UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                                               WSG 77A
                                                          Date Signed: January 10, 1992
MEMORANDUM

SUBJECT:   Consecutive Systems Regulated Under the National
             Primary Drinking Water Regulations for Lead and Copper

FROM:      Jeff Cohen, Chief
             Lead Task Force
             Office of Ground Water and Drinking Water

TO:          Regional Drinking Water Branch Chiefs
       Several States and public water systems have proposed consolidation of lead and copper
tap water sampling, and water quality parameter sampling, in consecutive water systems under
141.29. After reviewing the proposals submitted by Michigan, Massachusetts, and several
water suppliers in Colorado, we believe 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.

       We recognize the burdens on water systems and States to comply with and implement the
lead and copper rule.  We encourage innovative implementation approaches that will meet the
goals and intent of this regulations. We also believe that to insure effective state/EPA
partnerships, it is important that proposals to consolidate consecutive systems  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 (including public education and lead service line
replacement) be clearly identified and accept responsibility for any rule violations.

       Specifically, prior to allowing consecutive systems to consolidate their sampling, the
state must 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.  It is incumbent upon the regional offices to
agree to each State's proposal in writing and have that agreement in place before the regulatory
requirements become effective.

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                                                                                 WSG 77A

       To varying degrees, the proposals that have been submitted up until now have provided
rationale for reduced monitoring, and explanations of responsibilities among the communities
involved.  We believe that future proposals and agreements between States and consecutive
systems should explain which water system is responsible for collecting and reporting to the
State the results of lead and copper tap water monitoring, and all water quality parameter
monitoring.

       In addition, future proposals and agreements should include explanations of how the
following provisions in the lead and copper rule will be modified:

             determination of 90th percentile lead and copper concentrations in the
              consolidated system;

             water quality parameter monitoring to determine baseline values and insure that
              optimal corrosion control treatment is properly installed and maintained; and

             source water monitoring when needed.

       In the preamble to the final rule, we have stated that responsibility for public education
delivery resides with the retailer (the consecutive, or "satellite" system), and responsibility for
source water monitoring and treatment resides with the wholesaler (or "parent" system).  Any
modifications in these responsibilities should be clear in the State proposal and EPA/State
agreement.

       With respect to the other treatment technique requirements, State proposals should
identify the system that will be responsible for completing the corrosion control treatment
requirements under 141.81 and 141.82.  We expect that the parent supply will take
responsibility for corrosion control throughout the entire area served. Depending upon
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.  State proposals should also define responsibility
for lead service line replacement, where it may be necessary.

       If you have any questions, please feel free to call me at (FTS) 260-5456.
cc:     Jim Elder           Peter Cook
       Bob Blanco         Clive Davies
       Connie Bosnia       ASDWA HDQTRS

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