United States Environmental Protection Agency—Region 8
1595 Wynkoop Street
Denver, CO. 80202-1129
Phone: 1-800-227-8917
Fax: 1-877-876-9101
February 12, 2018


New Drinking Water Manager in EPA Region 8. We are pleased to welcome Angelique Diaz into the drinking water
program as the new Drinking Water Unit B Manager. Angelique has been with EPA since 2008, working first in the Air
Program on the regulation of radioactive emissions and mostly recently as the energy sector lead in the NEPA program.
Angelique is a licensed P.E., has a Ph.D. and M.S. in Environmental Science and Engineering (focusing on radiochemistry
as well as water and waste water treatment) and a B.S. in Chemical Engineering, all from the Colorado School of Mines. In
her new position, she will focus on tribal systems, Lead and Copper Rule, Radionuclides Rule, Surface Water Treatment
Rule, and inventory/data systems. If you need to reach Angelique, you may call her at 303-312-6344 or email
On November 30th, 2017, Mindy Mohr retired as the Drinking Water Tribal Liaison. Mindy served as a dedicated EPA
employee for 30 years, 20 of those years with R8's Drinking Water Program. Mindy's experience, dedication, and work
ethic will be sorely missed by all those who worked with her. Mindy's shoes are now being filled by Nate Delano. Nate has a
Master's Degree in Water Policy and GIS, began his EPA career with the Clean Water Act program, and has worked for the
last six months on the Lead and Copper Rule. Happy trails, Mindy, and welcome, Nate!
Please see the revised contact list on Region 8's WaterOps website for a full run-down on our staff.
There is good news and bad news about changes to Drink
The bad news is:
•	The last week of December, we had to decommission
the registration components of DWW because of
internal security changes.
•	No new DWW users will be able to register after
•	We are uncertain what all of the repercussions will be
at this time; we have to wait and see.
Water Watch.
The good news includes:
•	Currently registered users will still be able to logon to
DWW as before.
•	Passwords may or may not expire (we are uncertain at
•	If passwords expire, we have no way of resetting
•	Our current plan isto keep the existing DWW up and
running (to the degree possible) for as long as
•	Most importantly, the public version of DWW
(DWWPUB) at:
will soon have most of the information that the
password protected DWW has, except sanitary survey
•	As far as we know, we will still be able to send
monthly Sampling Reminders.
•	The process of opting in/out of receiving monthly
reminders will need to change because that process
was handled through the registration version of
DWW. This will become a manual (on request)
process, when necessary

How to Prepare for Your Water System's On-Site Sanitary Survey

Here's what you can do to
prepare for your sanitary survey to
make the process go smoother,
faster and result in fewer
significant deficiencies.
Review your system's previous
sanitary survey report (surveys for
Community systems are conducted
every 3 years, Non Community
systems - every 5 years).
Review the current year
sanitary survey report form,
attached to the email notification
from the EPA Region 8 saying that
your system is due for a survey this
You should see this email in
February or March. Collect updated
contact information or your facility
(mailing address, phone number
email address). Collect information
on the number of people served by
the water system: residential/
transient, and the number of service
connections (metered, unmetered).
Does your water system have a
certified operator? (Required only
for Community or Non-Transient
Non-Community systems).
If your system purchases water
what is the name of the system that
supplies your water, and its PWSID
number? (Who maintains the
connection between the two
If your system sells water to
other systems what are their names
and PWSID numbers? (Who
maintains the connection(s)
between the systems?)
If your system has wells, are the
well caps sealed (check the
compression seal, gasket or o ring,
and look for missing bolts or a
disconnected conduit). Is there a
source water tap?
If your system has a spring
source, do you have construction
drawings, as-built drawings, or
photographs documenting the
spring construction? Does the water
enterthe spring boxthrough a
perforated pipe? At what depth? Is
the hatch sealed with a gasket? Do
vents and overflows have (#24
mesh) screens?
Review the sections of the
current year sanitary survey report
form that apply to your water
system and identify any potential
significant deficiencies seen in red
text on the report form and
identified by an (a) symbol that you
may need to address. Ifyoursisa
surface water system, also address
the issues, prior to the survey,
identified in blue and by a ₯ symbol
on the survey report. Call the EPA if
you have any questions about any
potential significant deficiencies or
violations before you make any
For water systems that have
above-ground storage tanks
(ground level or elevated), EPA
doesn't require its surveyors to climb
storage tanks. We do not provide
the necessary safety training nor
safety equipment.
Be proactive and review the
"Storage Tank - Above Ground
Rooftop Component Checklist for
Finished WaterTanks" at
(click on Reporting Forms, click on
Sanitary Surveys) and inspect each
of your storage tanks' components
prior to the survey. For each
question on the checklist please
provide photos illustrating heights,
screen mesh size, etc. for each
feature, and include the storage
tank name and the facility ID
specified on your water system's
schematic (e.g. ST01).
Each storage tank should be
cleaned every 3 to 5 years. However,
if it has been more than 10 yearsthis
will be identified as a significant
deficiency and you will be asked to
provide a "Finished Water Storage
Tank Inspection/Cleaning
Checklist" completed by either the
water system staff or a tank cleaning
contractor. If you wish to take care
of this prior to the survey, you may
obtain a copy of the checklist at
(click on Reporting Forms, click on
Sanitary Surveys) and document
information for each of your
system's storage tanks that are due
for cleaning prior to the survey. The
questions on this checklist are the
same as on the "Rooftop Component
Checklist" above, in addition to
questions about the tank overflow,
tank drain and what wasfound
during the cleaning. Again,
photographic documentation is
required along with the answersto
each question on the checklist
Be sure that you have updated
sampling plans available for:
• Revised Total Coliform Rule
(RTCR) sampling locations.

Many Community and Non-
Transient systems should have
updated monitoring plansfor:
•	Disinfection Byproduct Rule
monitoring locations and
•	Lead and Copper Rule sampling
Priorto the survey, visit all of the
locations the surveyor will visit and
make sure you have access to all of
the facilities:
•	Obtain land owners'permission
for you and the surveyor when
traveling on or across private
•	Make sure there are no
rodents encamped on or around
well heads, pumps, sample taps,
• Make sure backflow prevention
devices have been tested within
the last year.
If you have any questions, need a
survey report or report form, contact
Jim Gindelberger, 303-312-6984,
Knowing that no one ever wants
to have an emergency disaster affect
a water system, all public water
systems should prepare as much as
possible BEFORE a disaster strikes.
With extreme and unpredictable
weather affecting all parts of
Wyoming, the first step is to dust off
and update your emergency
response plan. With the turnover of
personnel at some water systems, it
is highly recommended that, you
review the plan at least once a year.
An updated plan will reduce the work
and stress that occurs when an
emergency occurs. Please take a
look at the Region 8 Water
Operations webpage for guides and
templates, and use or modify the
template that will work best for your
system. See the templates at:
The Region 8 Drinking Water
Program offers occasional water
emergency preparedness
workshops. With local, state and
federal stakeholders at these
workshops, this is a great way for all
types of water systems to become
familiar with the process of
responding to an emergency
incident and establishing critical
partnerships before a situation
occurs. As part of the workshop, the
participants are presented with a
scenario and all stakeholders then
walk through the process of
responding to each stage of the
disaster. Past workshops show that
it's enlightening to consider all the
duties needed to respond to an
emergency, and it's fun to work
through the incident with other
water system personnel and
agencies outside of the emergency
Remember, if you have an
incident that disrupts your water
supply or poses potential
contamination you must call one of
the EPA staff as soon as possible. If
there is a drinking water emergency
and the EPA office is closed, please
call 303-293-1788 for assistance, and
let the operator know that you
represent a public water system that
is regulated by EPA Region 8. As the
primacy agency, the EPA may be
able to assist you with additional
The national EPA Drinking Water
and Wastewater Resilience website
includes more hands-on information
on how a water system can assess its
facilities, and plan and train for
specific disaster situations. The free
Water Utility Response On-the-Go
app is an excellent too! that can be
downloaded on your computer,
phone or tablet. The app will allow
water system personnel to:
•	Identify and contact emergency
response partners
•	Monitor local and national
severe weather
•	Review and complete incident-
specific checklists
•	Fill in, save and email damage
assessment forms with photo
•	Access Incident
Command System procedures
and resources
Instructions on how to use the
Water Utility Response On-the-Go
app can be found on this website.

Please consider all these options
as resources and guides to be the
best prepared water system
possible. A plan of action and
knowing your system's operation will
help you properly react in a limited
time. Please take a look at the EPA
Emergencies and Security webpage
for further resources. If you would
like to speakto someone directly for
further assistance, please contact
Kyle St. Clair at 303-312-6791 or
All compliance documentation
(monitoring results, significant
deficiency corrections, etc.) should
be submitted to the EPA Region 8
office through the
R8DWU@epa.aov (R8DWU) e-mail
portal. Documentation that is sent to
R8DWU, following the rules
described below, is instantaneously
distributed via an automated process
to the appropriate EPA staff. Use of
R8DWU helpsto ensure your
documentation is handled in a timely
manner, independent of staff
schedules or changes. It also
simplifies the documentation
submittal process by providing you
with a single e-mail addressto use
for all compliance reporting.
R8DWU E-mail Rules:
1. Include your PWS ID# in the
subject line of the e-mail.
2.	Include the correct keyword or
abbreviation for the
documentation being submitted
in the subject line of the e-mail
(see the table below).
3.	More than one type of
documentation can be
submitted in the same e-mail as
long asthe subject line ofthe e-
mail contains the correct
keyword or abbreviation for each
type of document being
submitted. Each keyword should
be separated by a comma. For
example, if an e-mail contains
both nitrates, inorganic
compounds (IOC), volatile
organic compounds (VOC), and
synthetic organic compounds
(SOC) results; the e-mail subject
should be: "WY5600000 NO3,
4.	Do not copy any EPA staff on the
If the above rules are not
followed, you risk your
documentation being mishandled
and not received by the appropriate
EPA Region 8 staff. For example, if
Rule 3 above is not followed, the
results will not be distributed to the
correct group of people. If you copy
EPA staff on the e-mail to R8DWU,
these individuals will receive the e-
mail from you directly and will also
receive a forwarded copy ofthe e-
mail from R8DWU. This creates
confusion and unnecessary
Please follow the above rulesto
help us make this process work for us
and for you!
Atable with the appropriate
keyword or abbreviation to use for
each type of documentation is
included below for your reference.

R8DWU Documentation Submittal Keyword List
Type of Documentation
Required Keywords
Example E-mail Subject
Consumer Confidence Report (CCR)
"CCR" or "Water Quality Report"
WY5600000 CCR
Disinfection Byproduct (DBP) Results (TTHM or HAA5)
"DBP" or "TTHM" or "HAA5"
WY5600000 DBP
DBP Precursor Results (Total Organic Carbon and/or
alkalinity and/or UV absorbance)
"TOC" or "TOCA" or "Precursor" or "SUVA"
WY5600000 TOC
DBP Operation Evaluation Level (OEL) Report
WY5600000 OEL
Inorganic Compounds (IOC), including asbestos and/or
Synthetic Organic Compounds (SOC) and/or
Volatile Organic Compounds (VOC)
"IOC" or "SOC" or "VOC"
WY5600000 IOC or
WY5600000 IOC, SOC, VOC
Lead and Copper Rule (LCR) Results (including Water
Quality Parameters results)
"LCR" or "Lead" or "Copper" or "Pb/Cu"
WY5600000 LCR
LCR Sample Plan
"LCR Sample Plan" or "LCR Plan"
WY5600000 LCR Sample Plan
LT2 Source Water Monitoring Results (E. Coli or
"LT2" or "Crypto"
WY5600000 LT2
Maximum Residual Disinfectant Level Report (MRDL)
WY5600000 MRDL
Nitrate or Nitrite Results
"Nitrate" or "Nitrite" or "N03" or "N02" or
"N+N" or "N-N"
WY5600000 NO3
Radionuclides Results
"RADS" or "Radionuclide"
WY5600000 RADS
Revised Total Coliform Rule (RTCR) Results - Wyoming
"Wyoming BACT" or "WY BACT" or BACT
WY" or Wyoming RTCR" orWY RTCR" or
WY5600000 WY BACT
RTCR Level 1 or Level 2 Assessment
"Level 1 Assessment" or "Level 2
Assessment" or "RTCR Assessment"
WY5600000 Level 1 Assessment
RTCR Seasonal Start-up Checklist
"Seasonal" or "Start-up"
WY5600000 Seasonal Start-up
Significant Deficiency Correction Notice
"Significant" or "Deficiency" or
WY5600000 Significant Deficiency
Surface Water Treatment Rule (SWTR) Monthly
Operating Report
"SWTR" or "LTi"
WY5600000 SWTR
System Changes (Contacts changes, change form, or
basic information form) - Wyoming
"Wyoming Change" or "WY Change" or "WY
INV Change"
WY5600000 WY Inv Change
Example subject for an e-mail that contains nitrates, IOC, SOC, VOC and Rads results: "WY5600000 NO3, IOC, SOC, VOC, Rads"

Region 8 directly audits and
certifies the primary state
laboratories in Colorado, Montana,
North Dakota, Utah and South
Dakota. Additionally, the following
Wyoming laboratories are certified
by EPA Region 8 either directly
through on-site evaluations or via
reciprocity with the National
Environmental Laboratory
Accreditation Program (NELAP):
•	Cheyenne Board of Public
Utilities Laboratory
•	Energy Laboratory in Gillette
•	Energy Laboratory in Casper
•	Intermountain Laboratory in
•	Lander Regional Hospital Lab
•	Lincoln Water Quality Lab in
•	National Park Service Lab in
Mammoth Hot Springs
•	Sweetwater Health Department
Lab in Rock Springs
•	Teton County Water Lab in
•	Wyoming Department of
Agriculture Lab in Laramie
•	Wyoming Public Health Lab in
•	Zedi US, Inc. lab in Pinedale
•	Zedi US, Inc. lab in Riverton
Billings and Helena branches of
Energy Laboratories, Inc. are
certified by their home state or
through The NELAC Institute (TNI).
EPA Region 8 recognizes these
certifications through reciprocity.
Before a PWS submits its water
sample to any lab, particularly any
lab that is not listed above, the water
system will have to askthe lab about
the status of its certification for the
particular contaminant(s) that will be
tested. If Region 8 receives lab
resultsfor drinking water samples
from a laboratory that is not certified
by EPA or a state for that particular
contaminant(s), then we cannot
accept the sample results and a
monitoring violation will be
The contaminants that labs are
certified for, vary from lab to lab. For
example, Wyoming Public Health
Lab in Cheyenne is certified for Total
Coliform and E Coli testing, but is
not certified for nitrate, lead and
copper or other chemicals. Atable
showing the labs listed above and
the chemicalsfor which they are
certified is posted on the Region 8
Drinking Water Online website at
this link:
Ultimately, it is the responsibility of
each water system to verify that the
lab it uses has unexpired certification
for the particular contaminant(s) it
wants tested.

Good job seasonal systems
on your Seasonal Startup
Where the process was
completed correctly, most systems
avoided any water quality problems!
In 2017, we found that seasonal
systems that did not disinfect and
flush their water facilities before
opening to the public experienced
contamination problems during their
open season, causing operational
disruptions and inconveniencing
their visitors. Based on feedbackthat
we heard from you we have tried to
make the form easierto complete
and added a section at the end for
public water systems (PWSs) with
multiple water sources.
A Seasonal Water System is
one that is operated as a public
water system for only part of the
year. Even if your system remains
pressurized during the off-season
while not open to the public, yours is
a seasonal system. Every seasonal
system MUST complete a Seasonal
Startup Checklist and EPA must
receive it BEFORE you start serving
water to the public (the form is
available at
This article discusses some
changes to the 2018 Seasonal
Startup Checklist based on feedback
and experiences from the past year:
•	Routine Total Coliform Sampling
•	"Special" Sample Requirement
•	Seasonal End Date
•	Systems that Remain
•	One Source and One
Distribution System
•	Multiple Sources and Multiple
Distribution Systems
Routine Total Coliform Sampling
At least one Routine total
coliform sample is required during
every calendar month a PWS serves
water to the public, even if only for
one day during the month. If you
write on the Checklist that your PWS
closes on September 1, 2018 then
EPA will expect a September
Routine sample result. Be sure to
collect your required Routine
sample(s) while the PWS is operating
under normal conditions. Don't wait
until you have already winterized
your distribution system to collect
your samples. If samples are
collected from locations different
from your RTCR Sample Siting Plan
(without prior approval) your PWS
may be subject to a monitoring
"Special" Sample Requirement
After inspecting your water
system, disinfecting the lines,
flushing the lines and making any
needed corrections at least one pre-
season "Special" sample must be
collected and submitted to EPA (#7
on the Checklist). This is not your
compliance "Routine" sample. The
"Special" sample(s) ensures that
your PWS is adequately disinfected
and flushed BEFORE you serve water
to the public. It is required BEFORE
you start serving water to the public
so that if there are any problems you
will have time to addressthem
before the water system opens and
you run the risk of making people
sick. Suggested pre-season sampling
locations are from the source(s) and
the most often used public tap(s) in
the distribution system.
If you complete the Seasonal
Startup Checklist during the same
month that your PWS opens to the
public, then you are required to
collect two sets of samples at
different times. Since the purpose of
the "Special" sample(s) isto make
sure the water system is in order,
EPA recommends waiting until your
"Special" results come back total
coliform negative (TC-) before
collecting your required Routine
sample(s). You can collect your
"Special" sample(s) from location(s)
of your choice but your "Routine"
samples must be collected from
location(s) specified on your RTCR
Sample Siting Plan. Be sure to allow
enough time in the calendar month
to collect both your "Special" and
"Routine" samples.
Seasonal End Date
This date will be used as your
seasonal shutdown date in the EPA
database. If you write that your PWS
closes on September 1, 2018 then
EPA will expect a September sample
result. In August, if you see that you
are not getting the September
reservations you expected, contact
EPA to change the closing date. If
you do not inform EPA that the PWS
actually closed on August 15, 2018,
then your PWS will receive a
monitoring violation for September.
An email to R8DWU(a)EPA.qov with
your Public Water System ID
(PWSID) and "RTCR Seasonal
closure" or something similar in the
subject line will get routed to the
proper EPA staff.
Systems that Remain Pressurized

If your water system remains
pressurized year-round but your
population drops below the required
minimum to be considered a PWS
you are required to complete a
Seasonal Startup Checklist. The
Revised Total Coliform Rule section
of your Monitoring and Reporting
Requirements will plainly state if you
are a seasonal system. Even if you
would preferto monitor all year
instead of completing the Seasonal
Startup Checklist that is not an
option. If you think EPA has
incorrectly categorized your PWS as
a seasonal system you can fill out a
Basic Information Form and EPA will
re-assess your status
oq/documents/wvominq basic infor
mation form.pdf).
One Source and One Distribution System
Kitchen Faucet
Sampling Station &
Sampling Point
Happy Well
Most PWSs have one source that feeds one or more distribution systems. If this is the case for your PWS, then you can disregard the new
table at the end of the Seasonal Startup Checklist. The main checklist will suffice for starting up your water system.
(Note: The star and arrow indicating a sampling point is not for total coliform samples. Your total coliform samples must be collected according to
your RTCR Sample Siting Plan.)
Multiple Sources and Multiple Distribution Systems
Kitchen Faucet
Sampling Station &
Sampling Point

Happy Well
(DIST 01)
Bai Sampling Station &
Sampling Point
Green Well
(DIST 02)

If you operate a seasonal system with separate distribution systems each served by a different water source then please continue reading,
EPA has changed the Seasonal Startup Checklist to address these situations. The Seasonal Startup Checklist is due BEFORE serving water from the
FIRST well/distribution system that opens for your PWS. If you have 2 wells/distribution systems and one opens in June and the other in July, then the
Seasonal Startup Checklist is due to EPA by the end of May. Use the table on the last page of the Checklist to list the individual wells, schedules and
what steps you plan on taking prior to serving water to the public from those wells. (Note: The star and arrow indicating a sampling point is not for
total coliform samples. Your total coliform samples must be collected according to your RTCR Sample Siting Plan.)
The following is an example of how the table should be filled out:
Well Name
Planned Startup Activity
Startup Date
Date Special
(i.e.. WLOxl
System Name
(i.e.. DSOxt
(use additional space if
(if different than
other sources)
lif different than
other sources)
(Happy Well)
Dist 01
**See the main checklist**
June 14, 2018
Sept 12, 2018
collected May
15, 2018
(Green Well)
Dist 02
1 will inspect the well and
clean the area around it,
inspect the hydro-pneumatic
tank, change the sediment
filter for the season, disinfect
and flush the distribution
system, and inspect the
pipes. 1 will collect special
samples from the well and
the bar sink on June 1, 2018.
July 25, 2018
Oct 16, 2018
Will collect
June 1, 2018
If you need more information, please contact Jamie Harris at harris.iamied&epa.qov or qoq-qi2-6o72.
Over the past couple of years, the Region 8 Lead and Copper Team, our technical assistance (TA) partners, and public
water systems have worked together to improve LCR Tap Sample Site Plans. As of December 2017, 66% of PWSs in
Wyoming and 54% in Indian country have fine-tuned, finalized and submitted their sample plans to us.
Thank you for all of your hard work on these!
If your system has not yet finalized a LCR Tap Sample Site Plan:
•	Call the Denver office or your TA provider for assistance in completing one.
•	Use resources like the County Assessor's Office and online real estate websites to determine the ages of the sample
locations (i.e.
•	Use the LCR Tap Sample Site Plan Instructions located on Drinking Water Online to ensure your sample plan complies
with the LCR.
Reminder: If your system has submitted a sample plan you must take your samples from locations that are listed
on your plan. Failure to follow your LCR Tap Sample Site Plan could result in samples being invalidated. If you need to
adjust your plan, contact the Denver office. Together we can work towards minimizing exposure to lead and copper from
drinking water!

To report a chlorine residual or not to report a chlorine
residual? That is the question that we will clarify here, as
well as other issues related to chlorine residual reporting
to EPA Region 8. If you operate a community water
system (CWS) or a non-transient non-community water
system (NTNCWS), you should read the rest of this article.
If you manage a transient non-community water system
(TNCWS), then please move on and enjoy the other
articles in this newsletter.
Underthe Code of Federal Regulations (CFR) §141.132
(c)(i)(i), all CWSs and NTNCWSs acrossthe country that
add chlorine to the water supply are required to measure
the amount of chlorine residual at the same time and
location as the total coliform samples collected for
compliance. This includes all routine and repeat total
coliform samples.
Special total coliform samples are not required to
have a measured chlorine residual. We recommend
measuring chlorine residualsfor special samples, so the
operator can have a full understanding of the disinfectant
levels when you receive your lab results a couple of days
after the sampling event. However, you are not required
to report this chlorine residual to EPA.
At the beginning of 2017, EPA required Wyoming and
Tribal public water systemsto submit a maximum residual
disinfectant level (MRDL) Form 2 to EPA Region 8 each
quarter. EPA is now calculating the MRDL values for public
water systems, and thus the MRDL Form 2 is no longer
required. However, in order for us to calculate these
valuesfor you, you must submit your chlorine residuals
with your total coliform samples.
After measuring the chlorine residual, we recommend
that you write "CI2 residual" and the measured value on
the lab's chain of custody form for your total coliform
sample. When writing the actual number, ensure that it
can be read, including the location of the decimal point.
To ensure this, we recommend using a zero followed by a
period if the value is lessthan 1.0 (for example, CI2
residual 0.2).
If your laboratory sends the total coliform results to
EPA directly, please have a short tailgate discussion with
the lab to ensure that they will include the chlorine
residuals with the total coliform results that they report to
It. is the public water system's responsibility to ensure
these chlorine residuals are passed along to EPA;
therefore, this short conversation may avoid extra work
down the road.
In 2018, EPA will be reviewing monthly all of the
routine and repeat total coliform samples submitted for
compliance to see if chlorine results are being reported. In
order to avoid unnecessary backtracking and possible
violations, please ensure that your measured chlorine
residuals are being passed along to EPA in a proper
For more information, please contact Seth Tourney at
tourney.seth(a) or 303-312-6579.

Using best sample collection
practices is imperative so that a
sample result is truly representative
of the water source and not a result
of cross contamination with other
chemicals. This is especially
important when conducting
sampling for inorganic and organic
chemicals because there are many
consumer products in the
marketplace that can cross
contaminate water samples if one is
not careful. It is also important to
use best practices for collecting
samples so that the highest quality
samples can be evaluated by the
The following recommended
best practices are not
comprehensive, but they do help
minimize the potential for cross
contamination of drinking water
samples in the field and ensure
quality samples are provided to the
laboratory for analyses.
•	Make sure you do not handle
chemicals before collecting
water samples.
•	Do not store chemicals like
gasoline, pesticides, oils,
epoxies, or sealants near the
sampling location(s).
•	Wash your hands with soap and
water before collecting water
•	Collect samples in an area free of
excessive dust, debris, rain,
snow, or other sources of
•	Check with the laboratory on
how to collect samples, noting
any sample volumes and
maximum holding times that are
required for analysis.
Ask the lab how to fill the bottles
since this will depend on what is
being sampled for
and the method used for
analysis. Plastic, clear glass,
and/or amber glass bottles will
be used for chemical sampling.
The type of cap on the sample
bottles will depend upon the
chemical being sampled for and
the analytical method used by
the laboratory. The absence of
head space is required for
collecting samples in small glass
bottles for volatile organic
analyses (VOA) because volatile
chemicals evaporate into the air.
These bottles are commonly
referred to as VOA vials.
If the bottle contains a
preservative, do not rinse the
Wear gloves and eye protection
when handling acids and other
Ship samples to the laboratory
as instructed and as soon as they
are collected. Delays in shipment
may necessitate re-sampling due
to sample holding times being
exceeded during storage and
Complete the chain-of-custody
form with all relevant
information, including the public
water system identification
number, water system name,
sample collection date, and
sample location(s). The sample
location should include a facility
number and a sample number
(e.g. treatment plant sampling
point TP01/SP01). This ensures
an accurate accounting of where
the sampling took place to
provide EPA with the
information needed to monitor
compliance with the Safe
Drinking Water Act.
Please contact Kendra Morrison
with any questions at (303) 312-6145
or morrison.kendra(a)epa.qov.

The way you label your water samples tells EPA a lot
about the sample, whether you mean it to or not. It also
determines whether your sample results will be credited
to your water system, or if you end up with a monitoring
violation if the correct sampling location is not clearly
indicated. This is the time of year when EPA sends out the
annual Monitoring and Reporting Requirements ("To Do"
lists), along with a "schematic" of your water system. The
schematic is an overly simplified, not-to-scale diagram of
your water system. Instead of showing individual buildings
and streets as your distribution system, it has a large
pound sign or hash-tag, that looks like this #. There is also
at least one red star and blue arrow indicating where a
sample should be collected for Nitrate-Nitrite, other
chemicals, and radionuclides (if required). In most cases,
this is NOT the sampling point for total coliform,
disinfection byproducts, lead or copper. There is a note on
the schematic that says "Sample Points (SP) shown on the
schematic are ONLY for Nitrates, RADs, lOCs, SOCs, and
VOCs. If you sample for other contaminants, please refer
to your individual Site Sampling or Monitoring Plans."
The following article discusses labeling requirements
only for total coliform, nitrate-nitrite, and triggered
Ground Water Rule. The information is applicable to all
PWSs but there is no discussion on how to label samples
for lead, copper, disinfection byproducts, chemicals,
asbestos, radionuclides or any other parameters that may
be required.
Nitrate/Nitrite Monitoring Location
If your system is required to sample for nitrate-nitrite
per your monitoring and reporting requirements, the
sampling point on the schematic is marked as SPxx (i.e.,
SPoi or SP04). The EPA database will only accept samples
labeled in this mannerfor nitrate-nitrite, other chemicals,
and radionuclides. The SPxx designation tells EPAthat a
water sample was collected AFTER any water treatment
processes and BEFORE it got to the first consumer and is
what we call "the entry point to the distribution system".
Please note that you may have more than one sampling
point for nitrate-nitrite due to the layout of your water
system. Please use a certified lab of your choice to analyze
the samples. It is the PWS' responsibility to make sure
that the lab analyzing your samples for compliance is
State or EPA certified for the specific analyte and method
being requested. Make sure the sampling point (the SPxx
number previously mentioned) is clearly noted on the lab's
chain of custody or other form that is submitted with your
samples. This will ensure that the sample result is
accurately recorded in the EPA database as a sample for
compliance. Without the correct sample name location,
your PWS will get a monitoring violation.
Total Coliform Monitoring Location
Sample results for total coliform must be labeled with
a sample location name that clearly indicatesthat it is in
the distribution system, preferably with the letters "DIST"
and according to your Revised Total Coliform Rule (RTCR)
Sample Siting Plan. For example, "men's restroom-DIST"
or "DIST 123 Main St." Total coliform samples must be
collected within the distribution system where the water is
used (not at the storage tank or well house). If you write
on your sample bottle or laboratory chain of custody form
that a total coliform sample was collected at SPxx the
sample will be rejected and you will receive a failure to
monitor violation.
Ground Water Rule (Source) Monitoring Locations
If your water source is a well or spring, you are
required to collect a groundwater source sample at the
well or spring if your PWS has a routine RTCR total
coliform positive (TC+) result. Samples must be collected
from all groundwater sources that were in use during the
collection of the routine RTCR TC+ sample, and they must
be analyzed for total coliforms and E. coli. If you have a
surface water source this requirement does not apply to
your PWS. If you purchase water from another system this
requirement does not apply to you either. However, you
must notify the PWS that you purchase water from, so
that they can take their source water sample. Collect the
source sample(s) at the groundwater source(s) (well or
spring) BEFORE any treatment. Ifthere is no sample tap
on your well(s), you may collect the source sample from
the faucet or tank inlet closest to the well. If your
groundwater sources combine before treatment, you may
take a combined source sample, but make sure to mark
the sample location as "combined" and note the
groundwater source facility codes that were combined
(e.g., Combined WL01, WL02, and WL03). This sample
must be labeled asthe Triggered Monitoring Ground
Water Rule sample (or "TG GWR"for short). You must
indicate that it is a source sample, or collected from the
well or spring so that we know it is not one of the required
RTCR repeat samples from the distribution system.
Remember: this sample is only required if you use

groundwater for your source water, and have a routine
total coliform positive result.
What if SPxx and/or DIST and/or TG GWR are the same
What if your PWS does not have a way to collect a
sample from the source (for the TG GWR), or from the
entry point to the distribution system (for the SPxx for
nitrate/nitrite)? Your first tap within the distribution
system may be designated asthe same sampling location
for all three water samples, the TG GWR, the nitrate-
nitrite, and the total coliform routine sample. If this is the
case, you will need to rememberto label each sample
bottle differently according to the naming conventions
described above. Even though the sample location isthe
same, the EPA database will not accept samples that are
labeled improperly.
So if a nitrate-nitrite sample is labeled as being in the
distribution system and says DIST, you will get a
monitoring violation for failure to collect a nitrate sample.
If the water sample from the same location is labeled as
"TG GWR", and you intended it to be a routine total
coliform sample, it will not be accepted as such, and you
will get a monitoring violation for failure to collect a
routine total coliform sample. If a total coliform sample is
labeled as being from SPxx, you will get a monitoring
violation forfailure to collect a total coliform sample.
Although it sounds confusing, if you print out your
Monitoring and Reporting Requirements, and keep the
form(s) with the correct facility code(s) and sample point
code(s) with your sample bottles, then you can always
refer to it for the proper way to label your samples. We
also recommend keeping your RTCR
Sample Siting Plan close by so that you remember
where to sample each month and the proper sample
naming convention to write on your sample bottles and
laboratory chain of custody as well.
If you do not have an agreement with your lab to send
sample results, then please send ALL lab reports to
R8DWU(a)EPA.GOV as soon as you receive them from the
lab. You must include your public water system
identification number (PWSID) and contaminant that was
analyzed in the subject line. If you are unsure which of
your monitoring requirements you have fulfilled already,
please take a look at your water system on Drinking Water
Simply type in your PWSID to search for your system.
Click on your PWSID to bring up your water system
profile. On the left hand side of the profile you will see an
option to view the contaminants that were analyzed.
EPA Regulation
Contaminant Analyzed
Physical Sample Location
Sample Site Name
Nitrate-Nitrite Rule
Nitrate, Nitrite, or
Entry point to the distribution
system, after treatment*
Example: SP01, SP04
Revised Total
Coliform Rule
Total Coliform and E. coli
Within the distribution
Example: DIST-Men's
restroom, or DIST-123 Main
Ground Water Rule
E. coli
Directly from the well or
spring, before treatment*
Example: TG GWR - source
* If the sample location is the same for all 3 regulations please collect your samples and label each bottle
according to the naming convention above.