What's in a Sample Bottle Label Name?
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., SP01 or SP04). The EPA database will only accept samples labeled in this
manner for nitrate-nitrite, other chemicals, and radionuclides. The SPxx designation tells EPA that 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 indicates that 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. If there 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
From the 2018 Annual EPA Newsletter
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groundwater source facility codes that were combined (e.g., Combined WL01, WL02, and WL03). This sample must be
labeled as the 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 location?
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
as the 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 remember to label each sample bottle differently according to the naming
conventions described above. Even though the sample location is the 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 for failure 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@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 Watch
(https://sdwisr8.epa.gov/Region8DWWPUB/). 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
Nitrate-Nitrite
Entry point to the distribution
system, after treatment*
Example: SP01, SP04
Revised Total
Coliform Rule
Total Coliform and E. coli
Within the distribution
system*
Example: DIST - Men's
restroom, or DIST-123 Main
Street
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.
From the 2018 Annual EPA Newsletter
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