementing the change or addition.
Systems were required to collect a
minimum of five tap samples.
Revised LCR Monitoring and Reporting Guidance
48
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xhibit 11-10: Revisions to Lead and Copper Tap Monitoring and Reporting
Requirements and Corrosion Control Treatment Schedule
CFR Citation
New Requirements under the
Short-Term Revisions
Previously Required under the 1991
Rule as Amended by LCRMR
fewer than five tap samples if all available
drinking water taps are sampled. State
must approve this in writing.
§141.86(d)(4)(i)
Small or medium systems collecting fewer
than five tap samples, and do not exceed
the lead and copper action levels during
two consecutive six-month monitoring
periods may reduce sampling to annually,
beginning in the next calendar year.
Systems cannot reduce the number of tap
samples to less than one per available tap.
Systems were required to collect a
minimum of five tap samples. Systems
were permitted to reduce monitoring to
once per year, but the Rule did not specify
when reduced monitoring would begin.
§141.86(d)(4)(ii)
Systems that do not exceed the lead action
level and that meet OWQP specifications
during two consecutive six-month
monitoring periods may reduce sampling to
annually, beginning in the next calendar
year.
Systems that had a lead and/or copper
action level exceedance could monitor
annually if they met their OWQP
specification for two consecutive six-
month monitoring periods. The Rule did
not specify when this reduced monitoring
would begin.
§141.86(d)(4)(m)
Systems that do not exceed the lead action
level and that meet OWQP specifications
during three consecutive years of
monitoring may reduce sampling to
triennially. Note: The Revisions retain the
provision for medium and small systems to qualify
for triennial monitoring if they do not exceed an
action level for three consecutive years of annual
monitoring.
Clarifies that triennial monitoring must be
conducted no later than every third
calendar year.
Systems that had a lead and/or copper
action level exceedance could monitor
triennially if they met their OWQP
specification for three consecutive years of
monitoring.
The Rule did not specify that triennial
monitoring was to be conducted no later
than every third calendar year.
§141.86(d)(4)(iv)
(A)
Systems that are on a State-specified four-
month period must begin monitoring
during the calendar year immediately
following the end of the second six-month
monitoring period, or the end of the three-
year period for triennial monitoring.
The Rule did not specify when annual or
triennial monitoring must begin for a
system on a State-specified alternate four-
month monitoring schedule.
Revised LCR Monitoring and Reporting Guidance
49
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xhibit 11-10: Revisions to Lead and Copper Tap Monitoring and Reporting
Requirements and Corrosion Control Treatment Schedule
CFR Citation
New Requirements under the
Short-Term Revisions
Previously Required under the 1991
Rule as Amended by LCRMR
§141.86(d)(4)(vi)
(B)
Systems on reduced monitoring that
exceed the lead action level or exceed
OWQPs for more than nine days in any
six-month period must return to standard
monitoring (two consecutive six-month
samples).
The monitoring begins no later than the
six-month period beginning January 1 of
the calendar year following the lead action
level exceedance or OWQP excursion.
The Rule did not require systems to return
to standard monitoring if they met their
OWQPs but exceeded the lead action
level.
The Rule did not specify when standard
monitoring would begin.
§141.86(d)(4)(vi)
Clarifies that a return to annual sampling
begins in the calendar year following the
end of the second consecutive six-month
monitoring period in which the system was
at or below the lead action level and met its
OWQP specifications.
The Rule did not specify when reduced
monitoring would begin.
§141.86(d)(4)(vn)
Any system on reduced monitoring must
report any upcoming long-term change in
treatment or addition of a new source to
the State and must receive prior approval
before implementing the change or
addition.
Systems were required to report changes in
treatment or addition of a new source but
the Rule did not limit reporting of
treatment changes to those that were
long-term" changes. Also, prior State
approval was not needed before
implementing the change or addition.
§141.86(g)(4)(i)
Systems with a nine-year tap monitoring
waiver must collect samples no later than
every ninth calendar year.
The Rule did not specify that this
monitoring was to be conducted every
ninth calendar year.
§141.86(g)(4)(m)
Systems on a monitoring waiver must
report any upcoming long-term change in
treatment or addition of a new source to
the State and must receive prior approval
before implementing the change or
addition.
Systems were required to report changes in
treatment or addition of a new source but
the Rule did not limit reporting of
treatment changes to those that were
"long-term" changes. AJso, prior State
approval was not needed before
implementing the change or addition.
§141.90(a)(l)
Clarifies that for monitoring periods of less
than six months (e.g., four-month tap
monitoring), the end of the monitoring
period is the last date samples can be
collected during that period (e.g., Sept. 30).
The Rule did not include this clarification.
Revised LCR Monitoring and Reporting Guidance
50
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xhibit 11-10: Revisions to Lead and Copper Tap Monitoring and Reporting
Requirements and Corrosion Control Treatment Schedule
CFR Citation
New Requirements under the
Short-Term Revisions
Previously Required under the 1991
Rule as Amended by LCRMR
§141.90(a)(3)
Systems on reduced monitoring (including
(b)(3) systems or those on monitoring
waivers) must notify their State in writing,
at a time specified by their State, or as soon
as possible before adding a new source, or
changing long-term treatment processes.
States must review and approve new source
additions and long-term treatment changes.
This section also provides examples of
long-term treatment changes.
Systems were to notify their State within
60 days after adding a new source or
making a treatment change, and were
encouraged to notify their State before
making this addition or treatment change.
The Rule did not limit the reporting of
treatment changes to those that were
long-term" changes.
§141.90(f)(3)
Systems must mail a copy of the consumer
notification of lead tap results with a
certification that the notice was distributed
as required to its State no later than three
months after the end of the monitoring
period.
The Rule did not require lead consumer
notice or the corresponding State
reporting requirement.
Corrosion Control Treatment
Systems exceeding the lead or copper
action level must recommend optimal
corrosion control treatment within six
months after the end of the monitoring period
during which the exceedance occurs.
Systems were required to submit this
recommendation within six months after
exceeding an action level.
§141.81(e)(2)
States may require systems to perform a
corrosion control study within 12 months
after the end of the monitoringperiod during which
the exceedance occurs.
States were required to make this decision
within 12 months after the exceedance
occurred.
States will specify optimal corrosion
control within 18 months after the end of the
monitoringperiod during which the exceedance
occurs for medium systems that are not
required to perform a study.
States were required to make this decision
within 18 months after the exceedance
occurred.
§141.81(e)(2)(n)
States will specify optimal corrosion
control within 24 months after the end of the
monitoringperiod during which the exceedance
occurs for small systems that are not
required to perform a study.
States were required to make this decision
within 24 months after the exceedance
occurred.
Revised LCR Monitoring and Reporting Guidance
51
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T. What Provisions of the Short-Term Revisions Pertain to
Consumer Notice of Lead Tap Results and CCR
Requirements?
Exhibit 11-11 summarizes each of the revisions that impact your consumer notice of lead tap results
and CCR requirements. Those revisions that impact your public education requirements are
highlighted in Subsection I.H. In addition, EPA has developed guidance documents that provide
detailed information and templates
to help you comply with the
revised public education and CCR
requirements, and the new lead
consumer notice of tap results.
Remember if you own or operate a water system on Tribal lands (other than the Navajo Nation), in
Wyoming, or the District of Columbia, the Federal version of the LCR applies to you. Therefore,
you were required to implement the following provisions beginning April 7, 2008. Water system
owners or operators in other States should check with their Primacy Agencies to determine when
these provisions will be in effect.
These documents are listed in Appendix A and are
available at EPA's Web site:
httt>://www.et>a.sov/safewater/lcrmr/comt>liancehelt>.html
Exhibit II-1
Tap Results and Revisions to Consumer
onfidence Report Requirements
CFR Citation
New Requirements under the
Short-Term Revisions
Previously Required under the 1991
Rule as Amended by LCRMR
Consumer Notice of Lead Tap Results
§141.80(g);
40 CFR 141.85(d)
PWSs must provide lead tap sampling
results, lead health effects language, steps to
reduce exposure, contact information, and
the lead MCLG and AL values and
definitions to persons served at tested sites
within 30 days of learning of results.
PWSs were not required to notify
individual homeowners of their tap
monitoring results.
§141.90(t) (3)
PWSs must provide the State with a sample
consumer notification and certification of
its proper delivery within 3 months after the
end of the applicable monitoring period.
Rule did not require lead consumer notice
or the corresponding State reporting
requirement.
Consumer Confidence Report
§141.154
All CWSs must provide information in
their CCRs on lead in drinking water
irrespective of whether they detected lead
in any of its samples. Revisions also
provide mandatory language that clarifies
the risk of lead in drinking water, include
basic steps on how to reduce exposure to
lead in drinking water, provide sources of
additional information, and add EPA's
Web site as an information source.
Only CWSs that detected lead above the
action level in more than 5 percent of the
homes sampled were required to provide a
short informational statement. The CCR
Rule included suggested language that was
less specific about the risks of lead in
drinking water, possible sources of lead,
and the types of information that are
available from EPA.
Revised LCR Monitoring and Reporting Guidance
52
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U. What Key Points Should I Remember About Lead
and Copper Tap Monitoring? (40 CFR 141.81 & 141.86)
1—^
90th Percentile Levels Calculations and Follow-up Actions
.•f All CWSs and NTNCWSs must conduct lead and copper tap monitoring.
-f Lead and copper analytical results are evaluated against an action level, not an MCL.
-•>. No more than 10 percent of your samples can exceed the lead action level of 0.015 mg/L or copper
action level of 1.3 mg/L. This is determined by calculating the 90th percentile level.
The 90th percentile is determined by multiplying the number of all valid samples by 0.9 (e.g., 10
samples x 0.9 = 9 or the 9th highest sample result). For 5 samples, it is the average 4th and 5th highest
results, for fewer than 5 samples, it is the highest result.
-•f An action level exceedance is not a violation (thus, no public notification) but triggers other actions.
-•>• A lead action level exceedance triggers corrosion control treatment, source water monitoring, public
education, and lead service line replacement (if the exceedance continues after treatment).
w A copper action level triggers corrosion control treatment and source water monitoring.
••'. You must initiate corrosion control treatment steps if you serve more than 50,000 people and you are
not a (b)(2) or (b)(3) system, regardless of whether you have an action level exceedance.
--f If you serve 50,000 or fewer people, you can stop corrosion control treatment steps when you are at
or below both action levels for two consecutive six-month monitoring penods. You must
recommence these steps if you again exceed either action level, beginning with the last uncompleted
step, or as specified by the State in writing. However, if you have installed corrosion control
treatment, you must continue to operate it in compliance with your OWQP specifications.
Site Selection and Sampling Procedures
t:. You must sample at Tier 1 sites. If an insufficient number of Tier 1 sites exist, then use Tier 2,
followed by Tier 3 sites, and finally by representative sites. (Note: Tier 3 sites only apply to CWSs.)
If you have lead service lines in your distribution system, you must collect at least half of your
samples from sites served by available lead service lines. If you have none, but you have lead
goosenecks or pigtails, you can collect tap water samples at sites with goosenecks and/or pigtails.
•if 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 have fewer than five taps that are used for human consumption, you must collect more than
one sample from the same location on different days to obtain five samples, unless your State allows
you to collect one sample from each of these taps.
--f 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 six hours (except as noted below).
If you do not have enough inside taps that have been unused for at least six hours, your State may
allow you to sample inside taps that have remained unused for the longest period of time.
-•f You should sample early enough in the monitoring period in case WQP samples are required and to
meet your reporting deadline (e.g., October 10 is the deadline for most systems on reduced
monitoring).
If a tap has an aerator, it should not be removed prior to sample collection.
Revised LCR Monitoring and Reporting Guidance 53
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Reduced Monitoring
-•! If you serve more than 100 people and qualify for monitoring at a reduced frequency of annually,
triennially, or every nine years, you are required to collect half as many samples as standard monitoring.
-•>• If you serve 50,000 or fewer people, you qualify for reduced annual monitoring if you have two
consecutive six-month periods at or below both action levels.
If you serve 50,000 or fewer people, you can qualify for triennial monitoring if you have three
consecutive years of monitoring at or below both action levels. Your first year of annual monitoring can
count as the first year of the three years needed to qualify for triennial monitoring.
-•! Regardless of the number of people that you serve, you can qualify for annual reduced monitoring if you
are in compliance with your OWQP specifications, do not exceed the lead action level for a minimum of
two consecutive six-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: 1) you meet your OWQPs and are at or below the lead action level for three
consecutive years of monitoring; or 2) your 90th percentile lead level is <_ 0.005 mg/L and 90th percentile
copper level is < 0.65 mg/L, for two consecutive six-month periods (if the State has adopted this provision).
-•! If you serve 3,300 or fewer people, you can monitor once every nine years at the reduced number of
sites, if your State has adopted this provision and you qualify for a monitoring waiver.
If you are on reduced monitoring, you must collect your samples during June through September in the
same calendar year unless the State has designated an alternate monitoring period.
The monitoring period is the specific period in which you must conduct your required monitoring (e.g.,
June through September for most water systems on reduced monitoring).
Triennial and nine-year monitoring must be collected no less frequently than every three years and nine
years, respectively.
Reporting
If you are on a reduced lead and copper tap monitoring schedule, you must notify your State as soon as
possible if you plan to add a source or make a long-term change to your treatment. Your State may
specify the timing of this advanced notice.
-1 Your State must approve the new source or long-term treatment change before you implement them.
•^ You must notify consumers of lead sampling results collected from their home (or business) within 30
days of being notified of the results, regardless of whether theses results are less than the lead action
level or are non-detects.
You also must provide your State with a sample copy of this consumer notice of lead tap results, and a
certification that it meets the rule requirements no later than three months from the end of the
monitoring period.
If you are a CWS, you must provide information in your CCRs on lead in drinking water irrespective of
whether you detected lead in any of your samples. You also must use the amended language in 40 CFR
141.154 or your own educational statement after consultation with the State.
Revised LCR Monitoring and Reporting Guidance 54
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SECTION III: WATER QUALITY PARAMETERS
MONITORING AND REPORTING REQUIREMENTS
A. What Is The Purpose of Collecting Water Quality
Parameter (WQP) Samples? (40 CFR 141.87)
WQPs are used to determine the corrosivity of the water, and if needed, to help the State to
determine the type of corrosion control that a 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
See Exhibit 111-6 for a summary of Revisions that impact water quality parameter
monitoring and reporting requirements.
B. Which Systems Must Collect Water Quality Parameter
Samples? (40 CFR 141.87)
If your water system serves more than 50,000 people, you must conduct some WQP monitoring.
However, if you can demonstrate that your water system has minimal levels of corrosion entering
the distribution system based on lead and copper source and tap water samples (i.e., you are a (b)(3)
system), you are only required to conduct WQP monitoring during the same two consecutive six-
months in which you conducted initial lead and copper tap monitoring. Refer back to Subsection I.Efor
the specific (b)(3) criteria.
If your water system serves 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.
Revised LCR Monitoring and Reporting Guidance 55
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C. When Do I Collect Water Quality Parameter Samples? (40
CFR I4l.87(b)-(e))
WQP monitoring can be divided into three phases:
• Initial WQP monitoring;
• Follow-up monitoring that occurs during two consecutive six-month monitoring periods
immediately 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.
Initial WQP 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 your water system serves more than 50,000 people, you were required to conduct WQP
monitoring during the same two consecutive six-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 1 through
December 31, 1992.
If your water system serves 50,000 or fewer people, and exceeds the lead and/or copper action
level, you must monitor before the end of the six-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 six-month
monitoring period.
Exhibit III-l below illustrates the timing for systems serving 50,000 or fewer people that were in
existence prior to January 1992.
Revised LCR Monitoring and Reporting Guidance 56
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•33!
mill imFl! \ L*\ U IW« II 1 1 * J i iTJ u i-1 RT«^vi4< J MM 1
Serving 50,000 and Fewer People
If you serve...
3,301 to 50,000 people
25 to 3,300 people
And you exceeded the lend or copper action
level during the. . .
1st monitoring period of July - December 1992
2nd monitoring period of January -June 1993
1st monitoring period of July - December 1993
2nd monitoring period of January - June 1994
You were required to collect
WQP samples during...
July - December 1992
January - June 1993
July - December 1993
January - June 1994
Note: If your water system is new, the State will specify when you must begin initial lead and copper tap monitoring.
WQP samples must be collected before the end of the six-month initial tap monitoring period(s) during which an
action level is exceeded.
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:
• two sets of samples at each of
the number of distribution system tap sites specified in Exhibit III-2; and
• two sets of samples at each entry point to the distribution system.
:t 111-2: Standard Number of
"Tap" Sites and Sample
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)
10
No. of Samples
(2 per site)
50
20
As an example, assume a system serving 50,200 people has three entry points. The regulation
requires the system to collect two sets of distribution samples at 10 sites and two sets of samples at
each entry point to the distribution system. Therefore, during July through December 1992, these
systems would have collected 20 sets of WQP tap samples and 6 sets of entry point samples.
During January through June 1993, the system would have collected the same number of entry point
and WQP samples.
Follow-up WOP Monitoring
Follow-up monitoring occurs in the 12 months immediately following the installation of corrosion
control treatment. These samples are collected during the same two consecutive six-month
monitoring period(s) as follow-up lead and copper tap monitoring.
Revised LCR Monitoring and Reporting Guidance 57
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If your water system serves more than 50,000 people, you were required to conduct this
monitoring during two consecutive six-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 discussed in Subsection I.E, (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 your water system serves 50,000 or fewer people, WQP monitoring is only required during
each of the six-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 two sets of samples at each of the number of WQP sites specified in Exhibit III-2,
during each of two consecutive six-month monitoring periods for:
• 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 also must immediately begin taking one set of the following WQP samples at each entry point
at least once every two 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
...... two weeks.
When an inhibitor is used, a reading or
Once treatment has been installed,
entry point monitoring changes from
two sets of samples per entry point at
six-month intervals to one set of
samples per entry point at least every
the dosage rate of the inhibitor used and the concentration of orthophosphate or silicate
(whichever is used).
This option does not apply to initial
monitoring. You should first check with
your State to determine if it allows this
representative WQP monitoring.
After corrosion control treatment has been
installed, water systems that use ground water
exclusively can limit sampling points to those that
are representative of the water quality and
corrosion control treatment conditions throughout
the system if:
• This option is allowed by the State; and
• Prior to sampling, the water system demonstrates to the State that the selected sites are
representative.
Revised LCR Monitoring and Reporting Guidance 58
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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 six 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 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 Exhibit III-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 two
weeks.
If your water system serves more than 50,000 people and does 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., you
are a (b)(2) system), the State will designate OWQPs with which you must comply.
If your water system serves 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 two sets of samples every six months at the standard number of WQP tap
sampling sites that is specified in Exhibit III-2 for:
• pH;
• Alkalinity;
• Calcium, when calcium carbonate stabilization is used;
Revised LCR Monitoring and Reporting Guidance 59
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• Orthophosphate, when a phosphate-based inhibitor is used; and
• Silica, when a silicate-based inhibitor is used.
You must collect one 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 two 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).
The Short-Term Revisions clarify when the first six-month WQP monitoring period begins after the
State specifies OWQPs. Previously, this monitoring was to begin on the date the State specified
these values. Under the Revisions, large systems or those small or medium-sized systems that are on
standard lead and copper tap monitoring must begin WQP monitoring on either January 1 or July 1
(whichever comes first) after the State specifies the optimal values. For small or medium-size
systems that were on reduced lead and copper tap monitoring but exceed an action level, the
Revisions require the start of the six-month WQP monitoring period to coincide with the start of
the four-month monitoring period during which the exceedance occurred. This will allow small and
medium systems on reduced monitoring that exceed the action level an additional two months to
take WQP samples after the end of the four-month monitoring period in which they had to take
lead and copper tap samples (see example below). This provision is intended primarily for systems
that are not aware of the exceedance until the end of the lead and copper monitoring period.
However, those systems that are aware of the action level exceedance earlier in the four-month lead
and copper monitoring period should conduct their WQP monitoring when they learn of the
exceedance to better capture the water quality conditions at the time of the exceedance.
As described above, the six-month OWQP monitoring period is June I through November 30
for small or medium water systems that were on reduced lead and copper tap monitoring
when they exceeded the lead or copper action level. This compliance period should be used in
place of the July I - December 31 compliance period, that is recommended for these systems
on page 11 in the February 2001 guidance (EPA 815-R-99-019) "How to Determine
Compliance with Optimal Water Quality Parameters as Revised by the Lead and Copper Rule
Minor Revisions." Please note that the Short-Term Revisions do not revise the basic procedure
for assessing compliance with OWQPs as described in this February 2001 guidance (i.e.,
compliance is still based on six-month compliance periods).
Revised LCR Monitoring and Reporting Guidance 60
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EXAMPLE: Timing of WQP Monitoring for Small or Medium Systems
Exceeding an Action Level during Reduced Lead and Copper Tap
Monitoring
A water system exceeds the copper action level in tap samples collected between June and
September 2009.
The start of the six-month WQP monitoring period is June 1, 2009. (i.e., coincides with the
start of the monitoring period in which the exceedance occurred).
The system has until November 30, 2009, to collect its WQP samples, and until December 10,
2009, to report its results to the State.
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.
D. How Do I Select My Sampling Sites? (40 CFR I4l.87(a))
Distribution Samples
You must identify sampling sites in your distribution system that are 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 is specified in Exhibit III-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 retention 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.
Revised LCR Monitoring and Reporting Guidance 61
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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 are representative of typical water quality conditions in the distribution system.
Entry Point Samples
You must sample from each entry point to the distribution system (except those ground water
systems that can limit entry point monitoring to representative sites) to obtain a sample that is
representative of the source after treatment. If two or more sources are combined before
distribution, your sample must be representative of all sources used.
E. How Do I Collect Water Quality Parameter Samples? (40
CFR I4l.87(a))
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, the sources are combined before
distribution, and samples are not collected at the entry point to the distribution system, 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.
Revised LCR Monitoring and Reporting Guidance 62
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EPA's October 20, 2006, Memorandum: Management of Aerators during Collection of Tap
Samples to Comply with the Lead and Copper Rule, explains how samples should be collected if a
tap has an aerator. As previously discussed in Subsection II.G, screens that are part of aerators
may trap paniculate matter or debris within the faucet and should not be removed prior to
collecting lead and copper tap samples. Otherwise, water systems could fail to identify the
typically available contribution of lead from the tap, and thus, fail to take additional actions needed
to reduce exposure to lead in drinking water. This memorandum also clarifies that the aerator
should be removed, and the faucet outlet cleaned and thoroughly flushed to remove scale
particles, prior to collection of samples that may be monitored for pH and/or dissolved oxygen. A
copy of this memorandum is available at http://www.epa.gov/safewater/lcrmr/compliancehelp.html.
Parameter-specific Procedures
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. Measurements of pH 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 count as one set of samples;
thus, you must repeat this for each of your two entry point sample sets during initial monitoring, as
well as your two distribution ("tap") samples sets that are required during each WQP monitoring
period.
Revised LCR Monitoring and Reporting Guidance 63
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Please note that the State is not required to
use the OWQP compliance procedure that
was established under the 2000 LCRMR.
First check with your State to determine
when and if you should use this procedure
for assessing compliance with your OWQPs.
F. How Does the State Determine If I Am In Compliance
With My Optimal Water Quality Parameter Values? (40 CFR
I4l.82(g))
Prior to the 2000 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 three days of collecting the original sample.
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 two weeks. For tap WQP
monitoring, compliance was determined for the monitoring period in effect (i.e., six months, one
year, or three years).
Under the 2000 LCRMR, EPA revised the
procedure for calculating compliance with
OWQPs based on concerns raised by several
States and water systems. This approach has not
been modified by the Short-Term Revisions. 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.
Under the 1991 Rule, a water system was out of compliance if the results of any WQP sample, or
the average of the original sample and a confirmation sample, did not meet the State-designated
OWQP ranges or values. Another concern was that "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. The 2000 LCRMR no longer
allowed the use of confirmation samples.
Under the January 2000 LCRMR, compliance determinations are always based on a six-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 of the distribution system. Based on
the Short-Term Revisions that clarify the timing of WQP monitoring (refer back to previous
subsection) the six-month WQP periods will be January 1 through June 30 and July 1 through
December 31 for all systems except those medium and small systems that exceeded an action level
while on reduced lead and copper tap monitoring. For these systems, the six-month monitoring
periods will be June 1 through November 30 and December 1 through May 31.
You cannot be outside the OWQP ranges or below the OWQP minimum (also known as an
excursion) for more than a total of nine days at a specific sampling point or combination of
sampling points, or for a specific WQP or combination of WQPs during a six-month period. The
nine days can occur anytime during the six-month period and do not have to be consecutive. The
nine days allow you to make necessary repairs that may be causing your system to not meet its
OWQP specifications.
Revised LCR Monitoring and Reporting Guidance 64
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You must use the results of all WQP samples collected during the six-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 (40 CFR 141.86(g)).
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. Exhibit III-3, below, explains how to calculate the daily value based
on the sampling frequency for a given WQP.
If you are monitoring for
si specific WQP at a
sampling site:
More frequently than Daily
Daily
Biweekly
Semi-annually
Annually or Triennially
JjllLJA^jf ^JFl Jj2 il^R ^^^Q I&M
Then the daily value is:
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 two-week period for that WQP at
that location.
Results of each sample collected during the six-month period for that WQP at
that location.
The most recent measurement (s) taken, even if the measurement (s) was (were)
collected during a previous monitoring period.
Example: A system is on annual WQP tap monitoring during January -
December 2009. It measures pH at the tap on January 10, 2009 (pH = 7.5) and
June 20, 2009 (pH = 7.6). For the six-month period of January - June 2009,
there are two daily values because both measurements were collected during the
six-month period being evaluated. For the 6-month period of July - December
2009, only the most recent value of 7.6 is used.
//A^ For more information on this 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 81 5-R-99-0 1 9.
Revised LCR Monitoring and Reporting Guidance
65
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G. Can I Ever Reduce My WQP Monitoring? (40 CFR I4l.87(e))
111-4: Reduced Number o
p Sites and Sam pi
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
No. of Samples
(2 per site)
20
14
Note: The number of WQP tap samples for systems serving <
10,000 people is the same under standard and reduced monitoring.
After the State sets OWQPs, you can
qualify for a reduction in the amount of
monitoring conducted at tap locations
if you are in compliance with your
OWQPs (i.e., do not have excursions for
more than nine days in a six-month
period). This reduction does not apply to
entry point WQP monitoring. Entry point
monitoring remains at a frequency of
every two weeks.
Criteria for Reducing the Number of
WOP Tap Samples
If your water system is in compliance with
its OWQPs after two consecutive six-month monitoring periods and serves 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 Exhibit III-4. However, two sets of samples are still
required at each location and the frequency remains at semi-annually.
Criteria for Annual Monitoring
If you are in compliance with your OWQP specifications for three consecutive years of monitoring,
you may also reduce the frequency with which you collect your distribution WQP samples from
once every six months to once per year and collect from the reduced number of sites. These samples
should be collected evenly throughout the year to reflect seasonal variability.
The Short-Term Revisions clarify that the annual reduced WQP tap monitoring period begins
during the calendar year immediately following the end of the monitoring period in which the third
consecutive year of six-month monitoring occurred. Previously, the start of this monitoring period
was not explicitly stated.
EXAMPLE: Timing of Annual WQP Monitoring
Water system is in compliance with its OWQP requirements during
January I - June 30 and July I - December 31 of 2007, 2008, and 2009
(i.e., six consecutive six-month monitoring periods).
The start of the annual monitoring period is January I, 2010.
Revised LCR Monitoring and Reporting Guidance
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Criteria for Triennial Monitoring
If you are on an annual WQP tap monitoring frequency and you are in compliance with your
OWQPs for three consecutive years
of monitoring, you may reduce
the frequency with which you
collect WQP tap samples from
annually to once every three
years. Systems serving more
than 10,000 people would
continue to collect from the reduced number of sites.
Unlike lead and copper tap monitoring, the first year of
semi-annual 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
three consecutive years to qualify for triennial WQP tap
monitoring.
The number of WQP tap sampling locations for systems serving 10,000 or fewer
people is the same under standard and reduced monitoring. As shown in Exhibit 111-4,
systems serving 501 to 3,300 people that qualify for reduced WQP tap monitoring
would continue to collect 2 sets of WQP tap samples at 2 sampling locations. Those
serving 25 to 500 people would collect 2 sets of WQP tap samples at I location.
The Short-Term Revisions clarify that the triennial reduced WQP tap monitoring must begin no
later than three calendar years after the end of the monitoring period in which the system qualifies
for triennial monitoring. Prior to the Revisions, the rule language did not explicitly state when this
monitoring was to begin.
EXAMPLE: Tap WQP Triennial Monitoring
A PWS meets its OWQP specifications for the 3rd consecutive year
during 2008.
This system must collect its tap WQP samples by the end of
201 I (i.e., within 3 years after it qualifies for triennial monitoring).
You can also qualify for accelerated reduced WQP tap monitoring, which allows you to conduct
triennial WQP tap monitoring after only two consecutive monitoring periods (either six-month or
annually) if:
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;
3. You are in compliance with your OWQP requirements; and
4. Your State allows accelerated reduced WQP monitoring.
In general, this allowance applies 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.
The Short-Term Revisions also added language specifying that triennial monitoring must be
conducted at least every three calendar years. This language was added to help ensure that water
systems would not misinterpret the regulations to mean that samples could be collected anytime
Revised LCR Monitoring and Reporting Guidance 67
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during a three-year period. For instance, if a water system collects its first round of triennial samples
in 2008 within the compliance period of 2007 through 2009. The next compliance period would be
2010 through 2012. Because samples must be collected every three years, the system would have to
collect the sample no later than the end of 2011 (i.e., it would not have until the end of 2012 to
collect the sample).
Exhibit III-5 in the next section summarizes the criteria 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 two weeks.
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 nine days in a six-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.
H. Can I Ever Discontinue Water Quality Parameter
Monitoring? (40 CFR 141.81(b)(3), I4l.82(g), I4l.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 corrosion control treatment,
your State may require you to continue WQP monitoring or undertake other measures to ensure that
your treatment is operating properly.
Similarly, you are not required to continue WQP monitoring if you are a large system and the State
deems you to be a (b)(3) system (i.e., a water system that demonstrates it has minimally corrosive
water by meeting the requirements in 40 CFR 141.81 (b)(3)). However, if the State makes this
determination after you have installed treatment, the State may require you to continue to conduct
some WQP monitoring.
Criteria1
(Required time period in which system is in compliance with its OWQP Specifications)
Monitoring Frequency
(Samples are collected at reduced number of sites)
Two consecutive six-month periods
Every six months
Three consecutive years (equals six, six-month periods)
Annual
Three consecutive years of annual monitoring3
Two 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.
Triennial
1 Compliance with OWQPs must occur in consecutive periods to qualify for reduced monitoring.
2 Assumes that maximum of six months would occur before the system starts WQP monitoring. For example, if the
State sets OWQPs on January 1, 2009, the Short-Term Revisions would require WQP monitoring to begin on July 1,
2009 for systems on standard lead and copper tap monitoring.
3 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 three years in which it collects
WQP tap samples at the annual frequency before qualifying for triennial monitoring.
Revised LCR Monitoring and Reporting Guidance
68
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If you serve 50,000 or fewer people, and 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.
I. What Water Quality Parameter Monitoring Information
Must I Report to the State? (40 CFR I4l.90(a)(l)(vi)-(viii) & (a)(5))
You must report WQP monitoring results within the first 10 days following the end of each six-
month compliance period. This reporting requirement still applies even if jour State is not using the OWQP
compliance procedure that was introduced under the 2000 LCRMR. For example, during the year of 2009,
any WQP samples that you collected during January through June 2009 would be due to the State by
July 10, 2009. Those samples that you collected during July through December 2009 would be due
to the State by January 10, 2010 (or if you sample during June through November, you would report
your results no later than December 10, 2009). If you are on annual or triennial WQP tap
monitoring, there will be some six-month monitoring periods in which you will not have any tap
WQP results to report.
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.
J. What If I Do Not Fulfill My WQP Requirements? (40 CFR
I4l.80(k), I4l.82(g), I4l.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 at least one of these requirements:
• Use appropriate sampling procedures in accordance with 40 CFR 141.87(a)(l);
• Collect the required number and type of samples in accordance with 40 CFR
• Ensure samples are analyzed properly in accordance with 40 CFR 141.89(a);
• Submit all required monitoring information on time in accordance with 40 CFR
141.90(a)(vi)-(vm); or
• Meet the State -approved sampling plan for collecting WQPs at representative entry point
locations in accordance with 40 CFR 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 2000 LCRMR
compliance procedure, you are in violation of your requirements if you have OWQP excursions for
more than nine days in a six-month compliance period.
Revised LCR Monitoring and Reporting Guidance 69
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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
(refer to 40 CFR 141.31 (b)).
2. Deliver public notification to your customers (refer to 40 CFR 141.201 & 141.203 -
141.206 and additional information, available at
http://www.epa.gov/safewater/publicnotification/index.html).
3. Include a discussion of the violation in your CCR if you are a CWS, (refer to 40 CFR
141.153 and additional information, available at
http://www.epa.gov/safewater/ccr/index.html). Note: This CCR requirement is unrelated to
the new 40 CFR 141.154 provision that requires all CWSs to provide a short informational notice
about lead in their CCR (also refer back to Subsection H in Section I for more information).
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: ^4 monitoring and reporting violation does not impact jour
monitoring schedule.
K. What Provisions of the Short-Term Revisions Pertain to
Water Quality Parameter Monitoring and Reporting?
The exhibit below summarizes those provisions of the Short-Term Revisions that directly impact
your WQP monitoring and reporting requirements. If you own or operate a water system on Tribal
lands (other than the Navajo Nation), in Wyoming, or the District of Columbia, the Federal version
of the LCR applies to you. Therefore, you were required to implement the following provisions
beginning April 7, 2008. Water system owners or operators in other States should check with their
Primacy Agencies to determine when these provisions will be in effect.
Exhibit 111-6: Revisions to Water Quality Parameters
CFR Citation
§141.87(d)
New Requirements under the Short-Term
Revisions
Clarifies that systems on standard lead and copper
tap monitoring must begin monitoring for WQPs
in the first six-month period after the State sets
OWQPs. Begin dates will either be January 1 or
July 1, whichever comes first.
Defines the start of the first six-month WQP
monitoring period for small or medium systems
that are required to monitor for WQPs due to an
action level exceedance during a reduced lead and
copper tap monitoring period. The beginning of
the six-month WQP monitoring period is the same
as the lead and copper tap monitoring period in
which the exceedance occurred (e.g., if exceedance
occurred during June 1 - Sept. 30, 2009, the WQP
monitoring period will start June 1, 2009, and end
Previously Required under
the 1991 Rule as Amended
by LCRMR
Large systems began monitoring
for WQPs on the date the State
sets OWQPs.
Synchronized the end of the six-
month monitoring period for
WQP monitoring with the end of
the reduced lead and copper tap
monitoring period during which an
action level was exceeded, (e.g., if
exceedance occurred during June 1
- Sept. 30, 2009, the WQP
monitoring period would start July
1, 2009 and end Dec. 31, 2009). 1
Revised LCR Monitoring and Reporting Guidance
70
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mmmm
CFR Citation
New Requirements under the Short-Term
Revisions
Previously Required under
the 1991 Rule as Amended
by LCRMR
Nov. 30, 2009).
§141.87(e)(2)(i)
Specifies that annual WQP tap monitoring will
begin during the calendar year that immediately
follows the end of the monitoring period in which
the third consecutive year of six-month
monitoring occurs.
Specifies that triennial monitoring must begin no
later than three calendar years after the system
qualifies for triennial monitoring.
Was not specified.
§141.87(e)(2)(n)
Clarifies that triennial WQP monitoring must be
conducted no later than every third calendar year.
Was not specified.
1 Prior to the Short-Term Revisions, the end of the monitoring period for systems on reduced lead and copper tap
monitoring was defined as December 31 (although samples had to be collected by September 30). The Short-Term
Revisions clarify that the "monitoring period" is the specific period in which water system must conduct monitoring.
Therefore, the end of the monitoring period for systems on reduced monitoring is September 30 or for systems where
the State has designated an alternate period, the last day of that period.
Revised LCR Monitoring and Reporting Guidance
71
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L. What Key Points Should I Remember About Water Quality Ji^
Parameter Monitoring? (40 CFR I4l.82(g)f 141.87) c^lT
w If you serve more than 50,000 people, you must conduct some WQP monitoring.
*J 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 by the State. However, you must collect WQP
samples during any monitoring period in which you exceed the lead or copper action level.
'*f 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).
itf 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.
-•'. Before collecting a sample for pH and temperature (or dissolved oxygen, if needed)
remove the faucet aerator and run the water gently to flush the line.
-•'• After you install corrosion control treatment, entry point monitoring changes from two
sets of samples per site every six months to one sample per site every two 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.
*f 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 three consecutive years and be in compliance with your OWQPs for these three
years to qualify for triennial WQP tap monitoring.
ff If your State uses the 2000 LCRMR OWQP compliance approach, you are in compliance
with your OWQP requirements if you have excursions for no more than a total of nine
days at a specific sampling point or combination of sampling points, or for a specific
WQP or combination of WQPs during a six-month period.
«r WQP six-month monitoring periods are July 1 - December 31 and January 1 -June 30 for
all systems except medium and small that had an exceedance during a reduced lead and
copper tap monitoring period. For these systems, the six-month WQP periods are June 1
- November 30 and December 1 - May 31.
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
nine days in a six-month period (based on the 2000 LCRMR compliance approach.)
Revised LCR Monitoring and Reporting Guidance 72
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SECTION IV: LEAD AND COPPER SOURCE
WATER MONITORING AND REPORTING
REQUIREMENTS
A. What Is The Purpose of Collecting Source Water
Samples? (40 CFR I4l.8l(b)(3) & I4l.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 40 CFR 141.81(b)(3) (i.e., are a (b)(3) system). Refer
back to Subsection I.E, for a discussion of the (b)(3) criteria.
See Exhibit IV-1 for a summary of Revisions that impact source water
monitoring and reporting requirements.
B. Which Systems Must Collect Source Water Samples? (40
CFR I4l.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
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
level based on the 90 percentile lead or „ „.,.,.
, , . 70 copper tap monitoring to confirm your (b)(3)
copper level in tap water samples. Source water
Li. . . , F . /r status.
monitoring is also required tor 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.
C. When Do I Collect Source Water Samples? (40 CFR
I4l.88(a)-(e))
If This Is the First Time You Have Exceeded an 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.
Revised LCR Monitoring and Reporting Guidance 73
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The Short-Term Revisions clarify that these samples must be collected no later than 180 days after the
end of the monitoring period during which the lead or copper action level was exceeded. Previously, this
monitoring had to be conducted within six months of exceeding the action level. The Short-Term
Revisions also clarify that for systems that were on a reduced monitoring schedule when they
exceeded the lead or copper action level, the end of the monitoring period is September 30 or if the
State sets an alternate four-month monitoring period, the last day of the period.
You are also required to submit a source water treatment recommendation to the State no later than
180 days after the end of the monitoring period during which you exceeded the lead or copper
action level. Previously, this recommendation was due to the State within six months of exceeding
the action level. Your source water treatment 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 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 Capper Rule Guidance Manual Volume II: Corrosion Control, September
1992 (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. The State will use your sample results and recommendation to help determine if or
what type of source water treatment is needed.
Form 141-D in Appendix D 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 six months of its receipt of your sample results.
Immediately Following Source Water Treatment Installation
If the State requires you to install source water treatment, you have 24 months to install this
treatment. After installing this treatment, you must collect one sample from each entry point during
two consecutive six-month monitoring periods, and analyze this sample for both lead and copper
even if you exceeded only one of the action levels prior to treatment. With the "before and after
treatment" lead and copper results, the State will designate 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 for only one of these contaminants. Also note that some
States may set MPLs for systems that are not required to install source water treatment.
After the State Sets MPLs or Determines Source Water Treatment Is Not Needed
After the State sets MPLs and/or determines that source water treatment is not needed, your
monitoring requirements are based on your source type as explained below.
If your water system uses ground water as its only source, you must monitor during three-year
compliance periods. The first three-year compliance period is the one in effect when the State
specified MPLs for lead and copper or determines that source water treatment is not needed. These
are the same compliance periods that were established under the Standardized Monitoring
Framework (SMF) for Phase II/V contaminants (e.g., 2005 - 2007, 2008 - 2010, 2011 - 2013, etc.).
This was done to allow you to coordinate your source water monitoring for lead and copper with
other monitoring requirements.
Revised LCR Monitoring and Reporting Guidance 74
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The Short-Term Revisions clarify that triennial monitoring must occur every three years. Therefore,
if you collected your source water sample in 2008, the next sample would be due no later than
2011 (i.e., you would not have until the end of the compliance cycle (2013) to collect your sample).
If your water system uses surface water, ground water under the direct influence of surface
water (GWUDI), or any combination of these sources with ground water, you must monitor
annually. The Short-Term Revisions clarify that the first annual monitoring period begins during the
year in which the State set your MPLs or determines that source water treatment is not needed.
Therefore, both the determination and sample collection must occur before the end of December.
This clarification encourages States to make timely decisions to allow systems to meet the December
31 deadline. Previously, this monitoring period began on the date the State made the applicable
determination. The example below illustrates the timing of annual monitoring.
EXAMPLE I: Annual Source Water Monitoring
T*T A surface water system submits initial source water monitoring results to the State on
May 15, 2008.
T*T On October 31, 2008, the State determines that no treatment is needed.
T*T The system must collect a sample from each entry point to the distribution system by
December 31, 2008.
Note: Assume instead that the State set MPLs on October 31, 2008. The system would also be
required to complete source water monitoring by December 31, 2008.
Reduced Monitoring
You can further reduce your source water monitoring frequency to once every nine years based on
the SMF nine-year compliance cycle (i.e., 1993 - 2001, 2002 - 2010, 2011 - 2019, etc.) if you meet the
criteria listed below. The number of sites from which you must collect source water samples
remains at one sample per entry point. Once you are on nine-year monitoring, the Short-Term
Revisions specify that this monitoring must occur no more than nine years apart.
If your water system uses ground water exclusively, you can collect source water samples once
every nine years if you do not exceed either the lead or copper MPL for three consecutive, three-year
compliance periods (i.e., nine years).
If your water system uses surface water, GWUDI, or any combination of these sources with
ground water, you can collect source water samples once every nine years if you do not exceed
either MPL for three consecutive years. Refer to Example 2 below.
If the State has determined that source water treatment is not needed and has not set MPLs,
you can collect source water samples once every nine years if (see note below):
• your source water lead concentrations are <. 0.005 mg/L; and
• your source water copper concentrations are <. 0.65 mg/L; and
Revised LCR Monitoring and Reporting Guidance 75
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• you maintain these levels for three consecutive three-year compliance periods if your
system uses ground water only or for three consecutive years if your system uses surface
or a combined source(s).
Note: This provision was added by the 2000 LCRMR and was optional for States to adopt. First
check with jour State to determine whether this provision applies.
EXAMPLE 2: Criteria to Qualify for Reduced Source Water Monitoring
for Ground Water Systems
A ground water system collects source water samples in 2006, 2009, and 2012 (during three
consecutive three-year compliance periods). The value of these samples does not exceed the
MPLs set by the State.
It qualifies for nine-year monitoring and the next source water samples must be collected by
December 31, 2021. See diagram below.
T
T
'06 '07 '08 '09 '10 '11 '12 '13
I— 3 consecutive, 3-year compliance periods —I
Qualify \ Monitoring every
for / nine years (Ist
samples due by
Dec. 31,2021)
fa
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.
However, you do not have to conduct source water monitoring if you are at or under the lead and
copper action level for the entire source water monitoring period in effect.
D. Where Are These Samples Collected? (40 CFR I4l.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.
Revised LCR Monitoring and Reporting Guidance
76
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If you use surface water, GWUDI, 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
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 must be taken during normal operating
conditions so that the water is representative of all sources being used.
Some States allow a maximum of five samples to be combined together and analyzed as one sample
(known as compositing). The compositing must 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.
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 must 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.
Compositing allows you to save on analytical costs. It
7^fff\ does not reduce the number of samples that you must
i™ ' co//ect. Also remember to first check with your State
to determine if compositing of samples is allowed.
You must take each repeat sample
at each sampling point included in
the composite unless conditions
make sampling at another site more
representative of each source or
treatment plant.
E. How Does the State Evaluate My Source Water
Monitoring Results? (40 CFR I4l.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 for the contaminant that
exceeded its MPL within 14 days of collecting the original sample. This result of the contaminant
for which the MPL was exceeded is averaged with the initial sample and compared against your
MPL. Any sample value below the detection limit must be considered as zero. Any sample that is
above the detection limit but below the practical quantitation level (PQL) of 0.005 mg/L for lead or
0.050 mg/L for copper must be considered as measured or as Vz the PQL.
Revised LCR Monitoring and Reporting Guidance 77
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If the average of the initial and confirmation results is still higher than the MPL, you are in violation
of a treatment technique requirement. (Refer to Subsection IV.Hfor additional steps.) 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.
90th percentile levels are never calculated for source water samples.
F. Can I Ever Discontinue Source Water Monitoring? (40 CFR
I4l.88(d)(2))
After the State has designated MPLs and/or determines 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 and 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 Examples 3 through 5 below.
EXAMPLE 3: System on Nine-Year Source Water Schedule that Is Not
Required to Monitor
A system qualifies for reduced source water monitoring for the nine-year compliance cycle of
2002-2010.
It conducts tap monitoring during the 2001 - 2003, 2004 - 2006, 2007 - 2009, and 2010 - 2012
compliance periods, and all 90th percentile values are below the action levels.
Therefore, source water monitoring is not required because all samples were below the action
levels during the entire source water monitoring period in effect (i.e., the compliance cycle of
2002-2010).
EXAMPLE 4: System on Nine-Year Source Water Schedule that Is
Required to Monitor
A system qualifies for reduced source water monitoring for the 2002 - 2010 compliance cycle.
It conducts tap monitoring during 2002, 2005, 2008, and 201 I and has a copper action level
exceedance in 201 I.
It is not required to collect source water samples during the 2002 - 2010 compliance cycle
because it did not exceed either action level during this time period.
However, it must collect source water monitoring during the 201 I - 2019 compliance cycle
because it exceeded the copper action level in 201 I.
Revised LCR Monitoring and Reporting Guidance 78
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EXAMPLE 5: System on Annual Source Water Schedule that Is
Required to Monitor
A surface water system is on an annual source water monitoring schedule, and a triennial lead
and copper tap monitoring schedule.
It collects lead and copper tap samples during 2008 and exceeds the copper action level. It
remains on triennial tap monitoring because it is in compliance with its OWQPs and does not
exceed the lead action level.
It collects lead and copper tap samples in 201 I and is below both action levels.
It is required to collect source water samples in 2008, 2009, and 2010 due to the copper
action level exceedance. Assume it collects these samples but exceeds the copper MPL in
2008 and thus, does not qualify for nine-year source water monitoring (i.e., does not have
three consecutive years at or below both MPLs).
It is not required to collect an annual source water sample in 201 I because the lead and
copper 90th percentile levels were below the action levels.
If you are required to install source water treatment, you must
complete the two consecutive six-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.
G. What Source Water Monitoring Information Must I
Report to the State? (40 CFR I4l.90(b))
You must provide the following information within 10 days of the end of the monitoring period
(based on jour source water lead and copper sampling schedule of six months, one year, three years, or nine 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).
H. What If I Do Not Fulfill My Source Water Monitoring And
Reporting Requirements? (40 CFR I4l.80(k) & I4l.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 at least one of these requirements:
• Use appropriate sampling procedures (40 CFR 141.88(a)(l) and (2));
• Collect the required number of source water samples (40 CFR 141.88(a)(l) - (e));
• Ensure samples are analyzed properly (40 CFR 141.89(a)); or
• Submit all required sampling information on time (40 CFR 141.90(b)).
Revised LCR Monitoring and Reporting Guidance 79
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You are also in violation if you exceed your State-designated or approved MPLs. If you are above
either MPL, you can take a confirmation sample for the contaminant with the MPL exceedance
within two 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 (40
CFR141.88(a)(2)).
You must analyze both lead and copper source water samples even if you
exceeded only one of the action levels in tap water monitoring. However,
if you exceed the lead or copper MPL, you only need to collect a
confirmation sample for the contaminant with the MPL exceedance.
If you are out of compliance with your monitoring, reporting, or MPLs, you must:
1.
2.
3.
Report the violation to the
State within 48 hours of
determining the
noncompliance (40 CFR
You cannot qualify for reduced source water
monitoring unless the three compliance periods in
which you meet the reduced monitoring criteria are
consecutive. Thus, noncompliance with your
monitoring requirements will impact how quickly you
can qualify for reduced monitoring.
Deliver public notification
to your customers (refer
to 40 CFR 141.201 & 141.203 - 141.206 and additional information, available at
(http://www.epa.gov/safewater/publicnotification/index.html).
Include a discussion of the violation in your CCR if you are a CWS, (refer to 40 CFR
141.153 and additional information, available at
(http://www.epa.gov/safewater/ccr/index.html). Note: This CCR requirement is unrelated to
the new 40 CFR 141 . 1 54 provision that requires all CWSs to provide a short informational notice
about lead in their CCR (also refer back to Subsection H in Section I for more information).
I. What Provisions of the Short-Term Revisions Pertain to
Source Water Monitoring and Reporting Requirements?
Exhibit IV-1 summarizes each of the Short-Term Revisions that impact your source water
monitoring and replacement requirements.
xhibit IV-1: Revisions to Source Water Requirements
CFR Citation
New Requirements under the Short-
Term Revisions
Previously Required under
the 1991 Rule as Amended
by LCRMR
Clarifies that initial source water monitoring results
and a source water treatment recommendation are
due to the State no later than 180 days after the
end of the monitoring period during which the lead
or copper action level was exceeded.
This information was due within six
months after exceeding the lead or
copper action level.
Revised LCR Monitoring and Reporting Guidance
80
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CFR Citation
New Requirements under the Short-
Term Revisions
Previously Required under
the 1991 Rule as Amended
by LCRMR
§141.88(b)
Clarifies that initial source water monitoring must
be conducted no later than 180 days after the end
of the monitoring period during which the lead or
copper action level was exceeded.1
Defines the end of the monitoring period for
systems on reduced monitoring to be September
30 of the calendar year in which the sampling
occurred or if applicable, the last day of the State-
established alternate period.
Required this monitoring to be
completed within six months after
the exceedance.
The end of the monitoring period
was not defined.
Retains the requirement for systems on a triennial
source water monitoring schedule to monitor once
during the three-year compliance cycle but clarifies
that samples must be collected at least every three
years.
Required samples to be collected
once during the three-year
compliance period.
Clarifies that the first annual source water
monitoring period for systems using surface water
or a combined source (s) begins during the year in
which the State sets MPLs or determined that
source water treatment is not required.
Required this monitoring to begin
on the date that the State set MPLs
or determined that source water
treatment was not needed.
§141.88(e)(l) &
Retains the requirement for systems on a nine-year
source water monitoring schedule to monitor once
during the compliance cycle but clarifies that
samples must be collected at least every nine years.
Required samples to be collected
once during the nine-year
compliance cycle.
L
1 It was EPA's intent to revise the rule language in 40 CFR 141.88(b) to be consistent with that in 40 CFR 141.83(a),
which requires water systems to complete initial source water monitoring within 180 days (versus 6 months).
Revised LCR Monitoring and Reporting Guidance
81
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J. What Key Points Should I Remember About Source
Water Monitoring and Reporting? (40 CFR 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 exceeded only one of the action levels in
lead or copper tap monitoring.
-•f 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 180 days after the monitoring
period in which an action level was exceeded. No source water treatment study is required.
-( Source water samples are compared against your lead and copper MPLs. If you exceed an MPL,
you may collect a confirmation sample for the contaminant with the MPL exceedance within 14
days and average it with the initial sample.
-•! 90th percentile levels are not calculated for source water samples or compared against the action
level.
Vf 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 three years beginning with the SMF
compliance period in effect when the State made the applicable decision.
• surface water systems or ones using a combined source must monitor annually. The first
year begins during the year in which the State made the applicable determination.
• any water system is not required to collect any source water samples during any
monitoring period in which its 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.
w You can collect source water samples once every nine years based on SMF compliance cycles, if
for three consecutive compliance periods you do not exceed your MPLs (equals nine years for
systems using ground water exclusively and three years for all other systems).
-•j Your State may allow you to collect source water samples once every nine years if:
• you continue to exceed the lead action level and are not required to install source water
treatment, but
• for three 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.
Revised LCR Monitoring and Reporting Guidance 82
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SECTION V: LEAD SERVICE LINE MONITORING
AND REPORTING REQUIREMENTS
A. What Is The Purpose of Collecting Lead Service Line
Samples? (40 CFR I4l.84(a) - (d)(l))
Lead service line replacement is intended as an additional step to reduce lead exposure when
corrosion control treatment is unsuccessful. 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 other words, if you install both corrosion control and source water treatments,
you are not required to begin lead service line replacement unless you continue to exceed the lead
action level after installing both treatments. The State can also require you to begin lead service line
replacement if you are required to install corrosion control treatment and/or source water treatment
and have not installed such treatment(s).
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 is considered "replaced through testing" and
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 "replaced through testing" 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 entire line up to the
building inlet (e.g., a water system does not replace the privately-owned portion due to
legal restrictions or the owner's declining to have his/her portion replaced). 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
See Exhibit V-2 for a summary of Revisions that impact lead
service line replacement.
B. Which Systems Must Collect Lead Service Line Samples?
(40 CFR I4l.84(a)&(d)(l))
As stated above, testing 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
Revised LCR Monitoring and Reporting Guidance 83
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you replace the entire lead service line, or if you only replace a gooseneck, pigtail, or other fittings and
these are the only lead components in your service line.
C. When Do I Collect Lead Service Line Samples? (40 CFR
I4l.84(b)&(e)(3))
The Revisions clarify that the first year of lead service line replacement begins on the first day following
the end of the monitoring period in which 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 i ~~~~~I ; ~;
, ,T . i-i The Short-Term Revisions clarify when a
began. You must continue replacing the -*Wf I • • • . . <-
. , rr i i s*$ff\ monitoring period ends. For systems on
required percentage or lines each year until t»m*\
you no longer exceed the lead action level
during two consecutive monitoring periods or have
O O L
replaced all your lead service lines.
reduced monitoring, it is September 30 of
the calendar year in which the sampling
occurs, or for systems on a State-specified
alternate monitoring period, the last day of
that period.
If you are trying to replace lead service lines
through testing, you should collect your lead service line samples early enough in the 12-month
replacement period to allow the time needed to physically replace a line should your test results be
greater than 0.015 mg/L.
D. How Do I Collect Lead Service Line Samples? (40 CFR
I4l.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 Exhibit V-l, 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, and then close the tap.
• Direct Service Une Samples:
Sampling at a pre-existing tap: In communities where the meters are located outside
the buildings (or unmetered areas) service line taps may already exist. Prior to
collecting the sample, flush the estimated volume of the existing tap and the pipe
that is directly connected to the service line (similar to the procedure described
above under flushing a Specified Volume). This will help ensure that the water collected
for the sample resided in the service line.
Revised LCR Monitoring and Reporting Guidance 84
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Sampling when no tap exists: 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 existing
service line taps.
berature 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.
Exhibit V-l: 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
1-1/2
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.
Revised LCR Monitoring and Reporting Guidance
85
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Exhibit V-l
Pipe Length
(Feet)
3/8
Pipe Volume Table (Volumes Listed in Liters)
1/2
Pipe Diameter (Inches)
5/8
3/4
1
1
1-1/2
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.
E. Can I Ever Discontinue Lead Service Line Monitoring? (40
CFR I4l.84(f))
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 two consecutive monitoringperiods.
F. What Happens If I Have a Subsequent Lead Action Level
Exceedance? (40 CFR 141.84(b)(2))
You must start lead service line replacement again if you subsequently exceed the lead action level
during any monitoring period. In addition, the Short-Term Revisions require you to reconsider any
lines previously determined to not require replacement (i.e., "replaced through testing") if you
exceed the action level again in the future and resume the lead service line replacement program.
Specifically, you must update your inventory of lead service lines to include those that were classified
as "replaced through testing." You must divide the updated number of remaining lead service lines
by the number of remaining years in your replacement program (the program is typically 15 years) to
determine the number of lines that must be replaced per year (see example below). In the event that
you have completed a 15-year replacement program (or completed replacement on an accelerated
schedule), the State will determine a schedule for replacing or retesting lines that were previously
considered replaced through testing.
EXAMPLE: Reconsidering Lines "Replaced through Testing"
A PWS exceeded the lead action level in July - December 2005 after installing corrosion
control treatment, and thus is triggered into lead service line replacement (LSLR).
It began with 60 lead service lines in its inventory and is on a 15-year replacement schedule.
During 2006 and 2007, 3 lines were physically replaced and 4 lines were replaced through
testing (for a total of 7 lines over these two years).
During the monitoring period of Jan. -June and June - Dec. 2007, the system was below the
lead action level and therefore, discontinued LSLR in January of 2008.
The PWS began annual monitoring in 2008.
In 2009, it exceeded the lead action level.
The PWS is triggered back into LSLR on Oct. 1, 2009 (i.e., the day after the end of the
monitoring period in which the exceedance occurred).
The PWS has 57 lead service lines in its inventory to be considered (because it must include
Revised LCR Monitoring and Reporting Guidance
86
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the 4 previously considered replaced through testing).
T*T Because the system finished 2 of its 15 years of its replacement program (during 2006 and
2007), it must replace 57 lines over the remaining I 3 years or 4 to 5 lines per year.
Note that any retested or newly tested lines that are at or below 0.015 mg/L are considered replaced.
It takes two consecutive monitoring periods to stop replacement, but only one
monitoring period to be triggered back into lead service line replacement.
G. What Lead Service Line-Related Information Must I
Report to the State? (40 CFR I4l.90)(e))
All Systems Subject to Lead Service Line Replacement
During the first year of lead service line replacement, you must:
• Submit a materials evaluation that identifies the initial number of lead service lines in
your distribution system at the time your replacement program begins.
• Submit an overall schedule for annually replacing at least 7 percent each year of the
initial number of lead service lines in your distribution system.
• Submit a letter stating for the previous year:
the number of lines scheduled
to be replaced;
the number and location of lines
This letter is due every 12 months until you
complete lead service line replacement or no
,, ijj longer exceed the lead action level during
actually replaced; and . . , . .
; r two consecut/ve rounds of top monitoring.
if measured, the water lead
concentration and location of each lead service line sampled, the sampling method,
the date of sampling, and the date that the service line was partially replaced.
Provide this information no later than 12 months after the end of the monitoringperiod in
which you were first triggered into lead service line replacement. For example, a system
that begins lead service line replacement on October 12, 2009, would be required to
submit this information to the State by October 12, 2010.
If you are subsequently triggered back into lead service line replacement, you must reconsider any
lines that were "replaced through testing" and provide the annual letter to the State. You do not
need to resubmit your materials evaluation or overall lead service line replacement schedule.
Systems Conducting Partial Lead Service Line Replacement
The LCR requires you to replace the portion of the lead service line that you own. In those
instances where you do not own the entire lead service line up to the building inlet, you must offer
to replace the owner's portion of the line at his/her expense unless your local or State law precludes
this replacement In addition, you are not required to replace the privately-owned portion of the line
if 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 (i.e., conduct
Revised LCR Monitoring and Reporting Guidance 87
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partial lead service line replacement), a temporary increase in lead levels may occur. Therefore, 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.
• Report sample results to the building owner(s) and the resident(s) served by the partially
replaced line within three business days of receiving these results. You must notify
residents by mail or by other methods approved by the State. For multi-family dwellings
you can post the notification in a conspicuous common-use area of the building.
You also 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.
• 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.
You are not subject to the partial lead service line requirements if you: I) replace the
entire length of the line up to the building inlet; or 2) only replace a gooseneck, pigtail, or
other fittings and these are the only lead components in your service line.
H. What If I Do Not Fulfill My Lead Service Line Replacement
Requirements? (40 CFR I4l.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
percent annually) (40 CFR 141.84(a) & (b)); or
• Report the required lead service line information on time that demonstrates that the
replacement rate was met (40 CFR 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) (40 CFR 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 three business
days of receipt of the results; or
Revised LCR Monitoring and Reporting Guidance 88
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• 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 (40
CFR141.31(b)).
2. Deliver public notification to your customers (refer to 40 CFR 141.201 & 141.203 -
141.206 and additional information, available at
http://www.epa.gov/safewater/publicnotification/index.html).
3. Include a discussion of the violation in your CCR if you are a CWS, (refer to 40 CFR
141.153 and additional information, available at
http://www.epa.gov/safewater/ccr/index.html). Note: This CCR requirement is unrelated to
the new 40 CFR 141.154 provision that requires all CWSs to provide a short informational notice
about lead in their CCR (also refer back to Subsection H in Section I for more information).
I. What Provisions of the Short-Term Revisions Pertain to
Lead Service Line Monitoring and Replacement?
Exhibit V-2 summarizes each of the revisions that impact your lead service line monitoring and
replacement requirements. If you own or operate a water system on Tribal lands (other than the
Navajo Nation), in Wyoming, or the District of Columbia, the Federal version of the LCR applies to
you. Therefore, you were required to implement the following provisions beginning April 7, 2008.
Water system owners or operators in other States should check with their Primacy Agencies to
determine when these provisions will be in effect.
Exhibit V-2: Revisions to Lead Service Requirements
CFR
Citation
New Requirements under the
Short-Term Revisions
Previously Required under
the 1991 Rule as Amended
by LCRMR
§141.84(b)(l)
Clarifies that the first year of lead service line
replacement (LSLR) begins on the first day following
the end of the monitoring period in which the action level was
exceeded after installing the required treatment(s).
First year of LSLR began on the
date the action level was exceeded
after installing the required
treatment (s).
§141.84(b)(2)
Requires water systems to update their inventory of
lead service lines (LSLs) to include those that were
classified as "replaced through testing."
Requires water systems to divide the updated number
of remaining LSLs by the number of remaining years in
the replacement program to determine the number of
lines that must be replaced per year.
Specifies that for systems that have completed a 15-
year LSLR program, the State will determine a schedule
for replacing or retesting lines that were previously
Systems were not required to retest
lines that were considered
"replaced through testing."
Revised LCR Monitoring and Reporting Guidance
89
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CFR
Citation
New Requirements under the
Short-Term Revisions
Previously Required under
the 1991 Rule as Amended
by LCRMR
considered replaced through testing.
§141.90(e)(l)
Clarifies that the material evaluation identifying the
initial number of LSLs is due 12 months after end of
monitoring period in which the system is triggered into
LSLR.
Clarifies that the initial number of LSLs to be
submitted as part of the materials evaluation is the
number present in the distribution system during the
monitoring period that triggered the system into LSLR.
Information was due 12 months
after the lead action level was
exceeded.
The definition of initial number of
LSLs was not provided in this
section of the rule; however, it was
defined in 40 CFR 141.84(b).
§141.90(e)(2)
Clarifies that documentation that demonstrates
compliance with replacement requirements is due 12
months after the end of a monitoring period in which
the action level is exceeded after initiating LSLR.
This information was due 12
months after action level was
exceeded.
Revised LCR Monitoring and Reporting Guidance
90
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J. What Key Points Should I Remember About Lead
Service Line Monitoring and Reporting? (40 CFR 141.84 J^
& I4l.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 treatment.
*r 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 is "replaced
through testing" and counts as a replaced line.
If you are required to resume your lead service line replacement program, you must include
lines that previously were considered replaced through testing back into your inventory.
These lines can be retested to determine if they still meet the replaced through testing
criteria.
If you conduct partial lead service line replacement, you must:
• Provide notice and guidance to residents at least 45 days before the replacement begins
(unless the State allows a shorter notification period);
• Collect a tap sample that is representative of the water in the service line within 72
hours of the replacement and notify the individuals served by the line of the results
within 3 days.
• Report information as required by the State that demonstrates fulfillment of your
monitoring and notification requirements.
-1 There are three methods for collecting a lead service line sample: 1) Flushing a specified
volume; 2) Sampling directly from the service line; and 3) Using temperature variation.
if During the first year of lead service line replacement, you must submit to the State a
materials evaluation that identifies your initial number of lead service lines, provide a
schedule for replacing at least 7 percent of your lines each year, and submit a letter with
information that demonstrates that you have met your replacement requirements.
-•! You must provide this letter every 12 months until you have completed your lead service
line replacement or qualify to discontinue lead service line replacement.
W" You can discontinue lead service line replacement and thus, any need to conduct lead
service line monitoring or reporting, whenever your 90' percentile lead levels are at or
below the lead action level for two consecutive monitoring periods.
- f 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, EPA 815-R-99-022.
Revised LCR Monitoring and Reporting Guidance 91
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APPENDICES
Appendix A:
Appendix B:
Appendix C:
Appendix D:
Appendix E:
List of LCR Outreach Materials for Water Systems
Definitions
Summary of Monitoring and Reporting Violation
Definitions
Worksheets and Instructions
Lead Consumer Notice Certification Form
(Suggested Format)
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APPENDIX A
List of LCR Outreach Materials for Water Systems
Below is a comprehensive list of outreach materials that were developed to help you
understand and implement the Lead and Copper Rule, as amended by the October 10,
2007, Short-Term Revisions. Each document can be downloaded at:
http://www.epa.gov/safewater/lcrmr/compliancehelp.html.
Guidance that predates the Short-Term Revisions may
be superceded by the requirements of this revised rule.
Regulatory Guidance Documents
• How to Determine Compliance with Optimal Water Quality Parameters as Revised by the Lead and
CopperRule Minor Revisions, February 2001, EPA 815-R-99-019.
• Appendix B: 2007 Short-Term Revisions Compared to the Lead and Copper Rule from
the Lead and Copper Rule 2007 Short-Term Revisions and Clarifications State Implementation
Guidance, June 2008, EPA 816-R-08-009.
• Appendix C: Lead and Copper Rule Fact Sheets from the Lead and Copper Rule 2007
Short-Term Revisions and Clarifications Implementation Guidance, June 2008, EPA 816-R-08-
009.
• Implementing the Lead Public Education Provision of the Lead and Copper Rule: ^4 Guide for
Community Water Systems, June 2008, EPA 816-R-08-007.
• Implementing the Lead Public Education Provision of the Lead and Copper Rule: ^4 Guide for Non-
Transient Non-Community Water Systems, June 2008, EPA 816-R-08-008.
• 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.
Technical Guidance Documents
• Simultaneous Compliance Guidance Manual for the Long Term 2 and Stage 2 DBF Rules, March
2007, EPA815-R-07-017.
• Final Revised Guidance Manual for Selecting Lead and Copper Control Strategies, March 2003,
EPA816-R-03-001.
• M/DBP Simultaneous Compliance Manual (Chapter 4), August 1999, EPA-815-R-99-
015.
• Effect ofpH, DIC, Orth op hasp hate and Sulfate on Drinking Water Cuprosolvencj, June 1995,
EPA-600-R-95-085.
Revised LCR Monitoring and Reporting Guidance - March 2010 REVISED DRAFT A-1
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APPENDIX A (Continued)
Fact Sheets
• Lead and Copper Rule: A Quick Reference Guide, June 2008, EPA 816-F-08-018.
• Lead and Copper Rule: Public Education & Other Public Information Requirements for
Community Water Systems, June 2008, EPA 816-F-08-019.
• Lead and Copper Rule: Public Education & Other Public Information Requirements for
Non-Transient Non-Community Water Systems, June 2008, EPA 816-F-08-020.
Memoranda
• Memorandum: Management of Aerators during Collection of Tap Samples to Comply
with the Lead and Copper Rule, October 20, 2006.
• Memorandum: Lead and Copper Rule - Clarification of Requirements for Collecting
Samples and Calculating Compliance November 23, 2004 Memorandum.*
• Memorandum: Compliance Calculations Under the Lead and Copper Rule to Region 1
March 9, 2004.*
*Note: The Short-Term Revisions supersede the guidance in these documents regarding the 9(f percentile
calculation when a system is allowed to collect fewer than five samples.
Training
Lead and Copper Rule: Short-Term Revisions and Clarifications, April 2008.
Revised LCR Monitoring and Reporting Guidance - March 2010 REVISED DRAFT A-2
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APPENDIX B
40 CFR Definitions
Term
90th Percentile
Accelerated
Reduced Lead and
Copper Tap
Monitoring
Accelerated
Reduced Water
Quality Parameter
(WQP) Monitoring
Action Level (AL)
Alternate
Monitoring Period
(b)(l) system
(b)(2) system
(b)(3) system
Community Water
System (CWS)
Compliance Period
Corrosion Control
Treatment
Definition
The highest concentration of lead or copper in tap water that is exceeded by 10 percent of the sites
sampled during a monitoring period. For systems that are allowed by their States to collect fewer
than five samples, this value is the highest lead or copper result. The 90th percentile level 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 two consecutive six-month monitoring periods. 90th
percentile lead and copper levels must be < 0.005 mg/L and <. 0.65 mg/L, respectively.
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 two consecutive monitoring periods
(either six-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 (15 ppb). The action level for copper is 1.3 mg/L (1300 ppb).
A monitoring period designated by the State (other than June through September) in which water
systems may conduct reduced lead and copper tap monitoring. This period cannot exceed four
consecutive months in the same calendar year and must represent a time of normal operation
where the highest lead levels are likely to occur. For example, a State may decide to designate an
alternate monitoring period for seasonal systems that are closed during the summer months.
A small or medium system that is at or below both action levels during two consecutive six-month
rounds of lead and copper tap monitoring, as allowed under 40 CFR 141.81(b)(l) of the regulation.
A system that is deemed to have optimized corrosion control after demonstrating that it has
completed corrosion control treatment steps prior to December 7, 1992, which are equivalent to
those described in 40 CFR 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 in accordance with 40 CFR 141.81(b)(3) of the regulation.
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.
For the purpose of lead and copper tap monitoring, the compliance period is a three-year calendar
period for systems on triennial monitoring or a nine-year calendar period for systems on a
monitoring waiver. EPA clarified the meaning of the compliance period in the Short-Term
Revisions to emphasize that water systems on triennial monitoring must collect samples no less
frequently than every three years; and those on monitoring waivers must sample no less frequently
than every nine years. The compliance period is distinct from the monitoring period, which
defines the specific period in which the samples must be collected (see Monitoring Period definition).
A treatment designed to reduce the dissolving of lead and/or copper in plumbing materials during
water delivery to consumers.
Revised LCR Monitoring and Reporting Guidance
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Term
Cu
Daily values
Deemed to have
optimized
corrosion control
Entry Point
Exceedance
Excursion
First-Draw Sample
Follow-up
Monitoring
Full Waiver
GWUDI
Initial Tap
Monitoring
Large Water
System
LCR
LCRMR
Lead Service Line
(LSL)
Long-term
Treatment Change
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 after treatment.
Occurs when the 90th percentile lead or copper sample is above its respective action level.
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 occurs
after corrosion control treatment is in place and before the State determines OWQP ranges or
minimums. The samples are taken during the two consecutive six-month monitoring periods
immediately following the installation of corrosion control treatment.
A monitoring waiver that allows a small system to collect both lead and copper tap samples at a
frequency of once every nine 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, which have been determined to be served by 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 six-month intervals until which point the system either exceeds the action
level, or is at or below both action levels for two consecutive, six-month monitoring periods. For
systems serving more than 50,000 people, refers to tap samples collected during the first two
consecutive, six-month periods of monitoring.
A water system that serves more than 50,000 people.
An acronym for the Lead and Copper Rule, which were originally published on June 7, 1991. Also
referred to in this document as the 1991 Rule.
The acronym for the Lead and Copper Rule Minor Revisions, which were promulgated on January
12, 2000.
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.
The Short- Term Revisions require water systems to receive State approval prior to implementing
treatment changes that are long-term in nature. Examples include changing the type of secondary
disinfectants, coagulants, or corrosion inhibitor products. Other long-term treatment changes may
involve processes or combinations of processes that can greatly affect the pH, oxidation-reduction
potential, alkalinity, or the major composition of the ionic background of the water.
Revised LCR Monitoring and Reporting Guidance
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Term
Materials Survey
Maximum
Contaminant Level
Goal (MCLG)
Maximum
Permissible Levels
(MPLs)
Medium Water
System
Method Detection
Limit (MDL)
Monitoring Period
Monitoring Waiver
Non-transient,
Non-Community
Water System
(NTNCWSs)
Optimal Corrosion
Control Treatment
(OCCT)
Optimal Water
Quality Parameters
(OWQPs)
Partial Wavier
Pb
Practical
Quantitation Level
(PQL)
1
Definition
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 level of a contaminant in drinking water below which there is no known or expected risk to
health.
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.
Under the Short-Term Revisions, this is the specific period in which water systems must conduct
their required monitoring. For systems on standard lead and copper tap monitoring, the
monitoring periods are the six-month periods of January thro ugh June or July through December.
For systems on a reduced monitoring schedule (e.g., annual, triennial, or nine years), this period is
the four-month period of June through September of the same calendar year, or the alternate
monitoring period designated by the State.
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 nine years at a reduced number of sites. To receive this
waiver a system must meet the monitoring and materials criteria for lead and copper.
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 nine 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.
Revised LCR Monitoring and Reporting Guidance
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Term
Pre-existing Waiver
Public Water
System (PWS)
Reduced
Monitoring
Replaced Through
Testing
Representative Site
Sampling Site
Short-Term
Revisions
Service Line
Sample
Single Family
Residences (SFRs)
Single Family
Structure
Small Water
System
Solder
Source Water
Sample
Source Water
Treatment
A waiver that was granted by the State prior to April 11, 2000, the effective date of the LCRMR.
The LCRMR required systems that were not required to conduct lead and copper monitoring as a
condition of their "pre-existing waiver" to collect at least one set of lead and copper samples at the
tap at the standard number of sites by September 30, 2000.
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 40 CFR 141.86(d)(4) or 40 CFR 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.
Refers to a lead service line that meets the requirements of 40 CFR 141.84(c). Under this
provision, a water system may count a line as being replaced if all samples from the line are less
than or equal to 0.015 mg/L. Note that the Short-Term Revisions require water systems to
reconsider any lines that meet this requirement any time they must resume lead service line
replacement.
A sampling site that is connected to plumbing materials which are similar to materials used at other
sites in the water system.
As clarified by the Short-Term Revisions, refers to taps that can be used for human consumption
(e.g., kitchen or bathroom tap). Lead and copper tap samples must be collected at these locations.
Lead and Copper Rule Short-Term Regulatory Revisions and Clarifications, promulgated by EPA
on October 10, 2007.
A 1-liter sample of water, collected in accordance with 40 CFR 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 percent 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.
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.
Revised LCR Monitoring and Reporting Guidance
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Term
Special- Case CWS
Standard
Monitoring
Tier 1 Site
Tier 2 Site
Tier 3 Site
Water Distribution
System
Water Quality
Parameters
(WQPs)
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 a 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 six-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 a 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 a 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 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.
Revised LCR Monitoring and Reporting Guidance
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APPENDIX C
Summary of Monitoring and Reporting Violation Definitions
All citations from the Code of Federal Regulations
Monitoring and Reporting (M/R) violations fall into five major categories as described below.
1. Lead Consumer Notice
You are in violation if you do not meet all of the following provisions for the consumer notice of lead tap
results:
• Provide notice of lead results to individual served by taps used for lead and copper tap monitoring
in accordance with 40 CFR 141.85(d)(l);
• Meet the timing requirements for providing the notice in accordance with 40 CFR 141.85(d)(2);
• Meet the content requirements in 40 CFR 141.85(d)(3);
• Meet the delivery requirements in 40 CFR 141.85(d)(4); or
• Meet the reporting requirements in 40 CFR 141.90(f)(3) that require a sample notification and
certification be sent to the State within 3 month after the monitoring period end.
2. 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 40 CFR 141.86(a) and (b);
• Collect the required number of samples during the specified time frame in accordance with 40 CFR
141.86(c) and (d);
• Ensure samples are analyzed properly in accordance with 40 CFR 141.89(a);
• Submit all required monitoring information on time in accordance with 40 CFR 141.90(a); or
• Report a change in long-term treatment or addition of a new source within the time frame specified by
the State or as soon as possible, or to receive prior State approval before implementing the change
or addition, as required by 40 CFR 141.90(a)(3). Applies only to systems on reduced lead and
copper tap monitoring including (b) (3) systems and those on a monitoring waiver.
Depending on whether the State adopted the following provisions that were introduced under the 2000
LCRMR, 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 40 CFR
141.86(f)(4) where these samples are needed to meet minimum sampling requirements;
• Meet the conditions of your monitoring waivers in 40 CFR 141.86(g) or provide the required
information in 40 CFR 141.90(a)(4)(n)-(iv);
• Provide sample information needed for your State to perform the 90th percentile calculation as
outlined in 40 CFR 141.90(h);
• Collect non-first draw samples that did not meet the criteria in 40 CFR 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 40 CFR
141.86(d)(4)(iv)(B).
Revised LCR Monitoring and Reporting Guidance - DRAFT
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3. Water Quality Paramete
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 40 CFR 141.87(a) (1) and (b)-(e);
• Collect the required number and type of samples in accordance with 40 CFR 141.87(a)(2) or (e);
• Ensure samples are analyzed properly in accordance with 40 CFR 141.89(a);
• Submit all required monitoring information on time in accordance with 40 CFR 141.90(a) (vi)-
(vm);
• Meet the State-approved sampling plan for collecting WQPs at representative entry point
locations in accordance with 40 CFR 141.87(a)(l)(ii) and (c)(3) (this criterion would only apply if you are
a ground water system and your State's regulation allowsjou to limit entry point WQP monitoring to representative
sites.)
4. 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 40 CFR 141.88(a)(l) and (2));
• Collect the required number of source water samples (see 40 CFR 141.88(a)(l) - (e)(3));
• Ensure samples are analyzed properly (see 40 CFR 141.89(a)); or
• Submit all required sampling information on time (see 40 CFR 141.90(b)).
5. Lead Service Lines
You are in violation if you do not all of the following monitoring and reporting requirements within the
time frame specified by the rule:
• Replace the required number of lead service lines by the annual deadline (i.e., at least 7% annually)
(see 40 CFR 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 40 CFR 141.90(e)).
You are also in violation if you do not meet the following partial lead service line replacement
requirements (only applicable ifyou do not replace the entire lead service line) (see 40 CFR 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 three 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.
Note: This table does not include those violations that pertain to your treatment technique requirements.
Revised LCR Monitoring and Reporting Guidance - DRAFT
C-2
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APPENDIX D
Worksheet and Instructions
Worksheet I: 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 (e.g., 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.
Amended 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. These directions (step 3) were amended on
September 2006 to instruct homeowners to not remove an aerator prior to sampling.
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 2000
LCRMR. However, you should 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 2000
LCRMR no longer requires 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 two-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.
Revised LCR Monitoring and Reporting Guidance D-l
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WORKSHEET #1
MATERIALS SURVEY INVESTIGATION RESULTS (Suggested Format)
PWS ID NUMBER
POPULATION SERVED BY PWS
Type of
Structure
Location
Contact Person
Name
Phone
LSL
Home
Plumbing
Material
Verified
Volunteered
Selected
Routine
Optional
Received
Training
Material
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WORKSHEET #2
MATERIALS SURVEY RESULTS BY NUMBER OF SERVICE CONNECTIONS
FOR EACH PLUMBING MATERIALS TYPE (Suggested Format)
PWS ID NUMBER
POPULATION SERVED BY PWS
Type of Structure
SFRs1
MFRs2
BLDGs3
TOTAL
Type of Plumbing Material
Interior Plumbing
Lead Pipe
Copper with Lead
Solder > 19824
Copper with Lead
Solder < 1983s
Number of Service Connections
Distribution System Piping
LSLs
Entire Line
Partial Line
Number of Service Connections
1 SFR - single family residence
2 MFR - multi-family residence
3 BLDG - public or commercial 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.
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WORKSHEET #3
SUMMARY OF MATERIALS SURVEY RESULTS (Suggested Format)
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
Lead Service Lines
Entire Line
Partial Line
Total Available Sites
Type of Structure
SFR1
MFR2
BLDG3
Number of Service Connections
SFR - single family residence
MFR - multi-family residence
BLDG - public or commercial buildings
Refers to buildings that contain copper pipes with lead solder installed after 1982.
Refers to buildings that contain copper pipes with lead solder installed before 1983.
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Suggested Directions for
Homeowner Tap Sample Collection Procedures
(Revised 9/2006)
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. Do not remove the aerator prior to sampling. 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
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Form 141-A
Page 1 of 3 (Suggested Format)
SAMPLE SITE IDENTIFICATION AND CERTIFICATION
System's Name:
Address:
System Type: CH CWS
Number of People Served:
D NTNCWS
System ID #:
Contact Person:
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:
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)
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Form 141-A (continued) Page 2 of 3 (Suggested Format)
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 the Code of Federal Regulations (CFR),
40 CFR 141.42.
Capital improvement plans and/or master plans for distribution system development
Current and historical standard operating procedures and/or operation and maintenance (O&M) manuals for the
type of materials used for service connections
Utility records including meter installation records, customer complaint investigations and all historical
documentation which indicate and/or confirm the location of lead service connections
Existing water quality data for indications of "troubled areas"
Other Sources Which PWS Utilized
Interviews with senior personnel
Conduct service line sampling where lead service lines are suspected to exist but their presence is not confirmed
Review of permit files
Community survey
Review of USGS maps and records
Interviews with pipe suppliers, contractors, and/or developers
Explanation of fewer than 50% LSL sites identified (attach additional pages if necessary):
CERTIFICATION OF COLLECTION METHODS
I certify that:
• Each first draw tap sample for lead and copper is 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.
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Form 141-A (continued) Page 3 of 3 (Suggested Format)
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
you must still provide your sample results to the State b
percentile levels, you do not need to submit the 90th percentile calculations. However,
ine that they have specified.
THE RESULTS OF WATER QUALITY PARAMETER SAMPLES MUST BE ATTACHED TO THIS DOCUMENT
# of WQP tap samples required # of WQP tap samples submitted
# of entry point samples required # of entry point samples submitted
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
Note: The 2000 LCRMR no longer requires 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 2000 LCRMR. Please check with your State before using the revised
Form 141-A.
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Amended Form 141-A Page 1 of 2 (Suggested Format)
CAMPLE SITE IDENTIFICATIO:
System's Name:
Address:
System Type: CH CWS
Number of People Served:
D NTNCWS
System ID #:
Contact Person:
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:
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 9 Ob 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 WQP tap samples submitted
# of entry point samples required # of entry point samples submitted
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Amended Form 141-A (Continued) Page 2 of 2 (Suggested Format)
SAMPLE SITE IDENTIFICATIO1
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
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Note: The 2000 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 cannotbt 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 (Suggested Format)
RQUEST FOR REDUCED LEAD AND COPPER TAP WATE
System's Name:
Address:
System ID #:
Contact Person:
The
System Type: D CWS
Number of People Served:
D >100,000
D 10,001 to 100,000
D 3,301 to 10,000
Telephone number:
D NTNCWS
D 501 to 3,300
D 101 to 500
D <100
. 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:
Biannual to Annual
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
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Form 141-C Page 1 of 2 (Suggested Format)
OPTIMAL CORROSION CONTROL TREATMENT RECOMMENDATIO,
System's Name:
Address:
System Type: DCWS
Number of People Served:
D NTNCWS
System ID #:
Contact Person:
D >ioo,ooo
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
RESULTS OF MONITORING
The Results of Source Water, Tap Water, and WQP Samples Must Be Attached to This Document
# of tap water samples required # of tap water samples submitted
# of source water samples required # of source water 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
Test 2 ~ Calcium Hardness Treatment
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
Test 3 ~ Addition of Corrosion Inhibitor
Test 4 ~ Other (please specify)
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
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Form 141-C (continued) Page 2 of 2 (Suggested Format)
OPTIMAL CORROSION CONTROL TREATMENT RECOMMENDATION
1. Treatment recommendation and rationale:
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
(date). Optimal corrosion control treatment was installed on (date).
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
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Form 141-D Page 1 of 2 (Suggested Format)
SOURCE WATER MONITORING AND TREATMENT
System's Name:
Address:
System Type: D CWS
Number of People Served:
D > 100,000
D 10,001 to 100,000
D 3,301 to 10,000
D NTNCWS
D 501 to 3,300
D 101 to 500
D
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Form 141-D (continued) Page 2 of 2 (Suggested Format)
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
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APPENDIX E
Lead Consumer Notice Certification Form (Suggested Format)
System name:
PWSID no:
Monitoring period to which the notice applies (e.g., June - Sept. 2009):
Date(s) results were received from laboratory:
Date(s) results were provided to consumers:
The water system named above hereby certifies that its lead consumer notice has been provided to each person
it serves at the specific sampling site from which the sample was tested. The water system also certifies that
these results and the following information were provided to such persons within 30 days of receiving the test
results from the laboratory:
Individual tap results from lead tap water monitoring carried out under the requirements of 40 CFR
141.86.
An explanation of the health effects of lead.
Steps that consumers can take to reduce exposure to lead in drinking water.
Contact information for our water utility.
The maximum contaminant level goals and action levels for lead, and the definitions of these two terms
from40CFR141.153(c).
Certified by:
Name
Title
Phone # Date
* * * You are not required by EPA rules to report the following information, but you may want to provide it to
your State. Check all items that apply. ***
Notice was distributed by mail or other direct delivery. Specify other direct delivery methods:
electronic mail.
posting the notice on the Internet at www._
posting the notice in public places (attach a list of locations).
delivery of multiple copies to single bill addresses serving several persons such as: apartments, businesses,
and large private employers.
other methods.
Revised LCR Monitoring and Reporting Guidance E-l
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