UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     GUIDANCE FROM HOTLINE COMPENDIUM
                                                                            WSGH43
                                                                 Date Issued: July 1992
SUBJECT:   Geographic Distribution of Sample Sites for Lead and Copper

SOURCE:    Jeff Cohen
The Final Lead and Copper Rule (56 FR 26460) does not clearly define the geographic
distribution required for tier one sampling sites.  The only language addressing the distribution
of sample sites is found in the preamble  of the Lead and Copper Rule on page 26518, which
refers to tier two monitoring sites after systems have exhausted their tier one sites. The
preamble indicates that the tier two sampling sites should be "... as equally distributed as
possible..."  when all the tier one sites have been used. However, the Rule does not explain what
geographic distribution of sampling sites is  required for the tier one samples.
Would a public water supply system better meet the requirements of the Final Lead and Copper
Rule if the tier one samples sites were close together, or if they were spread out over the area
served by the water system?
       Response:

       No specific geographic distribution requirement for tier one sampling sites is placed on
       the regulated community.  The intention of the Lead and Copper Rule is to obtain
       samples over the widest and most representative geographic distribution possible while
       maintaining compliance with the rule.

-------