Lead and Copper

Monitoring and

Reporting Guidance for

Public Water Systems 
 Printed on Recycled Paper

Office of Water

(4606M)

EPA-816-R-02-009 

www.epa.gov 

February 2002
Lead and Copper Monitoring Guidance February 2002

Disclaimer

The SDWA provisions and EPA regulations described in this document contain

legally-binding requirements. This document does not substitute for those

provisions or regulations, nor is it a regulation itself. Thus, it does not impose

legally-binding requirements on EPA, States, or the regulated community, and

may not apply to a particular situation based upon the circumstances. EPA and

State decisionmakers 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, and

EPA will consider whether or not the recommendations or interpretations in the

guidance are appropriate in that situation. EPA may change this guidance in the

future. Mention of trade names or commercial products does not constitute

endorsement or recommendation for use.
Lead and Copper Monitoring Guidance February 2002 i

TABLE OF CONTENTS

CHAPTER I: INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

What Is the Purpose of this Guidance Document? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

How Is This Document Organized? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

What Is the Purpose of the Lead and Copper Regulations? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

What Systems Are Affected by the Lead and Copper Regulations? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

What Are the Requirements of the Lead and Copper Regulations? . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

What Are the Corrosion Control Treatment Requirements? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

What Are the Source Water Treatment Requirements? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

What Are the Public Education Requirements? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

What Are the Lead Service Line Replacement Requirements? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

CHAPTER II: LEAD AND COPPER TAP MONITORING AND REPORTING

REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

What Is The Purpose of Collecting Lead and Copper Tap Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Is My System Required to Collect Lead and Copper Tap Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

When Do I Collect Lead and Copper Tap Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Am I Eligible for Reduced Lead and Copper Tap Monitoring? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Where Must I Collect My Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

How Do I Collect Lead and Copper Tap Water Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

What Are the Approved Methods for Analyzing Water Samples for Lead and Copper? . . . . . . . . . . . . 23

How Do I Evaluate My Results? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

What If the State Determines that My Samples Are Invalid? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

What Should I Do If I Exceed an Action Level While I am Monitoring at 6-month intervals? . . . . . . . 32

What Should I Do If I Exceed the Lead or Copper Action Level During Reduced Monitoring? . . . . . 33

Can I Ever Discontinue Lead and Copper Tap Monitoring? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

What Lead and Copper Tap Monitoring Information Must I Report to the State? . . . . . . . . . . . . . . . . 34

What Should I Do If I Sell Water To, or Buy Water From, Another Water System? . . . . . . . . . . . . . . . 35

What Happens If I Do Not Fulfill My Lead and Copper Tap Monitoring And Reporting Requirements?36

What Provisions of the LCRMR Pertain to Lead and Copper Tap Monitoring and Reporting? . . . . . . 38

What Key Points Should I Remember About Lead and Copper Tap Monitoring? . . . . . . . . . . . . . . . . 40

CHAPTER III: WATER QUALITY PARAMETER MONITORING AND REPORTING

REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

What Is The Purpose of Collecting Water Quality Parameter Samples? . . . . . . . . . . . . . . . . . . . . . . . . 41

Which Systems Must Collect Water Quality Parameter Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

When Do I Collect Water Quality Parameter Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

How Do I Select My Sampling Sites? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

How Do I Collect Water Quality Parameter Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

How Does the State Determine If I Am In Compliance With My Optimal Water Quality Parameter Values? 49

Can I Ever Reduce My WQP Monitoring? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

Can I Ever Discontinue Water Quality Parameter Monitoring? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

What Water Quality Parameter Monitoring Information Must I Report to the State? . . . . . . . . . . . . . 54

What If I Do Not Fulfill My WQP Requirements? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55
Lead and Copper Monitoring Guidance February 2002 ii

What Provisions of the LCRMR Pertain to Water Quality Parameter Monitoring and Reporting? . . . 56

What Key Points Should I Remember About Water Quality Parameter Monitoring? . . . . . . . . . . . . . . 58

CHAPTER IV: LEAD AND COPPER SOURCE WATER MONITORING AND

REPORTING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

What Is The Purpose of Collecting Source Water Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

Which Systems Must Collect Source Water Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

When Do I Collect Source Water Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

Where Are These Samples Collected? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

How Does the State Evaluate My Source Water Monitoring Results? . . . . . . . . . . . . . . . . . . . . . . . . . . 63

Can I Ever Discontinue Source Water Monitoring? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

What Source Water Monitoring Information Must I Report to the State? . . . . . . . . . . . . . . . . . . . . . . . 65

What If I Do Not Fulfill My Source Water Monitoring And Reporting Requirements? . . . . . . . . . . . . 65

What Provisions of the LCRMR Pertain to Source Water Monitoring and Reporting Requirements?

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

What Key Points Should I Remember About Lead and Copper Source Water Monitoring? . . . . . . . . 67

CHAPTER V: LEAD SERVICE LINE MONITORING AND REPORTING

REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

What Is The Purpose of Collecting Lead Service Line Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

Which Systems Must Collect Lead Service Line Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

When Do I Collect Lead Service Line Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69

How Do I Collect Lead Service Line Samples? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69

Can I Ever Discontinue Lead Service Line Monitoring? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71

What Lead Service Line-Related Information Must I Report to the State? . . . . . . . . . . . . . . . . . . . . . . 71

What If I Do Not Fulfill My Lead Service Line Replacement Requirements? . . . . . . . . . . . . . . . . . . . . 72

What Provisions of the LCRMR Pertain to Lead Service Line Monitoring and Replacement? . . . . . . . 73

What Key Points Should I Remember About Lead Service Line Monitoring and Reporting? . . . . . . . 74

APPENDIX A

List of LCRMR Outreach Materials for Water Systems . . . . . . . . . . . . . . . . . . . A-1

APPENDIX B

Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

APPENDIX C

Monitoring Timelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1

APPENDIX D

Summary of Monitoring and Reporting Violations . . . . . . . . . . . . . . . . . . . . . D-1

APPENDIX E

Worksheet and Instructions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1
Lead and Copper Monitoring Guidance February 2002 iii

LIST OF TABLES

Table 1-1: Corrosion Control Treatment Steps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Table 1-2: Source Water Monitoring and Treatment Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Table 2-1: Schedule for Initial Monitoring1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Table 2-2: Minimum Number of Lead and Copper Tap Samples for Systems on Standard Monitoring

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Table 2-3: Minimum Number of Lead and Copper Tap Samples for Systems on Reduced Monitoring

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Table 2-4: Reduced Lead and Copper Tap Monitoring Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Table 2-5: Tiering Classification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Table 2-6: Approved Analytical Methods for the Lead and Copper Rule . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Table 2-7: Sample Handling Requirements for Lead, Copper, and Water Quality Parameters . . . . . . . . . . 27

Table 3-1: Initial WQP Requirements for Systems Serving 50,000 and Fewer People . . . . . . . . . . . . . . . . . 43

Table 3-2: Standard Number of WQP “Tap” Sites and Samples . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

Table 3-3: Daily Value Calculation Based on Monitoring Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Table 3-4: Reduced Number of WQP Tap Sites and Samples . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

Table 3-5: Reduced WQP Tap Monitoring Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

Table 5-1: Pipe Volume Table (Volumes Listed in Liters) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70
Lead and Copper Monitoring Guidance February 2002 1

List of Acronyms and Abbreviations

AL Action level

ALE Action level exceedance

CCT Corrosion control treatment

Cu Copper

CWS Community water system

EP Entry point

GUDI Ground water under the direct influence of surface water

HNO3 Nitric Acid

LCR Lead and Copper Rule

LCRMR Lead and Copper Rule Minor Revisions

LSL Lead service line

MCL Maximum contaminant level

MDL Method detection limit

MFR Multi-family residence

mg/L Milligrams per liter

MPL Maximum permissible level

NTNCWS Non-transient, non-community water system

OCCT Optimal corrosion control treatment

OWQP Optimal water quality parameter

Pb Lead

ppb Parts per billion

PQL Practical quantitation level

PSA Public service announcement

PWS Public water system

QA/QC Quality assurance/Quality control

SFR Single family residence

SMF Standardized monitoring framework

SOWT Source water treatment

WQP Water quality parameter
Lead and Copper Monitoring Guidance February 2002 2

Lead and Copper Rule Monitoring and Reporting

Guidance for Public Water Systems

CHAPTER I: INTRODUCTION

What Is the Purpose of this Guidance Document?

On June 7, 1991, the United States Environmental Protection Agency or EPA, published in the

Federal Register, a regulation to control lead and copper in drinking water. This regulation is known

as the Lead and Copper Rule (also referred to as the LCR or 1991 Rule throughout this

document). 

On January 12, 2000, EPA published minor revisions to the 1991 Rule. The purpose of the Lead

and Copper Rule Minor Revisions (LCRMR) is to eliminate unnecessary requirements,

streamline and reduce monitoring and reporting burdens, and promote consistent national

implementation. In some cases, EPA has added language which clarifies requirements and

corrects oversights in the original rule. EPA calls the revisions “minor” because they do not affect

the lead and copper maximum contaminant level goals, action levels, or other basic regulatory

requirements to monitor for lead and copper at the tap and to optimize corrosion control. 

This guidance document has been developed for you, the water system owner and operator of

community water systems (CWSs) and non-transient, non-community water systems (NTNCWSs). 

It provides a comprehensive discussion of the monitoring and monitoring-related reporting

requirements of the LCR, as amended by the LCRMR. Some of the LCRMR provisions are

clarifications to the LCR while other provisions are more stringent than the LCR. These are

revisions for which you and your States were required to begin implementation on April 11, 2000. 

Some of the revisions are less stringent than the LCR (e.g., allow a reduction in monitoring if

specific criteria are met) and you may not be able to implement them because your State has

chosen not to adopt these provisions or has not yet incorporated these provisions into its State’s

drinking water regulations. Therefore, you should first check with your State before following any

of these “less stringent” provisions. For water systems on Tribal lands, or located in Wyoming or

the District of Columbia, the Federal version of the entire LCRMR applies. Therefore, you were

able to take advantage of the burden reduction requirements of the LCRMR on April 11, 2000.

EPA recognizes that the majority of systems already have their monitoring programs underway

but believes that systems will find this document useful in understanding the modifications to the

monitoring and reporting requirements resulting from the LCRMR. 
Lead and Copper Monitoring Guidance February 2002 3

How Is This Document Organized?

The document contains five chapters, including this introduction and a discussion of the four

monitoring protocols contained in the LCR. These chapters are listed below. 

q Chapter I: Introduction

q Chapter II: Lead and Copper Tap Water Monitoring and Reporting Requirements

q Chapter III: Water Quality Parameter Monitoring and Reporting Requirements

q Chapter IV: Lead and Copper Source Water Monitoring and Reporting

Requirements

q Chapter V: Lead Service Line Monitoring and Reporting Requirements

Chapter 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 lead service line

replacement requirements. Chapters II through V address the following topics: 

• The purpose of the 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 allows a system to reduce and/or eliminate its monitoring requirements;

• Information that must be reported to the State; 

• How the LCRMR have impacted monitoring and reporting requirements; and 

• Key points to remember. 

Chapter 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, Chapter 40 (i.e.,

EPA’s 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, Department of

Health). For the District of Columbia, Wyoming, and Native American Lands, the contact is

often from the respective EPA Regional Office.

This guidance document focuses on those revisions that impact monitoring and reporting

requirements. Those revisions that are unrelated to monitoring and reporting requirements are
Lead and Copper Monitoring Guidance February 2002 4

discussed in more detail in separate guidance documents. For example, the guidance document,

entitled, Lead and Copper Rule: Summary of Revisions, April 2000, EPA 815-R-99-020, contains a

discussion of each of the important changes made to the 1991 Rule by the LCRMR by major rule

section (e.g., §141.81, §141.82, etc.), and identifies when you must begin complying with the new

requirements. It also contains an appendix which compares the rule language of the LCR against

the minor revisions. All available guidance documents, can be obtained by contacting the Safe

Drinking Water Hotline at (800) 426-4791 or via the EPA website:

www.epa.gov/safewater/leadcop.html. A list of key documents is provided as Appendix A. 

Also included are five appendices to this document:

q Appendix A: List of LCRMR Outreach Materials for Water Systems.

q Appendix B: Definitions that explain the terms used in this guidance.

q Appendix C: Timelines that illustrate the schedule for corrosion control treatment (if

applicable), lead and copper tap monitoring, and water quality

parameters (if applicable).

q Appendix D: Summary of Monitoring and Reporting Violations. 

q Appendix E: Worksheets and instructions to assist in identifying sampling sites,

sample collection, and the documentation and justification of decisions.

What Is the Purpose of the Lead and Copper Regulations? (See §141.80 &

§141.81(b))

The purpose of the lead and copper regulations is to protect public health by minimizing lead and

copper levels in drinking water. Most regulations require sampling at entry points to the

distribution system. Because lead and copper in drinking water is primarily due to the corrosion

of distribution 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 you, the water system, to coordinate with the people you serve. 

What Systems Are Affected by the Lead and Copper Regulations? (See

§141.80(a))

Lead and copper tap monitoring applies to all community water systems (CWSs) and nontransient, 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

provisions.

Size No. of people served

Small 25 - 3,300

Medium 3,301 - 50,000
Lead and Copper Monitoring Guidance February 2002 5

Large over 50,000

What Are the Requirements of the Lead and Copper Regulations? (See

§§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. 

There is no maximum contaminant level (MCL) for lead or copper. However, if your lead and

copper tap monitoring results are higher than the lead action level of 0.015 milligrams 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. An explanation of how to

calculate the 90th percentile levels is provided in Chapter II.

If your 90th percentile level exceeds the lead action level of 0.015 mg/L, you must:

• Begin 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 within 6 months of the exceedance and install source

water treatment, if needed;

• Deliver public education within 60 days of the exceedance that informs your users

about the health effects of lead and measures that will reduce their exposure to lead;

and

• Replace lead service lines if you still exceed the lead action level after installing

treatment.

If your 90th percentile level exceeds the copper action level of 1.3 mg/L, you must:

• Begin corrosion control treatment steps which include WQP monitoring during the

same monitoring period in which the exceedance occurs; and

• Conduct source water monitoring within 6 months of the exceedance and install source

water treatment, if needed.

O Note: Public education and lead service line replacement are

not required if only the copper action level is exceeded.
Lead and Copper Monitoring Guidance February 2002 6

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 have naturally non-corrosive

water and would not benefit from installing treatment. Others installed corrosion control

treatment prior to the effective date of the original LCR (i.e., December 7, 1992). Still other

systems must install corrosion control to reduce the corrosivity of their water and thereby, their

lead and copper levels. 

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.

You can be deemed to have optimized corrosion control if:

1. You are a small or medium system (i.e., serve 50,000 or fewer people) and your 90th

percentile levels are at or below both the lead and copper action levels for 2,

consecutive, 6-month monitoring periods. EPA also refers to these systems as “(b)(1)

systems” because they meet the requirements of §141.81(b)(1) of the federal version of

the lead and copper regulations.

2. You already have treatment in place, prior to the effective date of the 1991 LCR (i.e.,

prior to 12/7/92) and have conducted activities equivalent to those outlined in

§141.81(b)(2). EPA also refers to these systems as “(b)(2) systems ”.

3. You demonstrate 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 (see Table 2-2), and source water samples for lead at each entry point to the

distribution system during each of 2, consecutive, 6-month monitoring periods. EPA

also refers to these systems as “(b)(3) systems” because these criteria are specified in

§141.81(b)(3) of the regulations. 

4. You demonstrate that for 2, consecutive, 6-month periods your source water lead levels

are below the method detection limit (MDL) and your 90th percentile lead levels are

less than or equal to the practical quantitation level (PQL) of 0.005 mg/L. This new

criterion was added in the LCRMR because systems with undetectable source water

lead levels and low 90th percentile lead levels could be precluded from qualifying as a

(b)(3) system under the 1991 LCR. This is because source water levels that are below

the MDL must be reported as 0; whereas, levels above the MDL, but less than 0.005

mg/L must be reported as 0.0025 mg/L which is half the PQL. This point is more

clearly illustrated in the following two examples.
Lead and Copper Monitoring Guidance February 2002 7

Example 1: A system with source water lead levels just below a MDL of 0.001 mg/L and a 90th

percentile tap level of 0.005 mg/L would not be deemed to be optimized using the 1991 LCR

(b)(3) criteria, which requires the difference to be less than 0.005 mg/L. The difference here

would be 0.005 mg/L, as shown in the following equation: 0.005 mg/L - 0 mg/L = 0.005 mg/L. 

Example 2: With a lead MDL of 0.001 mg/L, a system with source water levels of 0.002 mg/L

and a 90th percentile of 0.0050 mg/L would be optimized under the 1991 LCR criteria because

the source levels could be reported as 0.0025 mg/L. The difference here would be 0.0025 mg/L,

as shown in the following equation: 0.0050 mg/L - 0.0025 mg/L = 0.0025 mg/L. 

O Note: The LCRMR also clarify that a (b)(3) system’s 90th percentile

cannot exceed the copper action level of 1.3 mg/L. The 1991 LCR

did not include copper levels as part of the (b)(3) criteria. A (b)(3)

system that exceeds the copper action level after July 12, 2001 (i.e., 18

months after the date of rule promulgation) will no longer qualify as a

(b)(3) system. Such a system must begin corrosion control treatment

steps, unless such treatment is already in place.

What Are the Corrosion Control Treatment Requirements? (See §§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: System serving 50,000 or fewer people submit 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 WQPs after the

installation of corrosion control treatment. Note: Systems serving # 50,000 people are

only required to collect WQP samples if they continue to exceed the lead or copper action level.

Step 7: The State sets WQPs 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
Lead and Copper Monitoring Guidance February 2002 8

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 # 50,000 people are only required to collect WQP samples during any monitoring

period in which they exceed the lead or copper action level.

O Notes: Systems serving 50,000 or fewer people can discontinue these steps

whenever their 90th percentile levels are at or below both action levels for 2,

consecutive, 6-month monitoring periods. In addition, (b)(2) systems are not

required to conduct a study, install corrosion control treatment, or conduct

follow-up monitoring. The LCRMR clarify that (b)(2) systems must

conduct lead and copper tap and WQP monitoring after the State sets

OWQPs. Further, a system that meet the (b)(3) criteria based on initial

monitoring is not subject to the corrosion control treatment requirements.

Table 1-1 shows the schedule for completing corrosion control treatment steps for those systems

that are subject to these requirements.

Table 1-1: Corrosion Control Treatment Steps

Requirement

Timetable for Completing Corrosion Control Treatment 

for Systems Serving:

50,000 or fewer people2 More than 50,000

System recommends the type

of treatment to be installed

6 months after the lead and/or copper action

level exceedance (ALE)

N/A (Part of the corrosion

control study)

State decides whether study is

required

12 months after the ALE N/A (System must conduct

study)

System completes study 18 months after State decision to conduct study July 1, 1994

State determines the type of

treatment to be installed

If study is required:

6 months after study completed

If no study is required:

S for # 3,300: 24 months after ALE

S for 3,301 - 50,000: 18 months after ALE

January 1, 1995

System installs treatment 24 months after State decision regarding the

type of treatment to be installed

January 1, 1997

System conducts follow-up

monitoring

12 months after treatment installation (2

consecutive, 6-month periods)

January 1, 1998

State designates OWQPs1 6 months after follow-up monitoring July 1, 1998

System conducts continued

monitoring

The schedule based on whether an action level is exceeded and/or compliance

with OWQP ranges or minimums
Table 1-1: Corrosion Control Treatment Steps

Requirement

Timetable for Completing Corrosion Control Treatment 

for Systems Serving:

50,000 or fewer people2 More than 50,000

Lead and Copper Monitoring Guidance February 2002 9

Notes:

1

The State is not required to designate OWQPs if a system no longer exceeds both action levels after installing

treatment. However, some States have opted to do so.

2

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.

Form 141-C, Optimal Corrosion Control Treatment/Water Quality Parameters, has been provided in

Appendix E. 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

Chapter II and III, respectively. In addition, Appendix C contains several lead and copper tap

and WQP monitoring timelines that illustrate how these monitoring requirements are impacted by

a system’s size category and whether a system exceeds an action level.

For more information on corrosion control treatment

refer to:

Lead and Copper Rule Guidance Manual, Volume II: Corrosion Control

Treatment, September 1992.

What Are the Source Water Treatment (SOWT) Requirements? (See

§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 SOWT. 

The SOWT steps are as follows:

Step 1: The system conducts source water monitoring 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.
Lead and Copper Monitoring Guidance February 2002 10

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 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).

Table 1-2 indicates the timing of these SOWT requirements. Please note that Steps 3 through 5

only apply to those systems that are required to install SOWT.

Table 1-2: Source Water Monitoring and Treatment Requirements

Action

Deadline for Completing Action Total Number of Months from

ALE

SOWT

Required

SOWT Not

Required

SOWT

Required

SOWT Not

Required

System monitors at

each EP & submits

recommendation

6 months after exceeding the lead and/or

copper action level

6 months

State determines if

SOWT is required

6 months after receipt of results &

recommendation

12 months

System installs

SOWT

24 months after

State requires

SOWT

N/A 36 months N/A

System conducts

follow-up monitoring

12 months after

installing treatment

N/A 48 months N/A

State sets MPLs for

lead & copper1

Within 6 months

after follow-up

monitoring

N/A 54 months N/A

System conducts

routine source water

monitoring 2

Annually for surface water/combined

sources

66 months 24 months

Triennially for ground water systems Depends on 3-yr compliance period in

effect

System conducts

reduced source water

monitoring 3

Once during each 9-year compliance cycle Depends on 9-yr compliance cycle in effect
Table 1-2: Source Water Monitoring and Treatment Requirements

Action

Deadline for Completing Action Total Number of Months from

ALE

SOWT

Required

SOWT Not

Required

SOWT

Required

SOWT Not

Required

Lead and Copper Monitoring Guidance February 2002 11

1

 State will set MPLs for both lead and copper even if the system exceeded only one action level. 

2

 The 1st year of annual monitoring begins on the date the State set MPLs or determined that SOWT was not

needed. Triennial monitoring begins with the 3-year compliance period in effect when the State set MPLs or

determined that SOWT was not needed. 3

 Systems can qualify for reduced monitoring, at a frequency of once every 9-year compliance cycle, if they are in

compliance with their MPLs for 3 consecutive compliance periods (i.e., 3 annual periods for surface

water/combined sources; 3, 3-year periods (equals 9 years) for ground water systems).

O Note: Unlike corrosion control treatment, systems that are at or below both

action levels must complete the source water treatment steps once begun. 

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 Chapter IV of this guidance. 

Detailed information regarding source water treatment is provided in Lead and Copper Rule Guidance

Manual, Volume II: Corrosion Control Treatment, September 1992.

What Are the Public Education Requirements? (See §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, measures you are taking to correct the problem, and what they

can do to minimize their exposure to lead. The public education requirements are different for

CWSs and NTNCWSs. An overview of the requirements are provided below.

Within 60 days of exceeding the lead action level (either for the first time or again after having

monitoring periods at or below the lead action level), a CWS must:

• Insert notices in each customer’s water utility bill;

• Deliver pamphlets and/or brochures that contain the public education materials to

facilities and organizations that provide services to pregnant women and children;

• Submit information to the editorial departments of the major daily and weekly

newspapers circulated throughout the community; and

• Deliver public service announcements (PSAs) to radio and television stations.
Lead and Copper Monitoring Guidance February 2002 12

A CWS must repeat delivery every 6 months for PSAs, and every 12 months for other forms of

delivery, for as long as the system exceeds the lead action level.

Within 60 days of exceeding the lead action level (either for the first time or again after having

monitoring periods at or below the lead action level), an NTNCWS must distribute public

education by:

• 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

NTNCWSs.

An NTNCWS must repeat this information annually for as long as it exceeds the lead action level. 

Any system can stop delivering public education whenever its 90th percentile lead level is at or below

the action level for one monitoring period. If it again exceeds the lead action level, it must

recommence public education within 60 days of the exceedance.

O Please note, the LCRMR offer some flexibility in making revisions to the

mandatory public education language and the distribution of public education

materials. 

For more information on public education, refer

to the updated guidance: Lead in Drinking Water

Regulation: Public Education Guidance, EPA 816-R-02-010.

What Are the Lead Service Line Replacement Requirements? (See §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 2 consecutive monitoring periods.

The monitoring requirements that are associated with lead service line replacement are discussed

in Chapter V. A detailed discussion of the lead service line replacement requirements is provided

in Lead and Copper Rule Guidance Manual, Volume II: Corrosion Control Treatment, September 1992.
Lead and Copper Monitoring Guidance February 2002 13

CHAPTER II: LEAD AND COPPER TAP MONITORING

AND REPORTING REQUIREMENTS

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 not only allows you to determine

the lead and copper concentrations in drinking water, but if you have installed treatment,

monitoring allows you to assess the effectiveness of corrosion control treatment and/or source

water treatment. 

Is My System Required to Collect Lead and Copper Tap Samples? (See

§§140.80(a) & 141.86(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.

When Do I Collect Lead and Copper Tap Samples? (See §§141.86(c) & (d))

Lead and copper monitoring can be divided into four phases:

• Initial monitoring that is required of all systems.

• Follow-up monitoring that corresponds to the 2, consecutive 6-month periods after

a system completes the installation of corrosion control and is only required for systems

that install treatment.

• Routine monitoring applies both to systems that are required to install treatment

and to (b)(2) systems. For these systems, this monitoring occurs after the State sets

OWQPs.

• Reduced monitoring corresponds to monitoring that occurs at a reduced frequency

and a reduced number of sample locations. This reduction is based on a system’s lead

and copper 90th percentile levels or compliance with OWQPs.
Lead and Copper Monitoring Guidance February 2002 14

Table 2-2: Minimum Number of

Lead and Copper Tap Samples for

Systems on Standard Monitoring

System Size No. of Samples

 > 100,000 100

 10,001 - 100,000 60

 3,301 - 10,000 40

 501 - 3,300 20

 101 - 500 10

 # 100 5

Each type of monitoring is discussed in greater detail below. In addition, refer to the monitoring

timelines in Appendix C which help illustrate how lead and copper tap monitoring requirements

are impacted by a system’s size category and whether the system exceeds an action level.

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 Table 2-1 below, and was

specified for discrete 6-month monitoring periods of January through June and July through

December.

Table 2-1: Schedule for Initial Monitoring1

System Size 

(No. of People Served)

1st Initial 

Monitoring Period

2nd Initial 

Monitoring Period

3,300 and under 7/1/93 - 12/31/93 1/1/94 - 6/30/942

3,301 - 50,000 7/1/92 - 12/31/92 1/1/93 - 6/30/932

50,001 and more 1/1/92 - 6/30/92 7/1/92 - 12/31/92

O NOTES: 1

If you are a new system, consult with your State LCR Coordinator to find out when you

should 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 6-month rounds of

initial lead and copper tap monitoring at the standard number of sites, required for your system

size (see Table 2-2). 

If you serve 50,000 or fewer people, you were required to conduct a minimum of one, 6-

month round of initial monitoring at the standard number of sites (see Table 2-2). 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

Chapter I). You also had the option to

continue lead and copper tap

monitoring while conducting corrosion
Lead and Copper Monitoring Guidance February 2002 15

control treatment steps to determine if you were eligible to stop these steps (i.e., you

had 2, consecutive, 6-month periods in which your 90th percentile lead and copper

levels were at or below their respective action levels). 

O Note: If you are triggered into corrosion control treatment requirements,

some lead and copper tap monitoring will be needed to evaluate the type of

corrosion control to be installed and/or fine-tune your treatment. These

samples are not part of your monitoring requirements. However, some

States may require systems to submit these data for compliance purposes. 

In this event, the lead and copper samples must be used by systems and

States in calculating 90th percentile levels [See §141.86(e)]. 

• You were required to conduct a second round of initial monitoring during the next 6

months, if you were at or below the lead and copper action levels during the first round

of monitoring.

O Note: 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 requirements apply to you ~

Follow-up Lead and Copper Tap Monitoring

If you are required to install corrosion control treatment, you must conduct 2, consecutive, 6-

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.

Routine Lead and Copper Tap Monitoring

If you serve more than 50,000 people and you do meet the (b)(3) criteria, you must

monitor semi-annually at the standard number of sites until you qualify for reduced monitoring by

being in compliance with your OWQP specifications for 2, consecutive, 6-month monitoring

periods.

If you serve 50,000 or fewer people and you continue to exceed either action level after

installing corrosion control treatment, you must monitor semi-annually at the standard

number of sites until you qualify for reduced monitoring by being in compliance with your

OWQP specifications for 2, consecutive, 6-month monitoring periods.
Lead and Copper Monitoring Guidance February 2002 16

Table 2-3: Minimum Number of

Lead and Copper Tap Samples for

Systems on Reduced Monitoring

System Size No. of Samples

> 100,000 50

10,001 - 100,00 30

3,301 - 10,000 20

501 - 3,300 10

101 - 500 5

# 100 5

Note: The number of samples for systems serving #

100 people is the same under standard and reduced

monitoring.

Am I Eligible for Reduced Lead and Copper Tap Monitoring? (See

§§141.86(d)(4) & (g))

Reduced Lead and Copper Tap Monitoring

Criteria for Annual Monitoring: You can reduce the frequency of your monitoring to

annually and collect from a reduced number of sites, as shown in Table 2-3, if:

 1. You serve 50,000 or fewer people, and you are

at or below both action levels during 2,

consecutive, 6-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 during 2,

consecutive, 6-month monitoring periods. 

The LCRMR no longer require you to request reduced

monitoring status from the State. However, you must

receive written permission to proceed to reduced

monitoring.

REMEMBER: If you do not have the required number of 

sampling sites, it may be necessary to collect more than one

sample from the same location, on different days, in order to

collect the minimum number of required samples.

Criteria for Triennial Monitoring: You can reduce the frequency of sampling to once every

3 years and collect the reduced number of samples if you are: 

1. A system that serves 50,000 or fewer people and your 90th percentile lead and copper levels

are at or below both action levels for 3 consecutive years. You do not need prior approval from the

State). Two, consecutive, 6-month periods at or below both action levels (such as the two

initial monitoring periods) can count as the first year of the 3 years needed to qualify for

triennial monitoring.

2. Any size system that operates in accordance with State-specified OWQPs during, 3

consecutive years, even if you exceed one or both action levels. You must receive written

permission to proceed to reduced monitoring.
Lead and Copper Monitoring Guidance February 2002 17

3. Any size system that demonstrates that it meets the (b)(3) criteria. The LCRMR clarify

that (b)(3) systems must 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 3 calendar years, thereafter (Note: Some States may not allow

triennial monitoring for certain size systems). 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 90th 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 2, consecutive, 6-month

periods (also known as accelerated reduced lead and copper tap monitoring). This

provision is newly allowed under the LCRMR and is less stringent than the original LCR. 

T You must first check with your State to determine if it has adopted this provision.

Criteria for a Monitoring Waiver: Under the LCRMR, 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 9-year intervals at the reduced number of sites if you meet specific

materials and monitoring criteria.

• To meet the materials criteria for lead, you must certify that the plumbing materials in

your system contain no plastic pipes which contain lead plasticizers, or plastic service

lines which 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). To meet the materials criteria for copper, you must certify that the

plumbing materials in your system do not contain any copper pipes or copper service

lines. 

• The monitoring criteria specify that your 90th percentile lead level cannot be greater

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. Note: Some States are not planning on adopting this

waiver provision. 

A few States granted waivers prior to the April 11, 2000, effective date of the LCRMR. If you

were granted a “pre-existing waiver” and were not required to monitor, the LCRMR specify that
Lead and Copper Monitoring Guidance February 2002 18

you had to conduct 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 815-R-99-021.

Table 2-4 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.

Table 2-4: Reduced Lead and Copper Tap Monitoring Criteria

System Size

(No. of people

served)

Criteria Monitoring

Frequency

50,000 and fewer At or below both action levels for 2 consecutive 6-month monitoring

periods. Annual

Any size Meet OWQP specifications for 2 consecutive 6-month monitoring

periods.

50,000 and fewer At or below both action levels for 3 consecutive years of monitoring.

Triennial

Any size Meet OWQP specifications for 3 consecutive years of monitoring.

Any size 90th percentile lead level is # 0.005 mg/L and 90th percentile copper

level is # 0.65 mg/L for 2, consecutive, 6-month periods. ONote: This

is newly allowed under the LCRMR and the State must adopt it before it can be

implemented.

Any size Meet (b)(3) criteria:

1. the 90th percentile lead level minus the highest source water level is

< 0.005 mg/L for 2 consecutive, 6-month monitoring periods.

or

2. source water lead levels are below the MDL and the 90th percentile

lead level is # 0.005 mg/L for 2 consecutive, 6-month monitoring

periods.

and

3. after July 12, 2001, 90th percentile copper levels are at or below the

copper action level. 
Table 2-4: Reduced Lead and Copper Tap Monitoring Criteria

System Size

(No. of people

served)

Criteria Monitoring

Frequency

Lead and Copper Monitoring Guidance February 2002 19

25 to 3,300 Meet monitoring waiver criteria:

1. 90th percentile levels are # 0.005 mg/L for lead and/or # 0.65

mg/L for copper. 

and

2. plumbing materials meet certain criteria that indicate negligible risk

from lead and/or copper exposure.

and

3. waiver is approved by the State.

Once every 9

years

Note: 2 consecutive, 6-months at or below both action levels can count as the first year of the 3 years needed to

qualify for triennial monitoring.

Under the LCR, you were required to conduct reduced lead and copper tap monitoring (i.e.,

annual or triennial monitoring) during the months of June through September. Under the

LCRMR, the State may require you to collect your tap samples during months other than June

through September, if it believes that another time period better represents a time of normal

operation where the highest lead levels are likely to occur (e.g., seasonal system that is closed

during the summer months). The LCRMR specify a one-time transition period for switching

to the new monitoring period, including systems granted monitoring waivers.

If you monitor: Then the next round of samples is due no later than:

Annually 21 months after the previous round

Triennially 45 months after the previous round

Every 9 years The end of the 9-year cycle

For example, assume a system is on annual monitoring and last sampled on July 7, 2001. The

system is typically closed during the summer months and the State requires the system to collect its

samples during October through December. The LCRMR allow a maximum of 21 months for

a system on annual monitoring to transition to the new monitoring schedule or April 7, 2003 in

this example. However, since this system must collect its samples during October through

November, it only has until December 31, 2002 to complete this monitoring (a little under 18

months). 
Lead and Copper Monitoring Guidance February 2002 20

Where Must I Collect My Samples? (See §141.86(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 Table 2-1). Table 2-5, below, defines the tiering system for prioritizing sampling

sites.

Table 2-5: Tiering Classification

If you are a CWS If you are an NTNCWS 

Tier l sampling sites are single family structures:

 P with copper pipes with lead solder installed

after 1982 (but before the effective date of your State’s

lead ban) or contain lead pipes; and/or

 P that are served by a lead service line. 

O 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: 

 P with copper pipes with lead solder installed

after 1982 (but before effective date of your State’s lead

ban) or contain lead pipes; and/or 

 P that are served by a lead service line. 

Tier 3 sampling sites are single family structures

w/ copper pipes having lead solder installed before

1983.

Tier l sampling sites consist of buildings:

 P with copper pipes with lead solder installed

after 1982 (but before the effective date of your

State’s lead ban) or contain lead pipes; and/or

 P 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.

O Note: All States were required to ban the use of lead solder in all public water systems, and all homes and

buildings connected to such systems by June 1988 (most States adopted the ban in 1987 or 1988). Contact the

Drinking Water Program in your State to find out the effective date.

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 replaced). 

The LCRMR specify that sites that are chosen for reduced monitoring (i.e., monitoring that is

conducted at a 1-year, 3-year, or 9-year frequency) must be representative of those sites that were

used during standard monitoring. The LCR did not contain language regarding which sites

should be used 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
Lead and Copper Monitoring Guidance February 2002 21

not use only those sampling locations with the lowest lead or copper levels. The revised rule also

gives States the choice to 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;

• 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 are

shown in Tables 2-2 and 2-3. 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) 2, consecutive, 6-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, the LCRMR clarify

that 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 if the lead ban (typically 1988

or 1989), provided these sites can be considered representative.

If your system contains lead service lines, then, if possible, half of the required sampling sites

should be served by a lead service line. Using the medium system example: 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.
Lead and Copper Monitoring Guidance February 2002 22

The preamble of the LCRMR (see page 1970) also clarifies that you may need to collect more

than one sample from the same location, on different days, in order to meet your minimum

sampling requirements. For example, if you are required to collect a minimum of five samples,

but you only have one sampling site, you must collect five samples from this sampling site on

different days. 

Three worksheets for organizing the information collected during the materials evaluation are

included in Appendix E as follows:

• Worksheet 1: Materials Survey Investigation Results

• Worksheet 2: Materials Survey Results by Number of Service Connections for each

Plumbing Materials Type

• Worksheet 3: Summary of Material Survey Results 

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 Sampling Sites with High Risk

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, you should

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 should complete your sampling pool with Tier 3 sites.

• According to the LCRMR, any water system that cannot complete its sampling at sites

that meet the applicable tiering 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 site that is served by a lead service line. 

For example, a system serving 3,301 to 10,000 people does not qualify for reduced

monitoring and is required to collect tap water samples from a total of 40 sites, 20 of

which must be from sites served by a lead service line. If, after reviewing all of the

records listed on the previous page, the system can identify only 12 sites served by a

lead service line, it must collect a tap water sample from each of those sites. The

remaining 28 samples would be collected from other Tier 1 sites. If an insufficient

number of Tier 1 sites are available, the system must use Tier 2 sites, followed by Tier
Lead and Copper Monitoring Guidance February 2002 23

3 sites, and lastly by representative sites. Refer back to Tables 2-2 (standard monitoring) and 2-

3 (reduced monitoring) to identify the appropriate number of sites for your system size.

• 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.

How Do I Collect Lead and Copper Tap Water Samples? (See §141.86(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 6 hours (e.g., no flushing, showering, etc.), except where noted below in the box titled:

“Related LCRMR Provisions”. However, make sure it is a tap that is used regularly, and

not an abandoned or infrequently used tap.

• First-draw samples collected at single-family residences should always be drawn from

the cold-water kitchen tap or bathroom tap.

• First-draw samples collected from buildings other than single-family homes should

always be drawn from an interior tap from which water is typically taken for

consumption.

• You may allow residents to collect sample, but you must supply the residents with

instructions as to the sample collection procedures. You can use the instruction form

provided as page E-5 of Appendix E. Be sure to properly label sample bottles prior to

distributing them to residents.

• 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 Chapter III for a more detailed discussion of WQP monitoring).

• 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. 

• If you cannot gain access to an original sampling site during any repeat sample

collections, you should 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.) Form 141-A in Appendix E provides you with an

easy-to-follow format for tracking sample site identification and certification.
Lead and Copper Monitoring Guidance February 2002 24

Related LCRMR Provision 

If you are an NTNCWS or CWS (such as a prison or hospital) that does not

have enough inside taps where the water stands unused for at least 6 hours, the

LCRMR allow you to use inside taps that are the most likely to have remained

unused for the longest period of time. Your State contact will tell you whether

you must submit a sampling plan for State approval prior to sampling at nonfirst-draw sample locations or if you can proceed with sampling and submit the

plan with your sampling results.

T Please check with your State before collecting any non-first draw

samples.

What Are the Approved Methods for Analyzing Water Samples for Lead

and Copper? (See §141.23(l))

The approved analytical methods for lead, copper, and all WQPs (pH, calcium, alkalinity, silica,

orthophosphate, conductivity, and temperature) are shown in Table 2-6. A summary of the

preservation protocols, sample containers, and maximum holding times for analysis is provided in

Table 2-7.

Table 2-6: Approved Analytical Methods for the Lead and Copper Rule

Contaminant 

Methodology 8

EPA ASTM3 SM4 Other

Alkalinity

Titrimetric D1067-92B 2320 B

Electrometric titration I-1030-855

Calcium

EDTA titrimetric D511-93A 3500-Ca D

Atomic absorption; direct aspiration D511-93B 3111 B

Inductively-coupled plasma2 200.7 3120 B

Copper

Atomic absorption; furnace D1688-95C 3113 B

Atomic absorption; direct aspiration D1688-95A 3111 B

Inductively Coupled Plasma (ICP)2 200.7 3120 B

ICP-Mass spectrometry2 200.8

Atomic absorption; platform2 200.9
Table 2-6: Approved Analytical Methods for the Lead and Copper Rule

Contaminant 

Methodology 8

EPA ASTM3 SM4 Other

Lead and Copper Monitoring Guidance February 2002 25

Conductivity Conductance D1125-95A 2510 B

Lead

Atomic absorption; furnace D3559-95D 3113 B

ICP-Mass spectrometry2 200.8

Atomic absorption; platform2 200.9

Differential pulse anodic stripping

voltammetry

Method

10019

Orthophosphate7

Colorimetric, automated, ascorbic acid6 365.1 4500-P F

Colorimetric, ascorbic acid, single reagent D515-88A 4500-P E

Colorimetric, phosphomolybdate I-1602-855

Colorimetric, automated-segmented flow I-2601-905

Colorimetric, automated discrete I-2598-855

Ion Chromatography6 300.0 D4327-91 4110 B

pH

Electrometric1 150.1, 150.2 D1293-95 4500-H+B

Silica

Colorimetric: molybdate blue I-1700-85

Colorimetric: automated-seg. flow I-2700-85

Colorimetric D859-95

Colorimetric: molybdosilicate 4500-Si D

Colorimetric: heteropoly blue 4500-Si E

Colorimetric: automated method for

molybdate-reactive silica

4500-Si F

Colorimetric: inductively-coupled plasma 200.7 3120 B

Temperature

Thermometric 2550

Notes

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.
Table 2-6: Approved Analytical Methods for the Lead and Copper Rule

Contaminant 

Methodology 8

EPA ASTM3 SM4 Other

Lead and Copper Monitoring Guidance February 2002 26

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

Asso-ciation, 1015 Fifteenth Street NW, Washington, DC 20005.

5

 Method I-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 I-1030-85; I-1601-85; I-1700-85; I-2598-85; I-2700-85; and I-3300-85 See Techniques of Water Resources

Investigation of the U.S. Geological Survey, Book 5, Chapter A-1, 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.

7

Unfiltered, no digestion or hydolysis.

8

 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-furnace depositions are made.

9The 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. 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. However, 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.
Lead and Copper Monitoring Guidance February 2002 27

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: (2 Fields)

a. First-draw tap, Distribution system, Source water for lead and copper, Source water

for WQPs, or Lead service line.

b. Initial, Follow-Up, Routine, Reduced, or Lead Service Line.

5. Sample Site Identifier: (3 Fields)

a. Region of Distribution System. (Suggest that Region 0 be assigned for each entry

point location.)

b. Subregion of Distribution System. (Suggest that Subregion 0 be assigned for each

entry point location.)

c. 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, Water Quality Parameters or pH and

Temperature (field measurements).

11. Sample Site Street Address - for water system use.

12. Sample Collection Route - for water system use.

13. Water system Name.

14. 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.
Lead and Copper Monitoring Guidance February 2002 28

Table 2-7: Sample Handling Requirements for Lead, Copper, and Water Quality Parameters

Contaminant or

Parameters Preservative Container1 Maximum Holding

Time2

Lead

Copper

pH

Conductivity

Calcium

Alkalinity

Orthophosphate

Silica

Temperature

Conc. HNO3 to pH <23

Conc. HNO3 to pH <23

None

Cool, 4EC

Conc. HNO3 to pH <25

Cool, 4EC

Cool, 4EC

Cool, 4EC

None

P or G

P or G

P or G

P or G

P or G

P or G

P or G

P only

P or G

6 months

6 months

Test Immediately4

28 days

6 months

14 days

48 hours

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 (HNO3) 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 HNO3 as soon as possible but not later than 14 days after sample collection. 

Sample 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 HNO3 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 HNO3 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 HNO3 to pH < 2.
Lead and Copper Monitoring Guidance February 2002 29

How Do I Evaluate My Results? (See §§141.80(c)(3) & 141.86(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 level 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 5 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(i.e., 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 90th percentile copper level against its action

level of 1.3 mg/L. If your 90th percentile value is greater than 1.3 mg/L, you have an exceedance.

If you are required to collect 5 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.

REMEMBER: All sample results taken during the monitoring

period must be included in your 90th percentile calculations, unless a

result has been invalidated (refer to the section in this chapter,

entitled, What If The State Determines That My Samples Are

Invalid?). If a sample is invalidated, its replacement sample must be

included in the 90th percentile calculation. Further, a 90th percentile

level cannot be calculated if the system has collected less than the

minimum required number of samples.

 M
Lead and Copper Monitoring Guidance February 2002 30

Below are two examples to help demonstrate the 90th percentile calculation for systems that are

required to collect more than 5 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

90th percentile level contains a decimal. This may happen when you collect more than the

minimum required number of samples.

Example 1: Determining Whether An Action Level Has Been

Exceeded When the 90th Percentile Level is A Whole Number

Sample Rank Sample Value (mg/L)

1

2

3

4

5

6

7

8

9 (90th %)

10

0.000

0.000

0.002

0.005

0.005

0.006

0.006

0.010

0.015

0.020

The system does not exceed the lead action level because its 90th percentile level (the 9th sample)

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 below, 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. In this example, the

90th percentile level is 10.8 (i.e., 12 samples x 0.9 = 10.8).

Example 2: Determining Whether An Action Level Has Been

Exceeded When the 90th Percentile Level Contains A Decimal

Sample Rank Sample Value (mg/L)

1

2

3

4

5

6

7

8

9

10

11

12

0.000

0.000

0.002

0.005

0.005

0.005

0.006

0.006

0.010

0.014

0.018

0.020
Lead and Copper Monitoring Guidance February 2002 31

Either rounding or interpolation can be used to determine the 90th percentile level when the

sample that represents the 90th percentile value is not a whole number. Your State may specify

which method you should use.

Using Rounding: EPA’s policy is to: 

1. Round down to the nearest whole number if your decimal is 0.4 or lower.

2. Round up to the nearest whole number if your decimal is 0.5 or higher. 

In this example, the 90th percentile sample is 10.8, and you would round up to 11. So, the sample

that is ranked 11th in the list represents the 90th percentile value that you compare to the relevant

action level.

Using rounding, the 90th percentile result is 0.018 mg/L and 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 between the two samples between which your 90th percentile

falls. In this example you 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.

2. Multiply the difference of 0.004 mg/L by 0.8 because the 90th percentile level is 0.8

higher than the 10th sample result: 0.004 x 0.8 = 0.0032 mg/L (or 0.003 when rounded

to the number of significant figures).

3. 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.

Using interpolation, the 90th percentile lead level is 0.017 mg/L

and the system exceeds the lead action level.

O Note: The LCRMR allow the State to perform the 90th percentile calculation

for you if:

C your State has notified you that it will perform this calculation;

C you provide your sampling results and sampling site information by the

State-specified date; and

C your State gives you the results of the 90th percentile calculation before

the end of the monitoring period.

However, if you do not meet all three of these criteria, you must calculate

the 90th percentile results yourself, and provide them to the State.
Lead and Copper Monitoring Guidance February 2002 32

What If the State Determines that My Samples Are Invalid? (See

§141.86(f))

Under the LCRMR the State can invalidate a lead or copper tap water sample if any one of the

following are 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. 

In order for the State to make this determination, you must report to the State 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. T Please check with your State before requesting sample invalidation,

because your State may be unable to implement this provision until it has been

incorporated into its drinking water regulations.

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. Note that if a replacement cannot be taken at the same

location, it should be taken at a location other than one already used for sampling during the

monitoring period.

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. Note that 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 replacement

sample is collected in July 2001 for one invalidated sample that was collected during the January

through June 2001 monitoring period. You cannot include this replacement sample as part of

your samples for the July through December 2001 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
Lead and Copper Monitoring Guidance February 2002 33

your samples on October 15, 2000. You have until November 4, 2000 (i.e., 20 days after the

State’s invalidation decision) to collect the replacement sample. 

REMEMBER: If a sample is determined to be invalid, you cannot

include it in your 90th percentile calculations. However, the

replacement sample must be included in the calculation.

What Should I Do If I Exceed an Action Level While I am Monitoring at 6-

month intervals? (See §141.80)

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) (see §141.87). Refer to Chapter 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 6 months of the

exceedance (see §141.83(b)). Form 141-D, Source Water Monitoring and Treatment,

in Appendix E 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 6 months of the exceedance 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 (see

§141.81)(e)(1)). 

In addition, for lead action level exceedances, you must:

• Deliver the public education program described in Lead in Drinking Water Regulation:

Public Education Guidance, EPA 816-R-02-010. If your system has never exceeded, or if

the exceedance occurred after a monitoring period without a lead exceedance, then

delivery is due within 60 days. If it is a continued exceedance, then delivery is every 6

months or annually depending on whether you are a CWS or NTNCWS and

depending on the form of public education delivery required (see §141.85).

• 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
Lead and Copper Monitoring Guidance February 2002 34

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 (see §141.84). Chapter V provides an overview of the lead service

line replacement requirements and a more detailed discussion regarding the related

monitoring and reporting requirements. 

What Should I Do If I Exceed the Lead or Copper Action Level During

Reduced Monitoring? (See §§141.80 & 141.86(d)(4)(vi)(A))

If the 90th percentile lead level exceeds 0.015 mg/L or 90th percentile copper level exceeds 1.3

mg/L, you must:

• Stop monitoring at a reduced number and frequency, and, 6 months from the date of

the exceedance, begin collecting the standard number of samples every 6 months (see

§141.86(d)(4)(vi)). Refer back to Table 2-2 to find the correct number of sites for your

system size.

• 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) (see §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 within 6 months of the exceedance (see §141.83(b)). 

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 (see §141.84). 

• Within 60 days of a lead action level exceedance, deliver the public education program

described in EPA’s Lead in Drinking Water Regulation: Public Education Guidance, EPA 816-R02-010 (see §141.85).

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.
Lead and Copper Monitoring Guidance February 2002 35

What Lead and Copper Tap Monitoring Information Must I Report to the

State? (See §§141.90(a) & (h))

Within 10 Days of the End of the Monitoring Period

Within 10 days of the end of the monitoring period (i.e., 6 months, 1 year, 3 years, or 9 years), you

must report the following information to the State:

• 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. Under the LCRMR, the State may elect to do this for you.

However, if the State has not contacted you about this, you are responsible for these

calculations.

• Written explanation for any changes in sampling location (e.g., if homeowners no

longer allow sampling from their taps).

Newly Required by the LCRMR

If you are on a reduced monitoring schedule (i.e., collect lead and copper tap samples less

frequently than semi-annually), the LCRMR require you to submit notification of any change in

source water or treatment within 60 days of the change or sooner if required by the State. The

State may return you to a standard monitoring schedule or take other appropriate steps, if needed.

Less Stringent LCRMR Reporting Provisions:

The following provisions are generally less stringent than the LCR and your State may not be able

to implement them until the provisions are incorporated into its regulations. Your State may also

elect not to incorporate these revisions into its regulations. T Please check with your State

before following through on any of these provisions.

• Under the LCRMR you may no longer be required to provide 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 tap monitoring schedule when you meet

your optimal WQPs (under §141.86(d)(4)).

• If you are an NTNCWS or CWS (such as a prison or hospital) that does not have

enough inside taps where the water stands unused for at least 6 hours, the LCRMR

allow you to use inside taps that are the most likely to have remained unused for the

longest period of time. The State will determine whether you must receive prior

approval to collect non-first draw samples, or whether you can submit documentation
Lead and Copper Monitoring Guidance February 2002 36

that identifies each site and length of standing time for the samples collected at these

sites when you submit your sample results. Unless you make additional changes to

your sampling plan during subsequent monitoring periods, this is a one-time reporting

requirement. 

What Should I Do If I Sell Water To, or Buy Water From, Another Water

System? (See §141.29)

EPA’s position on the consolidation of sampling requirements under the Lead and Copper Rule

was stated in a January 10, 1992 memorandum, entitled “Consecutive Systems Regulated under the

National Primary Drinking Water Regulations for Lead and Copper”. 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 §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 §§141.81 and 141.82; and

• Lead service line replacement.
Lead and Copper Monitoring Guidance February 2002 37

O Note: 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.

3. How the following provisions will be modified:

• Determination of 90th 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.

O Note: In the preamble to the 1991 LCR, EPA has 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.

What Happens If I Do Not Fulfill My Lead and Copper Tap Monitoring

And Reporting Requirements? (See §141.80(k)) 

If you do not meet all of the following monitoring and reporting requirements within the time

frame specified by the rule, you are in violation of these requirements:

• Use appropriate sampling procedures in accordance with §§141.86(a) and (b);

• Collect the required number of samples during the specified time frame in accordance

with §§141.86(c) and (d);

• Ensure samples are analyzed properly in accordance with §141.89(a);

• Submit all required monitoring information on time in accordance with §141.90(a); or

• Report a change in treatment, or an addition of a new source, within 60 days or within

the time frame specified by the State, if you are on reduced monitoring, have a waiver,

or are a (b)(3) system, as required by §141.90(a)(3).
Lead and Copper Monitoring Guidance February 2002 38

Depending on whether the State adopts the less stringent provisions of the LCRMR into its

revised drinking water regulation, 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

§141.86(f)(4) where these samples are needed to meet minimum sampling requirements;

• Meet the conditions of your monitoring waivers in §141.86(g) or provide the required

information in §§141.90(a)(4)(ii)-(iv);

• Provide sample information needed for your State to perform the 90th percentile

calculation as outlined in §141.90(h);

• Collect non-first draw samples that did not meet the criteria in §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 §141.86(d)(4)(iv)(B).

If you are out of compliance, you must:

1. Report the violation to the State within 48 hours of determining the noncompliance

(see §141.31(b)).

2. Deliver public notification to your customers. If your State has not adopted the new

public notification requirements, refer to §141.32. Otherwise, refer to §141.201 &

§§141.203 - 141.206 or to EPA’s Public Notification Handbook (EPA 816-R-00-010, June

2000). The Handbook is available on EPA’s website at

www.epa.gov/safewater/pn.html.

3. If you are a CWS, include a discussion of the violation in your consumer confidence

report, including potential adverse health effects and actions taken to address the

violation. Refer to §§141.153 & 141.154 or to EPA’s Preparing Your Drinking Water

Consumer Confidence Report (EPA 816-R-99-002, March 1999). This document is

available on EPA’s website at www.epa.gov/safewater/ccr1.html.

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

consumer confidence report, 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 the State may revoke your waiver. You can reapply at a later date when

you again meet the eligibility requirements for a waiver.
Lead and Copper Monitoring Guidance February 2002 39

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.

What Provisions of the LCRMR Pertain to Lead and Copper Tap

Monitoring and Reporting? (See §141.86 & §141.90(a))

The table below summarize those lead and copper tap monitoring and related reporting

provisions that have been discussed throughout Chapter II. The table distinguishes between those

provisions that you were required to begin implementing on April 11, 2000 and those less

stringent provisions with which you must first check with your State before implementing. 

Remember, if you own or operate a water system on Tribal lands, in Wyoming, or the District of

Columbia, the Federal version of the LCRMR applies to you. Therefore, you were required to

implement all of the following provisions beginning April 11, 2000.

You Were Required to Comply with

These Monitoring Requirements Beginning April 11, 2000

If you do not have enough Tier 1, 2, or 3 sites, you must use representative sites to meet

minimum sampling requirements.

If you are on reduced lead and copper tap monitoring, you must collect from sites that are

representative of the ones you used during standard monitoring. (Your State entity may specify where

to collect these samples.)

If you are on reduced lead and copper tap monitoring, are a (b)(3) system, or have a monitoring

waiver, you must notify your State in writing no later than 60 days after changing treatment or

adding a new source. 

You Must First Check With Your State Before Implementing the Following

Provisions

Your State may allow you to conduct reduced lead and copper monitoring during months other

than June through September.

If you operate 24 hours a day and you do not have enough taps that can supply first-draw lead

and copper samples, you may be able to collect samples from the taps that have the longest

standing times.

You can collect lead and copper tap water samples once every 3 years after monitoring for only

2 consecutive, 6-month monitoring periods, if your 90th percentile levels are # 0.005 mg/L for

lead and # 0.65 mg/L for copper.
Lead and Copper Monitoring Guidance February 2002 40

You Must First Check With Your State Before Implementing the Following

Provisions

(Continued)

You can ask your State to invalidate lead and copper tap water samples if the samples meet at

least one of the criteria below and you provide documentation that supports your request:

• There is a laboratory error;

• The sample was damaged in transit;

• The State determines that the sample was taken from an inappropriate site; or

• The State believes the sample was tampered with.

Note: If you do not have enough valid samples after the State invalidates your sample(s), you must collect enough

replacement samples to meet the minimum sampling requirements.

You may request a 9-year monitoring waiver for lead and/or copper tap monitoring if:

• You serve 3,300 or fewer persons;

• Your 90th percentile levels are # 0.005 mg/L for lead and/or # 0.65 mg/L for copper;

and

• Your plumbing materials meet certain criteria that indicate negligible risk from lead

and/or copper exposure.

You may no longer be required to:

1. Calculate and report your 90th percentile lead and copper levels if:

• Your State has notified you that it will perform this calculation;

• You provided your sampling results and sampling site information to your State no

later than the date specified by your State (Note: this date will be sometime before the end of

the monitoring period); and

• Your State gave you the results of the 90th percentile calculation before the end of

the monitoring period.

2. Submit certifications that you followed proper sampling procedures or that homeowners

collected samples after receiving proper instructions.

3. Provide justifications if your sampling pool contains Tier 2 or Tier 3 sites or an

insufficient number of sites served by lead service lines.

4. Request in writing your State’s permission to monitor for lead and copper on a reduced

schedule after you meet your OWQPs. (You still must receive written approval from

your State before you begin reduced monitoring.)
Lead and Copper Monitoring Guidance February 2002 41

What Key Points Should I Remember About Lead and Copper Tap

Monitoring? (See §§141.81 & 141.86)

g You must sample at Tier 1 sites. If an insufficient number exist, use Tier 1, followed by Tier 2,

Tier 3, and representative sites. (Note: Tier 3 sites only apply to CWSs.)

g If you have lead service lines in your distribution system, you should collect at least half of your

samples from sites served by lead service lines. 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. 

g 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.

g If you do not have the required number of sampling sites, it may be necessary to collect more than

one sample from the same location, on different days, in order to collect the minimum number of

required samples.

g 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 6 hours (except as noted below).

g If you are an NTNCWS or CWS that does not have enough inside taps where the water stands

unused for at least 6 hours, your State may allow you to use inside taps that have remained unused

for the longest period of time.

g You should collect samples early enough in the monitoring period in case WQP samples are

required (e.g., small or medium systems that exceeds the lead or copper action level).

g You must initiate corrosion control treatment steps if you exceed the lead or copper action level or if

you serve more than 50,000 people and you are not a (b)(2) or (b)(3) system.

g You must collect source water samples if you exceed lead and copper action levels.

g If you serve 50,000 or fewer people, you can stop corrosion control treatment steps whenever your

90th percentile lead and copper levels are at or below their action levels for 2, consecutive, 6-month

monitoring periods. You must recommence these steps if you again exceed either action level.

g If you serve 50,000 or fewer people, you qualify for reduced annual monitoring if you have 2,

consecutive, 6-month periods at or below both action levels. You can qualify for triennial

monitoring if you have 3 consecutive years of monitoring at or below both action levels. 

g Regardless of the number of people that you serve, you can qualify for reduced monitoring if you are

in compliance with your OWQP specifications for a minimum of 2, consecutive, 6-month periods

and you receive written approval from the State.

g Regardless of the number of people that you serve, you can qualify for triennial monitoring at the

reduced number of sites, if your 90th percentile lead level is # 0.005 mg/L and 90th percentile copper

level is # 0.65 mg/L, for 2, consecutive, 6-month periods (if the State has adopted this provision).

g If you serve 3,300 or fewer people, you can monitor once every 9 years at the reduced number of

sites, if you qualify for a monitoring waiver, and the State has adopted this provision.
Lead and Copper Monitoring Guidance February 2002 42

CHAPTER III: WATER QUALITY PARAMETER

MONITORING AND REPORTING REQUIREMENTS

What Is The Purpose of Collecting Water Quality Parameter Samples? (See

§141.87)

WQPs are used to determine the corrosivity of the water, and if needed, to help the system and

State determine the type of corrosion control that the 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

may be used).

Which Systems Must Collect Water Quality Parameter Samples? (See

§141.87)

If you serve more than 50,000 people, you must conduct some WQP monitoring. However, if

you meet the (b)(3) criteria based on initial lead and copper tap monitoring, you are only required

to conduct WQP monitoring during the same 2, consecutive, 6 months in which you conducted

initial lead and copper tap monitoring.

If you serve 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. 
Lead and Copper Monitoring Guidance February 2002 43

When Do I Collect Water Quality Parameter Samples? (See §§141.87(b)-(e))

Water quality parameter monitoring can be divided into three phases:

• Initial WQP monitoring;

• Follow-up monitoring that occurs in the year 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. In addition, refer to the timelines in

Appendix C which illustrate how WQP monitoring requirements are impacted by a system’s size

category and whether it exceeds an action level.

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 you serve more than 50,000 people, you were required to conduct WQP monitoring during

the same 2, consecutive, 6-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 through December 31, 1992. 

If you serve 50,000 or fewer people, and you exceeded the lead and/or copper action level,

you must monitor before the end of the 6-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 6-month

monitoring period. Table 3-1 below illustrates the timing for systems serving 50,000 or fewer

people that were in existence prior to January 1992.
Lead and Copper Monitoring Guidance February 2002 44

REMEMBER: For systems of any size, while you are

conducting a corrosion control study and installing corrosion control

treatment, you are not required to collect WQP samples, unless

required by the State. Samples that are required as part of the study

or during treatment installation are not counted towards compliance

with your normal WQP sampling requirements.

Table 3-1: Initial WQP Requirements for Systems Serving 50,000 and Fewer

People

If you serve... And you exceeded during the...

You were required to

collect WQP samples

during...

3,301 to 50,000 people

1st monitoring period of July - December 1992 July - December 1992

2nd monitoring period of January - July 1993 January - July 1993

25 to 3,300 people

1st monitoring period of July - December 1993 July - December 1993

2nd monitoring period of January - July 1994 January - July 1994

O Note: If you are a new system, the State will specify when you must begin initial lead and copper tap

monitoring. WQP samples must be collected before the end of the 6-month initial tap monitoring period(s)

during which an action level is exceeded. 

REMEMBER: 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:

• 2 samples at each of the number of tap sites specified in Table 3-2; and

• 2 sample at each entry point to the distribution system. 
Lead and Copper Monitoring Guidance February 2002 45

Table 3-2: Standard Number of WQP “Tap” Sites and Samples

System Size 

(No. of People Served)

No. of Sites

(Standard)

No. of Samples 

(2 per site)

> 100,000 25 50

10,001 to 100,000 10 20

3,301 to 10,000 3 6

501 to 3,300 2 4

# 500 1 2

As an example, assume a system serving 9,000 people has 3 entry points. The regulation requires

the system to collect 2 distribution samples at 10 sites and 2 samples at each entry point to the

distribution system. Therefore, during January through June 1992, these systems would have

collected 20 WQP tap samples and 6 entry point samples. During July through December 1992,

the system would have collected the same number of entry point and WQP samples. 

Follow-up WQP Monitoring

Follow-up monitoring occurs in the 12 months immediately following the installation of corrosion

control treatment. These samples are collected during the same 2, consecutive, 6-month

monitoring period(s) as follow-up lead and copper tap monitoring.

If you serve more than 50,000 people, you were required to conduct this monitoring during 2,

consecutive, 6-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

previously discussed, (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 you serve 50,000 or fewer people, WQP monitoring is only required during each of the 6-

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 2 samples at each of the number of WQP sites specified in Table 3-2, during

each of 2, consecutive, 6-month monitoring periods for:

• pH;

• 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. 
Lead and Copper Monitoring Guidance February 2002 46

These samples should be collected evenly throughout the year to reflect seasonal variability.

You also must immediately begin taking 1 set of the following WQP samples at each entry point

at least once every 2 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

• 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).

O Note: Once treatment has been installed, entry point monitoring

changes from 2 samples per entry point at 6-month intervals to 1

sample per entry point at least every 2 weeks.

After corrosion control treatment has been installed, the LCRMR allow ground water systems to

limit sampling points to those representative of the water quality and corrosion control treatment

conditions throughout the system. If this option is used, prior to sampling, the system must

demonstrate to the State that the selected sites are indeed representative. Please note that this

option does not apply to initial monitoring and can only apply if the State incorporates this

provision into its drinking water regulations. T First check with your State to determine if

you can take advantage of this provision.

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 6 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
Lead and Copper Monitoring Guidance February 2002 47

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 Table 3-2). 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 2

weeks.

If you serve more than 50,000 people and do 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., are a (b)(2)

system), the LCRMR clarify that the State will designate OWQPs and that you must conduct

WQP monitoring. Prior to the LCRMR, the regulation was unclear regarding the continuing

monitoring requirements for (b)(2) and (b)(3) systems. 

If you serve 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 2 samples every 6 months at the standard number of WQP tap sampling sites

that is specified in Table 3-2 for:

• pH;

• 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 must collect 1 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 2 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).
Lead and Copper Monitoring Guidance February 2002 48

O Note: The LCRMR also clarify that 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.

~Refer to the section entitled, “Can I Ever Reduce My WQP Monitoring?”, 

for a discussion of the criteria that allow you to reduce the frequency of WQP tap monitoring~

How Do I Select My Sampling Sites? (See §141.87(a))

Distribution Samples

You must identify sampling sites in your distribution system 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 are specified in Table 3-2. 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 detention 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.

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 is representative of typical water quality conditions in the distribution system.
Lead and Copper Monitoring Guidance February 2002 49

Entry Point Samples

You must sample from each entry point to the distribution system to obtain a sample that is

representative of the source after treatment. If 2 or more sources are combined before

distribution, your sample must be representative of all sources used. 

How Do I Collect Water Quality Parameter Samples? (See §141.87(a))

To Keep in Mind 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, and the sources are combined before

distribution, 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.
Lead and Copper Monitoring Guidance February 2002 50

Parameter-specific procedures to keep in mind

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. pH measurements 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 counts as one set of samples;

thus, you must repeat this for each of your 2 entry point sample sets during initial monitoring, as

well as your 2 distribution (“tap”) samples sets that are required during each WQP monitoring

period.

How Does the State Determine If I Am In Compliance With My Optimal

Water Quality Parameter Values? (See §141.82(g))

Prior to the 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 3 days of collecting the original sample.
Lead and Copper Monitoring Guidance February 2002 51

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 2 weeks. For tap

WQP monitoring, compliance was determined for the monitoring period in effect (i.e., 6 months,

1 year, or 3 years).

Under the LCRMR, EPA revised the procedure for calculating compliance with OWQPs based

on concerns raised by several States and water systems. 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. 

Another concern was the “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. 

Under the LCRMR, compliance determinations are always based on a 6-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 or the distribution system. The

start of the first 6-month period begins on the day the State has designated OWQPs.

You cannot be outside the OWQP ranges or below the OWQP minimum (also known as an

excursion) for more than a total of 9 days at a specific sampling point or combination of sampling

points, or for a specific WQP or combination of WQPs during a 6-month period. The 9 days can

occur anytime during the 6-month period and do not have to be consecutive. The 9 days allow

you to make necessary repairs that may be causing your system to not meet its OWQP

specifications.

Confirmation samples are no longer used. You must use the results of all WQP samples collected

during the 6-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. 

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. Table 3-3, below, explains how to calculate the daily

value based on the sampling frequency for a given WQP. 

O Please note that the State is not required to use this new OWQP compliance procedure. 

T First check with your State to determine when and if you should use this new

procedure for assessing compliance with your OWQPs.
Lead and Copper Monitoring Guidance February 2002 52

Table 3-3: Daily Value Calculation Based on Monitoring Frequency

If you are monitoring

for a specific WQP at

a sampling site: 

Then the daily value is:

More frequently than

Daily

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. T First check with your State regarding the frequency of

recording values and procedures for aggregating results.

Daily Results of each daily sample for that WQP at that location.

Biweekly Results of each sample collected during the 2-week period for that WQP

at that location.

Semi-annually Results of each sample collected during the 6-month period for that WQP

at that location.

Annually or Triennially 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 2000. It measures pH at the tap on January 10, 2000 (pH =

7.5) and June 20, 2000 (pH = 7.6). For the 6-month period of January -

June 2000, there are two daily values because both measurements were

collected during the 6-month period being evaluated. For the 6-month

period of July - December 2000, only the most recent value of 7.6 is used. 

For more information on the new 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 815-R-99-019.
Lead and Copper Monitoring Guidance February 2002 53

Can I Ever Reduce My WQP Monitoring? (See §141.87(e))

After the State sets OWQPs, you can qualify for a reduction in the amount of monitoring

conducted at tap locations only if you are in compliance with your OWQPs (i.e., do not have

excursions for more than 9 days in a 6-month period). This reduction does not apply to entry

point WQP monitoring. Entry point monitoring remains at a frequency of every 2 weeks. 

Criteria for Reducing the Number of WQP Tap Samples

If you are in compliance with your OWQPs after 2, consecutive, 6-month monitoring periods and

you serve more than 10,000 people, 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 Table 3-

4 below. However, 2 samples are still required at each location and the frequency remains at

semi-annually. 

Table 3-4: Reduced Number of WQP Tap Sites and Samples

System Size 

(No. of People Served)

No. of Sites

(Reduced)

No. of Samples 

(2 per site)

> 100,000 10 20

10,001 to 100,000 7 14

3,301 to 10,000 3 6

501 to 3,300 2 4

25 to 500 1 2

O Note: The number of WQP tap samples for systems serving # 10,000 people is the same under

standard and reduced monitoring.

Criteria for Annual Monitoring

If you are in compliance with your OWQP specifications for 3 consecutive years of monitoring

(beginning on the date the State sets WQP values), you may also reduce the frequency with which

you collect your distribution WQP samples from once every 6 months to once per year and collect

from the reduced number of sites.

Criteria for Triennial Monitoring

If you are on an annual WQP tap monitoring frequency and you are in compliance with your

OWQPs for 3 consecutive years of monitoring, you may reduce the frequency with which you

collect WQP tap samples from annually to once every 3 years. Systems serving more than 10,000

people would continue to collect from the reduced number of sites. 
Lead and Copper Monitoring Guidance February 2002 54

O Note: Unlike lead and copper tap monitoring, the first year of

semi-annually 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 3

consecutive years to qualify for triennial WQP tap monitoring. 

The LCRMR has added an accelerated reduced monitoring provision for tap WQPs. You can

now reduce the frequency of WQP monitoring at the tap to once every 3 years more rapidly than

before. In order to qualify, you must demonstrate for 2 consecutive monitoring periods (either 6-

month or annual periods):

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; and 

3. You are in compliance with your OWQP requirements. 

In general, this provision will apply 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. T First check with your State to determine if you can take advantage of

this provision.

Table 3-5 below summarizes the criteria that 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 2 weeks.

Table 3-5: Reduced WQP Tap Monitoring Criteria

Criteria1

(Required time period in which system is in

compliance with its OWQP Specifications)

Monitoring Frequency Number of Years

Since State Set OWQPs

2 consecutive 6-month periods Every 6 months One

3 consecutive years (equals six, 6-month periods) Annual Three

3 consecutive years of annual monitoring2

Triennial

Six

2 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.

As early as One Year

1

 Compliance with OWQPs must occur in consecutive periods to qualify for reduced monitoring. 2

 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 3 years in which it collects

WQP tap samples at the annual frequency before qualifying for triennial monitoring.
Lead and Copper Monitoring Guidance February 2002 55

REMEMBER: 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 9 days in a 6-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. 

Can I Ever Discontinue Water Quality Parameter Monitoring? 

(See §§141.81(b)(3), 141.82(g), & 141.87(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 treatment, your State may

require you to continue WQP monitoring. The LCRMR clarify that systems with treatment in

place must continue to properly operate it. Systems will also be required to undertake any

additional measures that the State deems necessary to ensure treatment is operated properly. This

may mean continued WQP monitoring even if you are at or below both action levels. 

Similarly, if you are a large system and the State deems you to be a (b)(3) system, you are not

required to continue WQP monitoring. However, if the State makes this determination after you

have installed treatment, the State may require you to continue to conduct some WQP

monitoring.

REMEMBER: If you serve 50,000 or fewer people, 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.

What Water Quality Parameter Monitoring Information Must I Report to

the State? (See §§141.90(a)(1)(vi)-(viii) & (5)) 

The LCRMR clarify that you must report WQP monitoring results within the first 10 days

following the end of each 6-month compliance period. This reporting requirement still applies even if your

State has not adopted the new OWQP compliance procedure. For example, during the year of 2001, any

WQP samples that you collected during January through June 2001 would be due to the State by

July 10, 2001. Those samples that you collected during July through December 2001 would be

due to the State by January 10, 2001. If you are on annual or triennial WQP tap monitoring,

there will be some 6-month monitoring periods in which you will not have any tap WQP results to

report.
Lead and Copper Monitoring Guidance February 2002 56

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. T Please check with your State before providing this

demonstration to be sure this provision is included in the State’s regulations.

What If I Do Not Fulfill My WQP Requirements? (See §§141.80(k),

141.82(g), & 141.87(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 these requirements:

• Use appropriate sampling procedures in accordance with §§141.87(a)(1);

• Collect the required number and type of samples in accordance with §§141.87(a)(2),(b)-

(e);

• Ensure samples are analyzed properly in accordance with §141.89(a);

• Submit all required monitoring information on time in accordance with §141.90(a)(vi)-

(viii); or

• Meet the State-approved sampling plan for collecting WQPs at representative entry

point locations in accordance with §§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 LCRMR, you are in violation of your requirements if you have OWQP excursions for more

than 9 days in a 6-month compliance period.

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 (see

§141.31(b)).

2. Deliver public notification to your customers (see §141.32 if your State has not adopted

the new public notification requirements or §141.201 & 141.203 - 141.206 if your State

has adopted these new requirements). 

3. Include a discussion of the violation in your consumer confidence report if you are a

CWS, (see §§141.153). 

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: A monitoring and reporting violation does not impact your

WQP monitoring schedule.
Lead and Copper Monitoring Guidance February 2002 57

EPA has also defined the timing of a 6-month monitoring period for small and medium systems

on reduced lead and copper tap monitoring that are triggered into WQP monitoring because of

an action level exceedance. For these systems, the end of the 6-month period for WQP

monitoring is synchronized with the end of the reduced lead and copper tap monitoring period

during which an action level was exceeded. This revision was made to correspond to the new

OWQP compliance procedure which is based on 6-month monitoring periods. For example, if

you are on annual lead and copper tap monitoring during the time period of January 1 through

December 31, 2001 and you exceed an action level, the corresponding WQP monitoring period

would be July 1 through December 31, 2001.

What Provisions of the LCRMR Pertain to Water Quality Parameter

Monitoring and Reporting? (See §141.82(g), §§141.87(c)(3) & (e)(ii), &

§141.90(a))

The table below summarizes those provisions that directly impact your WQP monitoring and

reporting requirements. It distinguishes between those provisions that you were required to begin

implementing on April 11, 2000 and those less stringent provisions with which you must first

check with your State before implementing. For water systems owned or operated on Tribal

lands, in Wyoming, or the District of Columbia, all of the provisions listed below became

applicable on April 11, 2000.

You Were Required to Comply with

These Monitoring Requirements Beginning April 11, 2000

If you have installed corrosion control treatment but are not required to conduct WQP

monitoring, you must continue to properly operate and maintain corrosion control treatment at

all times.

You must report WQP monitoring results within the first 10 days following the end of the 6-

month OWQP compliance period.
Lead and Copper Monitoring Guidance February 2002 58

You Must First Check With Your State Before Implementing the Following

Provisions

The LCRMR revises the OWQP compliance procedure as follows:

• “Daily values” are now used to determine compliance. Daily values are the sample

results for each WQP and are calculated for each WQP at each sampling location. 

They are based on the sampling frequency for that WQP and sampling point.

• You are only out of compliance if you have an “excursion” for more than a total of 9

days during a 6-month period. An excursion is any “daily value” for a WQP that is

below the minimum value or outside the range set by the State. 

• Compliance determinations are always based on 6-month periods, regardless of your

monitoring schedule (e.g., daily, biweekly, semi-annually, annually, triennially) or

whether the sample is from an entry point or tap.

• Confirmation samples are no longer used. You must report the results of all samples

collected during the 6-month period.

You can proceed to triennial WQP tap monitoring if you:

• Qualify for accelerated reduced lead and copper tap water monitoring (your 90th

percentile levels are # 0.005 mg/L for lead and # 0.65 mg/L for copper), and

• Are in compliance with your OWQPs for 2 consecutive monitoring periods (either 6-

month or annual).

You may limit biweekly WQP entry point monitoring to representative locations if:

• You are a ground water system; and

• You can demonstrate that these sites are representative of your system’s water quality

conditions.
Lead and Copper Monitoring Guidance February 2002 59

What Key Points Should I Remember About Water Quality

Parameter Monitoring? (See §§141.82(g) & 141.87)

g If you serve more than 50,000 people, you must conduct some WQP monitoring.

g 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 to by the State. However, you must collect WQP

samples during any monitoring period in which you exceed the lead or copper action level.

g 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). 

g 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.

g After you install corrosion control treatment, entry point monitoring changes from 2 samples

per site every 6 months to 1 sample per site every 2 weeks.

g 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.

g 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 3 consecutive years and be in compliance with your OWQPs for these 3 years

to qualify for triennial WQP tap monitoring.

g If your State adopts the new procedure for OWQP compliance, you are in compliance with

your OWQP requirements if you have excursions for no more than a total of 9 days at

specific sampling point or combination of sampling points, or for a specific WQP or

combination of WQPs during a 6-month period. 

g 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 9

days in a 6-month period (based on the LCRMR compliance approach). 
Lead and Copper Monitoring Guidance February 2002 60

CHAPTER IV: LEAD AND COPPER SOURCE WATER

MONITORING AND REPORTING REQUIREMENTS

What Is The Purpose of Collecting Source Water Samples? (See

§§141.81(b)(3) & 141.88(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 §141.81(b)(3). Refer to the section entitled, What

Is the Purpose of the Lead and Copper Regulations?, in Chapter I for a discussion of the (b)(3)

criteria.

Which Systems Must Collect Source Water Samples? (See §141.88(a))

For systems of any size, source water monitoring for lead and copper is required if a system

exceeds the lead or copper action level based on the 90th percentile lead or copper level in tap

water samples. Source water monitoring is also required for 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. 

O Note: 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 copper tap monitoring to confirm your (b)(3) status.

When Do I Collect Source Water Samples? (See §§141.88(a)-(e))

If This Is The First Time You Have Exceeded The Lead Or Copper 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 and the results must be submitted to the State within 6 months of the exceedance. The

State will use these sample results to determine if source water treatment is needed. In addition to

submitting source water samples, you must also submit a source water treatment recommendation

to the State for review and approval within 6 months of exceeding an action level. This

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
Lead and Copper Monitoring Guidance February 2002 61

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 Copper Rule Guidance

Manual Volume II: Corrosion Control, September 1992 (see 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.

Form 141-D in Appendix E 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 6 months of its receipt of your sample results.

If The State Requires You To Install Source Water Treatment 

If the State requires you to install source water treatment, you have 24 months to complete

installing this treatment. You are not required to conduct source water monitoring while

installing this treatment other than samples that you may elect to take to evaluate the performance

of your treatment. You are not required to report these results to the State.

Once you have installed source water treatment, you must collect one sample from each entry

point during 2, consecutive, 6-month periods, and analyze this sample for both lead and copper

even if you exceed only one of the action levels. With the “before and after treatment” lead and

copper results, the State will designate maximum permissible levels (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 of only one of these contaminants. 

After the State sets MPLs, your monitoring requirements are based on your source type as follows:

• If you use ground water as your only source, you must monitor during 3-year

compliance periods. The first 3-year compliance period is the one in effect when the

State specified MPLs for lead and copper. These are the same compliance periods that

were established under the Standardized Monitoring Framework (SMF) for Phase II/V

contaminants (e.g., 1993 - 1995, 1996 - 1998, 1999 - 2001, 2002 - 2004, etc.). This was

done to allow you to coordinate your source water monitoring for lead and copper with

other monitoring requirements.

• If you use surface water, ground water under of the direct influence of

surface water (GUDI), or any combination of these sources with ground

water, you must monitor annually. The first annual monitoring period begins on the

date that the State set your MPLs.

You can further reduce your source water monitoring frequency to once every 9 years based on

the SMF compliance cycle (i.e., 1993 - 2001, 2002 - 2010, etc). The number of sites from which

you must collect source water samples remains at one sample per entry point.

You can reduce your monitoring frequency to once every 9 years if you meet the criteria listed

below.

 
Lead and Copper Monitoring Guidance February 2002 62

• If you use ground water exclusively, you can collect source water samples once

every 9 years if you do not exceed either the lead or copper MPL for 3 consecutive, 3-

year compliance periods (i.e., 9 years). 

• If you use surface water, ground water under of the direct influence of

surface water (GUDI), or any combination of these sources with ground

water, you can collect source water samples once every 9 years if you do not exceed

either MPL for 3 consecutive years. 

If You Are Not Required To Install Source Water Treatment

If you continue to exceed the lead or copper action level but the State determines that source

water treatment is not needed, your continued monitoring requirements are based on the date that

the State made this determination and your source type as follows: 

• If you use ground water as your only source, you must monitor during 3-year

compliance periods. The first 3-year compliance period is the one in effect when the

State determines that source water treatment is not needed.

• If you use surface water, GUDI, or any combination of these sources with

ground water, you must monitor annually. The first annual monitoring period begins

on the date that the State determines that source water treatment is not needed.

O Note: Some States may have set MPLs for systems that were not required

to install source water treatment. For these systems, the monitoring

schedule is based on when the State set MPLs. More specifically, systems

using ground water exclusively would begin triennial monitoring with the 3-

year period in effect when the State set MPLs. All other systems would

begin annual monitoring on the date that the State set MPLs.

The LCRMR expand the universe of systems that can conduct source water monitoring at a

frequency of once every 9 years. The 1991 LCR did not allow systems that exceeded an action

level, but for which the State did not set MPLs, to reduce the frequency of source water

monitoring. T Please check with your State to determine if they have adopted the

provision described below. 

If you exceed an action level after the State has determined that source water treatment is not

needed, you can reduce the frequency of source water monitoring if:

• your source water lead concentrations are # 0.005 mg/L; and 

• your source water copper concentrations are # 0.65 mg/L; and

• you maintains these levels for 3 consecutive compliance periods.

Ground water systems would qualify for reduced monitoring after 3 consecutive, 3-year

compliance periods or after 9 years. Surface water systems (or those using a combined source)

would qualify after 3 consecutive years. 
Lead and Copper Monitoring Guidance February 2002 63

REMEMBER: You cannot qualify for reduced source water

monitoring unless the 3 compliance periods in which you meet

the reduced monitoring criteria are consecutive.

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.

Where Are These Samples Collected? (See §141.88(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.

If you use surface water, GUDI, 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 the 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 should be taken during normal

operations so that the water is representative of all sources being used.

Some States allow a maximum of 5 samples to be combined together and analyzed as one sample

(known as compositing). The LCRMR require that compositing 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. 

T First check with your State to determine whether compositing of source water

samples is allowed.
Lead and Copper Monitoring Guidance February 2002 64

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 should 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. 

O Note: The LCRMR increased the copper resampling trigger from greater

than 0.020 mg/L or 0.001 mg/L (depending on the analytical method) to

greater than or equal to 0.160 mg/L and the changed the lead resampling

trigger from greater than 0.001 mg/L to greater than or equal to 0.001 mg/L.

You must take each repeat sample at the same sampling site unless conditions make sampling at

another site more representative of each source or treatment plant.

REMEMBER: Compositing allows you to save on analytical

costs. It does not reduce the number of samples that you must

collect. Also remember to first check with your State to

determine if compositing of samples is allowed.

How Does the State Evaluate My Source Water Monitoring Results? 

(See §§141.83(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 within 14 days

of collecting the original sample. If the average of these results are still higher than the MPL, you

are in violation. 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.

O Note: 90th percentile levels are never calculated for source water samples.
Lead and Copper Monitoring Guidance February 2002 65

Can I Ever Discontinue Source Water Monitoring? (See §141.88(d)(2)) 

Once you exceed either the lead or copper action level, you are always subject to source water

monitoring requirements. However, after the State has designated MPLs or determined 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 or 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 the three examples below. 

EXAMPLE 1:

A system qualifies for reduced source water monitoring for the compliance cycle of 2002 through

2010. During this time period, the system is on triennial lead and copper tap monitoring. It

conducts lead and copper tap monitoring during 2001 through 2003, 2004 through2006, 2007

through 2009, and 2010 through2012. Both the lead and copper 90th percentile levels are below

the lead and copper action levels for all four monitoring periods. The system is not required to

conduct source water monitoring because it was below both action levels during the entire source

water monitoring period in effect (i.e., the 9-year compliance cycle of 2002 through 2010).

EXAMPLE 2:

Another system qualifies for reduced source water monitoring for the compliance cycle of 2002

through 2010. It conducts lead and copper tap monitoring during 2001 through2003, 2004

through 2006, 2007 through 2009, and 2010 through 2012. During the compliance period of

2010 to 2012, it exceeds the lead action level. These lead and copper tap samples were collected

during 2011. This system is not required to conduct source water monitoring during 2001

through 2010, but it would be required to conduct this monitoring during 2011 through 2019

because of the exceedance that occurred in 2011.

EXAMPLE 3:

Beginning January 1, 2000, a surface water system is on an annual source water monitoring

schedule, and a triennial lead and copper tap monitoring schedule. The system collects lead and

copper samples during 2001 for the compliance period of 2000 through 2002. It continues to

exceed the copper action level, but still qualifies for triennial tap monitoring because it is in

compliance with its OWQPs. The next time the system collects samples is in 2004 (for the 3-year

tap monitoring period of 2003 through 2005) and for the first time, it is below both action levels.

The source water monitoring period in effect in this example is one year. This system must

conduct source water monitoring in 2000, 2001, and 2002 because the system exceeded the

copper action level. The system is also required to conduct monitoring in 2003 although no lead

and copper tap monitoring occurred because it exceeded the copper action level during the last

monitoring period. It is not required to conduct source water monitoring during 2004 and 2005

because the system was below both action levels.
Lead and Copper Monitoring Guidance February 2002 66

REMEMBER: Once the State sets MPLs or determines that you are

not required to install source water treatment, you can discontinue

source water monitoring if you no longer exceed the lead or copper

action level during the entire source water monitoring period in effect. 

The State does not set MPLs until after follow-up monitoring has been

completed. Therefore, if you are required to install source water

treatment, you must complete the 2 consecutive, 6-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. 

What Source Water Monitoring Information Must I Report to the State? 

(See §141.90(b))

You must provide the following information within 10 days of the end of the monitoring period

(based on your source water lead and copper sampling schedule — 6 months, 1 year, 3 years, or 9 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).

What If I Do Not Fulfill My Source Water Monitoring And Reporting

Requirements? (See §§141.80(k) & 141.83(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 these requirements:

• Use appropriate sampling procedures (see §§141.88(a)(1) and (2));

• Collect the required number of source water samples (see §§141.88(a)(1) - (e));

• Ensure samples are analyzed properly (see §141.89(a)); or

• Submit all required sampling information on time (see §141.90(b)).

You are also in violation if you do not meet your State-designated or approved MPLs. If you are

above either MPL, you can take a confirmation sample within 2 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 (see §§141.88(a)(2)).

If you are out of compliance with your monitoring, reporting, or MPLs, you must:

1. Report the violation to the State within 48 hours of determining the noncompliance (see

§141.31(b)).

2. Deliver public notification to your customers (see §141.32 or if the State has adopted the

new public notification requirements, see §141.201 & §§141.203 - 141.206.)
Lead and Copper Monitoring Guidance February 2002 67

3. Include a discussion of the violation in your consumer confidence report if you are a

CWS (see §§141.153). 

 ~ Also keep in mind that consecutive rounds of monitoring are needed to qualify for reduced lead and copper

source water monitoring. Thus, noncompliance with your monitoring requirements will impact how quickly

you can qualify for reduced monitoring. ~

What Provisions of the LCRMR Pertain to Source Water Monitoring and

Reporting Requirements? (See §§141.88(a)(iv) & 141.88(e)(2)(ii))

The table below summarizes those provisions that directly impact your source water monitoring

requirements. The LCRMR did not change your source water reporting requirements. The table

distinguishes between those provisions that you were required to begin implementing on April 11,

2000 and those less stringent provisions with which you must first check with your State before

following. For water systems owned and operated on Tribal lands, Wyoming, or the District of

Columbia, all of the provisions listed below became applicable on April 11, 2000.

You Were Required to Comply with These Monitoring Requirements Beginning April 11, 2000

EPA has clarified that compositing (if permitted by the State) must be conducted by certified

lab personnel.

EPA has revised the resampling trigger for composite samples to:

• $ 0.001 mg/L for lead; and 

• $ 0.160 mg/L for copper. (This one for copper is less stringent because the resampling trigger was

increased from 0.020 mg/L to 0.160 mg/L.)

You Must First Check With Your State Before Implementing the Following Provisions

You may conduct source water monitoring on a reduced schedule even though you exceed an

action level, if:

• your source water levels are # 0.005 mg/L for lead and # 0.65 mg/L for copper; and

• your State has determined that source water treatment is unnecessary.
Lead and Copper Monitoring Guidance February 2002 68

What Key Points Should I Remember About Lead and Copper Source

Water Monitoring? (See §§141.83 & 141.88)

g 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.

g You must analyze for both lead and copper even if you exceed only one of the action levels in lead or

copper tap monitoring.

g 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 6 months of exceeding an action

level. No source water treatment study is required. 

g Source water samples are compared against the lead and copper MPLs. 90th percentile levels are

not calculated for source water samples and compared against the action level.

g 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. 

g Once the State sets MPLs or determines that source water treatment is not needed, ground water

systems must monitor every 3 years beginning with the SMF compliance period in effect when the

State made the applicable decision.

g Once the State sets MPLs or determines that source water treatment is not needed, surface water

systems or ones using a combined source must monitor annually. The first year begins on the date

the State made the applicable decision.

g You can collect source water samples once every 9 years based on SMF compliance cycles, if for 3

consecutive compliance periods you do not exceed your MPLs (equals 9 years for ground water

systems and 3 years for all other systems).

g Your State may allow you to collect source water samples once every 9 years if:

S you continue to exceed the lead or copper action level and are not required to install source

water treatment, but 

S for 3 consecutive compliance periods your source water lead and copper levels do not exceed

0.005 mg/L and 0.65 mg/L, respectively.

g 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.

g After the State has designated MPLs or determined 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 or copper levels of tap water samples are at or below their action

levels for the entire source water monitoring period in effect.
Lead and Copper Monitoring Guidance February 2002 69

CHAPTER V: LEAD SERVICE LINE MONITORING

AND REPORTING REQUIREMENTS

What Is The Purpose of Collecting Lead Service Line Samples? 

(See §§141.84(a) - (d)(1)) 

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 whichever sampling

occurs later). The State can also require you to begin lead service line replacement if you are

required to install corrosion control treatment or source water treatment and have not installed

such treatment. 

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 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 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 privately-owned

portion of the line, because of legal restrictions or the owner decides not to pay for the

replacement of the privately-owned portion. 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 required. 

Which Systems Must Collect Lead Service Line Samples? (See §§141.84(a)

& (d)(1)) Only those systems that are required to replace lead service lines may be required to conduct

some lead service line monitoring. As stated above, monitoring 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 you replace the entire lead service line, or if you only replaces a gooseneck, pigtail, or other

fittings and these are the only lead components in your service line. 
Lead and Copper Monitoring Guidance February 2002 70

When Do I Collect Lead Service Line Samples? (§§141.84(b) & (e)(3))

The first required year of lead service line replacement begins on the date 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 began. You must continue replacing the

required percentage of lead service lines each year until you no longer exceed the lead action level

during 2 consecutive monitoring periods of any duration.

How Do I Collect Lead Service Line Samples? (See §141.86(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 Table 5-1, 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, then close the tap. 

• Direct Service Line Samples - In communities where the meters are located outside the

buildings (or unmetered areas) service line taps may already exist. Prior to sampling,

water should be run to flush the pipe that connects the faucet and the service line. 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 no existing service line taps. 

• Temperature 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.
Lead and Copper Monitoring Guidance February 2002 71

Table 5-1: Pipe Volume Table (Volumes Listed in Liters)

Pipe

Length

(Feet)

Pipe Diameter (Inches)

3/8 1/2 5/8 3/4 1 11⁄4

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

25

30

35

40

60

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

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

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

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

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

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.

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.

Can I Ever Discontinue Lead Service Line Monitoring? (See §141.84(f))
Lead and Copper Monitoring Guidance February 2002 72

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 2, consecutive monitoring periods. You must start replacement again if you

subsequently exceed the lead action level during any monitoring period.

REMEMBER: It takes 2, consecutive monitoring periods

to stop replacement, but only 1 monitoring period to be

triggered back into lead service line replacement.

What Lead Service Line-Related Information Must I Report to the State? 

(See §141.90)(e))

Within 12 Months of When You Exceed the Lead Action Level

You must provide the State with written demonstration that your materials evaluation was

completed, including the evaluation to identify the initial number of lead service lines in your

distribution system, as follows:

• Schedule for replacing at least 7 percent each year of the initial number of lead service

lines in your distribution system.

• Letter stating for the previous year: 

- the number of lines scheduled that were to be replaced;

- the number and location of lines actually replaced; and 

- if measured, the water lead concentration and location of each lead service line

sampled, the sampling method, and the date of sampling. 

This letter is due every 12 months until you complete lead service line replacement or no longer exceed the lead

action level during 2, consecutive rounds of tap monitoring.

Newly Required Under the LCRMR

If you do not replace the entire length of the lead service line (i.e., partial replacement), you 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. 
Lead and Copper Monitoring Guidance February 2002 73

• 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.

No Longer Required under LCRMR

Under the LCRMR you are no longer need to provide evidence that you do not control the entire

lead service line if you are only replacing a portion of the line. Under the 1991 LCR, you were

required to replace the entire line unless you could demonstrate that you did not “control” the

entire line. The LCRMR require you to replace the portion that you own versus control, thereby,

making this demonstration unnecessary.

What If I Do Not Fulfill My Lead Service Line Replacement Requirements? 

(See §141.80(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% annually) (see §§141.84(a) & (b)); or

• Report the required lead service line information on time that demonstrates that the

replacement rate was met (see §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) (see §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 3 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.

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 (see

§141.31(b)).

2. Deliver public notification to your customers (see §141.32 if your State has not adopted

the new public notification requirements or §141.201 & 141.203 - 141.206 if your State

has adopted these new requirements). 

3. Include a discussion of the violation in your consumer confidence report if you are a

CWS (see §141.153). 
Lead and Copper Monitoring Guidance February 2002 74

What Provisions of the LCRMR Pertain to Lead Service Line Monitoring

and Replacement? (See §141.88(d) & §141.90(e))

The table below summarize each of the LCRMR provisions that impact your lead service line

monitoring and replacement requirements. You were required to begin implementing these

requirements on April 11, 2000.

You Were Required to Comply with

These Monitoring and Reporting Requirements Beginning April 11, 2000

Under the LCRMR, you:

• Must replace the portion of the lead service line that you own. Under the LCR you were

required to replace the portion of the line that you controlled, unless you could

demonstrate that you controlled less than the entire line.

• Must notify the owner (or owner’s authorized agent) about the replacement, and offer to

replace the owner’s portion of the line.

• Are not required to pay for replacing the privately-owned portion of the line.

• Are not required to replace the privately-owned portion of the line if precluded by law, or

where 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, 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. Under the LCR, you were required to

collect a sample from each resident (if the resident(s) so desired) within 14 days of the

partial replacement.

• Report sample results to the building owner(s) and the resident(s) served by the partially

replaced line within 3 business days of receiving these results. You must notify residents

by mail. However, for multi-family dwellings you can post the notification in a

conspicuous common-use area of the building.

• Submit these monitoring results to the State within the first 10 days of the month

following that in which you receive the results. However, the LCRMR give States the

option to modify reporting requirements, so you need to check with your State to be sure

of your specific requirements.
Lead and Copper Monitoring Guidance February 2002 75

What Key Points Should I Remember About Lead Service Line

Monitoring and Reporting? (See §§141.84 & 141.86(b)(3))

g 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 corrosion

control treatment or source water treatment. 

g 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 counts as a replaced

line.

g If you do not replace the privately-owned portion of a lead service line (also known as partial

lead service line replacement), you must collect a sample that is representative of the water in

the service line within 72 hours of the replacement.

g There are 3 methods for collecting a lead service line sample: 1) Flushing a specified volume;

2) Direct service line samples; and 3) Using temperature variation.

g You can discontinue lead service line replacement and thus, any need to conduct lead service

line monitoring whenever your 90th percentile lead levels are at or below the lead action level

for 2, consecutive monitoring periods. 

g 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
Lead and Copper Monitoring Guidance February 2002

APPENDICES

3⁄4 Appendix A: List of LCRMR Outreach Materials for Water

Systems

3⁄4 Appendix B: Definitions

3⁄4 Appendix C: Monitoring Timelines

3⁄4 Appendix D: Summary of Monitoring and Reporting Violations 

3⁄4 Appendix E: Worksheets and Instructions
Lead and Copper Monitoring Guidance February 2002 A-1

APPENDIX A

List of LCRMR Outreach Materials for Water Systems

Below is a comprehensive list of outreach materials that were developed to help you

understand and implement the minor revisions to the Lead and Copper Rule. 

Guidance Documents

T How to Determine Compliance with Optimal Water Quality Parameters as Revised by the Lead and Copper

Rule Minor Revisions, February 2001, EPA 815-R-99-019.

T Lead and Copper Rule: Summary of Revisions, April 2000, EPA 815-R-99-020. 

T 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.

T Notification and Reporting Requirements for Partial Lead Service Line Replacement under the Lead and Copper

Rule, April 2000, EPA 815-R-99-022. 

T Lead and Copper Rule: Minor Revisions Compared to the 1991 Rule, April 2000, EPA 816-

R-00-009

T Lead in Drinking Water Regulation: Public Education Guidance (revised), EPA 816-R-02-010

Fact Sheets 

T Fact Sheet Lead and Copper Rule Minor Revisions, December 1999, EPA 815-F-99-010. 

T Fact Sheet for Public Water Systems that Serve 3,300 or Fewer Persons, February 2001,

EPA 816-F-00-007.

T Fact Sheet for Public Water Systems that Serve 3,301 to 50,000 Persons, February 2001,

EPA 816-F-00-008.

T Fact Sheet for Public Water Systems that Serve More Than 50,000 Persons, February

2001, EPA 816-F-00-009.

T Fact Sheet for Tribal Water System Owners and Operators, February 2001, EPA 816-F00-010.

Training

T Comprehensive Lead and Copper Rule Training, January 2001.

You can obtain any of these documents from the Safe Drinking

Water Hotline, or the Office of Ground Water and Drinking

Water web page at www.epa.gov/safewater/leadcop.html.
Lead and Copper Monitoring Guidance February 2002 B-1
Lead and Copper Monitoring Guidance February 2002 B-2

APPENDIX B

Definitions

Term Definition

ONote: New terms introduced under the LCRMR are shown in italics.

90th Percentile The highest concentration of lead or copper in tap water that is exceeded by 10 percent of

the sites sampled during a monitoring period. This value is compared to the lead or copper

action level (AL) to determine whether an AL has been exceeded.

Accelerated Reduced

Lead and Copper Tap

Monitoring

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 2, consecutive, 6-month monitoring periods. 90th percentile lead level must be #

0.005 mg/L, and 90th percentile copper levels must be # 0.65 mg/L.

Accelerated Reduced

Water Quality

Parameter (WQP)

Monitoring

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 2, consecutive monitoring periods (either 6-month or annual periods).

Action Level (AL) 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 or 15 ppb. The action level for copper is 1.3 mg/L

or 1300 ppb.

(b)(1) system A small or medium system that is at or below both action levels during 2, consecutive, 6-

month rounds of lead and copper tap monitoring. 

(b)(2) system A systems that is deemed to have optimized corrosion control after demonstrating that it has

completed corrosion control treatment steps prior to 12/7/92 that are equivalent to those

described in §141.81(b)(2) of the regulation.

(b)(3) system 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.

Community Water

System (CWS)

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.

Corrosion Control

Treatment

A treatment designed to reduce the dissolving of lead and/or copper in plumbing materials

during water delivery to consumers.

Cu The chemical symbol for copper.

Daily values 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.

Deemed to have

optimized

corrosion control

Systems that are delivering minimally corrosive water (i.e., (b)(1), (b)(2), or (b)(3) systems). 

These systems are subject to fewer monitoring and treatment technique requirements.

Entry Point Refers to points of entry to the drinking water distribution system from which samples will be

representative of each source of supply after treatment.

Exceedance Occurs when the 90th percentile lead or copper sample is above its respective action level.
Term Definition

ONote: New terms introduced under the LCRMR are shown in italics.

Lead and Copper Monitoring Guidance February 2002 B-3

Excursion 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.

First-Draw Sample 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.

Follow-up

Monitoring

Refers to the lead and copper tap water and WQP (tap and entry point) monitoring that takes

place after corrosion control treatment is in place and before the State determines OWQP

ranges or minimums. The samples are taken during the 2, consecutive 6-month monitoring

periods immediately following the installation of corrosion control treatment.

Full Waiver This waiver allows a small system to collect both lead and copper tap samples at a frequency of once every 9

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.

GUDI An acronym for systems that have been determined to be ground water under the direct

influence of surface water.

Initial Tap

Monitoring

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 6-month intervals until which point the system exceeds either

action level, or is at or below both action levels for 2, consecutive, 6-month monitoring

periods. For systems serving more than 50,000 people, refers to tap samples collected during

the first 2, consecutive, 6-month periods of monitoring.

Large Water

System

A water system that serves more than 50,000 people.

LCR An acronym for the Lead and Copper Rule. Also referred to in this document as the 1991

Rule.

LCRMR The acronym for the Lead and Copper Rule Minor Revisions.

Lead Service Line

(LSL)

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.

Materials Survey 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.

Maximum

Permissible Levels

(MPLs)

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.

Medium Water

System

A water system that serves 3,301 to 50,000 people.

Method Detection

Limit (MDL)

The minimum concentration of a substance that can be measured and reported with 99%

confidence that the analyte concentration is greater than zero.

Monitoring Waiver 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 9 years at a reduced number of sites. To receive this waiver a system must meet the

monitoring and materials criteria for lead and copper.
Term Definition

ONote: New terms introduced under the LCRMR are shown in italics.

Lead and Copper Monitoring Guidance February 2002 B-4

Non-transient,

Non-Community

Water System

(NTNCWSs)

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.

Optimal Corrosion

Control Treatment

(OCCT)

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.

Optimal Water

Quality Parameters

(OWQPs)

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. 

Partial Wavier 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 9 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.

Pb The chemical symbol for lead.

Practical

Quantitation Level

(PQL)

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. 

Public Water

System (PWS)

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.

Reduced

Monitoring

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 §141.86(d)(4) or §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.

Representative Site A sampling site that is connected to plumbing materials which are similar to materials used at other sites in the

water system. 

Service Line

Sample

A 1-liter sample of water, collected in accordance with §141.86(b)(3), that has been standing

for at least 6 hours in a lead service line.

Single Family

Residences (SFRs)

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% of the service connections within the system’s service area.

Single Family

Structure

A building constructed as a single-family residence that is currently used as either a residence

or a place of business.

Small Water

System

A water system that serves 25 to 3,300 people.
Term Definition

ONote: New terms introduced under the LCRMR are shown in italics.

Lead and Copper Monitoring Guidance February 2002 B-5

Solder A metallic compound used to seal joints in plumbing. Until the lead ban took effect, most

solder contained about 50 percent lead.

Source Water

Sample

A sample collected at entry point(s) to the distribution system representative of each source of

supply after treatment.

Source Water

Treatment

Treatment designed to remove lead and/or copper from the source of the water supply.

Special-Case CWS 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 an NTNCWS.

Standard

Monitoring

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 6-month intervals.

Tier 1 Site 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 an NTNCWS, it is a

building that contains copper pipes with lead solder installed after 1982, and/or is served by

lead service lines.

Tier 2 Site 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 an

NTNCWS, it is a building that contains copper pipes with lead solder installed before 1983. 

Tier 3 Site Applies only to a CWS, and is a single family structures that contain copper pipes with lead

solder installed before 1983. 

Water Distribution

System 

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.

Water Quality

Parameters (WQPs)

Used to help systems and States determine what levels of corrosion control treatment would

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. 
Lead and Copper Monitoring Guidance February 2002 C-1

APPENDIX C

Monitoring Timelines

8 Lead and Copper Tap and WQP Monitoring Schedule for Large Water

Systems (> 50,000)

This timeline illustrates the schedule for corrosion control treatment (CCT), lead and copper

tap monitoring, and WQP monitoring for (b)(3) and non-(b)(3) large systems.

8 Lead and Copper Tap Schedule for Medium Water Systems (3,301 -

50,000) that Do Not Exceed An Action Level

This timeline shows the lead and copper monitoring requirements for medium water systems

that do not exceed an action level.

8 Lead and Copper Tap and WQP Monitoring Schedule for Medium

Water Systems (3,301 - 50,000) that Exceed An Action Level (No Longer

Exceed After Installing Treatment)

This timeline illustrates the CCT and monitoring schedule for medium systems that no longer

exceed an action level after treatment.

8 Lead and Copper Tap and WQP Monitoring Schedule for Medium

Water Systems (3,301 - 50,000) that Exceed An Action Level (Continue

to Exceed After Installing Treatment)

This timeline shows the CCT and monitoring schedule for medium water systems that

continue to exceed an action level after CCT.

8 Lead and Copper Tap Schedule for Small Water Systems (# 3,300) that

Do Not Exceed An Action Level

This timeline shows the lead and copper monitoring requirements for small water systems that

do not exceed an action level.

8 Lead and Copper Tap and WQP Monitoring Schedule for Small Water

Systems (# 3,300) that Exceed An Action Level (No Longer Exceed After

Installing Treatment)

This timeline illustrates the CCT and monitoring schedule for small systems that no longer

exceed an action level after treatment.

8 Lead and Copper Tap and WQP Monitoring Schedule for Small Water

Systems (# 3,300) that Exceed An Action Level (Continue to Exceed

After Installing Treatment)

This timeline illustrates the CCT and monitoring schedule for small systems that continue to

exceed an action level after installing CCT.
WQP m

Initial Monitoring

Initial Monitoring

Initial Monitoring

Initial Monitoring

(b)(3) Systems

State Specifies CCT

Conduct 

Treatment 

Studies

Install Treatment

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 20

Follow-up monitoring

State Sets OWOPs

Standard

Reduced Trien

Reduced Annual

Reduced 

Annual

WQP

Non-(b)(3)

Systems

Pb/Cu

WQP

Standard

Standard

Standard

Follow-up monitoring

Follow-up monitoring

Follow-up monitoring

Initial Monitoring

Initial Monitoring

Initial Monitoring

Initial Monitoring

1991 LCR was unclear on the system’s continuing

monitoring requirements

One round of monitoring is

conducted between 9/1/97 -

9/30/00

(LCRMR requirement)

Reduced Triennial

1991 LCR was unclear on the system’s continuing

monitoring requirements

Reduced semi-annual

Reduced semi-annual

Reduced semi-annual

Reduced semi-annual

Reduced 

Annual

Reduced 

Annual

Pb/Cu

Lead and Copper Tap and WQP Monitoring Schedule for Large Water 

Notes:1. If a water system exceeded the lead or copper action level, it must conduct initial source water monitoring within 6 months of the exceedance (Timel2. The diagram assumes that (b)(3) systems meet these criteria based on initial lead and copper tap and source water samples.3. Reduced lead and copper tap monitoring and WQP tap monitoring (shown in the shaded boxes) is conducted at the reduced number of sites. 4. Depending on when and if the State adopts the accelerated reduced lead and copper tap provision and the system meets the criteria of this provision, 

and proceed directly to triennial monitoring.

5. Similarly, depending on when and if the State adopts the accelerated reduced WQP tap monitoring provisions and if a non-(b)(3) system meets these 

monitoring and proceed directly to triennial monitoring.

Lead and Copper Monitoring Guidance C-2 
Lead and Copper Tap Schedule for Medium Water Systems (3

that Do Not Exceed An Action Level

Initial Monitoring

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 20

Reduced Triennial Reduced Triennial

Systems Serving

3,301 – 50,000

Pb/Cu

WQP

Notes: 1. Corrosion control treatment is not required for systems serving 50,000 and fewer people that remain at or below both action levels.2. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites. 

Reduced 

Annual

Reduced 

Annual

Initial Monitoring

Reduced Trien

WQP monitoring does not apply to these systems

Lead and Copper Monitoring Guidance C-3 
Init

ial Monitoring Initial Monitoring

Systems Not 

Conducting

Studies

State Specifies CCT

Install Treatment

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 20

Follow-up monitoring

Standard

WQP mon

Re

Reduced 

Annual Pb/Cu

WQP

Systems 

Conducting

Studies

Pb/Cu

WQP

Standard

Follow-up monitoringFollow-up monitoring

Follow-up monitoring

Notes:1. This diagram assumes that the system exceeded the lead or copper action level in the first round of initial monitoring and no longer exceeds after the 

2. Initial source water monitoring is due within 6 months of the lead or copper exceedance (Timeline for source water monitoring to be developed.)3. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites. Depending on when and if the State 

monitoring provisions and the system meets these criteria, it can omit some of the annual monitoring rounds and proceed directly to triennial tap mo

Initial Monitoring Initial Monitoring

State 

Specifies

Corrosion

Control 

Treatment

State Decides Study Is Needed

Conduct 

Treatment 

Study

State sets OWQPs

Reduced 

Annual

Install Treatment

Follow-up monitoring

Standard Reduced Annual

Standard

Follow-up monitoringFollow-up monitoring

Follow-up monitoring

State sets OWQPs

Reduced 

Annual

Reduced Triennial 

WQP monitoring i

Lead and Copper Tap and WQP Monitoring Schedule for Medium Wate

that Exceed An Action Level 

(No Longer Exceed After Installing Treatment)

Lead and Copper Monitoring Guidance C-4 
Lead and Copper Tap and WQP Monitoring Schedule for Medium Wate

that Exceed An Action Level 

(Continue to Exceed After Installing Treatment

Initial Monitoring Initial Monitoring

Systems Not 

Conducting

Studies

State Specifies CCT

Install Treatment

Follow-up monitoring

Standard

Re

Reduced 

Annual Pb/Cu

WQP

Systems 

Conducting

Studies

Pb/Cu

WQP

Standard

Follow-up monitoringFollow-up monitoring

Follow-up monitoring

Notes:1. This diagram assumes that the system exceeded the lead or copper action level in the first round of initial monitoring. 2. This diagram also assumes that the system continued to exceed an action level after installing treatment and qualifies for reduced lead and copper tap and 

compliance with its OWQPs.

3. Initial source water monitoring is due within 6 months of the lead or copper exceedance (Timeline for source water monitoring to be developed.)4. Reduced lead and copper tap monitoring and WQP tap monitoring (shown in the shaded boxes) is conducted at the reduced number of sites. 

Initial Monitoring Initial Monitoring

State Decides Study Is Needed

Conduct 

Treatment 

Study

State sets OWQPs

Reduced 

Annual

Install Treatment

Follow-up monitoring

Standard Reduced Annual

Standard

Follow-up monitoringFollow-up monitoring

Follow-up monitoring

Reduced 

Annual

State sets OWQPs

State 

Specifies

Corrosion

Control 

Treatment

Standard

Standard

Reduced semi-annual

Reduced semi-annual

Reduced semi-annual

Reduced semi-annual

Reduced 

Annual

Standard

Standard

Reduced semi-annual

Reduced semi-annual

Reduced semi-annual

Reduced semi-annual

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 20

Reduced 

Annual

Reduced 

Annual

Reduced 

Reduced Triennial

Lead and Copper Monitoring Guidance C-5 
Lead and Copper Tap Schedule for Small Water Systems 

that Do Not Exceed An Action Level

Initial Monitoring 

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 20

Reduced Triennial Reduced Triennial

Systems 

Serving 25 –

3,300

Pb/Cu

WQP

Reduced 

Annual

Reduced 

Annual

Initial Monitoring Red

WQP monitoring does not apply to these systems

Notes:1. Corrosion control treatment is not required for systems serving 25 – 50,000 people that remain at or below both action levels.2. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites. 

Lead and Copper Monitoring Guidance C-6 
Lead and Copper Tap and WQP Monitoring Schedule for Medium Wate

Exceed An Action Level 

(No Longer Exceed After Installing Treatment)

Initial Monitoring Initial Monitoring

Systems Not 

Conducting

Studies

State Specifies CCT

Install Treatment

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 20

Follow-up monitoring

Standard

Reduced 

Annual Pb/Cu

WQP

Systems 

Conducting

Studies

Pb/Cu

WQP

Standard

Follow-up monitoringFollow-up monitoring

Follow-up monitoring

Initial Monitoring Initial Monitoring

State Specifies

Corrosion

Control 

Treatment

State Decides Study Is Needed

Conduct 

Treatment 

Study

State sets OWQPs

Reduced 

Annual

Install Treatment

Follow-up monitoring

Standard Reduced Annual

Standard

Follow-up monitoringFollow-up monitoring

Follow-up monitoring

Reduced 

Annual

Re

WQP 

State sets OWQPs

WQP mon

Notes:1. This diagram assumes that the system exceeded the lead or copper action level in the first round of initial monitoring and no longer exceeds after in

2. Initial source water monitoring is due within 6 months of the lead or copper exceedance (Timeline for source water monitoring to be developed.)3. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites. Depending on when and if the Sta

monitoring provisions and the system meets these criteria, the system can omit some of the annual monitoring rounds and proceed directly to trien

Lead and Copper Monitoring Guidance C-7 
Init

ial Monitoring Initial Monitoring

Systems Not 

Conducting

Studies

State Specifies CCT

Install Treatment

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 20

Follow-up monitoring

Standard

Reduced 

Annual

Semi-annual

Semi-annual

Pb/Cu

WQP

Systems 

Conducting

Studies

Pb/Cu

WQP

Standard

Standard

Standard

Follow-up monitoringFollow-up monitoring

Follow-up monitoring

Notes:1. This diagram assumes that the system exceeded the lead or copper action level in the first round of initial monitoring. 2. This diagram also assumes that the system continued to exceed an action level after installing treatment and qualifies for reduced lead and copper ta

compliance with its OWQPs.

3. Initial source water monitoring is due within 6 months of the lead or copper exceedance (Timeline for source water monitoring to be developed.)4. Reduced lead and copper tap monitoring (shown as shaded boxes) is conducted at the reduced number of sites. 

Initial Monitoring Initial Monitoring

State Specifies

Corrosion

Control 

Treatment

State Decides Study Is Needed

Conduct 

Treatment 

Study

State sets OWQPs

Reduced 

Annual

Semi-annual

Semi-annual

Install Treatment

Follow-up monitoring

Standard Reduced Annual

Semi-annual

Semi-annual

Standard

Standard

Standard

Follow-up monitoringFollow-up monitoring

Follow-up monitoring

Reduced 

Annual

Semi-annual

Semi-annual

Re

Annual 

State sets OWQPs

Lead and Copper Tap and WQP Monitoring Schedule for Medium Wate

Exceed An Action Level 

(Continue to Exceed After Installing Treatment

Lead and Copper Monitoring Guidance C-8 
Lead and Copper Monitoring Guidance February 2002 D-1

APPENDIX D

Summary of Monitoring and Reporting Violations

 Monitoring and Reporting (M/R) violations fall into four major categories as described below.

1. M/R for 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 §§141.86(a) and (b);

• Collect the required number of samples during the specified time frame in accordance with

§§141.86(c) and (d);

• Ensure samples are analyzed properly in accordance with §141.89(a);

• Submit all required monitoring information on time in accordance with §141.90(a); or

• Report a change in treatment, or an addition of a new source, within 60 days or within the time

frame specified by the State, if you are on reduced monitoring, have a waiver, or are a (b)(3)

system, as required by §141.90(a)(3).

Depending on whether the State adopts the less stringent provisions of the LCRMR into its revised

drinking water regulation, 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 §141.86(f)(4)

where these samples are needed to meet minimum sampling requirements;

• Meet the conditions of your monitoring waivers in §141.86(g) or provide the required

information in §§141.90(a)(4)(ii)-(iv);

• Provide sample information needed for your State to perform the 90th percentile calculation as

outlined in §141.90(h);

• Collect non-first draw samples that did not meet the criteria in §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

§141.86(d)(4)(iv)(B).

2. M/R for WQPs at entry points and taps in the distribution system

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 §§141.87(a)(1);

• Collect the required number and type of samples in accordance with §§141.87(a)(2),(b)-(e);

• Ensure samples are analyzed properly in accordance with §141.89(a);

• Submit all required monitoring information on time in accordance with §141.90(a)(vi)-(viii);

• Meet the State-approved sampling plan for collecting WQPs at representative entry point

locations in accordance with §§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).

2. M/R for WQPs at entry points and taps in the distribution system (continued)
Summary of Monitoring and Reporting Violations

 Monitoring and Reporting (M/R) violations fall into four major categories as described below.

Lead and Copper Monitoring Guidance February 2002 D-1

In addition, you are in violation if you do not meet your OWQP ranges or minimums set by the State

as follows: 

• 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.

• If your State assesses compliance using the LCRMR, you are in violation of your requirements

if you have OWQP excursions for more than 9 days in a 6-month compliance period.

3. M/R for 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 §§141.88(a)(1) and (2));

• Collect the required number of source water samples (see §§141.88(a)(1) - (e));

• Ensure samples are analyzed properly (see §141.89(a)); or

• Submit all required sampling information on time (see §141.90(b)).

In addition, you are in violation if you do not meet your State-designated or approved MPLs (see

§141.88(a)(2)) (Note: If you are above either MPL, you can take a confirmation sample within 2 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)

4. M/R for lead and other requirements associated with lead service line

replacement

You are in violation if you do not:

• Replace the required number of lead service lines by the annual deadline (i.e., at least 7%

annually) (see §§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 §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) (see §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 3 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.
Lead and Copper Monitoring Guidance February 2002 E-2

APPENDIX E

Worksheet and Instructions

8 Worksheet 1: 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).

8 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 (i.e., 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).

8 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.

8 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.

8 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.

8 Amended Form 141-A: Sample Site Identification and Certification

This version of Form141-A deletes those certifications which are no longer required under the LCRMR. 

However, you must first check with your State before using this form.

8 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 LCRMR

no longer require you to submit a formal request for reduced monitoring; however, first check with your

State to determine if this requirement still applies.

8 Form 141-C: Optimal Corrosion Control Treatment Recommendation

This 2-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. 

8 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.
Lead and Copper Monitoring Guidance February 2002 E-3

WORKSHEET #1

MATERIALS SURVEY INVESTIGATION RESULTS

PWS ID NUMBERPOPULATION SERVED BY PWS

Type of

Structure Location

Contact Person

LSL

Home

Plumbing

Material

Verified Volunteered

Selected Received Training

Material Name Phone Routine Optional
Lead and Copper Monitoring Guidance February 2002 E-4

WORKSHEET #2

MATERIALS SURVEY RESULTS BY NUMBER OF SERVICE CONNECTIONS 

FOR EACH PLUMBING MATERIALS TYPE

PWS ID NUMBERPOPULATION SERVED BY PWS

Type of Structure

Type of Plumbing Material

Interior Plumbing Distribution System Piping

Lead Pipe

Copper with Lead

Solder >19824

Copper with Lead

Solder <19835

LSLs

Entire Line Partial Line

Number of Service Connections Number of Service Connections

SFRs1

MFRs2

BLDGs3

TOTAL

1 SFR - single family residence2 MFR - multi-family residence3 BLDG - public or commercials 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.
Lead and Copper Monitoring Guidance February 2002 E-5

WORKSHEET #3

SUMMARY OF MATERIALS SURVEY RESULTS

PWS ID NUMBER

POPULATION SERVED BY PWS

Plumbing Material

Type of Structure

SFR1 MFR2 BLDG3

Number of Service Connections

Interior Plumbing

Lead Pipe

Copper Pipe With Lead Solder >19824

Copper Pipe With Lead Solder <19835

Service Lines

LSLs

Entire Line

Partial Line

Total Available Sites

1

 SFR - single family residence

2

 MFR - multi-family residence

3

 BLDG - public or commercials 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.
Lead and Copper Monitoring Guidance February 2002 E-6

Suggested Directions for

Homeowner Tap Sample Collection Procedures

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. 

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: 

Sample was collected: 

Time_______________

Time_______________

Date_______________

Date_______________

I have read the above directions and have taken a tap sample in accordance with these directions.

_________________________________________ ___________________

Signature Date
Lead and Copper Monitoring Guidance February 2002 E-7

Form 141-A Page 1 of 3

SAMPLE SITE IDENTIFICATION AND CERTIFICATION

System’s Name: _____________________________

______

System Type: ~ CWS ~ NTNCWS

Address: ___________________________________ Number of People Served:

___________________________________________________

___________________________________________________

~ >100,000

~ 10,001 to 100,000

~ 3,301 to 10,000

~ 501 to 3,300

~ 101 to 500

~ #100

System ID:_________________________________________

Contact 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)

_________________________________

______________________________________________________________________________________________
Lead and Copper Monitoring Guidance February 2002 E-8
Lead and Copper Monitoring Guidance February 2002 E-9

Form 141-A (continued) Page 2 of 3

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 §141.42 of the Code

of Federal Regulations

_____ 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
SAMPLE SITE IDENTIFICATION AND CERTIFICATION

Lead and Copper Monitoring Guidance February 2002 E-10

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.

Form 141-A (continued) Page 3 of 3

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 your 90th 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 entry point samples required ________ 

# of WQP tap samples submitted ________

# of entry point samples submitted ________

CHANGE IN SAMPLING SITES
SAMPLE SITE IDENTIFICATION AND CERTIFICATION

Lead and Copper Monitoring Guidance February 2002 E-11

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

O Note: The LCRMR no longer require 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 LCRMR. Please

check with your State before using the amended Form 141-A.

Amended Form 141-A Page 1 of 2

SAMPLE SITE IDENTIFICATION AND CERTIFICATION

System’s Name: _________________________________ ______ System Type: ~ CWS ~ NTNCWS

Address: ______________________________________ _ Number of People Served:
SAMPLE SITE IDENTIFICATION AND CERTIFICATION

Lead and Copper Monitoring Guidance February 2002 E-12

___________________________________________________

___________________________________________________

~ >100,000

~ 10,001 to

100,000

~ 3,301 to 10,000

~ 501 to 3,300

~ 101 to 500

~ #100

System ID #: ______________________________________

Contact Person: _____________________________________ 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 90th 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 entry point samples required ______ # of WQP tap samples submitted ______

 # of entry point samples submitted ______
Amended Form 141-A (Continued) Page 2 of 2 1

SAMPLE SITE IDENTIFICATION AND CERTIFICATION

Lead and Copper Monitoring Guidance February 2002 E-13

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
Lead and Copper Monitoring Guidance February 2002 E-14

O Note: The 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 cannot be 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

REQUEST FOR REDUCED LEAD AND COPPER TAP WATER

System’s Name: _________________________________ System Type: ~ CWS ~

NTNCWS

Address: ________________________________________ Number of People Served:

________________________________________________

________________________________________________

~ >100,000

~ 10,001 to

100,000

~ 3,301 to 10,000

~ 501 to 3,300

~ 101 to 500

~ #100

System ID #: ___________________________________

Contact Person: __________________________________ Telephone number: ___________________

The __________________________________________________ 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

or

~ Annual to Triennial

~ 100 to 50

~ 60 to 30

~ 40 to 20

~ 20 to 10

~ 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
Lead and Copper Monitoring Guidance February 2002 E-15

Form 141-C Page 1 of 2

OPTIMAL CORROSION CONTROL TREATMENT RECOMMENDATION

System’s Name: _________________________________

__

System Type: ~ CWS ~ NTNCWS

Address: __________________________________________ Number of People Served:

___________________________________________________

___________________________________________________

~ >100,000

~ 10,001 to

100,000

~ 3,301 to 10,000

~ 501 to 3,300

~ 101 to 500

~ #100

System ID #: ___________________________________

Contact Person: _________________________________ Telephone number: ___________________

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 source water samples required ______

# of tap water samples submitted ______

# 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 —
Lead and Copper Monitoring Guidance February 2002 E-16

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

______

______

______

______

______

______

______

______

______

Form 141-C (continued) Page 2 of 2

OPTIMAL CORROSION CONTROL TREATMENT RECOMMENDATION

CORROSION CONTROL TREATMENT RECOMMENDATION

1. Treatment recommendation and rationale:

______________________________________________________________________________________

_______________________________________________________________________________________

2. 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).
OPTIMAL CORROSION CONTROL TREATMENT RECOMMENDATION

CORROSION CONTROL TREATMENT RECOMMENDATION

Lead and Copper Monitoring Guidance February 2002 E-17

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

Form 141-D Page 1 of 2

SOURCE WATER MONITORING AND TREATMENT

System’s Name: _________________________________

__

System Type: ~ CWS ~ NTNCWS

Address: __________________________________________ Number of People Served:

___________________________________________________

___________________________________________________

~ >100,000

~ 10,001 to 100,000

~ 3,301 to 10,000

~ 501 to 3,300

~ 101 to 500

~ #100

System ID #: ___________________________________

Contact Person: ____________________________________ Telephone number: ___________________

SOURCE WATER DATA

Attach all data collected at all entry points to the distribution system. List the highest values obtained

in sampling for this monitoring period and attach the results of all other samples collected at each entry

Entry Point Location Lead Values

(in mg/L)

Copper Values

(in mg/L)

1.

2.

3.

4.
SOURCE WATER MONITORING AND TREATMENT

Lead and Copper Monitoring Guidance February 2002 E-18

5.

6.

7.

8.

9.

10.
Lead and Copper Monitoring Guidance February 2002 E-19

Form 141-D (continued) Page 2 of 2

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