
Questions
on
State
Implementation
of
the
Lead
and
Copper
Rule
July,
2004
Lead
Sampling
Questions
State
Full
Response
What
is
the
state's
standard
operating
procedures
to
review
documentation
provided
by
the
systems
for
tap
water
monitoring
site
selection
criteria
(
e.
g,
tiering,

locations).
How
does
the
state
ensure
that
site
locations
were
correctly
followed
during
system
sampling
rounds?
MA
DEP
reviews
and
approves
all
sampling
plans.
DEP
routinely
checks
monitoring
reports.

ME
The
LCRCoordinator
reviews
the
141­
A
Form
that
is
submitted
with
the
test
result
summary
sheet.
The
State
relies
on
the
water
operator
to
select
the
correct
sample
sites
and
complete
the
141­
A
form
correctly.
The
state
will
provide
to
a
new
water
operator
the
historic
sample
site
information
upon
request.
The
water
systems
note
on
the
141­
A
Form
why
a
sample
site
is
dropped
from
the
sampling
pool
and
when
a
new
sample
site
is
added
to
the
sampling
pool.

RI
State
reviews
sites
during
each
round
of
sampling
to
insure
that
they
are
the
same
sites
approved
tin
their
sampling
plan.
VT
The
Water
Supply
Division
(
WSD)
provides
water
systems
copies
of
the
appropriate
EPA
Monitoring
Guidance
which
contains
the
sample
site
identification
and
certification
form.

The
systems
are
required
to
complete
the
form
for
initial
monitoring
and
specify
which
sites
are
tier
1,
2,
or
3
and
certify
that
they
have
included
all
tier
1
sites.
In
the
early
statges
of
implementation,
WSD
did
review
more
carefully
sample
site
selection
criteria
and
provided
more
oversight
to
the
systems.
Due
to
lack
of
resources
this
level
of
service
was
discontinued.
WSD
has
relied
upon
the
system
to
certify
that
they
have
selected
the
appropriate
sites.
Often
water
systems
call
the
WSD
to
verify
their
original
sampling
locations
before
sampling.
If
systems
subsequently
change
the
sampling
locations,
they
are
required
to
notify
WSD
in
writing
or
document
the
change
in
the
location
on
the
lab
sample
form
and
give
a
reason
for
the
change.

NH
A
preprinted
WSEB
site
certification
form
that
includes
each
of
the
system's
sites
to
be
sampled
is
sent
to
each
water
system
prior
to
sampling.
After
sampling
that
selection
form
must
be
submitted
to
the
WSEB
with
sample
results.

CT
The
CTDPH
 
DWD
B102
regulations,
as
they
pertain
to
the
sample
site
locations
for
tap
water
lead
and
copper
monitoring,
were
written
entirely
verbatim
from
the
40
CFR
141.86(
a).
The
current
standard
operating
procedures
are
such
that
all
Community
PWS
and
Non­
Transient
Non­
Community
PWS
submit
Sample
Site
Plans
containing
an
inventory
of
all
sampling
sites
within
the
distribution
system
to
be
used
for
tap
water
lead
and
copper
monitoring,
Total
Coliform
Rule
monitoring,
Disinfection
By­
Products,
etc.

The
information
submitted
as
part
of
each
PWS's
Sample
Site
Plan
is
reviewed
for
required
information
and
compliance
with
applicable
regs.
Mainly,
the
Sample
Site
Plans
are
reviewed
to
ensure
an
appropriate
number
of
sampling
sites
are
included
in
the
sampling
site
pool
and
that
the
approvable
sample
sites
represents
the
distribution
system
as
a
whole.

The
CTDPH
 
DWD
does
not
consult
or
possess
the
materials
evaluations
required
as
part
of
40
CFR
141.42
or
any
information
resources
on
infrastructure
materials
that
might
be
used
to
ensure
that
sampling
sites
are
"
tiered"
accurately.
CT
(
cont)
Such
a
review
could
be
initiated
during
any
compliance
investigations
proceeding
the
issuance
of
a
Lead/
Copper
Exceedance.
Once
the
Sample
Site
Plans
are
approved,
they
are
migrated
to
the
SDWIS/
STATE
to
establish
a
list
of
approved
sampling
sites.
This
list
is
the
only
sampling
sites
available
for
water
quality
data
entry
staff
and
EDI
water
quality
data
transfers.
Samples
reported
from
sampling
sites
not
on
the
approved
list
would
not
be
entered
into
the
SDWIS/
STATE
database
and
not
counted
for
compliance
purposes.
CT
received
clarification
from
Region
1
on
"
tiered"
sample
sites.
Specifically,
whether
the
tier
3
locations
should
be
used
to
the
same
extent
as
tier
1
&
tier
2
sites,
due
to
the
fact
that
tier
3
sample
sites
are
defined
as
the
"
older",
pre­
1983
locations
and
possibly
more
vulnerable
to
corrosion.
Region
1
cited
the
CFR
indicating
that
tier
1
locations
are
the
primary
locations
used
in
lead/
copper
monitoring
but
also
indicated
that
high­
risk
locations
should
be
targeted
and
that
if
a
PWS
is
experiencing
elevated
levels
at
tier
3
locations
then
they
should
fulfill
their
obligations
at
tier
1
sites
and
collect
additional
samples
at
tier
3
sites.

NY
Procedures
for
purveyors
to
select
their
sampling
pools
are
codified
by
state
regulation
in
10NYCRR
Part
5­
1.42(
a).
These
requirements
mirror
the
federal
rule.
As
part
of
their
initial
monitoring
efforts,
purveyors
were
required
to
identify
sampling
locations
and
create
a
sampling
pool
that
meets
the
requirements
of
the
state
and
federal
requirements.
Local
health
offices
reviewed
these
sample
pools
and
worked
with
systems
when
needed
to
ensure
proper
information
and
training
was
provided.
The
local
health
offices
continue
to
review
data
submitted
for
each
monitoring
period,
but
generally
do
not
accompany
water
purveyors
on
sampling
rounds
to
verify
that
site
locations
in
the
selected
pool
were
correctly
followed.
NJ
Material
Survey
within
distribution
system
and
Service
lines
according
to
40
CFR
141.42
(
d)
Vulnerability
of
potential
sites
assigned
based
on
­
lead
pipes,
age
of
homes,­
copper
pipe
with
lead
solder,
­
single
family
homes,
­
multifamily
homes
and
Historical
Water
Quality
data
for
location.
The
State
relies
by
rule
­
NJAC
7:
10A­
on
the
licensed
operator
to
operate
the
water
system
properly
at
the
risk
of
loss
of
license
and,
The
State
randomly
cross­
checks
the
water
systems
in
surprise
site
visits
to
sample
some
of
these
locations
to
be
tested
in
the
State
owned
laboratories
MD
The
public
water
systems
were
required
to
use
Tier
1
locations
unless
none
were
available.

The
monitoring
site
selection
was
reviewed
during
the
initial
monitoring
period.
Any
changes
that
occur
require
change
of
sample
site
location
form
to
be
completed.

DE
Systems
submit
information
on
their
sampling
locations.
We
will
then
compare
the
sample
result
locations
to
the
sampling
plan
when
results
are
received.

WV
When
LCR
was
first
implemented
(
approx
1992),
systems
were
required
to
submit
a
letter
of
justification,
based
on
tier
1,
tier
2,
or
tier
3
criteria(
i.
e.
if
there
were
not
enough
tier
1
sites
identified,
they
had
to
document
that
there
were
not
enough
sites).
Locations
of
the
sites
within
the
distribution
system
were
not
considered
a
factor.
New
systems
have
not
been
required
to
meet
this
criterion.
The
initial
sampling
plans
were
compared
with
initial
sampling
results
to
ensure
that
actual
sampling
locations
were
the
same
as
originally
proposed.
This
procedure
has
not
been
followed
since
initial
implementation.

PA
PA
DEP
field
staff
review
LCR
Sample
Site
Plans
for
compliance
with
Rule
requirements.

Staff
review
revisions,
as
necessary.
In
addition,
staff
discuss
monitoring
plans
with
the
supplier
during
sanitary
surveys.
Water
suppliers
are
required
to
report
a
unique
3­
digit
ID
number
with
all
Pb/
Cu
tap
results
that
identifies
the
sample
location.
This
ID
number
can
be
compared
to
the
Sampling
Plan
to
ensure
that
proper
sample
locations
are
being
used.

Staff
take
appropriate
enforcement
actions
when
suppliers
fail
to
monitor
correctly.
VA
We
require
the
owners
of
all
community
and
non­
transient
non­
community
waterworks
to
submit
a
written
materials
survey
that
identifies
sample
sites
for
lead
and
copper
tap
monitoring.
The
survey
indicates
the
number
of
identified
sites,
if
any,
in
each
of
the
tier
and
categories
contained
in
the
original
LCR.
The
materials
survey
also
indicates
what
criteria
the
waterworks
owner
used
to
identify
specific
plumbing
materials
at
the
sampling
locations.
We
do
not
ask
for
(
and
the
LCR
does
not
require)
any
documentation
from
the
waterworks
owners.
Our
Field
Office
staff
reviews
and
approves
each
materials
survey
but
we
do
not
verify
or
document
the
specific
plumbing
materials
identified.
The
majority
of
waterworks
in
VA
utilize
the
state
laboratory
(
Division
of
Consolidated
Laboratory
Services)
for
lead
and
copper
compliance
monitoring.
The
state
lab
provides
analytical
testing
services
on
a
fee­
for­
service
basis.
The
sample
kits
supplied
by
the
state
lab
contain
a
sample
result
report
form
that
is
completed
by
the
waterworks
owner.
The
report
form
has
the
sample
location
pre­
printed
on
the
form
so
the
owner
knows
where
to
collect
the
sam
VA
(
cont.)
These
sample
site
locations
are
from
the
approved
materials
survey
and
sample
site
selection.
This
pre­
printing
of
sample
locations
ensures
that
the
same
lead
and
copper
tap
sample
sites
are
used
in
subsequent
rounds
of
monitoring.
Additionally,
we
require
the
waterworks
owners
to
submit
a
written
request
if
previously
approved
sample
sites
must
be
changed.
FL
Systems
required
to
sample
for
lead
&
copper
must
submit
a
sampling
plan
for
review
prior
to
initiating
sampling.
Certain
sources
must
be
examined
by
the
system
in
the
record
review
process
to
determine
home
plumbing
characteristics.
Our
sampling
plan
form
includes
several
required
and
optional
record
sources
that
are
to
be
examined.
Required
sources
include,
but
are
not
limited
to,
the
review
of
plumbing
and
building
codes
and
permits,
contacts
with
building
dept
and
review
of
state
regulatory
records
related
to
the
historical
service
area
development
and
materials
used
therein;
optional
sources
include,
but
are
not
limited
to,
interviews
with
plumbing
inspectors
and
building
contractors.
The
form
has
a
materials
survey
section
that
must
be
completed
attesting
to
the
type
of
plumbing
material
used
at
each
selected
and
optional
sample
site
as
well
as
the
appropriate
corresponding
tier.
The
ranking
result
form
includes
a
location
code
that
ties
back
in
to
the
sampling
plan.
The
location
code
must
match
the
location
code
indicated
on
the
sampling
plan.

KY
Kentucky
Drinking
Water
Branch
staff
reviewed
and
approved
lead
and
copper
sample
site
plans
as
they
were
originally
received.
Information
on
the
sample
site
locations
was
entered
into
Kentucky's
legacy
database
system
(
SAS),
however
no
program
existed
to
cross
check
sample
site
numbers
as
sampling
results
were
submitted.
Kentucky
does
include
a
statement
on
the
lead
and
copper
sample
analysis
result
form
whereby
the
water
supply
must
sign
certifying
that
the
results
are
being
reported
in
accordance
with
CFR
141.90
(
a)
(
ii)
(
iii).

MS
The
state
provides
the
tiering
criteria
to
the
systems
to
utilize
when
developing
the
plans.

We
also
specify
how
many
sites
must
be
included.
New
lead
&
copper
sample
site
plans
are
required
every
five
years
in
conjunction
with
updated
bacteriological
plans.
Plans
are
reviewed
to
ensure
that
as
many
Tier
1
sites
as
possible
are
included
on
the
plan.
Systems
must
explain
that
no
sites
meet
Tier
1
criteria
if
that
is
the
case.
Systems
are
cautioned
that
utilizing
improper
sampling
locations
may
nullify
sampling.
Systems
must
sign
a
statement
on
the
plan
that
only
sites
identified
will
be
utilized.
MSDH
staff
routinely
pull
plans
for
comparison
with
sampling
locations
to
ensure
the
proper
sites
are
used.
NC
A
guidance
document
is
available
on
NC's
PWSS
website.
This
document
lists
the
procedures
and
criteria
to
be
used
by
the
water
systems
in
developing
and
submitting
their
sample
siting
plans.
It
is
also
enclosed
as
an
attachment
to
a
letter
sent
to
new
community
and
non­
transient
non­
community
water
systems
beginning
operation.
Once
submitted,
the
rule
manager
reviews
the
plans
to
see
if
any
problems
exist.
If
problems
are
noted,
the
rule
manager
confers
with
both
the
regional
office
and
the
water
system
to
resolve
the
problems.
Regional
offices,
when
requested
by
the
rule
manager,
may
review
sampling
sites
at
the
water
system
location
during
the
new
system's
initial
operation.
The
sample
locations
may
also
be
reviewed
during
routine
sanitary
inspections/
surveys
performed
by
the
regional
offices.
The
site
location
codes
and
site
tier
levels
reported
on
the
lab
analysis
forms
for
each
site
sampled
are
keyed
into
and
tracked
in
our
database.
Enforcement
is
not
tied
to
sampling
site
locations;
to
do
so
would
require
a
redesign
of
our
computer
program.

AL
Forms
are
provided
to
report
lead
and
copper
results
and
these
forms
include
a
place
to
report
the
tier
of
each
sample
location
and
the
age
of
the
plumbing.

SC
Prior
to
initiating
Lead
&
Copper
monitoring,
the
SC
Department
of
Health
and
Environmental
Control
(
Department)
provides
written
guidance
to
the
water
system
for
site
selection.
The
water
system
submits
a
list
of
monitoring
sites
with
the
type
of
plumbing
and
the
year
of
construction
or
age
of
the
locations.
The
Department
assigns
tracking
codes
which
identify
the
tier
level.
Water
systems
are
advised
that
monitoring
is
to
be
conducted
only
at
the
pre­
approved
sites,
and
each
sample
must
list
its
tracking
code.
TN
TN
implements
the
provisions
of
40CFR
141.86.
The
greatest
%
of
lead/
copper
sites
were
selected
in
1992­
1993
by
each
water
system.
This
was
done
after
a
thorough
offering
of
educational
materials
by
mail,
one
on
one
phone
conversations,
and
numerous
state­
wide
on­
site
educational
seminars;
as
well
as
personnel
visits.
Each
water
system
was
required
to
submit
a
site
list
numbering
150%
of
the
minimum
initial
sampling
sites
for
the
first
2
consecutive
six­
month
periods.
The
Tier#
designation
was
required
with
each
site
description
and
a
hard
copy
filed.
The
site
list
of
each
sampling
period
is
requested
to
be
submitted
with
the
sample
results
and
the
database
entry
includes
the
quantity
of
each
tier
#

designations.
Irregular
and
unexpected
tier
#
quantities
warrant
inquiry.
Ongoing
observations
of
water
systems'
historical
and
current
implementation
efforts
and
general
cooperation
with
the
Division
are
considered.
Most
water
plant
operators
live
within
the
service
area
of
their
plant
and
are
personally
interested
in
water
quality.

TN
(
cont)
TN
believes
the
process
used
by
public
water
suppliers
insured
the
highest
risk
sites
were
identified.
The
state
has
not
had
any
reason
to
challenge
the
sites
selected
by
the
public
water
supplier.
The
state
did
review
each
water
supplier's
submittal
and
questioned
water
suppliers
that
were
not
able
to
identify
all
Tier
1
sites.
Monitoring
reports
are
reviewed
when
they
are
received
by
the
state.
Any
deficiencies
noted
on
the
report
are
brought
to
the
attention
of
the
water
supplier
to
resolve
any
issues.
Water
suppliers
cannot
change
sampling
sites
without
the
approval
off
the
state.
The
water
supplier
must
submit
documentation
as
to
the
justification
for
eliminating
a
sampling
site
and
replacing
the
site.

Replacement
sites
must
be
of
the
same
tier
as
the
site
removed.
Some
of
the
justifications
include:
customer
refusing
to
allow
the
water
supplier
to
continue
to
sample
home,

structure
burned
and
was
no
longer
available
for
sampling,
plumbing
changed
to
plastic
and
no
longer
a
high
risk
site,
etc.

GA
The
systems
are
required
to
select
sites
following
CFR40,
141.86(
a)
targeting
criteria,

choosing
tier
1
sites
first,
then
tier
2,
and
then
tier
3.
Systems
were
required
to
submit
an
Initial
Site
monitoring
list
for
State
review.
For
systems
utilizing
the
State
lab
for
analysis,

the
lab
reviews
sampling
criteria
when
samples
are
submitted
for
analysis.
Systems
not
utilizing
the
State
lab
are
review
by
the
compliance
unit
of
the
State
Drinking
Water
Program
(
DWP).
IL
Prior
to
initial
monitoring,
information
regarding
how
to
select
lead
and
copper
sampling
sites
(
as
specified
40
CFR
141.86)
is
mailed
water
systems
(
WS).
The
WS
then
submits
its
proposed
site
plan.
This
site
plan
is
review
for
accuracy
and
completeness.
Site
numbers
are
then
assigned.
The
site
numbers
are
also
entered
into
SDWIS/
State.
The
number
of
"
active"
sites
correspond
with
the
require
sample
count
in
the
water
system's
current
monitoring
schedule.
These
"
active"
sites
are
automatically
imprinted
on
the
monitoring
written
notifications
sent
to
each
water
system
prior
to
the
required
monitoring
period.
If
a
water
system
unexpectedly
needs
to
sample
at
an
alternate
yet
approved
site,
they
must
notify
the
State
in
writing.

IN
The
system
is
instructed
to
choose
tier
1
sites
first,
tier
2
sites,
etc.,
with
a
description
of
what
these
sites
would
be.
The
system
is
expected
to
make
a
good
faith
effort
in
collecting
their
samples
from
these
locations
but
the
state
does
not
further
verify
the
validity
of
the
chosen
sites.

MN
Prior
to
the
initial
tap
monitoring
in
1992­
1993,
systems
are
required
to
identify
and
submit
the
list
of
sites
meeting
the
LCR
tier
criteria
to
the
MDH.
The
information
was
entered
into
the
MDH's
LCR
data
management
system,
containing
site
addresses
and
tier
classifications.
To
ensure
samples
will
be
taken
from
the
sample
pool,
lab
sheets
for
the
subsequent
monitoring
rounds
were
generated
via
the
LCR
database,
with
listing
of
all
qualified
addresses.
However,
as
gaining
residents'
cooperation
became
more
difficult,

systems
are
allowed
to
expand
the
sample
pool
if
they
have
difficulty
collecting
the
required
number
of
samples
using
the
addressed
listed
on
the
lab
sheets.
Tier
information
of
a
new
site
is
added
to
the
MDH's
LCR
database.

OH
Public
water
systems
are
issued
forms
(
Ohio
EPA
forms
5105
"
Drinking
Water
Lead
and
Copper
Monitoring
Report",
5106
"
Lead
Tap
Monitoring
Report",
and
5107
"
Copper
Tap
Monitoring
Report")
with
a
set
of
instructions
describing
tap
water
monitoring
site
selection
criteria.
These
forms
when
submitted
by
the
public
water
system
contain
information
as
to
location,
tap
type,
tiering,
interior
plumbing
material
and
service
line
material
on
each
of
the
sites
selected.
Any
changes
in
site
locations
must
also
be
documented
and
a
reason
given
for
the
change.
WI
The
State
provided
initial
training,
and
guidance
as
needed.
System
information
is
reviewed
during
sanitary
surveys
and
annual
inspections
as
needed.

MI
The
supply
signs
and
submits
a
lead
and
copper
report
form.
The
supply
lists
each
site
selected
and
assigns
a
sample
category.
The
sample
category
characterizes
the
site
by
tier,

type
of
residence,
service
line,
piping,
soldering,
and
time
period
constructed.
Additionally,

to
ensure
the
supply
selected
the
sites
based
on
criteria
under
the
rules,
the
supply
answers
the
following
questions:
Are
the
same
sampling
points
used
as
in
the
previous
monitoring
period?
Are
all
samples
from
Tier
1
sites?
Are
all
samples
from
Tier
1,
2,
or
3
sites
giving
Tier
1
priority?
If
no
Tier
1,
2,
or
3
sites
are
available,
do
all
sites
have
plumbing
materials
commonly
found
at
other
locations
in
the
water
system?
Is
the
minimum
number
of
lead
service
line
samples
taken
(
when
applicable)?
Explanation
is
expected,
where
appropriate,

and
a
comment
field
is
provided.
District
staff
reviews
the
supply's
report
form
against
sampling
results
to
verify
tier
site
selection
by
the
utility.
Attached
is
the
template
of
the
letter
and
report
form.

AR
System
are
given
a
detailed
methodology
and
then
are
required
to
certify
that
they
have
complied.
Systems
give
each
sample
site
a
unique
code.
All
unique
sample
site
codes
are
entered
into
database.
Samples
are
tracked
by
the
codes.

LA
Systems
have
historically
been
required
to
submit
a
copy
of
the
Sampling
Log
sheet
two
weeks
prior
to
sampling.
This
has
allowed
us
to
review
the
sampling
sites
before
samples
are
collected,
and
to
ensure
that
the
same
site
locations
are
being
sampled
for
each
event.

NM
Currently
NMED­
DWB
is
using
the
guidance
that
EPA
published
with
the
Lead
and
Copper
rule.
NMED­
DWB
reviews
the
sampling
results,
however
the
DWB
has
no
current
way
to
ensure
that
the
systems
are
choosing
the
sampling
locations
correctly.

OK
Systems
are
required
to
submit
DEQ
Site
Plan
Forms
for
review
and
approval;

Labs/
SDWIS
will
not
accept
samples
without
Location
Code
for
each
sample.

TX
The
TCEQ
follows
the
EPA
rules,
and
is
neither
more
or
less
stringent.
TCEQ
reviews
public
water
system's
(
PWS's)
lead/
copper
site
selection
form
for
completeness,
but
we
rely
on
the
system
to
accurately
select
their
sites.
The
systems
select
sites
based
on
the
Tiers
1­
2­
3,
and
sites
are
listed
on
the
laboratory
submission
forms.
IA
The
state
provides
the
guidance
information
that
EPA
has
developed
to
the
systems,
for
them
to
use
in
selecting
their
sampling
sites.

NE
Water
Systems
are
required
to
report
sample
site
characteristics.
These
include:
Site
location,
type
of
building,
age
and
content
of
plumbing
materials
present,
and
the
specific
tap
used
for
sampling.
This
data
is
reviewed
individually
for
each
round
of
samples
collected
by
each
water
system.
We
investigate
only
when
this
information
is
inappropriate,
missing,
unusual,
or
suspicious.

MO
Systems
are
required
to
fill
out
a
chain­
of­
custody
form
before
returning
completed
samples
to
DNR's
laboratory.
Sample
site
is
listed
on
laboratory
result
reports.
Each
report
is
reviewed
as
Drinking
Water
Branch
personnel
receive
it.
If
sample
sites
are
ambiguous
or
suspicious
this
is
reported
to
the
monitoring
coordinator
who
calls
the
system
operator
for
clarification.
If
there
is
a
problem
with
sampling
sites
the
system
may
be
required
to
re­
sample.

KS
Prior
to
initial
sampling,
systems
are
required
to
submit
a
lead
and
copper
sampling
plan
which
list
the
type
of
structure
(
e.
g.,
tier
level),
location
address,
contact
person,
phone,

home
plumbing
materials,
and
if
the
structure
is
served
by
a
lead
service
line.
In
addition,

each
system
is
required
to
submit
a
material
survey
which
list
the
type
of
interior
plumbing
and
the
type
of
service
lines.
The
sampling
plan
and
material
survey
are
reviewed
by
staff
members
and
placed
in
the
systems
file
for
future
reference.
During
subsequent
sampling
rounds,
each
system
required
to
monitor
is
mailed
a
letter
in
which
the
system
is
notified
of
the
sampling
period
schedule,
number
of
samples
to
be
collected,
and
advised
to
collect
samples
from
the
same
sites
used
during
the
last
sampling
period.
CO
The
State
is
able
to
ensure
that
a
lead
and
copper
sampling
event
is
valid
and
in
compliance
with
the
regulations
by
requiring
that
several
types
of
forms
be
completed
when
a
sampling
event
occurs,
as
described
below:
When
a
newly
activated
water
system
first
performs
its
initial
sampling
(
two
consecutive
six­
month
periods
of
sampling)
it
is
required
to
complete
a
"
Material
Survey
Report/
Sample
Site
Justification
Form".
This
forms
aids
the
system
in
establishing
a
sampling
pool
which
will
consist
of
homes
and
buildings
with
the
highest
tier
level
possible.
It
directs
the
system
in
a
tutorial
manner
to
look
at
the
targeted
sites
specified
in
the
lead
and
copper
regulation
(
there
are
two
form
types:
community
and
noncommunity
non­
transient.)
Based
on
the
completed
material
survey
form,
the
system
establishes
a
sampling
pool.
At
every
sampling
event
the
systems
are
required
to
complete
a
"
Sampling
Pool
For
Lead
And
Copper
Tap
Water
Samples".

CO
(
cont)
This
form
allows
the
State
to
track
whether
or
not
the
system
is
sampling
the
same
sites
and
to
assess
the
tier
levels
on
an
on­
going
basis.
If
a
system
changes
a
sampling
site,
it
is
required
to
complete
a
"
Sampling
Site
Change
Form".
This
form
allows
the
State
to
ascertain
whether
or
not
a
replacement
site
is
at
the
appropriate
tier
level.
A
"
Sample
Results
and
Collection
Method
Certification
Form"
is
also
required
to
be
completed.
This
requires
that
an
authorized
entity
of
the
public
water
system
certifies
that
sampling
protocols
were
followed
(
note
­
this
form
requires
an
entry
of
the
90th
percentile
calculation,
however
the
State
calculates
this
upon
receipt
and
review
of
the
lab
data).

A"
Homeowner
Certification
and
Instructions
for
Tap
Sample
Collection"
form
is
provided
to
the
systems
to
be
distributed
to
the
homeowners
performing
lead
and
copper
tap
water
monitoring.
This
form
gives
sampling
protocol
instructions
and
serves
as
a
certification
of
proper
performance.
CO
(
cont)
The
State
requires
each
public
water
system
to
complete
and
submit
the
above­
mentioned
forms
along
with
the
lab
results
for
each
lead
and
copper
sampling
event.
Upon
receipt
the
Lead
and
Copper
Rule
Manager
of
the
Compliance
Assurance
and
Data
Management
reviews
all
paper
work
submitted
and
after
determining
whether
the
system
has
sampled
at
the
appropriate
sites
and
followed
the
appropriate
protocol
calculates
the
90th
percentile.

This
90th
percentile
data
is
then
entered
into
the
SDWIS
database.
The
State
is
currently
in
the
process
of
entering
site
information
into
SDWIS
for
further
improvement
on
tracking
capabilities.

MT
As
the
vast
majority
of
our
systems
were
in
existence
when
the
LC
rule
came
into
effect,

that
verification
was
done
at
the
time
of
initial
sampling.
The
state
currently
relies
on
the
system
certified
operator
to
complete
the
"
Change
in
Sampling
Location
Form"
if
a
sample
site
has
been
changed.

ND
We
do
not
go
through
every
sample
result
to
verify
that
it
was
collected
at
a
Tier
1
site.

Most
systems
in
ND
(
e.
g.
smaller
towns)
do
not
have
any
Tier
1
sample
sites.
Larger
systems
generally
have
all
Tier
1
sites,
and
these
systems
on
reduced
monitoring
are
checked
to
see
if
half
of
the
samples
were
collected
at
sites
with
lead
service
lines.
When
the
sample
plans
were
initially
set
up
for
the
LCR,
the
systems
were
sent
information
to
determine
how
to
select
Tier
1
sites
(
through
material
evaluations,
researching
city
plans,

discussions
with
local
plumbers
and
engineers,
etc.).
We
do
not
require
any
updating
of
sampling
plans,
unless
there
needs
to
be
a
change
in
the
sample
plan.
When
a
system
needs
to
change
a
sample
site,
we
require
the
system
to
notify
us
in
writing
of
the
old
address
and
the
new
address
and
why
the
change
is
necessary.
Changes
in
the
sample
plan
are
allowed
only
for
the
following
reasons:
site
is
no
longer
available,
household
installs
a
treatment
device
or
system
is
not
able
to
obtain
a
sample
from
a
site.

SD
South
Dakota
requires
the
system
to
submit
a
material
evaluation
sheet
with
their
proposed
site
plan.
The
system
is
required
to
prioritize
their
site
plan
so
that
it
is
made
up
of
Tier
1
sites
first
followed
by
lower
risk
sites
(
Tier
3)
if
there
are
not
enough
Tier
1
sites.
Systems
are
only
allowed
to
collect
samples
from
their
approved
site
plan.
We
have
each
system's
site
plan
in
our
database
and
when
the
results
come
from
the
lab,
the
results
for
each
site
are
entered
into
the
corresponding
site
in
our
database.
UT
Water
Systems
are
directed
to
select
Lead/
Copper
sampling
sights
as
specified
by
Utah
rule
R309­
210­
6(
3).
A
review
of
an
individual
water
system's
Lead/
Copper
Sampling
Site
Plan
occurs
during
the
Sanitary
Survey.

WY
Region
8
follows
the
reporting
requirements
for
site
selection
listed
in
CFR
141.90
(
a).

Since
the
regulations
do
not
require
a
new
water
system
to
submit
a
list
of
selected
sites,

Region
8
only
reviews
changes
in
site
locations
and
locations
that
a
system
requests
to
have
invalidated.
Region
8
reviews
documentation
explaining
why
sampling
sites
have
changed
when
a
Wyoming
water
system
chooses
I
to
inform
us.
Many
Wyoming
water
systems
are
not
aware
of
this
requirement
and
change
sites
without
providing
an
explanation.

Amer.

Sam
ASEPA
provided
ASPA
with
EPA
guidance
on
site
selection
and
reviewed
sampling
plans
for
compliance
with
the
guidance.

AZ
Required
signed
sampling
plan
from
systems
prior
to
commencement
of
sampling
until
federal
rule
was
modified.

CA
Documentation
is
reviewed
when
necessary
by
field
staff.
Water
systems
are
expected
to
follow
requirements
pursuant
to
40
CFR
141.86.
We
do
not
verify
that
sampling
was
correctly
followed
at
site
locations.
Such
an
activity
is
beyond
our
resource
capabilities.

HI
The
State
relied
on
the
water
system's
evaluation
on
which
homes
or
buildings
qualified
for
the
Tier
1,
Tier
2,
or
Tier
3
category.
The
AWWA
Hawaii
Section
provided
training
to
water
system
personnel
on
the
Tier
1,
Tier
2,
and
Tier
3
selection
criteria.
The
State
did
not
perform
an
independent
check
to
assure
that
the
criteria
was
correctly
followed.

NV
We
require
the
"
Sample
Site
Justification
Method
Certification"
(
Form
141­
A(
rev))
to
be
submitted
by
the
system
with
the
sampling
results.
We
review
the
list
of
sites
sampled
for
each
round
of
monitoring.
Navajo
The
Navajo
Nation
Primary
Drinking
Water
Regulations
("
NNPDWR")
define
the
locations
of
required
sampling.
A
site
sampling
plan
needs
to
be
drafted
by
the
owner/
operator
of
the
public
water
system
and
be
submitted
to
the
Navajo
Nation
Public
Water
Systems
Supervision
Program
("
PWSSP")
for
review
and
approval.
Sample
results
identify
the
location
of
the
sample
and
the
time/
date
of
collection.
A
review
of
the
sampling
plan
and
the
sample
result
are
analyzed
when
reviewing
the
system's
file
and
prior
to
conducting
an
inspection
of
the
public
water
system.
Inspections
are
conducted
on
a
two
year
basis.
Lead/
Copper
sampling
reports
are
generated
and
reviewed
on
a
quarterly
basis.

AK
We
currently
do
not
have
an
SOP
for
requesting
and/
or
reviewing
a
lead
and
copper
site
selection
plan
from
Class
A
PWS.
The
SDWIS/
State
V.
8
data
program
does
not
allow
us
to
enter
individual
data
results
for
lead
&
copper
so
we
are
unable
to
automatically
track
Pb/
Cu
sample
site
locations.
We
discuss
the
site
selection
requirements
with
all
new
operators
and
review
their
selection
prior
to
sampling.
We
do
not
have
a
policy
to
manually
track
changes
in
sampling
sites.

WA
To
follow
the
expectations
of
the
paperwork
reduction
act,
and
the
then
proposed
Minor
revisions
to
the
lead
and
copper
rule
(
LCRMR),
in
1996/
97
Department
of
Health
(
DOH)

stopped
requiring
utilities
to
submit
specific
sample
site
information.
DOH
does
require
a
sample
site
physical
address
or
other
unique
identifier
on
the
lab
sample
sheet.
DOH
expects
water
systems
to
retain
the
specific
paper
work
on
each
sample
site
and
have
it
available
upon
request.
The
state
leaves
this
responsibility
to
the
water
systems
to
fulfill.

DOH
informs
systems
to
collect
samples
from
homes
deemed
more
vulnerable
to
lead
and
copper
corrosion,
which
generally
are
homes
with
copper
pipes
built
between
1982
and
1987.
If
a
system
cannot
find
enough
homes
in
this
category,
the
system
can
use
older
homes
or
homes
with
other
plumbing
materials
to
complete
their
full
sample
set.
If
needed,

DOH
may
evaluate
if
a
system
is
collecting
samples
from
appropriate
locations
by
contacting
the
system
and
reviewing
their
sample
site
selection
information.

ID
Idaho
has
not
developed
a
standard
operating
procedure
for
review
of
documentation
related
to
the
lead
copper
rule
OR
In
the
early
1990s,
OR
shared
EPA's
guidance
with
the
systems,
did
training
and
workshops
for
the
systems.
The
state
required
the
systems
to
submit
the
sampling
plan.

The
state
provided
the
system
with
the
information
that
system
needed
to
conduct
their
own
material
survey.
Describe
the
process
the
state
undertakes
to
determine
if
reduced
monitoring
is
appropriate.
Approximately
what
percentage
of
systems
have
been
placed
on
reduced
monitoring?

What
role
does
the
state
play
in
selecting
the
sites
used
for
reduced
monitoring?
MA
DEP
reviews
monitoring
results
to
determine
if
the
systems
meet
the
lead
and
copper
actions
levels.
Systems
that
meet
the
action
levels
for
two
consecutive
six­
month
monitoring
periods
may
reduce
the
monitoring
frequency
and
the
number
of
sample
sites
in
accordance
with
the
rule.
Systems
that
meet
the
action
levels
for
three
consecutive
years
of
monitoring
may
reduce
the
frequency
to
once
every
three
years.
DEP
must
approve
all
plans
for
reduced
monitoring
including
selecting
the
sites
to
be
used.
78
%
of
the
systems
in
Massachusetts
(
411
COM
and
193
NTNC)
are
on
reduced
monitoring.

ME
The
State
reviews
the
141­
A
Form
and
the
sample
results
to
ensure
the
90
th
percentile
is
calculated
correctly.
Once
the
State
determines
that
the
water
system
has
passed
2
consecutive
rounds
the
water
system
is
placed
on
reduced
monitoring
and
mailed
a
letter
informing
them
they
are
on
reduced
monitoring.
About
90%
of
the
water
systems
are
on
reduced
monitoring.
A
tier
group
review
is
conducted
when
the
sample
results
are
submitted.
The
State
reviews
the
reduced
monitoring
site
selection
to
ensure
the
water
system
uses
the
higher
risk
tier
sites.
Water
systems
need
to
submit
in
writing
the
reason
a
sample
site
is
no
longer
available
e.
g.
when
a
water
system
customer
no
longer
wishes
to
participate
in
the
monitoring
effort.
RI
System
is
eligible
for
reduced
monitoring
upon
completion
of
two
consecutive
six
month
rounds
of
sampling
showing
results
less
than
or
equal
to
action
levels.
70%.
Approves
sampling
plans
according
to
tier
criteria.

VT
VT
reviews
the
90th
percentile
results
to
ensure
they
meet
the
action
levels
and
the
system
has
completed
the
required
monitoring
to
qualify
for
reduced
monitoring.
The
state
considers
their
previous
test
results
and
reviews
the
system's
proposal
for
reduced
monioring
and
in
most
cases
the
water
syatems
alternate
the
original
sites
each
compliance
period.
Of
the
systems
required
to
do
monitoring,
88%
are
monitoring
every
3
years.

NH
The
WSEB
database
automatically
advances
systems
to
their
next
round
after
calculation
of
their
90
th
percentile.
Approximately
95%
at
one
time
or
another.
The
WSEB
designates
odd
or
even
numbered
sites
depending
on
the
system's
round
number.

CT
The
CTDPH
 
DWD
almost
exclusively
uses
the
same
sections
within
the
B102
regulations
as
the
40
CFR
141.86(
d)(
4)(
i)
and
(
iii)
for
tap
water
lead
and
copper
monitoring
reductions.
Simply,
if
a
PWS
meets
the
lead
and
copper
Action
Levels
(
ALs)
during
two
consecutive
six
month
monitoring
periods,
they
are
reduced
to
annual
monitoring
at
the
reduced
number
of
sites;
if
a
Public
Water
System
meets
the
lead
and
copper
ALs
during
three
consecutive
annual
monitoring
periods,
they
are
reduced
to
triennial
monitoring.

Approximately
85%
of
all
Community
Public
Water
Systems
and
Non­
Transient
Non­

Community
Public
Water
Systems
have
been
placed
on
reduced
monitoring.
Any
PWS
on
reduced
monitoring
is
required
to
use
sample
site
locations
from
the
aforementioned
approved
Sample
Site
Plan
while
complying
with
the
regulations
regarding
the
"
tiered"

sample
site
location
format
and
representing
the
distribution
system
as
a
whole.
NY
Determinations
for
reduced
monitoring
are
made
by
local
health
offices
based
on
data
provided
by
the
purveyor
and
pursuant
to
the
criteria
set
forth
in
state
and
federal
regulations.
10NYCRR
Part
5­
1.42
mirrors
federal
requirements
for
reduced
monitoring
frequencies
(
annual
or
every
third
year)
and
reduced
sampling
sites.
Local
health
offices
evaluate
each
system's
lead
and
copper
results
and
make
system
specific
determinations
regarding
reduced
monitoring
and
the
possible
return
to
standard
6
month
monitoring
if
reduced
monitoring
results
show
exceedance
of
action
levels.
A
large
majority
of
water
systems
in
New
York
State
are
on
reduced
monitoring.
SDWIS
data
is
not
sufficient
to
quantify
these
systems,
but
our
estimate
is
that
more
than
90%
of
systems
are
on
reduced
monitoring
as
result
of
good
sampling
results.

NJ
For
large
water
systems:
The
water
system
must
meet
the
optimal
water
quality
control
parameters
set
by
the
State
for
two
consecutive
6­
month
periods
and,
The
water
system
must
meet
the
Lead
and
Copper
action
levels
in
two
consecutive
6­
month
periods.
For
small
and
medium­
sized,
they
must
meet
Lead
and
Copper
action
levels
in
two
consecutive
6
 
month
periods.
Ninety­
seven
percent.
The
State
checks
and
approves
the
monitoring
plan.
Usually
the
system
selects
either
all
the
odd
numbered
or
even
numbered
sites
from
their
last
round
of
monitoring
when
it
is
put
into
decreasing
order
of
analyte
concentration.

Very
few
times,
the
State
has
intervened
in
selecting
the
sites
used
for
reduced
monitoring.

The
few
occasions
are
in
perceptible
drop
of
90
th
percentile
levels
when
standard
and
reduced
monitoring
are
compared.
MD
Small
and
medium
systems
with
lead
and
copper
90
th
percentile
values
less
than
the
lead
and
copper
Action
Levels
for
two
consecutive
six­
month
monitoring
periods
are
eligible
for
reduced
monitoring
(
annual)
under
the
LCR.
As
allowed
in
the
LCRMR
regulations,
any
system
with
very
low
lead
and
copper
90
th
percentile
values
(
less
than
or
equal
to
0.005
mg/
L
for
lead
and
0.65
mg/
L
for
copper);
are
reduced
to
triennial
monitoring
when
two
consecutive
six­
month
monitoring
periods
are
completed.
Currently
814
water
systems
are
on
reduced
monitoring
frequencies.
In
addition
6
systems
have
been
place
on
the
9­
year
sample
frequency
based
on
their
system
construction
and
water
quality.
Maryland
advises
water
systems
on
reduced
monitoring
to
randomly
select
sites
from
their
original
sample
pool.

DE
We
will
review
sample
results
when
they
are
submitted
and
make
a
determination
on
whether
the
system
is
eligible
for
reduced
monitoring.
Approximately
75%
of
systems
are
on
reduced
monitoring.
We
leave
it
up
to
the
system
to
determine
the
sites
used
for
reduced
monitoring.

WV
A
review
of
the
90
th
percentile
results
for
the
last
two
consecutive
six
month
monitoring
periods
is
made,
and
if
both
lead
and
copper
90
th
percentile
levels
are
below
the
Action
Level,
the
system
is
placed
on
reduced
monitoring.
Without
actually
performing
a
calculation
and
reviewing
the
monitoring
schedules,
an
estimate
of
90%
+
of
all
systems
are
on
reduced
monitoring.
WV
plays
no
role
in
selecting
the
sites
used
for
reduced
monitoring,
other
than
through
the
lead
and
copper
packet
that
is
given
to
the
system
when
initiating
monitoring,
which
does
inform
the
system
that
tier
1
sites
are
to
be
used
for
all
sample
sites
when
that
is
possible.
There
has
been
no
follow
up
by
WV
on
updating
of
sample
sites
since
initial
implementation.

PA
PA
DEP
grants
reduced
monitoring
as
per
§
109.1103.
According
to
PADWIS,

approximately
89%
of
our
systems
are
on
reduced
monitoring
(
222
systems
are
on
annual
monitoring,
2,777
systems
are
on
triennial
monitoring).
Water
suppliers
are
responsible
for
selecting
appropriate
sites
for
reduced
monitoring.
These
sites
must
be
selected
from
the
sampling
pool
that's
identified
in
the
Sampling
Plan.
See
item
#
1
for
an
explanation
of
PA
DEP's
over­
site
role.
VA
A
waterworks
is
allowed
to
reduce
lead
and
copper
tap
monitoring
based
upon
the
results
of
tap
monitoring
or
Water
Quality
Parameter
monitoring,
as
appropriate.
If
a
waterworks
has
lead
and
copper
90
th
percentile
concentrations
that
are
below
the
Action
Levels
during
two
six­
month
monitoring
periods,
we
allow
monitoring
to
be
reduced
to
annually
at
the
prescribed
reduced
number
of
sites.
After
two
additional
years
of
annual
reduced
monitoring
(
with
results
still
below
the
Action
Levels),
we
allow
the
waterworks
to
further
reduce
monitoring
to
once
per
three
years.
For
large
waterworks
(
serving
>
50,000
population)
or
small
or
medium
waterworks
required
to
install
corrosion
control
treatment,

we
use
the
results
of
Water
Quality
Parameter
monitoring
to
establish
reduced
monitoring
(
i.
e.,
the
waterworks
must
maintain
the
established
range
of
values
for
the
Water
Quality
Parameters
reflecting
optimal
corrosion
control
treatment).

VA
(
cont.)
We
also
allow
the
accelerated
reduced
monitoring
criteria
contained
in
the
Lead
and
Copper
Rule
Minor
Revisions
(
LCRMR).
Waterworks
may
proceed
directly
to
ultimate
reduced
monitoring
(
once
per
three
years
at
the
prescribed
reduced
number
of
sites)
if
the
90
th
percentile
lead
concentration
is
less
than
or
equal
to
0.005
mg/
L
and
the
90
th
percentile
copper
concentration
is
less
than
or
equal
to
0.65
mg/
L
for
two
consecutive
six­
month
monitoring
periods.
Approximately
90%
are
currently
in
reduced
monitoring.
We
typically
do
not
select
specific
sites
to
be
used
in
reduced
monitoring.
Our
Waterworks
Regulations
require
that
sites
used
in
reduced
monitoring
be
representative
of
sites
identified
in
the
original
materials
survey.
FL
An
electronic
file
review
is
conducted
at
the
conclusion
of
each
sampling
period,
including
initial,
standard,
and
reduced
monitoring
periods,
to
determine
a
system's
eligibility
for
reduced
monitoring
and
whether
that
monitoring
should
be
annual
or
triennial.
The
system
is
informed
in
writing
of
their
eligibility
status.
If
the
system
desires
a
move
to
reduced
monitoring,
a
form
is
completed
and
returned,
along
with
the
minimum
number
of
sites
representative
of
those
locations
exhibiting
the
highest
lead
levels
during
the
most
recent
sampling
event.
The
selected
sites
are
audited
to
determine
if,
in
fact,
these
sites
are
the
most
likely
to
yield
lead
contamination
based
on
historical
sample
results
from
a
particular
system.
Approximately
95
to
97%
of
our
systems
have
qualified
for
reduced
lead/
copper
monitoring.

KY
Kentucky
Drinking
Water
Branch
staff
makes
the
determination
on
whether
a
system
may
reduce
lead
and
copper
monitoring
after
the
results
of
two
(
2)
consecutive
6­
month
sampling
periods
have
revealed
no
action
level
exceedances.
Approximately
98%
of
water
systems
in
Kentucky
have
been
placed
on
reduced
monitoring.
The
selection
of
sites
used
for
reduced
monitoring
was
left
to
the
water
systems'
discretion.

MS
The
state
uses
the
federal
guidelines
for
determining
whether
or
not
a
system
may
be
placed
on
reduced
monitoring.
They
must
have
two
consecutive
six
month
rounds
of
sampling
below
the
action
level
for
lead/
copper
before
reducing
to
annual
sampling.
Reduced
monitoring
to
once
every
three
years
must
be
preceded
by
3
consecutive
annual
rounds
under
the
action
level.
The
state
is
in
the
process
of
reviewing
all
PWS
monitoring
data
to
determining
whether
or
not
systems
are
on
the
correct
monitoring
schedule
based
on
sampling
history
and
results.
Based
on
our
review
to
date,
approximately
85%
of
public
water
supplies
in
MS
are
on
reduced
monitoring.
The
state
requests
that
systems
utilize
all
Tier
1
sites
identified
on
the
Lead
and
Copper
Sample
Site
Plans
submitted
to
and
approved
by
the
state.
If
a
system
cannot
collect
samples
from
all
Tier
1
sites,
they
are
to
complete
sampling
with
Tier
2
and
then
Tier
3
sites
in
order
to
collect
the
correct
number
of
samples
based
upon
population
served.
NC
Upon
receipt
of
a
written,
verbal
or
e­
mail
request
for
reduced
monitoring
from
the
water
system,
the
rule
manager
performs
a
review
of
sampling
results
to
ensure
that
the
water
system
has
met
the
requirements
for
reduced
monitoring.
The
rule
manager
approves
or
disapproves
the
request,
in
writing,
based
upon
the
results
of
the
sampling.
In
addition,

monitoring
frequency
requirements
for
each
water
system
are
available
for
review
by
the
systems
on
the
PWSS
web
site.
Future
programming
efforts
may
include
mass
approval
of
reduced
monitoring
upon
data
review
of
sampling
results
at
the
end
of
each
sampling
cycle.

Currently,
approximately
91.5%
of
water
systems
subject
to
the
LCR
are
on
a
reduced
monitoring
schedule.
Currently,
the
water
systems
determine
the
sites
to
be
used
for
sampling
during
reduced
monitoring
from
their
sample
siting
plans
without
any
specific
input
from
the
state.
In
the
future,
PWSS
may
specify
sites
to
be
used
for
sampling
during
reduced
monitoring
based
on
the
history
of
past
monitoring
results.

AL
Small
and
medium
systems
that
meet
the
action
levels
and
large
systems
that
meet
the
action
levels
and
meet
the
optimal
corrosion
control
guidelines.
99%
We
provide
guidance
that
systems
use
sites
from
original
sites
starting
with
Tier
one
sites.

SC
Water
systems
are
placed
on
reduced
monitoring
when
they
complete
two
(
2)
consecutive,

6­
month
periods
of
monitoring
and
if
the
90
th
percentiles
are
below
the
action
levels.

Ninety­
two
(
92)
percent
of
the
SC's
water
systems
are
on
reduced
monitoring.
When
moving
to
a
reduced
monitoring
schedule,
water
systems
are
advised
to
retain
all
sites
that
previously
exceeded
action
levels
to
be
included
as
reduced
monitoring
sites.
The
Department
has
assisted
water
systems
in
the
selection
of
reduced
monitoring
sites.

TN
Reduced
monitoring
is
warranted
only
if
each
of
two
consecutive
six­
month
monitoring
periods
yields
90th
percentiles
meeting
the
action
levels.
98
%
of
the
applicable
systems
are
conducting
reduced
monitoring.
The
state
instructs
the
water
system
to
select
from
the
pool
of
sites
originally
designated
as
the
highest
risk
as
defined
by
the
tier
designation.

GA
Approx.
93%.
None.
IN
If
a
system
has
completed
two
6­
month
rounds
of
consecutive
sampling
below
both
the
lead
and
copper
action
levels,
a
letter
is
sent
reducing
the
system
=
s
frequency
to
annual
for
a
minimum
of
three
years.
At
the
end
of
the
third
year
if
the
system
has
continued
to
meet
the
action
levels
another
letter
is
sent
reducing
the
systems
to
once
every
three
years.
A
system
is
not
reduced
beyond
once
every
three
years
as
specified
by
the
rule.

Approximately
87%
of
active
systems
are
currently
on
reduced
monitoring.
The
State
currently
does
not
play
an
active
role
in
selecting
the
reduced
sampling
sites,
systems
are
expected
to
choose
sites
representative
of
all
the
water
throughout
the
distribution
system.

MN
For
systems
without
exceedance:
According
to
the
LCR
­
meeting
action
levels
for
two
consecutive
6­
month
rounds,
proceed
to
reduced
annual;
meeting
the
action
levels
for
3
years
in
a
row,
proceed
to
reduced
triennial
monitoring.
Also
use
the
accelerated
reduced
procedure
in
recent
years.
For
systems
with
OCCT:
Similar
process
as
above
applies.

However,
since
meeting
the
copper
action
level
after
OCCT
continues
to
be
a
challenge
with
the
groundwater
characteristics
(
high
DIC)
in
Minnesota,
systems
may
be
allowed
to
proceed
to
reduced
monitoring
if
operating
within
OWQPs
or
continued
to
be
deemed
to
have
optimized
treatment.
About
90%
of
the
systems
are
placed
on
reduced
monitoring.

Prior
to
proceeding
to
annual
monitoring,
systems
were
instructed
to
divide
the
sample
pool
into
two
groups,
each
group
will
be
targeted
alternately
in
subsequent
monitoring
events.

OH
Rule
3745­
81­
86
(
D)(
4)
of
the
Ohio
Administrative
Code
describes
the
process
used
to
determine
if
reduced
monitoring
is
appropriate
and
is
analogous
to
paragraph
(
d)(
4)
of
40
CFR
141.86.
It
is
estimated
that
approximately
75%
of
the
systems
have
been
placed
on
reduced
monitoring.
Selection
of
sites
used
for
reduced
monitoring
is
described
in
the
instructions
provided
systems
to
prepare
Ohio
EPA
forms
5105
"
Drinking
Water
Lead
and
Copper
Monitoring
Report",
5106
"
Lead
Tap
Monitoring
Report",
and
5107
"
Copper
Tap
Monitoring
Report".
Cites
their
regulations.
WI
We
query
the
PWS
data
system
to
identify
systems
that
have
completed
2
consecutive
rounds
of
samples
during
6
months,
or
3
consecutive
annual
samples
to
qualify
for
reduced
monitoring.
Approximately
80%
of
the
systems
are
on
reduced
monitoring.
We
ask
systems
on
reduced
monitoring
to
select
every
other
site
from
their
list
of
ranked
lead/
copper
sample
locations.

MI
The
DEQ
allows
reduced
monitoring
after
the
90
th
percentile
from
both
of
two
rounds
of
full
sampling
meet
both
action
levels.
Almost
all
systems
that
qualified
for
reduced
monitoring
were
allowed
to
do
so.
After
each
round
of
sampling,
the
DEQ
notifies
the
supply,
in
writing,
of
their
next
lead
and
copper
monitoring
requirement,
which
reflects
reduced
monitoring,
if
appropriate.
Attached
is
the
template
of
the
letter
and
report
form,

Lead
 
90
th
Letter
and
Report
Form.
pdf.
The
only
time
reduced
monitoring
may
not
have
been
applied
is
in
consecutive
systems,
where
modified
sampling
arrangements
may
have
reduced
the
number
of
samples
initially
required
in
certain
customer
supplies.
If
the
number
of
samples
required
initially
is
less
than
the
number
of
samples
allowed
under
reduced
monitoring
tables,
then
no
further
reduction
in
the
number
of
samples
was
granted
to
these
customer
systems
 
only
a
reduced
frequency.

IL
SDWIS/
State
calculates
and
maintains
sample
summaries.
For
water
systems
on
a
sixmonth
monitoring
frequency,
at
the
end
of
the
six­
month
monitoring
period,
sample
summaries
are
reviewed
and
if
the
water
system
has
two
consecutive
monitoring
periods
below
the
action
levels,
the
system
is
reduced
to
annual
monitoring.
For
water
systems
on
annual
monitoring,
we
review
that
the
last
three
years
of
sample
summaries
to
determine
(
three
years
below
ALs)
if
the
water
system
qualifies
for
triennial
monitoring.

AR
If
they
meet
conditions
of
141.86
then
they
go
on
reduced
monitoring.
95%
Systems
are
required
to
use
same
sampling
procedure
as
for
routine
monitoring.
LA
Upon
review
of
the
Lead
and
Copper
Rule
results,
the
State
notifies
the
systems
as
to
the
date
of
their
next
sampling
event.
The
criteria
used
to
determine
if
a
system
should
move
to
reduced
monitoring
is
as
follows:
If
system
has
conducted
biannual
monitoring
and
results
are
less
than
½
of
the
Action
Levels,
then
the
State
gives
notice
that
the
system
should
conduct
reduced
monitoring
on
a
triennial
basis.
If
the
results
are
less
than
the
Action
Levels
but
greater
than
½
of
the
Action
Levels,
then
the
systems
are
given
notice
that
reduced
annual
monitoring
should
be
conducted
for
2
years
before
being
considered
for
triennial
monitoring.

NM
No
answer.
Unknown.
None.

OK
LCR
Coordinator
evaluates
on
case­
by­
case
basis
and
at
request
of
system;
~
70%;
system
must
use
top
half
of
Location
Codes,
which
are
usually
Tier
1'
s.

TX
TCEQ
maintains
a
sampling
schedule
for
all
systems
in
the
program,
and
sends
a
letter
to
notify
systems
of
the
schedule
before
the
actual
sampling
of
their
schedule.
Approximately
90%
of
the
systems
are
on
reduced
monitoring
as
triennial,
annual,
or
noniennial.

IA
The
sampling
history
and
90%
percentiles
for
copper
and
lead
are
reviewed
by
state
staff.

If
eligible
for
reduced
monitoring
(
annual
or
triennial),
the
system
is
issued
a
new
operation
permit
that
lists
its
new
sampling
requirement.
In
Iowa,
we
have
1,157
CWS
and
NTNC
systems
on
reduced
triennial
monitoring
at
this
time
(
or
90.2%
of
the
total
1,283
NTNC
and
CWS
systems
required
to
comply
with
the
lead
&
copper
rule).
We
developed
the
site
selection
procedure
which
was
approved
by
EPA
years
ago,
and
provide
that
to
the
systems
for
their
use
in
selecting
sites
for
reduced
monitoring.
In
short,
they
are
to
select
every
other
site
from
their
last
sampling
when
ranked
according
to
lead
levels.

NE
Systems
are
placed
on
reduced
monitoring
based
solely
on
the
frequency
and
results
of
prior
monitoring
as
specified
in
the
Lead
&
Copper
Rule.
As
of
2004,
approximately
97%

of
Nebraska
water
systems
are
on
reduced
monitoring.
Sites
used
for
reduced
monitoring
must
meet
the
site
selection
criteria,
and
we
ask
water
systems
to
continue
using
prior
sites
as
long
as
they
remain
available
and
appropriate.
Systems
may
choose
the
sites
used
for
reduced
monitoring
from
their
larger
pool
of
original
sampling
sites.
MO
If
the
first
two
rounds
are
completed
without
exceeding
action
levels
all
systems
are
placed
on
reduced
monitoring.
Any
small
system
classified
as
a
mobile
home
park
or
subdivision
with
lead
levels
at
the
90th
percentile
below
5
ppb
for
lead
or
650
ppb
for
copper
and
completes
a
survey
certifying
the
system
is
lead
free
may
be
placed
on
a
9
year
monitoring
schedule.
98%
of
all
systems
in
Missouri
are
on
reduced
monitoring.

KS
Once
a
system
completes
two
consecutive
six­
month
sampling
periods
without
exceeding
the
lead
or
copper
action
levels
they
are
placed
on
reduced
monitoring.
The
frequency
of
sampling
is
reduced
to
once
per
year
during
June
through
September,
and
the
number
of
samples
reduced
by
one
half.
Systems
collecting
five
samples
do
not
have
the
number
of
samples
reduced.
Approximately
98
percent
of
systems
are
in
reduced
monitoring.
The
2
percent
not
in
reduced
monitoring
includes
systems
that
have
been
placed
on
reduced
monitoring
but
exceeded
one
of
the
action
levels
during
reduced
monitoring.
Systems
placed
on
reduced
monitoring
are
advised
to
sample
the
same
sites
used
during
initial
sampling,
using
all
the
tier
1
sites
available
first,
then
include
the
tier
2
sites,
then
the
tier
3
sites
until
the
required
number
of
sites
are
completed.

CO
CO
follows
reduction
in
monitoring
frequency
as
specified
in
40
CFR
141.86(
d)(
4)(
i)
­

141.86(
d)(
4)(
iii).
CO
automatically
advances
a
system
along
this
gradient
of
reducing
monitoring
schedules
depending
upon
evidence
of
data
received
and
the
sampling
schedule
completed
successfully.
We
do
not
automatically
advance
a
system
from
a
six­
month
schedule
to
a
triennial
schedule
as
described
in
40
CFR
141.86(
d)(
4)(
v).
Although
this
has
been
adopted
into
the
CO
Primary
DW
Regs
it
is
not
applied
in
the
State's
current
standard
policy
on
reducing
lead
and
copper
tap
water
monitoring
schedules.
To
date,
CO
has
not
been
directly
involved
with
determining
site
selection
for
a
reduced
monitoring
schedule.

At
this
time,
the
State
is
in
the
process
of
notifying
systems
currently
on
reduced
monitoring
schedules
to
review
the
original
sampling
pool
&
affirm
that
they
have
selected
the
highest
risk
sites.
The
highest
risk
site
would
be
determined
by
two
criteria:
the
information
from
the
material
survey
and
historical
sampling
data.
CO
(
cont)
In
the
future,
the
State
will
notify
systems
that
are
moving
from
a
6
month
schedule
to
a
reduced
monitoring
schedule
of
the
requirement
to
select
the
highest
risk
sites
from
the
original
sampling
pool
when
reducing
the
site
number.
For
the
years
2002
and
2003
of
the
current
monitoring
period
(
2002­
2004),
approximately
67%
of
the
systems
were
on
a
triennial
schedule,
21%
were
on
an
annual
schedule
and
13%
were
on
a
6
month
schedule
(
either
initial
or
follow­
up
sampling).

MT
The
way
the
federal
rule
is
written,
the
"
system"
may
reduce
if
the
initial
sample
90%

results
are
less
than
the
action
level
in
2
consecutive
6­
month
periods.
An
estimated
80%
of
our
systems
are
on
reduced
monitoring.
The
systems
are
required
to
meet
the
requirements
of
our
rules,
that
adopt
by
reference
the
federal
requirements.

ND
It
is
up
to
the
system
which
sites
are
to
be
used
when
they
are
on
reduced
monitoring,
as
long
as
the
sites
are
on
their
sample
plan.
The
only
exception
is
those
systems
with
Tier
1
sites;
half
of
the
samples
must
be
from
sites
with
lead
service
lines
and
the
other
half
Tier
1
sites
that
have
copper
pipe
with
lead
solder
in
the
home.
We
do
not
use
previous
sample
results
as
criteria
for
sample
sites
for
systems
on
reduced
monitoring.
We
encourage
systems
to
rotate
through
their
sample
sites
on
reduced
monitoring
(
although
not
required
by
the
Lead­
Copper
Rule),
rather
than
always
sample
from
the
same
sites.
Water
Quality
Parameter
monitoring
results
are
not
used
to
make
reduced
monitoring
decisions.

SD
If
a
system's
90
th
percentile
level
for
both
of
the
first
two
consecutive
rounds
of
routine
sampling
are
less
than
the
action
level,
they
may
be
moved
to
reduced
annual
monitoring.

If
they
are
less
than
½
of
both
action
levels
they
are
moved
to
triennial
monitoring.
About
95%
(
466
out
of
491)
are
on
reduced
monitoring.
South
Dakota
plays
a
small
role
in
selecting
reduced
sites.
We
require
the
system
to
remove
sites
with
the
lowest
risk
(
Tier
3)

first.
If
their
site
plan
has
only
Tier
1
sites
and
they
still
need
to
remove
some
sites,
the
system
has
the
freedom
to
choose
these
sites,
but
the
plan
must
be
first
made
up
of
sites
with
lead
service
lines
or
lead
pipes
followed
by
other
Tier
1
sites.
UT
If
a
system
meets
the
lead
and
copper
action
levels
during
two
consecutive
six­
month
monitoring
periods,
the
system
may
reduce
monitoring
in
accordance
with
Utah
rule
R309­

210­
6(
3)(
d)(
iv)
to
annual
monitoring.
Then,
if
the
system
continues
to
meet
the
lead
and
copper
action
levels
for
three
rounds
of
annual
monitoring,
the
system
can
further
reduce
monitoring
to
once
every
three
years.
There
are
450
water
systems
that
are
on
a
three­
year
frequency
of
monitoring
for
lead/
copper
which
is
87.55
percent
of
the
affected
systems
in
Utah.

WY
If
a
system
has
just
completed
two
successive
rounds
of
six­
month
monitoring
and
the
90
th
percentile
levels
are
less
than
the
action
levels
of
0.015
mg/
L
and
1.3
mg/
L,
respectively,

but
greater
than
0.005
mg/
L
for
lead
and
greater
than
0.65
mg/
L
for
copper,
the
water
system
is
placed
on
annual
monitoring
(
40CFR
141.86
(
d)(
4)
f
and
the
number
of
samples
required
is
reduced
according
to
population
as
shown
in
40
CFR
141.86
(
c).
When
a
system
has
met
the
lead
and
copper
levels
for
three
consecutive
years
of
monitoring
(
the
two
six­
month
periods
are
included),
the
frequency
of
monitoring
may
be
reduced
from
annually
to
once
every
3
years.
If
a
system
has
just
completed
two
successive
rounds
of
sixmonth
monitoring
and
the
lead
and
copper
90
th
percentile
levels
are
less
than
the
action
levels
of
0.015
mg/
L
and
1.3
mg/
L
WY
(
Cont.)
and
less
than
or
equal
to
0.005
mg/
L
for
lead
and
less
than
or
equal
to
0.65
mg/
L
for
copper,
the
water
system
is
placed
on
once
every
3
years
monitoring
(
40CFR
141.86
(
d)(
4)
f
and
the
number
of
samples
required
is
reduced
according
to
population
as
shown
in
the
table
in
40
CFR
141.86
(
c).
In
Wyoming
approximately
93%
of
the
water
systems
are
on
reduced
monitoring
and
samples.
The
water
systems
select
their
sites
for
reduced
monitoring
from
the
original
pool
of
sites.
Region
8
supplies
input
if
a
water
system
requests
information.

Amer
Sam
ASEPA
follows
the
provisions
for
reduced
monitoring
found
in
Section
141.86(
d)(
4).
No
systems
have
been
placed
on
reduced
monitoring.
Due
to
the
small
number
of
systems
in
American
Samoa,
ASEPA
will
oversee
sampling
plan
revisions
and
site
selection
for
all
systems
implementing
reduced
monitoring.
AZ
Systems
must
request
reduced
monitoring
and
receive
approval
from
Department.

Approximately
90­
95%
have
been
issued
some
level
of
reduced
monitoring
CA
We
follow
the
process
as
described
in
40
CFR
141.86(
d)(
4).
Approximately
95%
to
100%

of
systems
have
been
placed
on
reduced
monitoring.
It
is
our
understanding
that
State's
need
only
to
address
the
approval
process
for
systems
required
to
conduct
water
quality
control
parameter
monitoring,
as
small
and
medium
systems,
which
meet
the
action
level,

can
reduce
their
lead
monitoring
at
the
tap
without
State
approval.
In
either
case,
we
do
not
believe
that
we
are
required
to
play
a
role
in
selecting
the
sites
used
for
reduced
monitoring.

HI
The
State
reviews
the
lead
and
copper
monitoring
data
and
authorizes
each
water
system
in
writing
when
the
reduced
monitoring
provisions
in
the
Lead
and
Copper
Rule
can
be
implemented.
Approximately
99
percent
of
the
systems
are
on
reduced
monitoring.
The
State
allows
the
water
systems
to
select
the
sites
used
for
reduced
monitoring.

NV
The
requirements
of
40CFR
141.86(
d)(
4)
are
adhered
to.
Over
90
percent.
We
require
that
the
sites
be
from
the
list
of
sites
used
for
the
initial
monitoring,
and
be
tier
1
sites
unless
all
tier
1
sites
are
exhausted.

Navajo
Upon
review
of
the
public
water
system's
submission
of
lead/
copper
results,
compliance
with
the
sampling
locations
and
frequency
are
evaluated.
§
710(
D)(
5)
of
the
NNPDWR
(
40
CFR
§
141.86
(
d)(
4))
defines
the
process
for
reduced
monitoring.
The
public
water
system
must
have
not
exceeded
the
action
level
for
two
consecutive
periods
in
order
to
be
eligible
for
reduced
monitoring.
Approximately
38%
are
placed
on
a
reduced
monitoring
schedule.

PWSSP
does
not
select
sites
for
monitoring
or
reduced
monitoring.
PWSSP
requires
the
owner/
operator
of
a
public
water
system
to
develop
a
site
sampling
plan
and
submit
the
plan
to
PWSSP
for
review
and
approval.
AK
We
do
not
have
an
SOP
for
choosing
sites
for
reduced
monitoring.
Reduced
monitoring
is
based
on
fulfillment
of
initial
and
routine
monitoring
requirements,
as
well
as
maintaining
results
below
the
action
levels.
After
two
consecutive
initial
sets
are
completed
the
system
goes
to
annual
routine
sampling
for
two
years
and
then
to
once
every
three
years.
Reduced
monitoring
sites
may
be
at
any
of
the
initial
monitoring
locations
and
are
not
tracked
or
reviewed
unless
a
sampling
problem
arises.
Approximately
51%
of
Class
A
PWSs
are
on
reduced
monitoring
(
once
every
three
years).
If
a
system
has
completed
an
optimal
corrosion
control
(
OCC)
program,
they
are
required
to
begin
with
their
initial
monitoring
requirements
and
then
complete
two
annual
sets
of
sampling
before
they
are
permitted
to
go
to
reduced
monitoring.
WA
DOH
follows
the
LCR
and
LCRMR
criteria
to
determine
if
reduced
and
accelerated
monitoring
options
are
appropriate.
Specifically
DOH
evaluates
the
sample
results
and
applies
the
rule.
Most
water
systems
in
Washington
State
were
able
to
meet
the
requirement
of
seasonal
6­
month
sampling.
However
many
small
systems
had
difficulty
in
meeting
the
letter
of
the
law
in
sampling
in
consecutive
6­
months.
DOH
negotiated
with
EPA
Region
10
to
allow
an
alternative
schedule
to
the
consecutive
6­
month
sample
frequency.
The
benefit
is
that
systems
were
able
to
continue
sampling
and
accomplish
the
seasonality
expectations
of
the
lead
and
copper
rule.
DOH
instructs
systems
to
collect
samples
from
a
subset
of
the
same
locations
as
used
in
initial
monitoring.

ID
Idaho
uses
criteria
established
in
40CFR141.86(
d)
to
determine
eligibility
for
reduced
monitoring.
Over
90%
of
our
community
and
noncommunity
nontransient
water
systems
are
estimated
to
be
on
reduced
monitoring.

OR
OR
followed
the
federal
regulations
for
moving
systems
to
reduced
monitoring.
If
the
system
was
under
the
action
level
for
the
initial
two
6­
month
rounds,
then
the
state
sent
the
system
a
letter
explaining
the
next
steps
and
reduced
monitoring.
The
state
required
the
system
to
use
sites
from
the
original
sampling
pool
and
recommended
using
the
highest
values.
Over
90%
of
the
systems
in
OR
are
on
reduced
monitoring.
Are
systems
that
sample
annually
or
less
frequently
conducting
lead
tap
sampling
during
the
months
of
June,
July,
August,
or
September?
If
the
state
has
designated
alternate
sampling
times,
please
explain
the
basis
for
that
designation?
MA
Systems
that
sample
annually
or
less
frequently
collect
samples
during
June,
July,
August,

or
September.
No
alternative
sampling
times
are
allowed
unless
specifically
approved
by
DEP.

CT
All
Community
Public
Water
Systems
and
Non­
Transient
Public
Water
Systems
on
reduced
monitoring
are
required
to
sample
during
the
months
of
June,
July,
August
and
September.

The
CTDPH
 
DWD
has
not
received
any
requests
to
modify
any
Public
Water
System's
four
consecutive
month
sample
collection
period
nor
is
the
CTDPH
 
DWD
willing
to
accept
any
such
requests
at
this
time.

ME
Yes,
annual
and
triennial
monitoring
is
conducted
during
the
months
of
June,
July,
August
and
September.
However
schools
and
business
that
are
open
seasonally
are
required
to
collect
the
samples
in
one
of
the
4
warmest
months
they
are
open
or
in
session.

NH
Review
of
sampling
history
and
source
water
(
surface
or
ground)
to
try
to
insure,
when
possible,
worst­
case
scenario.
Surface
water
systems
are
sampled
in
the
third
quarter.

RI
Yes.
Due
to
the
use
of
facilities
such
as
schools
(
little
to
no
water
usage
in
summer),

alternate
monitoring
(
October)
may
be
approved.

VT
Yes.
No
other
sampling
times
are
approved
by
the
Division.
WSD
does
not
allow
sampling
across
years
(
June­
August­
Sept­
June.)
NY
NY
State
regulations
10NYCRR
Part
5­
1.42(
c)
codified
the
requirement
that
reduced
monitoring
sampling
occur
during
the
period
from
June
1
to
September
30.
State
regulations
have
not
codified
the
alternate
sampling
period
flexibility
set
forth
in
the
federal
2000
Lead
and
Copper
Rule
Minor
Revisions.
However,
as
a
practical
matter,
the
State
has
adjusted
the
sampling
period
to
match
operational
periods
for
seasonal
systems
that
do
not
operate
in
the
summer.
Local
health
offices
also
allow
and
require
systems
to
sample
at
other
times
if
needed
to
make
up
sampling
missed
during
the
regularly
scheduled
sampling
time.

NJ
Yes 
40
CFR
141.86
(
d)
4
(
iv),
they
are
required
to
test
in
that
period.
Getting
them
all
to
do
that
has
been
difficult.
No
blanket
change
but
on
a
case
by
case
basis
for
some
systems
where
to
the
periods
where
the
highest
levels
of
lead
have
occurred
historically
or
if
the
systems
are
seasonal
operations
not
open
in
those
months.

DE
Yes,
we
require
reduced
monitoring
to
be
conducted
in
the
summer
months.

MD
Public
water
systems
that
sample
annually
or
less
frequently
are
required
to
sample
during
the
months
of
June­
September
of
the
year
that
testing
is
required.

WV
Yes.
Only
one
exception
to
the
summer
month
rule
was
granted
to
a
ski
resort.
Meets
the
definition
of
a
non
transient
system,
and
may
actually
drop
below
25
population
during
the
summer
months
(
has
over
500
population
during
the
winter
months,
with
a
large
number
of
persons
employed
for
six
months
or
longer
)­
only
full
time
employees
are
present
with
a
few
visitors
in
these
four
months.
WV
decided
in
this
case
that
a
different
time
frame
would
be
more
protective
of
public
health.
WV
does
not
allow
sampling
across
years.

PA
Most
of
our
systems
are
sampling
during
the
months
of
June
 
September.
Alternate
sampling
times
may
be
designated
on
a
case­
by­
case
basis.
The
most
common
reason
to
grant
an
alternate
sampling
time
is
when
the
system
isn't
open
during
the
summer
months.
VA
All
waterworks
monitoring
annually
or
less
frequently
are
required
to
collect
lead
and
copper
tap
samples
during
the
months
of
June,
July,
August,
or
September.
The
only
exception
is
non­
transient
non­
community
waterworks
that
do
not
operate
during
those
months.
If
that
situation
should
occur,
we
would
establish
an
alternate
monitoring
period
that
is
representative
of
the
actual
period
of
operation
for
the
waterworks.

AL
Yes.
No
alternate
periods
have
been
designated.

FL
Yes.
On
rare
occasions,
we
do
allow
systems
to
sample
in
May
or
October.
This
is
due
to
the
relatively
warm
temperatures
that
persist
in
the
State
of
Florida
through
the
May
to
October
time
period.
This
action
mainly
benefits
schools
that
are
closed
in
the
summer.

Also,
Florida
has
a
number
of
work
camps,
housing
developments
and
mobile
home
courts
that
cater
to
migrant
workers,
Canadians
and
Europeans
who
return
home
during
the
summer
leaving
the
housing
units
vacant.

KY
Kentucky
water
systems
that
sample
annually
or
less
frequently
are
required
to
conduct
lead
tap
monitoring
during
the
months
of
June,
July,
August
or
September.

MS
Systems
on
reduced
monitoring
are
scheduled
for
collection
of
lead
and
copper
samples
during
the
months
of
June
­
September
only.
The
state
has
not
designated
alternate
sampling
times.

NC
NC
requires
all
annual
or
less
frequent
samples
to
be
collected
between
June
1
and
September
30.
The
monitoring
status
and
sampling
schedule
for
each
water
system
is
available
on
the
PWSS
web
site.
The
web
site
shows
the
monitoring
schedule
for
all
contaminants
for
each
water
system.
Information
shown
includes
the
contaminant
requiring
sampling,
the
last
sample
date,
the
next
sample
date,
and
the
monitoring
frequency.
The
information
on
the
web
site
clearly
indicates
that
annual
and
less
frequent
sampling
for
lead
and
copper
must
be
accomplished
during
the
time
period
between
June
1
and
September
30.
The
state
has
not
designated
an
alternate
sampling
period.

SC
Yes,
all
annual
and
triennial
monitoring
is
conducted
June
1
 
September
30.
No
alternate
sampling
times
have
been
designated.

TN
Yes.

GA
Yes.
There
are
no
alternate
sampling
periods
in
the
State
of
Georgia
at
this
time.
MI
All
supplies
that
sample
annually
or
less
frequently
are
scheduled
to
do
so
in
June,
July,

August,
or
September.
With
the
adoption
of
the
LCR
Minor
Revisions,
Michigan
retained
the
authority
to
designate
an
alternative
monitoring
period
in
R325.10710a(
4)(
d)(
iv)(
A);

however,
the
DEQ
has
not
exercised
that
authority.
There
may
be
a
few
exceptions
that
were
granted
on
a
case­
by­
case
basis
for
some
groundwater
systems
where
we
accepted
some
sampling
outside
these
four
months,
given
the
relatively
constant
groundwater
temperatures.

IL
Yes,
SDWIS/
State
is
set
up
to
reject
sample
results
collected
outside
these
months
(
called
Seasonal
collection
period
which
are
mandatory
criteria)
and
identify
these
as
monitoring
violations
during
compliance
determination.

IN
Systems
on
annual
or
triennial
frequencies
are
required
to
sample
between
June­
Sept.
of
that
year.
However,
IDEM
does
allow
schools
on
annual
or
triennial
frequencies
to
monitor
in
May
in
order
to
meet
the
intent
of
the
rule,
which
is
for
samples
to
be
collected
during
the
warmest
weather
months
of
operation.
Sampling
in
May
allows
schools
to
sample
during
periods
of
normal
water
usage
rather
than
during
the
summer
when
there
is
little
to
no
water
usage.

MN
The
MDH
uses
one
contract
lab
to
analyze
all
LCR
compliance
samples.
Systems
are
scheduled
to
conduct
(
and
complete)
tap
monitoring
in
their
assigned
month
of
either
June,

July,
August,
or
September.
A
small
portion
of
systems,
such
as
schools,
colleges,
and
seasonal
systems
are
allowed
to
complete
the
sampling
in
October,
(
or
in
other
months
approve
by
the
MDH.)
Sampling
for
validation/
repeat
samples
may
fall
out
of
the
June
­

October
window
due
to
lengthy
turnaround
for
lab
results
and/
or
other
delays.

OH
Yes,
systems
that
sample
annually
or
less
frequently
conduct
lead
tap
sampling
during
the
months
of
June,
July,
August,
or
September.
Designated
alternate
sampling
times
have
not
been
assigned
in
the
past,
however
the
director
may
assign
such
per
rule
3745­
81­
86
(
D)(
4)(
d)(
i)
of
the
Ohio
Administrative
Code,
which
is
analogous
to
paragraph
(
d)(
4)(
iv)(
A)
of
40
CFR
141.86,
as
noted
above.
WI
Most
systems
on
reduced
monitoring
sample
in
June,
July,
Aug,
or
Sept.
Notable
exceptions
are
schools,
which
are
generally
closed
during
the
summer
months.

AR
Yes.
This
option
has
not
been
used.

LA
Yes,
all
of
the
systems
that
are
sampling
annually
or
triennially
are
required
to
complete
sampling
between
June
1
and
September
30
of
the
year
that
sampling
was
required.

NM
Yes.

OK
Yes.
No
alternate
times.

TX
Yes.
Alternate
sampling
periods
are
scheduled
if
a
PWS
has
a
valid
reason
for
failing
to
collect
any
or
all
samples
during
a
routine
schedule.
The
TCEQ
will
determine
the
validity
of
the
PWS's
reason.

IA
Yes.
None
at
this
time.

KS
Systems
that
sample
annually
or
less
frequently
are
required
to
sample
during
the
months
of
June
through
September.
No
alternate
sampling
times
have
been
requested
and
no
alternate
sampling
times
have
been
approved.

MO
All
systems
in
Missouri
on
reduced
monitoring
are
scheduled
to
do
so
during
the
months
of
June,
July,
August,
or
September.

NE
Water
systems
receive
their
sample
kits
and
instructions
in
June,
with
instructions
to
collect
the
samples
promptly.
Nebraska
has
no
other
designated
sampling
time.
However
we
have
accepted
rounds
of
samples
collected
after
the
end
of
September
in
cases
where
water
systems
had
failed
to
get
them
done
during
the
June­
through­
September
time
window.

CO
Systems
on
an
annual
or
triennial
schedule
are
required
to
sample
during
the
months
of
June,
July,
August
and
September.
The
State
offers
no
alternative
monitoring
schedules.

MT
Yes.
Some
schools
and
other
seasonal
systems
are
allowed
to
sample
at
other
periods.
The
department
determines
when
the
hottest
month
of
use
is,
and
that
becomes
the
period
required
to
be
sampled.

ND
We
have
not
approved
any
alternative
sampling
times
for
reduced
monitoring,
other
than
June
­
September.
We
allow
sampling
across
years
(
July­
August­
September­
June)

although
it
very
rarely
occurs
as
we
send
out
sample
bottles
all
at
once
and
encourage
the
systems
to
collect
the
samples
at
the
same
time.
SD
Yes.
None
of
our
systems
on
reduced
monitoring
are
collecting
samples
at
alternate
times
of
the
year.

UT
system
by
the
State.
In
the
section
of
the
report
covering
Lead/
Copper
sampling
requirements
it
clearly
states
that
sampling
should
occur
in
the
months
of
June,
July,

August,
or
September.

WY
Yes.
There
are
no
systems
in
Wyoming
using
alternate
sampling
times.

Amer
Sam
Yes.

Navajo
The
NNPWDR
requires
the
samples
to
be
collected
during
the
the
months
of
June,
July,

August
or
September.
Designated
alternate
sampling
times
are
evaluated
by
the
PWSSP
by
the
site
sampling
plan.
Formal
letters
by
the
owner/
operator
requesting
for
a
change
in
sampling
times
are
required
prior
to
the
Director's
determination
of
an
alternate
sampling
time.

AZ
State
rule
requires
that
the
systems
monitoring
in
the
designated
months.
Deviations
are
approved
on
a
case­
by­
case
basis.

CA
Yes
all
systems
conduct
sampling
during
the
summer
months.
With
regard
to
alternate
sampling
times,
this
information
may
be
obtained
from
the
State
LCR
primacy
package,
as
the
special
primacy
requirement
contained
in
40
CFR
142.16(
d)(
4)
required
States
to
describe
the
basis
on
which
the
State
will
designate
an
alternative
period
for
sample
collection
for
community
water
systems
subject
to
reduced
monitoring.

HI
The
water
systems
are
sampling
during
June,
July,
August
or
September.
The
State
has
not
specified
other
sampling
times
for
water
systems.

NV
Yes.
Certification
of
such
is
included
on
Form
141­
A.

AK
Systems
that
are
on
annual
or
reduced
monitoring
are
allowed
to
collect
samples
from
any
time
of
the
year
that
they
are
operational.

WA
DOH
informs
systems
of
the
requirement
to
monitor
during
these
months,
however
we
do
accept
data
outside
of
this
time
frame.
The
LCRMR
offers
states
the
discretion
to
specify
other
times
of
the
year
for
systems
in
colder
climates.
To
date
DOH
has
not
exercised
this
option.
DOH
has
not
formally
designated
alternative
sampling
times.
ID
Idaho
allows
systems
that
are
not
operational
during
one
of
the
4
summer
months
to
sample
during
the
warmest
month
they
are
open.
Systems
that
sample
outside
the
required
range
of
summer
dates
have
the
results
calculated
into
their
90
percentile
level
as
the
rule
requires
but
are
in
violation
for
failure
to
sample
within
the
required
period.

OR
OR
required
sampling
during
June
­
Sept.
If
a
system
approaches
them
requesting
a
different
time
period,
they
will
consider
it,
but
this
has
not
happened
to
date.
Describe
what
procedures
the
state
has
in
place
to
ensure
that
homeowners
are
adequately
trained
to
collect
samples.
CT
The
CTDPH
 
DWD
refers
Public
Water
Systems
to
the
applicable
sections
of
the
B102
regulations
for
sample
collection
methods,
which
are
taken
from
40
CFR
141.86(
b).
Public
Water
Systems
provide
sample
collection
guidance
sheets
to
their
customers
based
on
the
aforementioned
regulations
and
system­
specific
requirements.

MA
DEP
provides
training
to
public
water
systems
routinely.
Written
training
materials
are
provided.

ME
All
water
systems
are
given
a
Form
141­
A
and
a
copy
of
"
First
Draw
Sampling
Instructions."
Sampling
instructions
are
sent
again
with
each
sample
container
along
with
a
"
Chain
of
Custody
Form."
The
phone
number
of
the
Lead
and
Copper
Rule
Coordinator
is
included
with
the
sampling
instructions
so
a
customer
can
call
if
they
have
any
questions.

Water
system
operators
are
required
to
sign
the
141­
A
form
certifying
that
the
customer
has
been
instructed
in
the
proper
method
of
collecting
a
first
draw
lead
and
copper
sample.

NH
Sampling
instructions
are
given
out
by
the
sampling
agent
with
each
sampling
bottle.

RI
Directions
describing
sampling
protocol
are
distributed
with
each
sample
container
either
by
the
water
system
(
large
systems)
or
by
the
State
(
small
systems).

VT
Homeowners
are
trained
by
water
system
personnel
using
the
EPA
Lead
and
Copper
Monitoring
Guidance
Manual.
In
some
cases,
water
system
personnel,
after
discussing
the
sampling
procedure
with
the
homeowner,
take
the
samples.
During
the
initial
rounds
of
sampling,
homeowners
signed
and
submitted
the
"
Suggested
Directions
for
Homeowners
TAP
Sample
Collection
Procedures"
to
certify
the
sample
was
taken
properly.
NY
State
regulations
in
10NYCRR
Part
5­
1.42(
a)
require
water
purveyors
that
use
homeowners
for
lead
and
copper
compliance
sampling
to
provide
the
information
and
training
required
for
proper
sampling,
and
to
then
certify
that
the
homeowners
are
properly
trained.
As
part
of
initial
monitoring
efforts,
purveyors
were
required
to
identify
sampling
locations
and
create
a
sampling
pool
that
meets
the
requirements
of
state
and
federal
requirements.
Local
health
offices
reviewed
these
sample
pools
and
worked
with
systems
to
ensure
proper
information
and
training
was
provided.

NJ
The
State
leaves
this
matter
to
individual
water
systems
as
to
who
train
participating
home
owners
and
provide
instruction
sheets
to
residents
on
first­
draw
sampling
procedures.
40
CFR
141.86
(
b)
2
DE
We
rely
on
the
systems
to
conduct
the
training
of
homeowners.
We
do
not
have
the
resources
to
follow
up
on
this
activity.

MD
The
State
has
provided
all
laboratories
and
water
systems
a
detailed
sample
collection
form
to
use
when
collecting
a
sample.
Based
on
the
information
provided
by
the
homeowner,
it
can
be
determined
whether
the
minimum
holding
time
requirement
is
met
and
if
the
sample
location
is
appropriate.
The
laboratories
verify
that
a
sufficient
volume
of
water
was
collected
prior
to
performing
the
analysis.

WV
The
lead
and
copper
package
sent
to
a
system
when
they
begin
the
sampling
program,
has
an
instruction
sheet
to
distribute
to
homeowners
with
the
collection
bottle.
WV
relies
on
the
Public
Water
System
to
distribute
this
document
to
the
customer.

PA
Water
suppliers
are
responsible
for
ensuring
that
homeowners
are
provided
with
sample
collection
procedures.
The
supplier
must
provide
a
copy
of
the
written
procedures
in
their
Sampling
Plan.
PA
DEP
staff
look
at
the
sampling
procedures
when
they
review
the
Sampling
Plan.
VA
As
stated
previously,
the
vast
majority
of
waterworks
in
Virginia
utilize
the
state
laboratory
for
lead
and
copper
testing.
The
state
lab
sends
detailed
sampling
instructions
(
including
the
minimum
6
hour
holding
time)
with
each
sample
kit.
These
instructions
are
given
to
the
homeowner
by
the
waterworks
owner
with
the
lead
and
copper
sample
containers.
This
procedure
ensures
that
homeowners
are
properly
instructed
to
collect
the
lead
and
copper
tap
samples.

AL
Before
it
as
no
longer
required,
systems
were
required
to
submit
a
statement
if
customers
collected
the
samples,
they
were
properly
instructed
how
to
collect
the
samples.
Because
systems
are
using
sites
and
customers
who
have
sampled
before,
those
customers
should
be
familiar
with
how
to
collect
the
samples.

GA
A
video
was
produced
by
the
DWP
and
distributed
to
all
the
systems
to
provide
to
the
designated
samplers,
to
show
how
to
correctly
collect
lead
and
copper
samples.
Also,
the
State
provides
detailed
instruction
on
the
sample
collection
sheets
that
are
given
out
with
each
bottle.

FL
Until
August
2003,
Florida
had
a
form
titled,
"
Collection
Method
Training
for
Homeowners
Collecting
their
Own
Samples."
It
was
determined
that
there
was
no
federal
requirement
to
document
homeowner
training
and
the
form
was
deleted.
We
do
encourage
water
system
representatives
to
instruct
homeowners
on
the
appropriate
methods
for
collecting
samples.
We
let
water
systems
know
that
we
will
not
delete
a
high
lead
or
copper
result
simply
because
the
system
suspects
the
sample
was
not
taken
correctly.

Many
water
systems
have
developed
their
own
training
programs
in
the
form
of
a
hand­
out.

KY
On
Kentucky's
lead
and
copper
analytical
results
form,
the
water
systems
must
sign
a
statement
certifying
the
sample
was
taken
by
either
a
trained
homeowner
or
trained
utility
representative.
MS
When
sample
kits
are
prepared
to
ship
to
the
systems,
the
state
provides
the
system
with
homeowner
instruction
sheets
for
sample
collection.
Systems
are
also
encouraged
to
train
homeowners
selected
for
lead
&
copper
sampling.
Some
systems
offer
incentives
for
participation
in
sampling
such
as
a
small
reduction
in
the
water
bill.

NC
Instructing
residents
in
proper
sampling
procedures
is
the
responsibility
of
the
water
system.
When
requested,
however,
PWSS
has
supplied
instructions
for
proper
sampling
procedures
to
water
systems
for
distribution
to
residents
taking
samples.
The
document
entitled
"
Guidance
for
Site
Selection
and
Sampling",
as
indicated
in
our
response
to
question
A1,
is
also
available
on
our
web
site
to
provide
guidance
for
proper
sample
collection.

SC
Sampling
instructions
are
shipped
with
the
bottles
to
the
water
systems.
The
Department
encourages
water
systems
to
use
the
instructions
or
to
develop
their
own
sampling
instructions
for
homeowners.
Water
systems
are
encouraged
to
review
the
instructions
with
homeowners
to
minimize
sampling
error.

TN
Public
water
systems
are
required
to
provide
homeowners
with
appropriate
training
in
collecting
lead
and
copper
samples
if
the
system
elects
to
allow
homeowners
to
collect
the
samples.
In
addition,
the
certified
laboratories
and
the
water
systems
include
written
instructions
with
each
delivered
sample
bottle.
MI
The
supplies
were
very
clearly
told
by
DEQ
staff
to
properly
instruct
customers
on
sampling,
given
the
significant
impact
sampling
technique
and
location
could
have
on
the
overall
results.
Most
supplies
recognized
the
importance
of
these
factors
and
many
provided
written
instructions
to
homeowners
on
sample
collection.
The
noncommunity
program
has
instructions
on
their
web
site
at
which
is
attached
in
*.
pdf
format.
When
the
LCRMR
became
effective,
previously
exempt
CWS
began
the
lead
and
copper
initial
monitoring.
These
supplies
are
typically
apartment
complexes,
many
of
which
employ
operators
with
limited
experience.
To
ease
the
burden
of
this
very
complicated
rule
and
limit
the
risk
of
improper
sampling,
the
DEQ
provided
the
previously
exempt
systems
with
specific,
easy­
to­
understand
instructions
and
a
sample
instruction
sheet
to
give
to
the
residents.
Attached
is
the
template
of
a
letter
that
district
offices
sent
to
the
supplies
with
sample
instructions
to
residents.

IL
Instructions
on
how
to
properly
collect
lead/
copper
samples
have
been
sent
to
all
bottle
recipients.
The
IEPA
has
always
and
continues
to
educate
sample
collectors
on
the
importance
of
properly
collecting
samples
and
have
stressed
that
they
need
to
pass
this
information
along
to
the
homeowners.

IN
IDEM
sends
instructions
on
how
the
samples
should
be
collected
via
letter.

MN
Each
sample
bottle
is
attached
with
sampling
instructions
and
a
certification
form
for
the
sample
collector,
as
instructed
in
the
LCR
Guidance
Manual
on
sampling.
OH
Public
water
systems
are
provided
instructions
on
how
samples
are
to
be
collected.
The
person
in
charge
of
monitoring
for
the
public
water
system
is
required
to
sign
the
report
(
Ohio
EPA
form
5105)
and
certify
that
the
first­
draw
samples
were
collected
properly.
The
certification
on
the
form
reads:
"
I
certify
that
each
first­
draw
lead
and
copper
sample
collected
for
our
water
system
was
one
liter
in
volume,
was
taken
from
a
kitchen
or
bathroom
cold­
water
tap
or
a
drinking
fountain,
and,
to
the
best
of
my
knowledge,
had
stood
motionless
in
the
service
line
and
in
the
interior
plumbing
of
the
sampling
site
for
at
least
six
hours.
I
further
certify
that
each
tap
sample
collected
by
residents
was
taken
after
the
water
system
informed
them
of
proper
sampling
procedures."

WI
The
State
provided
initial
training,
and
guidance
as
needed.
System
information
is
reviewed
during
sanitary
surveys
and
annual
inspections
as
needed.

AR
Utilities
are
given
specific
instructional
sheets
that
explain
to
homeowners
exactly
what
they
are
to
do.

LA
The
state
includes
a
copy
of
the
recommended
instructions
to
homeowners,
which
is
presented
in
the
Implementation
Guidance
Manuals
from
EPA,
with
each
shipment
of
sampling
supplies.
The
water
system
is
then
expected
to
review
the
sheet
with
each
homeowner.
In
order
to
ensure
that
proper
instructions
were
given,
the
homeowners
must
sign
the
form,
which
is
sent
along
with
the
samples
to
the
lab.
A
copy
of
this
instruction
sheet
is
included
as
Appendix
A
of
this
response.

NM
A
hand
out
is
given
to
home
owner
along
with
sample
container
instructing
home
owner
on
proper
procedures
for
collecting
the
sample
and
returning
the
samples
back
to
the
state
for
acidification
and
shipping
to
the
labs.

OK
Sampling
instructions
are
included
with
each
bottle.

TX
They
are
provided
a
very
clear
and
easy
to
follow
instructions
form,
and
the
PWS
official
assures
that
the
homeowner
gets
instructions
and
understands
the
process.
IA
We
provide
the
federal
guidance
to
the
systems
for
their
use
in
training
homeowners
to
collect
the
samples.

KS
The
Kansas
Department
of
Health
and
Environment
Laboratory
provides
detailed
sample
collection
procedures
with
each
sample
container.
In
addition,
a
lead
and
copper
rule
survival
guide
is
available
to
system
operators
on
request.
The
guide
contains
a
list
of
tips
for
collecting
lead
and
copper
samples.

MO
An
instruction
sheet
is
sent
with
containers
for
water
system
personnel
to
distribute
to
home­
owners.

NE
NE
places
the
responsibility
of
sample
collection
training
on
the
licensed
operator
for
the
water
system
if
they
choose
to
use
homeowners
to
collect
samples.
We
routinely
encourage
water
systems
to
use
their
own
staff
to
collect
samples
whenever
possible.
We
have
provided
written
instructions
for
water
systems
to
give
to
homeowners
for
those
systems
who
use
homeowners
to
collect
samples.
In
addition,
detailed
collection
instructions
are
included
with
each
lead
&
copper
sample
kit.

CO
The
"
Homeowner
Certification
and
Instructions
for
Tap
Sample
Collection"
form
is
provided
to
the
public
water
systems
to
be
distributed
to
the
homeowners
performing
lead
and
copper
tap
water
monitoring.
This
form
gives
sampling
protocol
instructions
and
serves
as
a
certification
of
proper
performance.

MT
The
department
always
required
the
homeowners
to
complete
and
submit
the
certification
of
training
form.

ND
We
send
sample
instructions
to
the
systems
when
sample
bottles
are
sent
out
and
ask
the
systems
to
make
copies
of
the
sample
instructions
and
distribute
them
to
the
homeowners.

SD
Sampling
information
is
sent
with
the
empty
bottles
to
the
certified
operator.
The
certified
operator
is
responsible
to
make
sure
that
the
samples
are
collected
properly.
UT
The
operator,
who
disseminates
and
collects
the
sample
bottles,
is
expected
to
inform
the
homeowner
on
all
sampling
procedures.
On
forms
specified
and
supplied
by
the
State,
the
operator
is
required
to
signs
a
statement
which
reads:
"
I
certify,
to
the
best
of
my
knowledge,
the
data
listed
on
this
form
is
from
kitchen
and
bathroom
cold
water
taps
taken
immediately
after
the
water
has
stood
in
the
pipes
for
at
least
six
hours
(
first­
draw
samples)."

WY
As
part
of
a
package
for
new
systems,
Region
8
encloses
an
information
sheet
detailing
the
procedure
for
collecting
drinking
water
samples
for
lead
and
copper
analysis.
Also,
when
a
system
fails
to
monitor,
the
violation
letter
contains
information
on
the
sampling
procedure.

We
leave
it
up
to
the
water
system
to
pass
this
information
along
to
the
homeowners.

AZ
Provide
procedures
and
guidance
from
laboratories.

CA
The
LCR
does
not
appear
to
require
States
to
have
procedures
in
place
to
ensure
adequate
training
of
homeowners
to
collect
samples.
The
provisions
relating
to
homeowner
collection
of
tap
samples
are
found
in
40
CFR
141.86(
b)(
2)
and
references
the
responsibility
of
the
system
to
instruct
homeowners
in
the
proper
procedures
for
collecting
the
sample.

HI
The
State
provides
a
Lead
and
Copper
Custody
and
Laboratory
Report
Form
to
all
water
systems
to
use
when
collecting
lead
and
copper
water
samples.
The
back
side
of
the
form
provides
instructions
for
the
homeowner
on
how
to
collect
the
sample
correctly.

NV
System
operators
provide
residents
with
instruction
forms
and
verbal
instructions.
The
state
provides
written
guidance
to
system
operators,
including
"
How
to
Sample"

instructions.
An
operator
training
session
(
130
participants)
including
Lead
and
Copper
Monitoring
training
was
conducted
via
video
conference
on
June
24,
2004.

Amer
Sam
ASEPA
reviewed
and
approved
the
letter
with
instructions
and
signature
block
provided
with
each
sampling
bottle.
ASPA
procedures
are
consistent
with
40
CFR
Section
141.86(
b)(
2).
Navajo
§
710
(
B)(
2)
of
the
NNPDWR
(
40
CFR
§
141.86(
b)(
2))
describe
the
sample
collection
methods.
PWSSP
offers
technical
assistance
to
teach
the
homeowner
or
operators
of
public
water
systems
to
collect
samples.
In
1991,
EPA
issued
Lead
and
Copper
Monitoring
Guidance.
In
that
document,
there
is
a
document
titled
"
Suggested
Directions
for
Homeowner
Tap
Sample
Collection
Procedures".
NNEPA
refers
to
this
document
when
providing
technical
assistance
to
homeowners.

AK
We
have
information
on
our
website
outlining
how
to
collect
Pb
&
Cu
samples.
In
addition,

we
have
included
sampling
instructions
in
our
quarterly
newsletter.
Operator
training
covers
sampling
requirements
and
it
is
the
responsibility
of
the
operator
to
properly
instruct
the
homeowner
on
proper
sampling
protocol.

WA
DOH
developed
a
guidance
brochure
for
utilities
to
provide
to
homeowners.

ID
Idaho
distributes
sampling
instruction
models
to
the
public
water
systems
and
requires
that
the
water
system
submit
one
copy
of
what
was
actually
distributed
to
homeowners.

OR
OR
provided
EPA's
guidance
early
on
to
the
systems.
They
expect
operators
to
pass
this
on
to
the
homeowners.
One
excellent
example
is
Portland
who
gives
the
homeowner
very
detailed
instructions.
Although
not
required
by
Federal
regulation,
do
systems
provide
homeowners
with
lead
sampling
results
derived
from
any
volunteer
sampling
program?

Does
the
state
make
any
recommendations
to
public
water
systems
in
this
area?
CT
The
state
has
not
been
involved
with
the
Public
Water
Systems
on
such
a
level.
Most
large
and
some
medium­
sized
PWS
initiate
sampling
of
individual
customers
upon
request
or
based
on
complaints
filed
with
either
the
system
or
the
state.
It
should
be
noted
that
the
CTDPH
 
DWD,
in
partnership
with
the
CTDPH
 
Child
Care
Licensing
Program,
review
water
quality
test
results
submitted
by
licensed
Child
Care
facilities
for
licensing
and
relicensing
Lead
samples
are
part
of
this
effort.
The
CTDPH
 
DWD
provides
technical
assistance
to
all
PWS
serving
licensed
Child
Care
facilities
that
have
submitted
elevated
lead
samples
as
part
of
their
licensing,
or
re­
licensing
application.
The
licensing
cycle,
or
term,
is
minimally
every
two
years.
The
PWS
are
urged
to
follow­
up
with
corrective
actions
at
the
Child
Care
facilities
and
further
enforcement
action
and
investigations
proceed
as
necessary
or
applicable.

MA
State
regulations
do
not
require
water
suppliers
to
provide
results
to
participating
homeowners.
However,
DEP
strongly
encourages
water
suppliers
to
provide
participating
homeowners
with
the
results.
Many
homeowners
volunteered
for
the
program
in
order
to
receive
this
type
of
information.

ME
The
larger
water
systems
send
sample
results
to
the
homeowner
every
time
to
encourage
the
customers
to
continue
to
participate.
Most
of
the
small
water
systems
make
the
results
available
to
the
homeowners
if
they
request
a
copy
of
the
results.
The
State
recommends
to
the
water
systems
that
each
time
they
have
a
samples
result
over
the
action
level
that
they
contact
the
homeowner
involved.
NH
Many
systems
do
give
lead
and
copper
results
to
their
sampling
volunteers.
The
WSEB
recommends
to
systems
to
give
results
to
volunteers.

RI
Yes
for
large
systems.
Most
of
the
time
for
medium
systems.
Probably
not
the
case
for
small
systems.
State
recommends
that
results
be
reported
to
occupants
of
structure
where
sampling
was
conducted.

VT
Yes.
The
state
encourages
water
system
personnel
to
share
results
and
provide
health
effects
language
when
results
are
above
the
action
levels.

NY
Some
purveyors
in
New
York
voluntarily
provide
lead
sampling
and
analysis
services
to
homeowners
that
request
lead
analysis.
The
results
are
provided
to
the
homeowners,
but
unless
the
samples
were
taken
by
homeowners
properly
trained
and
certified,
the
results
would
not
be
used
in
calculating
90%
levels
for
lead
and
copper
compliance
determinations.
In
some
cases
(
e.
g.
New
York
City)
the
purveyors
provide
follow
up
to
individual
property
owners,
including
education,
building
inspections
and
technical
support.

The
State
has
encouraged
this
voluntary
program,
but
does
not
direct
it.

NJ
We
do
not
track
this
information
but
some
systems
do
it.
Generally
systems
provide
results
to
those
who
request
it
and
to
those
homes
that
have
exceeded
the
lead
or
copper
action
level.
If
asked
we
recommend
that
systems
provide
test
results
to
participating
homeowners.

DE
It
has
been
our
experience
that
systems
do
not
provide
copies
of
the
results
homeowners.

We
do
encourage
this
but
cannot
enforce
it
at
it
this
time.
Individuals
are
provided
summary
results
via
the
CCR.

MD
This
information
is
not
tracked.
In
training
and
guidance
material,
the
State
recommends
that
the
water
systems
provide
the
test
results
to
the
homeowners.

WV
Unknown.
No.

PA
Water
suppliers
are
responsible
for
ensuring
that
public
health
is
protected.
Because
this
activity
is
not
required
by
Federal
or
State
regulations,
PA
DEP
does
not
track,
nor
do
we
have
knowledge
of
whether
water
suppliers
provide
homeowners
with
results
derived
from
any
volunteer
sampling
program.
VA
We
do
not
have
data
indicating
the
number
of
waterworks
providing
homeowners
with
the
results
of
lead
sampling.
We
know
that
some
waterworks
do
notify
the
individual
homeowners
of
high
lead
results.
The
State
Health
Commissioner
has
sent
a
letter
to
the
owners
of
all
community
and
non­
transient
non­
community
waterworks
strongly
recommending
that
lead
sample
results
be
provided
to
the
individual
homeowners.

Additionally,
our
lead
and
copper
sample
results
transmittal
letters
encourage
the
waterworks
owners
to
notify
the
respective
homeowners
of
high
lead
results.

AL
Unknown.
No.

GA
Copies
are
provide
to
the
systems
that
utilize
the
State
lab
to
distribute
to
each
collection
site
owner.
It
is
recommend
that
they
provide
each
sampler
with
a
copy
of
the
water
analysis
perform
on
their
water.

FL
Until
August
2003,
Florida
had
a
form
that
water
systems
had
to
submit
on
which
they
certified
that
all
individual
homes
that
had
exceeded
either
the
lead
or
copper
action
levels
had
been
notified.
It
was
determined
that
there
was
no
federal
requirement
for
this
action
and
the
form
was
deleted.
We
encourage
systems
to
make
results
available.
This
is
not
only
good
public
relations
for
the
water
system,
but
also
is
common
courtesy
given
the
fact
that
homeowners
are
not
required
to
participate
and
the
need
for
homeowners
to
continue
participating
through
the
years.

KY
No,
we
are
not
aware
of
any
water
systems
that
provide
homeowners
with
lead
sampling
results
and
the
state
does
not
make
recommendations
to
public
water
systems
in
this
area.

MS
The
state
requests
that
individual
homeowner
results
be
provided
to
participants
in
the
monitoring
program.
Individual
results
are
sent
to
the
system
along
with
the
90th
percentile
calculations.
NC
When
a
water
system
responds
to
an
exceedance
letter,
the
rule
manager
discusses
the
exceedance
situation
with
the
water
system.
The
rule
manager
may
then
recommend
that
the
system
inform
the
homeowner
of
their
high
sampling
results
and
provide
information
to
the
homeowner
on
health
effects,
possible
causes
for
the
high
levels,
and
potential
remedies.

SC
Some
water
systems
provide
results
to
the
homeowners;
however,
the
Department
encourages
all
water
systems
to
do
so.

TN
This
is
determined
by
each
system
and
homeowner.
Systems
are
encouraged
to
share
analytical
results
with
homeowners.

MI
During
the
initial
implementation
of
LCR,
the
DEQ
strongly
encouraged
the
supplies
to
notify
customers
of
all
sampling
results
from
their
home.
(
See
numerous
templates
developed
for
systems
to
use
for
notifying
residents.)
At
this
point
in
the
implementation
of
the
LCR,
the
district
staff
has
discontinued
formally
encouraging
supplies
to
notify
residents
of
results
after
each
monitoring
period.
However,
they
may
remind
a
water
supply
to
do
so
when
they
are
investigating
a
high
lead
result.
At
least
one
of
our
eight
districts
uses
the
attached
Investigation
Form.
pdf
and
others
use
the
criteria
on
this
form
to
ensure
samples
were
taken
properly.
The
Manufactured
Housing
Community
program
encourages
their
supplies
to
notify
residents
whose
results
exceed
either
the
lead
or
copper
action
level,
regardless
of
the
90
th
percentile.

IL
Some
do
and
some
don't.
We
do
not
know
the
percentage
that
do.

IN
IDEM
is
not
aware
of
any
volunteer
sampling
programs.
We
have
not
made
recommendations
in
that
area.
MN
The
MDH
has
no
established
policy
on
this.
It
appears
that
during
the
initial
monitoring
phase
in
1992­
1993,
the
majority
of
systems
did
provide
the
test
results
to
all
participants;

in
recent
years,
most
systems
provide
results
only
to
residents
with
elevated
lead
and/
or
copper
levels
alone
with
PE
materials,
fact
sheets,
brochures,
etc.,
on
how
to
minimize
their
exposure
to
lead/
copper
in
drinking
water.
Some
systems
provide
the
results
only
if
requested
by
the
residents.

OH
It
is
not
known
if
systems
provide
homeowners
with
lead
sampling
results
derived
from
any
volunteer
sampling
program.
There
is
no
formal
procedure
that
requires
the
public
water
system
to
inform
individual
homeowners
of
their
lead
sampling
results.

WI
Section
809.541(
12)
Wis.
Adm.
Code,
requires
system
owners
to
provide
results
to
the
occupants
of
all
premises
used
as
sample
locations.

AR
Not
to
our
knowledge.
We
do
not
require
that
systems
report
monitoring
results
to
homeowners;
however,
when
sample
site
results
are
forwarded
to
systems,
they
are
encouraged
to
notify
homeowners
of
lead
exceedances.
In
addition,
homeowners
would
know
there
were
exceedances
by
reading
the
CCR
and
asking
either
the
State
or
system
personnel.

LA
To
our
knowledge
none
of
the
systems
provide
homeowners
with
lead
sampling
results
derived
from
this
volunteer
sampling
program.
However,
all
public
water
system
sampling
results
are
designated
as
public
information.
Accordingly,
any
homeowner
who
wishes
to
get
copies
of
the
results
can
do
so
by
contacting
the
Louisiana
Safe
Drinking
Water
Program
Administrator.

NM
The
NMED­
DWB
is
not
sure
if
the
water
systems
are
providing
the
costumers
with
this
type
of
service.

OK
Yes,
most
do.
DEQ
encourages.
TX
PWSs
are
encouraged
to
make
results
available
to
customers
upon
request
and
is
in
the
CCR.
The
TCEQ
requires
systems
that
have
an
exceedance
to
contact
the
homeowner
to
explain
how
to
limit
their
exposure
to
lead/
copper.
This
information
is
also
in
their
CCR.

IA
Unknown,
although
the
state
has
been
told
that
some
systems
do
provide
the
homeowner
with
the
data
from
their
home.
The
state
encourages
systems
to
provide
the
information
to
the
homeowners,
but
has
no
requirements
to
do
so.

KS
No
information
is
available
on
systems
providing
sampling
results
to
homeowners.

However,
the
state
does
recommend
to
systems
that
results
of
sampling
be
provided
to
the
homeowners.

MO
Some
systems
do
and
some
do
not.
We
make
no
recommendations
except
for
when
samples
are
high
at
a
particular
site.

NE
Because
Nebraska
does
not
require
or
monitor
such
information­
sharing,
we
cannot
speak
for
individual
water
systems.
Our
policy
is
to
recommend
and
encourage
water
systems
to
share
such
information
gathered
by
other
entities
or
programs 
especially
with
owners
of
the
sampled
sites.

CO
The
State
is
not
aware
of
any
public
water
systems
performing
volunteer
sampling
programs.
The
State
has
not
made
any
recommendations
in
this
area.

MT
We
have
no
information
in
regards
to
"
voluntary"
lead
sampling.

ND
As
this
is
up
to
the
system,
we
are
unsure
whether
systems
do
this
or
not.
We
recommend
that
all
lead
and
copper
data
be
provided
to
homeowners.

SD
Not
that
we
know
of
and
no
we
don't
make
any
recommendations
in
this
area.

UT
Some
systems
do
provide
homeowners
with
the
sample
results.
The
State
encourages
this
as
a
very
good
idea.
But,
as
noted,
the
State
can't
require
that
such
be
done.
WY
Region
8
is
not
aware
of
any
Wyoming
water
systems
that
provide
this
information.
When
results
that
exceed
the
action
levels
are
received
from
the
required
sampling,
the
water
system
is
encouraged
to
notify
the
affected
homeowners.
Region
8
has
not
made
any
recommendations
to
Wyoming
water
systems
concerning
a
volunteer
sampling
program.

AZ
Yes,
the
information
is
typically
provided
when
requested.
State
encourages
this
practice.

CA
Not
applicable.

HI
In
Hawaii,
the
State
performs
the
lead
and
copper
analyses,
and
the
State
will
call
the
water
system
when
a
specific
home
has
lead
levels
of
100
ppb
or
higher.
The
State
will
recommend
that
the
water
system
contact
the
homeowner
to
determine
whether
the
sampling
protocol
was
followed
and
to
alert
the
homeowner
about
the
lead
levels
in
the
sample
provided.
NV
We
are
not
aware
of
any
systems
which
provide
results
to
homeowners.
No.

Amer
Sam
ASPA,
the
utility,
does
not
provide
each
homeowner
with
the
results
unless
the
Pb
or
Cu
levels
are
elevated
above
the
action
level.
In
that
case
they
write
a
letter
to
the
homeowner
and
explain
the
risks
of
the
contaminant
and
precautions.

Navajo
There
may
be
times
that
water
purveyors
provide
information
to
homeowners.
The
water
purveyors
are
required
to
notify
the
homeowners
by
the
Consumer
Confidence
Report
and
by
public
notice
if
this
system
exceeds
the
action
level.
PWSSP
recommends
to
the
owner/
operator
to
notify
their
consumers,
if
they
request
for
information.
Often
times,

sharing
information
leads
to
a
community
finding
funds
to
address
the
problem.

AK
Most
systems
do
not
voluntarily
collect
additional
samples
for
Pb
&
Cu.
Once
we
have
any
result,
they
become
public
record
and
any
homeowner
can
request
copies
or
view
them
in
the
office
WA
DOH
recommends
in
a
monitoring
notification
packet
sent
to
public
water
systems
that
sampling
results
be
provided
to
homeowners
participating
in
volunteer
sampling
programs.

Yes,
see
contents
of
Attachment
A,
instructions
to
the
homeowners
"
Results
of
this
monitoring
will
be
provided
to
participants
when
results
have
been
submitted
to
the
state
unless
excessive
levels
of
lead
and/
or
copper
are
found.
In
those
cases,
immediate
notification
should
be
provided
(
usually
within
10
days
of
sample
collection)".

ID
Idaho
does
not
track
whether
water
systems
inform
homeowners
of
their
respective
individual
sample
results
OR
The
state
encourages
the
systems
to
share
this
information.
In
most
cases
they
believe
the
systems
do
share
the
results,
especially
when
those
results
are
high.
Describe
the
process
the
state
goes
through
when
it
identifies
that
a
system
has
exceeded
the
action
level.
CT
As
Community
Public
Water
Systems
and
Non­
Transient
Non­
Community
Public
Water
Systems
are
identified
as
exceeding
the
lead
and/
or
copper
ALs
a
Lead
and
Copper
Rule
Exceedance
letter
is
issued
outlining
all
applicable
requirements
and
timeframes
including
water
quality
parameter
and
source
water
monitoring,
public
notification
and
education
requirements
and
the
initial
requirements
regarding
the
corrosion
control
treatment
steps.

The
Lead
and
Copper
Rule
Exceedance
is
tracked
within
the
SDWIS/
STATE
database
with
informal
enforcement
being
issued
for
any
violations
of
the
aforementioned
requirements
following
the
exceedance
with
formal
enforcement
pursued
if
the
Public
Water
System
does
not
return
to
compliance
with
said
requirements.
In
the
event
a
Public
Water
System
is
once
again
deemed
optimized
in
the
midst
of
completing
the
requirements
following
an
exceedance,
the
Public
Water
System
is
notified
and
all
exceedance
requirements
are
halted
to
be
continued
if
the
Public
Water
System
is
found
to
again
exceed
the
lead
and/
or
copper
ALs.

MA
Systems
must
submit
the
results
of
sample
rounds
to
DEP.
When
it
is
determined
that
a
systems
has
exceeded
the
action
level,
DEP
notifies
the
system
of
the
actions
required
and
the
time
period
for
completing
the
action.
These
actions
can
include
more
water
quality
sampling,
preparation
of
a
corrosion
control
study,
installation
of
treatment,
public
education,
and
lead
service
line
replacement.
ME
The
Pb&
Cu
sample
summary
results
are
entered
into
SDWIS.
The
water
system
is
mailed
a
letter
that
they
have
exceeded
the
AL
with
the
steps
the
water
system
must
take
within
the
specified
time
limits
for
each
step.
If
the
Lead
AL
was
exceeded
then
the
letter
will
include
a
copy
of
the
Lead
Education
Material
instructing
the
water
system
to
complete
the
Lead
Education
within
60
days.
A
copy
of
the
Lead
Education
Material
must
be
submitted
to
the
State.
The
water
system
is
instructed
to
submit
a
corrosion
control
plan
within
6
months.

Once
the
corrosion
control
plan
is
submitted
the
State
reviews
the
water
quality
parameters
to
determine
the
optimum
corrosion
control
treatment.
The
State
informs
the
water
system
of
the
corrosion
control
treatment
installation
due
date
and
the
date
the
water
system
needs
to
be
optimized.
Once
the
corrosion
control
treatment
is
installed
the
State
reviews
the
water
quality
parameters
to
ensure
the
water
system
is
maintaining
an
optimum
corrosion
control
treatment.
The
State
determines
when
the
water
system
is
optimized
and
will
adjust
the
corrosion
control
water
quality
parameters
when
needed.

NH
The
WSEB
sends
a
letter
to
the
water
system
giving
them
their
latest
90
th
percentile
values
that
also
instructs
them
to
provide
public
education,
proceed
with
water
quality
sampling
and
that
they
need
to
submit
a
n
OCCT.
Compliance
dates
are
given
and
compliance
is
tracked
and
violations
are
given
if
necessary.

RI
State
calculates
action
levels
and
notifies
system
of
compliance
status
in
writing.

Exceedances
trigger
treatment
steps/
public
education.

VT
WSD
staff
sends
a
letter
to
the
water
system
which
requires
the
following:
sampling
for
water
quality
parameters
with
a
specified
due
date
for
reporting
test
results,
sampling
sources
for
lead,
recommending
treatment
within
6
monhts,
and
issuing
public
education
if
the
system
exceeds
the
lead
action
level.
NY
Local
health
offices
receive
regular
lead
and
copper
monitoring
data
from
purveyors
in
their
jurisdictions.
Local
health
offices
evaluate
this
data,
previous
lead
and
copper
data,
and
other
system
information
to
determine
if
90%
results
exceed
the
action
level
and
what
follow
up
actions
may
be
required.
Local
health
offices
direct
systems
that
exceed
an
action
level
to
ensure
they
are
aware
of
their
action
requirements
(
e.
g.
public
education,

supplemental
monitoring,
service
line
replacement)
and
to
return
monitoring
back
to
initial
requirements
(
6
months,
full
sampling
set)
if
the
system
was
on
reduced
monitoring.
The
requirements
for
public
education
and
supplemental
monitoring
are
prescribed
by
state
regulation
in
10NYCRR
Part
5­
1.44.
Requirements
for
lead
service
line
replacements
are
codified
in
10NYCRR
Part
5­
1.48.
Exceedance
of
an
action
level
is
not
a
violation
and
formal
enforcement
actions
based
on
action
level
exceedances
alone
are
not
initiated.

NJ
A
system
that
exceeds
the
action
level
for
Lead
receives
a
letter
from
the
State
detailing
actions
that
must
be
taken
to
come
into
compliance.
These
actions
must
include
Tier
2
Public
Notice
(
Appendix
A
to
Subpart
Q
of
Part
141)
and
Public
Education
materials
­
40
CFR
141.85.
Depending
on
the
size
of
the
system,
it
may
also
include
Water
Quality
Parameter
monitoring,
Source
Water
Monitoring
or
Treatment,
Corrosion
Control
Studies
and
Treatment,
and
Lead
Service
Line
Replacement.
For
a
large
(>
50,000)
system,
a
corrosion
control
studies
40
CFR
141.82
(
c),
State
designation
of
optimal
corrosion
treatment
~(
d)
and
installation
of
corrosion
control
~(
e)
are
required.
Water
quality
monitoring
is
required
to
ensure
compliance
with
State
directives.
If
the
system
already
has
a
corrosion
control
programs
and
STILL
exceeds
lead
action
level,
then
Source
monitoring
and
Treatment
is
required
­
40
CFR
141.83
even
if
it
operates
within
State
specified
parameters.
Replacement
of
Lead
Service
Line
 
40
CFR
141.84
that
is
owned
by
the
water
system
is
the
last
action
undertaken
if
lead
action
level
is
still
exceeded.

NJ
(
cont.)
State
could
modify
designated
optimal
parameters
based
on
additional
data.
For
medium
(
3,300<
population
<
50,000)
and
small
(<
3,300)
systems
that
exceeds
lead
action
level,

treatment
steps
in
40
CFR
141.81
(
e)
is
mandatory.
DE
An
action
level
exceedance
triggers
a
letter
to
the
system
explaining
what
they
need
to
do
next.
If
it
is
a
lead
exceedance
then
public
education
is
required
along
with
the
additional
monitoring
and
we
will
provide
copies
of
the
material
that
must
be
distributed.

MD
The
compliance
deadlines
are
added
to
the
PDWIS
database.
The
water
system
is
contacted
by
telephone
to
discuss
the
deadlines.
The
water
systems
receive
a
revised
monitoring
schedule
each
year
that
indicates
the
required
actions
and
deadlines.

WV
A
form
letter
is
sent
to
the
pws
informing
them
to
begin
Water
Quality
Parameter
testing,

source
water
testing
and
public
education
requirements
(
if
lead
exceedence).
The
system
is
advised
that
additional
treatment
may
need
to
be
installed
and
that
they
should
use
the
data
they
are
collecting
to
decide
on
the
best
course
of
action
to
reduce
the
90
th
percentile
levels.

PA
When
a
system
exceeds
an
action
level,
PA
DEP
staff
notify
the
supplier
in
writing
and
provide
a
list
of
required
follow­
up
actions,
including
a
timeframe
for
completion
of
the
various
activities.
VA
The
results
of
individual
lead
and
copper
tap
samples
are
sent
to
our
respective
Field
Office
by
either
the
state
lab,
by
certified
private
laboratories,
or
by
the
waterworks
owners.
The
Field
Office
staff
calculates
the
90
th
percentile
lead
and
copper
concentrations
from
the
individual
sample
results
and
makes
the
determination
as
to
whether
either
Action
Level
has
been
exceeded.
The
individual
sample
results
and
90
th
percentile
determinations
are
then
transmitted
to
the
waterworks
owner.
Each
transmittal
letter
(
i)
identifies
the
next
required
monitoring
(
both
lead
and
copper
tap
monitoring
and,
if
applicable
Water
Quality
Parameter
monitoring),
(
ii)
recommends
that
the
waterworks
owner
provide
the
results
of
elevated
lead
levels
to
individual
homeowners,
(
iii)
details
any
required
treatment
techniques
that
must
be
initiated
(
corrosion
control
treatment,
public
education,
etc),
and
(
iv)
specifies
any
dates
by
which
the
treatment
techniques
must
be
completed.
If
the
lead
AL
is
exceeded
we
provide
a
draft
of
the
required
Public
Education
text
and
provide
technical
assistance
for
corrosion
control
or
source
water
treatment,
if
required.

AL
Exceedance
letter
sent
requiring
source
water
samples,
a
corrosion
control
plan
or
study,

increased
monitoring
and
public
education
(
if
lead
action
level
exceedance).
Deadlines
are
also
included
in
this
letter.
After
system
submits
corrosion
control
plan,
it
is
evaluated
and
if
approved
system
is
given
deadline
to
make
changes
and
begin
water
quality
parameter
monitoring.
Water
quality
parameter
limits
are
also
set.

GA
The
DWP
determines
which
parameter
AL
was
exceeded,
then
calls
the
system
with
the
information
that
their
system
exceeded
an
AL.
We
then
mail,
fax,
or
e­
mail
the
directions
for
complying
with
the
State
regulations
regarding
a
AL
exceedance.
For
lead,
we
send
Public
Education
(
PE)
guidelines,
Water
Quality
parameter
requirements,
for
copper
only,

the
State
sends
the
WQP
requirements.
The
State
of
Georgia
also
has
contracted
with
the
Georgia
Rural
Water
Association
(
GRWA)
to
conduct
the
WQP
monitoring
and
collect
raw
water
samples
on
every
system
that
wants
to
utilize
this
service.
FL
We
require
the
water
systems
to
do
the
following:
Notify
each
participant
that
exceeded
the
Lead
and/
or
Copper
Action
Level,
giving
health
effects
of
Lead
and/
or
Copper
in
drinking
water
and
possible
corrective
measures.
Submit
copy
of
public
notification
and
public
Education
form
to
the
Department.
Submit
a
water
quality
parameters
sampling
plan
to
the
Department.
Measure
the
water
quality
parameters
and
submit
to
the
Department.
Sample
for
(
point
of
entry)
lead
and
copper.
Perform
a
desktop
evaluation
and
recommend
installation
of
one
or
more
corrosion
control
treatments.
Provide
an
implementation
schedule
for
completing
the
treatment
modifications.

KY
When
the
state
identifies
that
a
system
has
exceeded
the
action
level,
a
letter
is
sent
to
the
system
informing
them
that
they
must
1]
monitor
the
source
water
for
lead
by
a
date
certain;
2]
perform
public
education
as
specified
in
the
regulations;
3]
begin
Water
Quality
Parameter
Testing
of
the
plant
tap
and
3
sites
in
the
distribution
system;
and
4]
return
to
initial
lead
and
copper
monitoring.

MS
The
first
step
in
the
state
process
is
to
allow
the
system
to
complete
all
the
required
public
notification/
public
education.
The
state
then
follows
the
process
outlined
in
the
federal
guidelines/
regulations.
The
state
does
not
require
systems
to
perform
corrosion
control
studies.
This
process
is
completed
by
the
state
and
treatment
recommendations
are
made
by
the
state
to
the
system.
NC
When
the
90
th
percentile
sampling
results
indicate
that
an
exceedance
of
an
action
level
has
occurred,
PWSS
mails
exceedance
letters
to
the
affected
water
systems.
The
exceedance
letters
summarize
the
requirements
of
the
Lead
and
Copper
Rule.
The
letters
further
denote
the
specific
actions
such
as
recommending
corrosion
control
treatment
(
CCT)
and/
or
source
water
treatment
(
SOWT),
monitoring
of
water
quality
parameters
(
WQP)
in
tap
and
source
water,
and
public
education
efforts
(
for
lead
exceedance)
that
the
system
must
take,

and
the
timeframes
in
which
the
actions
must
be
completed.
Included
with
the
exceedance
letters
are
attachments
to
be
used
by
the
water
system
if
public
education
is
required.

These
attachments
are
entitled
"
Public
Education
on
Lead
in
Drinking
Water"
and
"
Guidelines
on
Distributing
Public
Education
on
Lead
in
Drinking
Water."
Also
included
is
a
copy
of
Form
141­
C,
"
Evaluation
Form
for
Corrosion
Control
Treatment,"
for
the
system
to
use
in
examining
its
CCT
recommendation.

SC
When
the
state
has
identified
that
a
system
has
exceeded
the
AL,
the
state
sends
a
Notice
of
Exceedance
letter
to
the
system
notifying
the
system
of
each
requirement
following
an
exceedance.
Each
requirement
is
due
to
the
state
within
the
established
timeframe
set
by
the
LCR
from
the
date
in
which
the
system
received
the
Notice
of
Exceedance.
If
the
system
exceeded
lead,
the
system
is
required
to
compete
the
following:
Issue
Public
Education
(
PE)
to
each
person
served
by
the
water
system
and
provide
a
copy
of
the
PE
to
the
Department
within
60
days
of
receipt
of
the
notice.
Conduct
monitoring
for
source
and
distribution
Water
Quality
Parameters
(
WQPs)
within
30
days
of
receipt
of
the
Notice.

System
must
contract
with
a
private
State­
certified
laboratory
of
their
choice
to
complete
this
requirement.
Conduct
source
water
monitoring
within
6
months
of
receipt
of
the
Notice.
Bottles
will
be
provided
by
the
Department's
Contract
Laboratory.
System
must
collect
samples
within
30
days
upon
receipt
of
bottles.
Submit
an
Optimum
Corrosion
Control
Treatment
recommendation
to
the
department
within
6
months
of
receipt
of
notice.
TN
The
state
routinely
calls
by
telephone
and
discusses
the
results.
An
effort
is
made
to
review
the
sampling
methodology
at
each
sampling
site
and
a
resample
performed
at
any
site
suspected
of
a
sampling
irregularity.
These
include
sampling
at
a
location
other
than
the
typical
drinking
water
location
(
ex:
Swimming
pools,
outside
hydrants,
rarely
used
guests'
bathrooms,
garage
sinks,
newly
installed
faucets),
and
sites
having
been
vacant
prior
to
sampling.
If
the
validated
sites'
sample
results
exceed
the
action
level,
the
system
is
notified
in
writing
of
actions
triggered.
These
include
measuring
Water
Quality
Parameters,

sampling
the
Source
Water
for
lead
and
copper,
performing
Public
Education
for
lead
action
level
exceedances,
submitting
an
Optimal
Corrosion
Control
Treatment
Recommendation
for
evaluation,
and
returning
to
a
monitoring
frequency
of
a
minimum
of
two
consecutive
six­
month
monitoring
periods
and
collecting
the
required
routine
number
of
samples.

MI
District
staff
review
the
results
and
immediately
notify
the
supply
if
it
is
above
either
action
level.
The
DEQ
reviews
the
monitoring
protocol
to
ensure
all
the
sampling
sites
were
properly
sampled
and
that
sampling
was
performed
at
sites
with
plumbing
materials
commonly
found
at
other
locations
in
the
water
system.
At
least
one
of
our
eight
districts
uses
the
attached
Investigation
Form.
pdf
and
others
use
the
criteria
on
this
form
to
ensure
samples
were
taken
properly.
The
staff
might
also
review
the
lead
and
copper
history
of
the
supply
and
of
the
sampling
sites,
especially
those
sites
with
a
history
of
low
results.

Staff
reminds
the
supply
to
perform
water
quality
parameter
sampling,
source
water
sampling,
and
public
education
if
the
90
th
percentile
was
above
the
lead
action
level.
If
previous
results
have
all
been
below
the
action
levels,
then
the
district
staff
may
request
the
system
return
to
full
monitoring
rounds.
Also,
the
district
staff
directs
the
supply
to
conduct
an
optimal
corrosion
control
treatment
study,
unless
the
supply
demonstrates
compliance
with
the
AL
in
subsequent
periods.
IL
Sample
data
is
entered
into
SDWIS/
State
either
manually
or
electronically.
The
SDWIS/
State
LCR
Compliance
Report
"
Action
Level
Exceedence"
is
run
monthly
to
identify
any
new
exceedences.
Once
a
system
is
identified,
the
supply
is
sent
an
initial
action
level
"
packet"
that
explains
corrosion
control
requirements
and
includes
the
lead
public
education
requirements
with
guidance
(
if
lead
AL).

IN
An
action
level
exceedance
letter
is
sent
via
certified
mail
to
the
system
which
outlines
what
steps
need
to
be
taken
and
by
when
(
WQP,
SW,
OCCTR,
PE
if
necessary,
follow­
up
sampling).
Follow­
up
telephone
calls/
letters
are
made
to
systems
that
have
not
submitted
the
required
information
by
the
due
dates
specified.
Systems
that
fail
to
submit
the
information
are
referred
to
enforcement.

MN
If
exceedance
occurs
with
no
known
changes
in
treatment
precesses
or
source,
and
the
historical
results
for
the
site(
s)
had
been
consistently
low
or
below
detections
­
The
MDH
will
contact
the
system
to
investigate
possible
causes,
such
as
interview
sample
collector
and
conduct
site
validation
etc.
If
the
identified
cause
meets
sample
invalidation
criteria,

the
system
will
be
required
to
submit
a
repeat/
replacement
sample(
s).
If
no
unusual
cause
is
identified,
the
MDH
will
issue
a
Notice
of
Exceedance,
requiring
systems
to
start
PE
for
lead
and
take
the
steps
for
OCCT.
MN
(
cont)
If
exceedance
occurs
after
OCCT
­
The
MDH
will
review
both
lead/
copper
and
the
WQPs
results
to
identify
possible
cause
due
to
treatment
upset/
inconsistency
or
unusual
distribution
system
events
prior
to
or
during
tap
monitoring.
MDH
will
issue
a
Notice
of
Exceedance
requiring
systems
to
resume
PE
for
lead
and
take
corrective
steps,
such
as
to
increase
the
inhibitor
dosage
rate,
etc.
If
no
unusual
cause
is
identified
and
a
system
has
been
operating
within
specified
OWQPs,
a
Notice
of
Exceedance
with
revised
OWQPs
specification
will
be
issued,
requiring
systems
to
start
PE
for
lead
and
to
step
up
to
meet
the
revised
OWQP
specifications.

OH
Ohio
EPA
staff
send
a
letter
with
instructions
detailing
actions
the
system
needs
to
take.

Due
dates
are
established
for
these
required
actions
and
the
system
is
tracked
to
make
sure
that
it
is
completing
the
required
actions
in
the
specified
time
frame.

WI
The
PWS
data
system
calculates
the
90
th
percentile
of
lead/
copper
samples.
The
Regional
representative
sends
a
letter
to
the
system
operator
that
outlines
required
milestones
they
must
complete.
The
PWS
data
system
tracks
compliance
with
milestones.

AR
We
follow
requirements
set
forth
in
141.80­
141.90.

LA
Upon
determination
that
an
action
level
has
been
exceeded,
the
state's
Lead
and
Copper
Program
Coordinator
sends
a
letter
to
the
water
system
notifying
them
of
the
exceedence.

Included
in
this
letter
is
a
step­
by­
step
outline
of
the
process
the
system
must
complete
in
order
to
maintain
compliance
with
the
Rule.
A
copy
of
this
letter
is
included
as
Appendix
B
of
this
response.

NM
Issue
notice
of
Violation,
increase
monitoring,
and
require
treatment
if
it
is
deemed
necessary.
Then
start
with
informal
enforcement
to
formal
enforcement.

OK
Notice
of
Exceedence
>
System
responds
to
NOE
>
Corrosion
Control
Study
>
CCS
recommendation
>
Corrosion
Control
Treatment
begins
>
sampling.
TX
Based
on
90%
percentile
results,
TCEQ
sends
PWSs
a
packet
containing
a
letter
stating
the
systems
90%
exceedance
and
their
sample
results
report.
They
will
receive
a
initial
Water
Quality
Parameter
(
WQP)
form
with
instructions
and
the
Desktop
Corrosion
Control
Study
141­
C.
For
lead
exceedance
they
receive
Public
Education
Materials
which
they
are
required
to
post.

KS
After
the
state
identifies
that
a
system
has
exceeded
the
lead
action
level,
the
system
is
mailed
a
letter
indicating
the
lead
action
level
has
been
exceeded.
The
letter
informs
the
system
that
lead
public
education
must
be
completed
within
sixty
days,
water
quality
parameter
samples
collected,
and
a
treatment
recommendation
submitted
to
the
state
within
six
months.
In
addition
to
the
letter,
the
system
is
provided
with
aUSEPA­
developed
public
education
guidance
manual,
a
mandatory
written
language
guide,
a
quick
reference
guide
for
systems
that
exceed
the
lead
action
level,
and
a
blank
form
for
submitting
a
corrosion
control
treatment
recommendation.
The
KDHE
lab
is
notified
to
provide
the
system
with
WQP
sample
containers,
the
90th
percentile
is
entered
into
SDWIS/
State,
and
the
deadlines
are
entered
into
Lotus
Notes.

MO
Confirmation
samples
may
be
ordered.
Source
water
samples
are
ordered.
An
exceedence
letter
is
sent
spelling
out
the
requirements
of
the
rule.

NE
We
mail
letters
to
the
water
system's
designated
`
owner'
and
to
its
designated
operator.

This
letter
states
in
detail
the
actions
that
must
be
taken
by
the
water
system
along
with
a
timeline
for
completion
of
each
step.
The
letter
also
encourages
the
system
to
collect
more
rounds
of
samples
in
a
timely
manner
to
either
confirm
or
eliminate
the
need
for
corrosion
control
treatment.
CO
When
an
exceedance
is
identified
by
the
LCR
Manager
a
letter
is
sent
to
the
PWS.
The
letter
notifies
the
system
of
the
exceedance,
presents
the
calculated
results
and
details
the
steps
to
be
taken
to
complete
the
water
quality
parameter
monitoring,
source
water
monitoring
and
public
education
where
applicable.
It
sets
deadline
dates
to
complete
the
sampling,
prepare
a
treatment
recommendation
for
submission
to
the
State,
and
complete
the
public
education
requirement.
The
letter
sets
a
deadline
for
the
system
to
get
in
touch
with
a
contact
in
the
Technical
Services
Unit
in
order
to
begin
a
desk
top
study
to
gather
data
for
an
optimal
corrosion
control
treatment
plan.
In
addition,
the
letter
outlines
the
instructions
for
performing
public
education
and
details
the
means
by
which
the
system
is
to
disseminate
the
message
to
the
public.
The
mandatory
language
for
public
education
is
enclosured
along
with
an
education
brochure
on
the
health
effects
of
lead
and
copper.
A
copy
of
the
letter
is
sent
to
the
contact
in
the
State's
Technical
Service
Unit,
the
Local
Health
Department
and
the
District
Engineer.

CO
(
cont.)
The
90th
percentile
data
is
then
entered
into
SDWIS
and
a
spreadsheet
maintained
by
the
LCR
Manger
is
updated
as
to
the
progress
of
the
system
through
the
public
education
process
(
where
applicable)
and
corrosion
control
study.

MT
The
state
follows
the
requirements
as
outlined
in
state
law
and
rules
(
federal
rules
adopted
by
reference).
ND
With
a
lead
action
level
exceedance,
the
first
step
the
system
must
do
is
to
conduct
a
public
education
program
as
required
by
the
LCR.
This
must
be
done
within
sixty
days
of
the
date
of
the
letter
informing
the
system
of
the
exceedance,
and
repeated
every
twelve
months
(
six
months
for
public
service
announcements)
for
as
long
as
the
exceedance
occurs.
The
system
must
submit
copies
of
the
public
education
program
by
the
end
of
each
year
the
lead
action
level
continues.
The
public
education
program
is
not
required
for
a
copper
action
level
exceedance.
The
following
are
requirements
of
both
a
copper
and
lead
action
level
exceedance:
the
system
must
conduct
water
quality
parameter
and
source
lead/
copper
monitoring
before
the
end
of
the
next
six­
month
monitoring
period.
The
system
must
submit
a
desktop
study
(
plan
to
solve
the
problem)
within
six
months
of
the
date
of
the
exceedance
letter.
After
the
desktop
study
is
reviewed
and
approved
the
system
has
twentyfour
months
to
install
treatment.
The
system
must
then
conduct
follow­
up
monitoring
starting
the
first
six­
month
period
after
the
treatment
is
installed.

SD
We
require
the
system
to
do
a
public
notice
and
a
public
education
program
if
they
exceeded
the
lead
action
level.
The
system
must
begin
source
water
sampling
and
start
a
corrosion
control
study.
The
system
then
is
required
to
implement
the
corrosion
control
program
and
begin
water
quality
parameter
monitoring.
The
system
then
begins
routine
tap
sampling
and
if
those
samples
are
below
the
action
level
then
the
system
may
be
put
on
reduced
tap
monitoring.
UT
The
water
system
is
contacted
by
phone
and
the
issue
is
discussed.
First
the
operator
is
instructed
to
collect
more
samples
to
validate
the
results.
If
the
water
system
has
existing
corrosion
control
treatment,
then
the
State
begins
a
process
of
evaluation
to
ensure
optimal
corrosion
control.
For
water
systems
that
have
not
had
a
problem
before,
we
discuss
the
treatment
options
listed
in
Utah
rule
R309­
210­
6(
4).
The
water
systems
then,
following
an
investigation
to
determine
the
optimal
treatment
chemical
and
design
parameters,

recommends
installation
of
one
or
more
of
the
corrosion
control
treatment
technologies
listed
in
the
rule.
The
State
may
require
the
system
to
do
further
investigations
or
provide
more
tests
or
documentation
justifying
the
selected
corrosion
control
chemicals
and
treatment
to
ensure
the
selected
alternative
is
indeed
optimal
treatment
for
the
water
being
treated.

UT
(
cont)
The
State
either
approves
the
corrosion
control
treatment
option
recommended
by
the
system,
or
designates
alternative
corrosion
control
treatment(
s)
from
among
those
listed
in
the
rule.
The
system
properly
installs
and
operates
the
optimal
corrosion
control
treatment
designated.
The
State
then
evaluates
the
results
of
all
lead
and
copper
tap
samples
and
water
quality
parameter
samples
submitted
by
the
water
system
and
determines
whether
the
system
has
properly
installed
and
operated
the
optimal
corrosion
control
treatment.

WY
A
letter
is
sent
to
the
water
system
notifying
them
that
the
lead
and/
or
copper
action
levels
were
exceeded.
The
letter
includes
detailed
information
on
what
needs
to
be
done
next.

This
includes
water
quality
parameter
monitoring,
optimal
corrosion
control
treatment
information.
The
water
system
is
also
informed
that
it
can
seek
to
return
to
compliance
through
monitoring.
This
involves
monitoring
for
two
consecutive
six­
month
periods
and
collecting
the
standard
number
of
samples
according
to
population
served
by
the
water
system.

AZ
By
fed
regulation
procedures.
E.
g.
Public
notice,
corrosivity,
etc.
CA
Pursuant
to
40
CFR
141.85
we
work
with
the
system
to
develop
and
provide
public
education
materials.
If
the
system
has
lead
service
lines
we
would
require
replacement
pursuant
to
40
CFR
141.84.
We
have
not
had
any
systems
to
date
that
have
had
to
replace
lead
service
lines
after
exceeding
the
action
level.

HI
The
State
notifies
the
water
system
in
writing
that
the
action
level
has
been
exceeded,
and
will
identify
each
action
item
triggered
when
the
action
level
was
exceeded.
The
notification
letter
also
identifies
the
specific
dates
when
each
action
item
must
be
completed.

NV
First
we
evaluate
why
there
is
an
apparent
exceedance,
to
determine
if
there
actually
is
an
exceedance.
If
there
is,
we
require
Water
Quality
Parameter
monitoring,
development
of
a
corrosion
control
plan,
and
public
notification
to
be
carried
out.

Amer
Sam
ASEPA
notifies
ASPA,
the
utility,
guiding
them
through
the
requirements
of
40
CFR
141.81
and
141.82
and
advising
them
on
the
requirements
for
delivery
of
a
public
education
program
per
40
CFR
141.85.

Navajo
The
PWSSP
receives
sample
results
which
are
evaluated
prior
to
being
entered
into
a
database.
If
there
are
exceedances
of
the
action
level,
then
the
system
is
notified
through
informal
letters
of
noncompliance.
Confirmation
samples
are
requested.
PWSSP
uses
the
NNPDWR
to
begin
corrosion
control
and
recommends
pipe
replacement.
For
example,
a
maintenance
worker
took
samples
from
a
preschool
at
the
request
of
an
official
inspection
report
of
the
facility.
The
maintenance
worker
found
that
the
lead
levels
in
the
kitchen
sink
were
elevated.
PWSSP
recommended
pipe
replacement
to
the
preschool
staff.
The
maintenance
worker
replaced
the
pipes
and
took
another
sample.
The
lead
levels
were
found
to
be
below
the
action
level.
The
preschool
purchases
water
from
a
purveyor
and
was
not
listed
on
the
purveyor's
site
sampling
plan.
AK
The
system
is
notified
that
it
has
exceeded
the
AL.
A
review
of
the
sampling
protocol
is
made
with
the
operator
and
it
is
determined
whether
or
not
the
sample
collection
protocol
was
followed.
If
the
results
are
valid,
the
system
is
instructed
to
collect
samples
for
WQPs
and
may
be
required
to
do
a
corrosion
control
study
and
implement
corrosion
control.

WA
After
DOH
becomes
aware
of
the
exceedance,
staff
provides
detailed
corrosion
control
packet(
s)
(
Lead
only,
Copper
only,
or
Lead
and
Copper).
DOH
directs
systems
to
submit
corrosion
control
recommendations
or
Water
Quality
Parameter
information
and
DOH
can
use
"
Black
and
Veech
­
Corrosion
Control
Recommendation
Guidance"
to
offer
one
or
more
potential
recommendations.

ID
Idaho
requires
a
corrosion
study
with
water
quality
parameters
and
lead
tap
samples
from
5
or
more
taps
for
four
consecutive
quarters.
The
correlation
between
lead
levels
and
water
quality
parameters
is
examined
with
the
most
practical
numbers
being
used
with
together
with
EPA
guidance
to
determine
optimal
corrosion
control.

OR
In
the
initial
years
of
implementing
the
LCR,
the
state
sent
out
extensive
letters
following
an
exceedance.
The
letter
detailed
everything
the
system
must
do
to
come
back
into
compliance.
The
state
then
did
followup
which
each
system
until
they
returned
to
compliance.
They
recently
reviewed
the
database
and
found
a
few
instances
of
systems
above
the
action
level.
The
database
flags
exceedances.
The
state
intents
to
go
through
the
same
process
for
these
systems.
Before
sending
out
any
information,
they
will
verify
that
the
high
samples
are
representative
samples
and
not
invalid.
Questions
on
State
Implementation
of
the
Lead
and
Copper
Rule
July,
2004
Calculation
of
90th
Percentile
State
Full
Response
Describe
the
protocol
used
by
the
state
to
invalidate
samples.
MA
DEP
protocol
is
based
on
instructions
from
EPA
Region
1
and
is
contained
in
310
CMR
22.06B(
7)(
f).

ME
The
water
system
must
submit
the
request
in
writing
outlining
the
reasons
behind
the
request.

The
State
will
review
the
circumstances
concerning
each
request
for
invalidation.
The
State
will
inform
the
water
system
in
writing
if
a
sample
can
or
cannot
be
invalidated.
Water
systems
are
not
allowed
to
challenge
the
results
based
on
customer
sampling
error,
prior
sample
results
or
additional
sample
results.
Water
systems
can
request
a
sample
to
be
invalidated
because
the
customer
contaminated
the
sample
container,
or
the
customer
installed
a
water
treatment
system
without
notifying
the
water
system.
For
NTNC
water
systems
Pb&
Cu
samples
have
been
invalidated
because
the
"
Water
Sampler"
used
invalid
sample
sites
such
as
Janitor
deep
sinks,

boiler
room
taps
or
outside
hose
bibs,
and
then
only
when
the
"
Chain
of
Custody
Form"
specifies
the
sample
site.

RI
No
answer.

VT
The
state
rarely
invaildates
samples.
Samples
are
invalidated
due
to
a
lab
error
or
inappropriate
sampling
site.
The
state
requires
the
water
system
to
submit
a
written
request
to
invlidate
a
sample.

NH
The
system
must
first
take
water
quality
samples.
If
the
water
appears
non­
corrosive,
resamples
may
be
allowed.
In
all
cases
a
confirmation
sample
request
in
writing
is
required.
CT
The
CTDPH
 
DWD
is
not
receiving
or
accepting
any
formal
written
invalidation
requests
from
any
Public
Water
Systems.
However,
the
CTDPH
 
DWD
has
initiated
the
process
of
invalidating
samples
based
on
a
determination
that
the
sample
was
taken
from
a
site
that
did
not
meet
the
site
selection
criteria
and
therefore,
was
not
an
approved
sample
site
location
per
the
invalidation
criteria
within
the
B102
regulations
and
40
CFR
141.86(
f)(
1)(
ii).
It
should
be
noted
that
there
have
been
instances
in
which
Public
Water
Systems
have
requested
that
samples
be
invalidated
based
on
the
analysis
results
being
significantly
higher
than
the
remaining
samples
submitted
for
compliance.
In
large
part,
these
requests
have
been
denied.

NY
Invalidation
of
lead
samples
are
uncommon.
Determinations
for
sample
invalidation
are
handled
case
by
case
by
local
health
offices.
Generally,
lead
or
copper
samples
would
not
be
subject
to
invalidation
unless
the
purveyor
provided
evidence
of
a
laboratory
problem,
if
a
sample
was
destroyed
in
transit,
or
if
the
sample
location
was
from
outside
the
approved
sampling
pool.

Unexpected
results
by
themselves
are
not
grounds
for
invalidation.

NJ
The
State
typically
invalidate
samples
under
any
of
following
condition:
Sample
container
is
damaged,
Sample
is
subjected
to
any
form
of
tampering,
Improper
sample
analysis
is
followed,

Site
selection
criteria
is
not
followed.

MD
A
written
request
must
be
received
from
the
water
system.
The
typical
reasons
for
invalidating
a
sample
include:
improper
sample
site
(
tap
is
not
used
for
consumption
 
e.
g.
janitor's
mop
sink;

outdoor
hose
bibs;
showerhead,
etc.)
and
laboratory
error.

DE
We
work
with
the
system
to
determine
if
a
sample
should
be
invalidated.
The
main
reason
for
invalidating
a
sample
is
that
it
was
not
collected
under
the
proper
sampling
protocol,
i.
e.,
the
water
sat
too
long
before
collection
such
as
a
homeowner
collecting
the
sample
after
returning
from
vacation.

WV
WV
has
adopted
the
federal
rules
by
reference,
therefore,
only
those
requests
that
fit
the
federal
rules
will
be
considered.
Unaware
that
any
samples
have
qualified
for
invalidation
to
date.
PA
As
per
the
minor
revisions
to
the
LCR,
PA
DEP
staff
may
invalidate
Pb/
Cu
tap
samples
if
the
lab
establishes
that
improper
sample
analysis
caused
erroneous
results,
DEP
determines
that
the
sample
was
taken
from
a
site
that
did
not
meet
the
site
selection
criteria,
the
sample
container
was
damaged,
or
if
there
is
substantial
reason
to
believe
that
the
sample
was
tampered
with.

DEP's
decision
and
rationale
for
invalidating
a
sample
is
documented
in
PADWIS
and/
or
in
the
system's
file.

VA
Virginia
basically
follows
the
invalidation
criteria
contained
in
the
Lead
and
Copper
Rule.
We
would
invalidate
a
lead
and
copper
tap
sample
if
any
of
the
following
conditions
are
met:
(
i)
The
laboratory
establishes
that
improper
sample
analysis
caused
erroneous
results,
(
ii)
the
sample
was
taken
from
a
site
that
did
not
meet
the
original
materials
survey
selection
criteria,
(
iii)
the
sample
container
was
damaged,
or
(
iv)
there
is
substantial
reason
to
believe
that
the
sample
was
subject
to
tampering.
Invalidated
samples
are
not
included
in
determining
lead
or
copper
90
th
percentile
concentrations.

FL
The
cause
must
fall
into
one
of
the
4
criteria
established
in
40
CFR
141.86(
f)(
1)
for
invalidation
of
samples.
The
system
must
report
the
result(
s)
of
samples
for
which
invalidation
is
requested.

If
we
invalidate,
the
system
is
informed
in
writing.
The
system
then
has
20
days
in
which
to
collect
a
replacement
sample
from
the
same
location
or,
if
not
available,
from
a
location
with
the
same
tier
characteristics.

KY
Kentucky
has
no
specific
protocol
for
invalidation
of
lead
and
copper
samples.
We
would
only
consider
invalidating
samples
if
we
were
provided
with
written
documentation
of
improper
sample
collection
or
analysis.

MS
The
state
uses
the
conditions
specified
in
40
CFR
141.86(
f)(
1)(
i­
iv)
for
determining
whether
or
not
a
sample
can
be
invalidated.
(
Improper
sample
analysis,
invalid
site
selection
criteria
utilized,

damaged
container,
or
sample
tampering).
NC
According
to
40
CFR
141.86(
f)(
1),
samples
may
be
invalidated
if
at
least
one
of
the
following
conditions
applies:
the
laboratory
establishes
that
improper
sample
analysis
caused
erroneous
results,
the
sample
was
taken
from
a
site
that
did
not
meet
the
site
selection
criteria,
the
sample
was
damaged
in
transit,
substantial
reason
exists
to
believe
that
the
sample
was
subject
to
tampering.
The
rule
manager
may
also
invalidate
samples
if
it
is
determined
that
the
sample
collected
was
not
representative
of
water
that
would
normally
be
expected
at
a
sampling
site.

Water
systems
that
request
invalidation
of
a
sample
must
do
so
in
writing
and
explain
the
circumstances
and
the
rationale
for
the
requested
invalidation.
The
rule
manager
reviews
the
request
and
responds
to
the
water
system
in
writing.

AL
If
approved
the
system
is
given
a
time
frame
to
collect
a
replacement
sample.

SC
The
Department
may
invalidate
a
sample
if
one
of
the
following
conditions
is
met:
the
lab
establishes
that
improper
sample
analysis
caused
erroneous
results;
the
Department
determines
that
the
sample
was
collected
from
a
site
that
did
not
meet
the
site
selection
criteria;
the
sample
container
was
damaged
in
transit;
or,
there
is
substantial
reason
to
believe
the
that
the
sample
was
subject
to
tampering.

TN
Samples
are
rarely
invalidated.
Occasionally
a
homeowner
will
admit
the
sample
was
collected
from
a
private
well
or
another
water
system.
We
inquire
of
the
viability
of
the
sampling
location
and
the
methodology
employed
during
sampling.
If
the
samples
taken
were
suspect,
a
resample
is
requested
and
the
two
results
compared.
Circumstances
which
may
make
a
sample
suspect
include
extended
stand
time
of
the
water
due
to
residents
absence
prior
to
sampling,
or
the
sampling
of
a
`
different'
location
not
typically
the
drinking
water
source,
or
a
location
of
minimal
use,
or
plumbing
maintenance.
Questions
are
asked
of
the
operators
concerning
adjustments
of
pH
or
chemical
feed
rates
or
supplier,
etc.

GA
Georgia
follows
the
federal
regulation
according
to
40
CFR
141.86(
f)(
1­
6).

IN
The
system
must
send
a
written
request
to
the
state,
once
received
the
state
reviews
the
request
and
denies/
grants
it
based
on
the
merit
of
the
reason
why
the
system
has
asked
for
a
sample
to
be
invalidated.
MN
All
SDWA
compliance
monitoring,
including
for
the
LCR,
is
coordinated
through
our
Drinking
Water
Program.
Annual
monitoring
schedules
are
provided
to
systems
prior
to
1/
1
of
each
year.

MDH
coordinates
with
the
MDH
Lab
and
contract
labs
to
send
out
sample
bottles,
receive
and
analyze
samples.
Once
the
analyses
are
completed,
the
labs
provide
results
to
MDH,

electronically.
For
the
LCR,
water
systems
also
receive
a
paper
copy
of
the
results
from
the
contract
lab.
However,
calculation
of
the
90th
percentile
level
for
lead/
copper
is
done
at
the
MDH.
Official
reports
are
then
sent
to
the
systems.
Systems
need
only
to
verify
the
results
but
need
not
send
the
report
back.
Since
systems
normally
receive
the
results
1­
2
days
ahead
of
the
MDH,
questions
with
the
test
results,
are
brought
to
our
attention
in
a
timely
manner.
If
the
cause
for
questionable
result/
sample
is
known,
and
meet
one
or
more
of
the
LCR
sample
invalidation
criteria,
the
result
is
invalidated,
sample
bottle
for
re­
sampling
will
be
sent,
and
the
new
results
will
be
used
in
calculating
the
90th
percentile
levels.

MN
(
Cont.)
Invalidation
could
be
due
to
Sample
was
taken
from
outside
tap.
Sample
was
taken
from
a
softened
tap.
Sample
site
does
not
meet
tier
criteria
specified
in
the
rule.
Sample
was
taken
from
tap
that
has
not
been
used
for
sometime.
Inconsistent
result(
s)
compared
to
previous
result(
s).

Error
in
sampling
process.
Resample
requested
by
Minnesota
Department
of
Health.
Other
(
explain
briefly)

OH
The
protocol
used
to
invalidate
samples
is
contained
in
rule
3745­
81­
86(
F)
of
the
Ohio
Administrative
Code
and
is
analogous
to
paragraph
(
f)
of
40
CFR
141.86.
Samples
have
been
invalidated
in
Ohio
for
reasons
such
as
collecting
from
outside
faucets,
collecting
outside
the
monitoring
period,
collecting
from
a
changed
site
without
proper
explanation
for
the
change,
or
collecting
from
a
site
that
was
know
to
have
not
sat
for
the
minimum
stand
time.
However,
there
have
been
a
few
cases
where
samples
have
been
invalidated
where
water
has
sat
in
the
line
for
more
than
two
weeks.
Invalidation
would
occur
only
upon
a
written
signed
statement
by
the
owner.
WI
The
protocol
used
to
invalidate
samples
is
contained
in
rule
3745­
81­
86(
F)
of
the
Ohio
Administrative
Code
and
is
analogous
to
paragraph
(
f)
of
40
CFR
141.86.
Samples
have
been
invalidated
in
Ohio
for
reasons
such
as
collecting
from
outside
faucets,
collecting
outside
the
monitoring
period,
collecting
from
a
changed
site
without
proper
explanation
for
the
change,
or
collecting
from
a
site
that
was
know
to
have
not
sat
for
the
minimum
stand
time.
However,
there
have
been
a
few
cases
where
samples
have
been
invalidated
where
water
has
sat
in
the
line
for
more
than
two
weeks.
Invalidation
would
occur
only
upon
a
written
signed
statement
by
the
owner.

MI
The
water
system
would
contact
the
state
to
discuss
what
they
felt
were
reasons
to
invalidate
a
particular
analysis,
such
as
the
use
of
a
tap
other
than
a
cold
water
kitchen
tap
or
bathroom
sink,

or
one
not
representative
of
the
monitoring
protocol
established
by
the
LCR.
If
the
MDEQ
agreed
with
the
invalidation,
we
would
ask
them
to
send
us
a
written
explanation
that
we
could
approve
and
place
in
the
files.

IL
The
water
system
must
submit
written
request
with
justification.
Procedures
as
specified
in
40
CFR
141.86(
f)
are
followed
in
determining
whether
invalidation
is
granted.
If
a
determination
is
made
to
invalidate
a
sample,
the
sample
and
sample
results
are
rejected
in
SDWIS/
State
indicating
the
reason
and
SDWIS/
State
recalculates
the
sample
summaries.

AR
We
follow
requirements
set
forth
in
141.86(
f).

LA
In
order
for
the
State
to
invalidate
samples,
a
water
system
must
make
such
a
request
in
writing.

The
public
water
system
must
outline
the
exact
reasons
as
to
why
the
sample(
s)
should
be
invalidated.
Acceptable
reasons
for
invalidation
include
sampling
from
a
site
that
had
previously
been
mistakenly
approved
and
sampling
from
a
tap
other
than
a
kitchen
or
bathroom
faucet.
The
requirement
for
a
written
request
for
invalidation
is
waived,
however,
if
the
state's
program
coordinator
determines
a
laboratory
accident
to
be
the
cause
of
erroneous
data.

NM
When
the
state
invalidates
any
samples
the
protocol
is
followed
as
stated
in
the
regulations.

OK
Lab
error,
contaminated
or
broken
bottle,
System
notifies
DEQ
that
sample
was
collected
by
incorrect
method.
TX
PWSs
must
request
invalidation
in
writing
if
the
sample
is
not
representative
of
the
systems
water
quality.
An
example
is
that
the
homeowner
has
a
water
softener
and
did
not
state
this
during
site
selection
process.

IA
A
written
request
for
invalidation
is
required
from
the
system
for
a
sample
that
they
wish
to
be
invalidated.
The
state
reviews
the
reasons
for
the
requested
invalidation,
and
responds
by
letter
to
the
request.
If
allowed
to
invalidate
that
sample,
the
system
is
required
to
collect
another
sample
so
that
they
meet
the
monitoring
requirements.
In
the
majority
of
cases,
it's
actually
the
sample
site
that
is
invalidated,
usually
due
to
the
installation
of
a
water
softener
or
refusal
of
the
homeowner
to
participate
in
the
program
anymore.

NE
At
minimum,
a
written
statement
by
the
certified
water
operator
for
the
system
is
required.
The
reason
given
for
the
invalidation
request
is
considered
and
approved
or
denied
by
the
Lead
&

Copper
Rule
Monitor
(
currently
Steve
Drda).
Sometimes
we
utilize
one
of
our
State
Field
Representatives
to
investigate
the
claim
made
by
the
water
operator
by
independently
contacting
the
sample
site
owner,
or
personally
investigating
the
site.

MO
When
a
sample
result
is
reviewed,
or
it
is
determined
that
an
invalid
site
was
used
he
system
is
called
by
the
coordinator.
If
the
coordinator
determines,
after
discussions
with
the
operator,
that
the
site
or
procedures
were
not
according
to
protocol
the
coordinator,
at
his
discretion,
may
invalidate
a
sample(
s).

KS
The
state
will
authorize
invalidation
of
a
tap
sample
if
the
laboratory
documents
that
the
sample
was
analyzed
improperly,
the
sample
was
collected
from
an
improper
site,
the
sample
container
was
damaged
in
transit,
or
the
sample
was
subject
to
tampering.
To
request
sample
invalidation,

a
system
must
report
the
results
of
all
the
samples
to
the
state,
and
provide
supporting
documentation
for
all
the
samples
to
be
invalidated.
The
state
will
provide
the
system
with
written
documentation
indicating
whether
or
not
the
sample
will
be
invalidated,
and
notification
of
replacement
samples
when
required..
If
replacement
samples
are
required,
the
KDHE
lab
is
notified
to
schedule
replacement
samples.
Invalidated
samples
are
not
used
for
compliance
and
are
not
included
in
calculation
of
the
90th
percentile.
CO
The
State
may
invalidate
a
sample
pursuant
to
40
CFR
141.86(
f).
The
State
has
notified
public
water
systems
that
if
they
believe
there
is
substantial
reason
that
a
lead
or
copper
sample
should
be
invalidated
it
must
request
this
in
writing.
The
request
is
required
to
state
all
the
pertinent
facts
and
the
reasons
why
the
public
water
system
believes
the
sample
should
be
invalidated.

Invalidation
of
samples
will
not
occur
solely
based
on
the
fact
that
a
follow­
up
sample
result
is
higher
or
lower
than
the
original
sample.
The
State
does
not
accept
replacement
samples
prior
to
the
approval
of
the
invalidation
request.
Once
approval
has
been
given,
the
system
is
required
to
resample
at
the
same
site
or
at
a
replacement
site
approved
of
by
the
State
when
applicable.

MT
A
system
that
can
demonstrate
that
the
samples
reported
do
not
represent
the
system
as
defined
in
the
LCR,
may
be
allowed
by
the
department
to
resample,
collect
additional
samples,
or
otherwise
supply
information
that
may
be
used
in
the
compliance
decision
making
process.

ND
Generally
the
only
time
we
invalidate
samples
is
when
the
sample
was
collected
inappropriately
(
i.
e.,
sample
was
collected
from
the
wrong
place
or
water
had
sat
for
an
extended
period
of
time).
In
cases
where
the
water
had
sat
for
an
extended
time,
we
require
a
follow­
up
sample
to
ensure
that
the
lead
and
copper
results
come
back
significantly
lower.

SD
Normally
we
don't
invalidate
many
samples,
the
answer
to
the
next
question
describes
how
we
replace
some
samples.

UT
According
to
Utah
rule
R309­
210­
6(
f),
the
State
may
invalidate
a
lead
or
copper
tap
water
sample
if
one
of
the
following
conditions
is
met.
(
A)
The
laboratory
establishes
that
improper
sample
analysis
caused
erroneous
results.
B)
The
State
determines
that
the
sample
was
taken
from
a
site
that
did
not
meet
the
site
selection
criteria
of
this
section.

UT
(
cont)
(
C)
The
sample
container
was
damaged
in
transit.
(
D)
There
is
substantial
reason
to
believe
that
the
sample
was
subject
to
tampering.
The
system
reports
the
results
of
all
samples
to
the
State
and
all
supporting
documentation
for
any
samples
the
system
believes
should
be
invalidated.
The
water
system
must
collect
replacement
samples
for
any
samples
invalidated
under
this
section.
If
the
system
has
too
few
samples
to
meet
the
minimum
requirements,
replacement
samples
must
be
taken
as
soon
as
possible
(
no
later
than
20
days
after
the
date
the
State
invalidates
the
sample
or
by
the
end
of
the
applicable
monitoring
period,
whichever
occurs
later).
WY
Region
8
follows
the
protocol
in
40
CFR
141.86
(
f)

AZ
Require
sufficient
documentation
to
make
invalidation
determination.

CA
We
would
invalidate
a
sample
pursuant
to
40
CFR
141.86(
f).

HI
The
State
uses
the
protocol
in
§
141.86(
f)
of
the
Lead
and
Copper
Rule.

NV
We
compare
the
sample
result
to
past
data
from
the
same
site,
assure
that
the
sample
was
from
the
site
listed,
review
who
collected
the
sample
and
the
procedure
used,
and
follow
the
criteria
in
40CFR
141.86(
f).

Navajo
§
710
(
F)
of
the
NNPDWR
(
40
CFR
§
141.86(
f))
outlines
the
process
for
invalidating
samples.

"
3.
To
invalidate
a
sample
under
subsection
(
F)(
1)
of
this
section,
the
decision
and
the
rationale
for
the
decision
must
be
documented
in
writing.
The
Director
may
not
invalidate
a
sample
solely
on
the
grounds
that
a
follow­
up
sample
result
is
higher
or
lower
than
that
of
the
original
sample."

Amer
Sam
ASEPA
follows
40
CFR
Section
141.86(
f).

AK
If
samples
were
taken
in
a
wrong
location,
or
from
a
faucet
that
is
not
in
routine
use,
or
exceeded
the
allowable
hold
time,
or
otherwise
taken
improperly,
the
sample
will
be
invalidated.
System
will
then
be
told
to
resample.

WA
Systems
must
submit
written
justification
for
invalidating
samples.
Some
reasons
for
invalidating
samples
and
re­
sampling
include
water
sitting
too
long
in
pipes
or
a
sample
collected
from
an
unoccupied
home.

ID
Federal
regulations
govern
when
it
is
appropriate
to
invalidate
samples.
Idaho
works
to
educate
systems
about
sampling
so
that
invalidation
is
seldom
if
ever
necessary.

OR
Initially
this
was
done
on
a
case
by
case
basis.
The
state
looks
at
if
the
sample
was
taken
after
the
correct
amount
of
time,
at
the
correct
location
(
tap
used
for
drinking
water).
They
want
to
ensure
it
is
a
representative
sample.
If
the
state
allows
for
the
replacement
of
samples
for
reasons
other
than
invalidation,

please
provide
the
conditions
under
which
such
replacement
is
allowed.
CT
In
large
part,
requests
of
this
nature
have
been
denied.
The
CTDPH
 
DWD
has
interpreted
the
B102
regulations
and
40
CFR
141.86(
f)
as
not
to
include
any
provisions
for
replacement
samples.

MA
DEP
does
not
allow
replacement
samples
for
reasons
other
than
invalidation.

ME
N/
A
NH
The
system
must
first
take
water
quality
samples.
If
the
water
appears
non­
corrosive,
resamples
may
be
allowed.
In
all
cases
a
confirmation
sample
request
in
writing
is
required.

RI
No
answer.

VT
Replacement
samples
are
allowed
when
a
sampler
uses
an
inappropriate
sampling
site
or
improper
sampling
technique.
Water
Systems
are
required
to
document
in
writing
any
changes.

NY
We
are
not
aware
of
any
instances
where
state
or
local
health
offices
in
NY
allowed
sample
replacement
for
reason
other
than
invalidation.

NJ
Replacement
samples
are
only
required
when
systems
would
have
too
few
samples
to
meet
minimum
sampling
requirements.

DE
We
have
found
that
many
systems
must
find
new
locations
due
to
lack
of
continuing
interest
on
the
part
of
homeowners
who
have
participated
in
the
past.

MD
N/
A
WV
Only
two
instances
comes
to
mind:
(
1)
non
transient
non
community
systems
have
collected
a
sample
from
a
water
tap
that
has
been
idle
for
several
months.
The
results
are
obviously
not
indicative
of
the
water
the
consumer
would
have
access
and
should
not
have
been
part
of
the
sampling
program.
(
2)
The
laboratory
for
some
reason
did
not
analyze
the
samples,
gave
us
a
letter
admitting
that
they
did
not
analyze
(
the
laboratory's
fault)
we
allowed
the
system
to
sample
out
of
the
seasonal
period
(
June,
July,
August,
September)
to
obtain
replacement
samples.
The
thinking
was
that
the
system
did
obtain
the
samples
and
made
a
good
faith
effort
to
collect
the
samples­
and
after
sending
the
results
to
the
laboratory,
it
was
not
their
fault
that
the
samples
were
not
analyzed.

PA
PA
DEP
does
not
allow
for
the
replacement
of
samples
for
reasons
other
than
invalidation.

VA
Virginia
currently
does
not
have
a
standing
policy
on
replacement
samples.
The
need
for
replacement
samples
would
be
determined
by
the
Field
Office
staff
on
a
case­
by­
case
basis
depending
upon
the
monitoring
history
of
the
waterworks
and
other
factors.
Some
situations
where
we
would
request
waterworks
owners
to
submit
a
replacement
sample
include
(
i)
samples
that
were
less
than
1­
liter
in
volume,
(
ii)
samples
collected
from
taps
where
the
water
has
not
stood
motionless
for
at
least
six
hours,
(
iii)
samples
with
results
that
are
obviously
anomalies
from
historical
monitoring
results.

AL
If
corrosion
control
is
in
place,
systems
exceeding
AL
can
make
minor
changes
and
resample.

FL
To
date,
we
have
not
permitted
replacement
samples.

MS
The
state
does
not
allow
for
the
replacement
of
samples
for
reasons
other
than
invalidation.

KY
Kentucky
does
not
allow
replacement
of
samples.

NC
Replacement
of
compliance
samples
for
reasons
other
than
invalidation
is
generally
not
allowed.

SC
N/
A
TN
The
state
does
not
allow
replacement
samples
unless
the
original
sample
is
invalidated.

GA
If
the
lab
determines
that
the
sample
did
not
meet
the
criteria
for
the
collection
of
Pb/
Cu
samples.

(
I.
E.
the
sample
did
not
meet
the
six
hour
non­
flush
requirement,
etc).

MI
Michigan
does
not
allow
for
replacement
of
samples
for
reasons
other
than
invalidation.

IL
N/
A
IN
Invalidation
of
samples,
due
to
improper
sampling
technique
or
location,
are
currently
the
only
conditions
in
which
the
state
allows
the
system
to
resample.
MN
Replacement
of
samples
is
allowed
if
during
site
investigation
a
site
is
found
longer
meeting
the
tier
specifications,
such
as
a
softener
or
new
plumbing
was
installed
since
last
sampling,
or
if
the
owner
refuses
further
participation.

OH
Replacement
of
samples
is
only
allowed
for
samples
that
have
been
invalidated
by
the
procedure
outlined
above.

WI
The
Department
has
allowed
invalidation
of
results
where
samples
were
collected
at
valid
locations,
but
after
water
was
motionless
in
the
system
for
long
periods
of
time
(
maybe
even
days).

AR
We
do
not
allow
replacement
samples
other
than
for
invalidation.

LA
No
such
replacements
are
currently
allowed.

NM
The
NMED­
DWB
does
not
allow
for
any
replacement
samples
other
than
invalidated
samples
or
lab
error
on
samples.
Such
as
loss
of
volume,
holding
time
or
PH.

OK
N/
A
TX
If
the
PWS's
90%
results
are
unusually
high
they
can
request
a
confirmation
sample
in
writing.
If
confirmation
samples
also
come
back
high,
the
results
stand.
If
confirmation
results
come
back
under
action
levels
then
the
results
can
be
changed.
Homeowners
must
collect
confirmation
samples
at
first
draw
after
6
hours
minimum
to
18
hours
maximum
detention.
If
longer
the
water
stands
in
the
pipe
the
higher
the
results
may
be.
The
proof
is
in
the
results
and
speaking
with
the
homeowner.

IA
No
instances
of
replacement
that
wasn't
related
to
invalidation
come
to
mind.

KS
Lost
or
damaged
sample
containers
are
replaced
by
the
KDHE
lab
when
requested
by
the
system.

Systems
have
reported
homeowners
discarding
the
containers,
losing
the
containers,
or
family
pets
damaging
the
containers.

MO
None.

NE
If
a
round
of
samples
was
taken
from
a
small
water
system
which
was
vacant
or
idle
at
the
time
of
sampling,
we
allow
the
entire
round
to
be
replaced
by
another
round
taken
at
a
time
when
the
water
system
is
again
in
regular
daily
use.
This
situation
sometimes
occurs
with
small
rural
schools
which
have
their
own
water
systems
and
are
idle
during
the
summer
months.

CO
The
state
does
not
currently
allow
replacement
of
samples
other
than
for
invalidation.

MT
Done
on
a
case­
by­
case
basis
as
explained
above.
ND
N/
A
SD
This
situation
seems
to
happen
at
a
couple
of
sites
each
year.
A
system
will
collect
their
samples
and
the
lab
will
send
us
the
results
and
a
particular
site
will
have
an
extremely
high
lead
or
copper
level.
We
will
look
in
the
database
and
see
if
that
system
has
ever
lead
levels
above
about
3
ppb
and
copper
above
0.2
ppm,
and
we
look
in
particular
at
the
site
to
see
if
that
site
has
had
any
levels
much
above
the
detection
limits.
If
the
site
and
system
both
show
that
they
have
never
had
problems
in
the
past,
we
call
the
certified
operator
and
ask
if
they
have
made
many
changes
in
the
system.
We
also
ask
him
to
contact
the
homeowner
and
ask
about
how
and
where
the
sample
was
collected
and
if
they
changed
any
plumbing
recently.
If
it
appears
that
there
is
no
reason
that
the
sample
should
be
this
high,
we
will
allow
them
to
retake
the
sample.
Almost
every
time
the
repeat
sample
comes
back
very
low.
We
haven't
figured
out
what
causes
these
spikes,
but
we
always
get
a
couple
every
year.
We
are
just
calling
it
sampling/
lab
error.

UT
The
State
does
not
allows
for
the
replacement
of
samples
for
reasons
other
than
invalidation.

WY
Occasionally,
a
high
lead
result
will
be
received
that
is
suspect
because
of
the
sampling
technique.

If
the
sample
was
collected
from
a
tap
that
had
not
been
used
for
some
time,
the
sample
is
invalidated
and
a
replacement
sample
is
collected
from
the
same
tap
after
the
tap
has
been
unused
for
six
hours.
If
the
location
is
no
longer
in
active
use,
a
replacement
site
is
selected.

AZ
No.

CA
We
would
invalidate
a
sample
pursuant
to
40
CFR
141.86(
f).

HI
The
State
does
not
allow
replacement
of
samples
other
than
the
reasons
stated
in
§
141.86(
f).

NV
Only
invalidated
samples
are
replaced.

Amer
Sam
Sample
replacement
for
other
reasons
is
not
allowed.

Navajo
§
710
(
F)(
4)
of
the
NNPDWR
(
40
CFR
§
141.86(
f)(
4))
outlines
the
process
for
sample
replacement
AK
We
do
not
allow
replacement
samples
for
anything
other
than
invalidated
samples.
WA
There
are
only
two
types
of
situations
where
DOH
allows
replacement
samples
for
lead
&

copper:
DOH
will
allow
for
a
replacement
sample
result
if
the
tap
sat
unused
for
longer
than
would
reasonably
be
expected
(
12
or
more
hours)
for
daily
water
use.
Examples
include:

residents
were
away
for
the
weekend
or
on
vacation
or
sample
was
collected
from
a
seldom
used
tap,
like
a
guest
bathroom,
workshop
sink,
or
janitors
closet,
and
the
water
was
not
run
the
day
before.
DOH
will
allow
for
a
replacement
sample
if
there
is
a
home
treatment
device
before
the
sample
collection
point.
A
sample
collected
under
this
situation
would
not
reflect
the
water
quality
delivered
by
the
system.

WA
(
cont.)
DOH
almost
always
requires
replacement
samples
be
collected
in
the
same
monitoring
period.
If
a
monitoring
period
is
over
before
it
is
realized
that
a
high
sample
result
fits
one
of
the
above
criteria,
we
require
the
system
to
take
two
more
six­
month
sets.
DOH
always
requires
written
documentation
from
the
water
system
that
the
first
sample
fits
one
of
the
above
criteria
before
we
delete
the
sample
from
our
database.
Justification
can
be
the
operator's
written
description
of
conversation
with
the
homeowner.

ID
Idaho
does
not
have
any
procedure
or
policy
in
place
that
allows
for
invalidation
or
replacement
outside
of
conditions
given
in
the
regulations.

OR
No.
When
calculating
the
90th
percentile
does
the
state
require
and/
or
use
the
results
from
all
samples
collected
or
the
required
number
of
samples?
How
does
the
state
calculate
the
90th
percentile
if
the
number
of
samples
is
less
than
the
required
minimum?
CT
All
tap
water
lead
and
copper
samples
collected
during
the
current
monitoring
period
are
required
to
be
considered
by
the
Public
Water
System
and
the
CTDPH
 
DWD
in
making
any
compliance
determinations
pursuant
to
the
B102
regulations
and
40
CFR
141.86(
e).
All
tap
water
lead
and
copper
samples
submitted
to
the
CTDPH
 
DWD
for
compliance
purposes
are
considered
in
calculating
the
90
th
percentiles
and
determining
compliance
with
the
lead
and
copper
ALs.
Under
the
scenario
in
which
a
Public
Water
System
submits
a
quantity
of
tap
water
samples
less
than
the
minimum
required
the
CTDPH
 
DWD
would
calculate
the
90
th
percentile
based
on
the
number
of
samples
submitted
and
also
pursue
informal,
or
formal
enforcement
actions
for
failure
to
collect
the
minimum
number
of
samples
required.

MA
DEP
uses
all
tap
samples
collected
to
calculate
the
90
th
percentile.
DEP
calculates
the
90
th
percentile
even
if
the
number
of
samples
collected
is
less
than
the
minimum
required.
Both
practices
are
based
on
instructions
from
EPA
Region
1.

ME
The
90
th
percentile
is
calculated
using
all
sample
results
submitted.
The
only
time
the
90
th
percentile
would
be
calculated
using
less
then
the
required
minimum
is
when
a
system
has
exceeded
the
action
level
in
more
than
10
percent
of
the
minimum
required
number
of
samples.

Example:
If
the
required
minimum
number
of
samples
for
the
given
water
system
is
20,
and
the
water
system
has
only
submitted
18
sample
results
and
3
or
more
samples
are
above
the
action
level.

NH
The
WSEB
uses
all
the
sample
results
submitted
for
any
given
round.
The
WSEB
does
not
allow
less
than
the
minimum
of
samples
required.
RI
No
answer.

VT
Yes.
WSD
does
not
calculate
the
90%
if
all
the
number
of
samples
is
less
than
the
required
minimum.
WSD
issues
a
monitoring
violation
instead.
The
WSD
does
include
results
for
samples
taken
outside
of
the
monitoring
period
as
long
as
they
are
taken
relatively
close
to
the
designated
monitoring
period.

NY
The
90%
level
is
calculated
from
all
samples
collected
for
the
monitoring
period,
including
samples
that
exceed
the
minimum
number
required.
An
exception
to
this
would
be
samples
taken
by
a
homeowner
and
analyzed
by
the
system
under
a
voluntary
program,
when
the
homeowner
is
not
properly
trained
and
certified.
If
a
sample
set
is
submitted
with
less
than
the
minimum
number
of
samples,
the
system
is
directed
to
complete
the
sampling
pool
immediately.
90%

calculations
are
only
accepted
if
made
on
a
full
set
of
sampling
results.
If
a
sampling
set
is
not
completed
within
the
required
time
frame,
then
a
notice
of
violation
would
be
issued.

NJ
All
Samples
collected.
Must
collect
replacement
samples
to
make
up
minimum
required,
then
calculate
90
th
percentile
DE
We
calculate
based
on
number
of
samples
collected.
We
no
longer
allow
a
system
to
collect
fewer
than
the
mandated
number
of
samples.
In
the
past
we
did
calculate
a
90
th
percentile
from
the
number
of
samples
collected.

MD
The
State
uses
the
results
from
all
valid
samples
collected
in
the
monitoring
period.
If
an
insufficient
number
of
samples
are
collected
for
the
monitoring
period,
the
testing
is
considered
incomplete
and
a
monitoring
violation
is
reported
by
MDE.
If
there
is
time
remaining
in
the
monitoring
period,
additional
samples
may
be
collected
by
the
water
system
complete
the
sampling
for
the
minimum
number
of
samples.

WV
All
samples
results
submitted
are
used
to
compute
the
90
th
percentile,
unless
the
number
of
samples
is
less
than
the
required
minimum,
then
the
90
th
percentile
is
not
computed,
and
only
a
monitoring
violation
is
issued.
Or
some
of
the
samples
were
collected
in
months
other
than
June,

July,
August
or
September
(
those
samples
are
not
considered
for
compliance
if
submitted).
PA
Certified
labs,
acting
on
behalf
of
the
water
suppliers,
calculate
and
submit
90
th
percentile
values
to
PA
DEP.
Provided
the
additional
samples
are
from
the
appropriate
tier
category,
the
lab
may
calculate
the
90
th
percentile
value
using
the
results
from
all
samples
collected.
PADWIS
will
not
recognize
a
90
th
percentile
value
for
compliance
purposes
unless
the
number
of
samples
taken
is
equal
to
or
greater
than
the
number
of
samples
required.
PADWIS
will
reject
the
incomplete
data
and
generate
a
monitoring
violation.

VA
We
normally
would
use
the
results
of
all
samples
submitted
during
the
monitoring
period
to
calculate
the
90
th
percentile,
excluding
any
invalidated
sample
results.
If
the
number
of
sample
results
submitted
is
less
that
the
minimum
number
required,
our
first
priority
is
to
get
the
additional
results
from
the
waterworks
owner.
If
we
are
successful,
we
will
use
all
of
the
sample
results
to
determine
the
90
th
percentile
 
even
if
the
delinquent
sample
results
are
collected
after
the
end
of
the
monitoring
period.
We
would
issue
a
Notice
of
Violation
to
the
waterworks
owner
for
failure
to
conduct
the
required
monitoring
within
the
established
monitoring
period.

There
have
been
situations
where
we
determined
the
90
th
percentile
concentration
based
upon
a
number
of
samples
that
is
less
than
the
required
minimum.
An
example
would
be
a
waterworks
required
to
submit
20
lead
and
copper
tap
samples
but
only
19
results
were
submitted.
Since,
for
20
required
samples,
the
18
th
highest
sample
result
represents
the
90
th
percentile
value,
we
would
use
the
18
th
highest
sample
result
to
determine
the
90
th
percentile.

AL
All.
Monitoring
violation
and
we
don't.

FL
In
the
event
more
that
the
required
number
are
collected,
all
are
taken
into
consideration
when
calculating
the
90
th
percentile
provided
the
additional
sample
sites
are
on
the
system's
sampling
plan.
We
have
never
had
the
occasion
where
less
than
the
required
are
used
to
determine
the
90
th
percentile.
In
the
rare
instance
fewer
than
the
required
are
submitted,
the
system
representative
is
contacted
immediately
and
advised
to
collect
the
remaining
number
to
meet
the
minimum
requirement.
KY
The
state
uses
the
results
from
all
samples
collected
to
compute
the
90
th
percentile.
If
a
water
system
fails
to
collect
their
required
number
of
samples,
we
do
not
calculate
the
90
th
percentile
from
that
set.
We
require
the
water
system
to
collect
a
complete
set
before
we
calculate
the
90
th
percentile.

MS
The
state
utilizes
the
results
from
all
samples
collected.
The
state
calculates
the
90th
percentile
even
if
the
system
fails
to
collect
the
required
number.
An
M/
R
violation
is
issued
and
the
results
are
interpolated.

NC
All
samples
submitted
for
analysis,
except
those
that
have
been
invalidated
by
the
rule
manager,

are
used
in
the
calculation
of
the
90
th
percentile.
If
a
water
system
submits
less
than
the
required
number
of
samples,
all
samples
submitted
for
analysis
are
included
in
the
90
th
percentile
calculation
and
a
monitoring
violation
is
also
issued.

SC
All
sample
results
are
used
to
calculate
the
90
th
percentile
for
water
systems
collecting
the
minimum
number
of
samples
or
more.
If
the
number
of
samples
is
less
than
the
minimum
required,
the
samples
are
not
used
for
compliance.

TN
All
samples
are
used
in
the
calculation
unless
invalidated,
regardless
of
the
number
of
samples.

However,
the
samples
must
be
collected
during
the
monitoring
period.
For
systems
on
reduced
monitoring
only
those
samples
collected
in
June,
July,
August,
and
September
are
used.

GA
Georgia
requires
that
the
proper
number
of
Pb/
Cu
samples
be
collected
to
calculate
the
90th
percentile.

MI
All
valid
samples
are
used
in
calculating
the
90
th
percentile.
When
a
sample
set
is
not
a
multiple
of
10
(
which
occurs
in
some
consecutive
system
sampling
arrangements),
MDEQ
interpolates
to
determine
the
90
th
percentile
values.
For
any
sample
set
less
than
5
samples,
all
samples
had
to
be
below
the
action
levels
or
a
violation
has
occurred.
If
the
number
of
sample
results
reported
is
less
than
the
minimum
number
established
by
MDEQ
for
a
specific
monitoring
period,
we
report
it
as
a
monitoring
violation
and
use
sample
results
available
to
calculate
a
90
th
percentile
level.

IL
If
a
90th
percentile
can't
be
calculated,
the
sample
summaries
in
SDWIS/
State
are
rejected
and
a
M/
R
violation
is
issued.
IN
The
90
th
percentile
is
based
on
the
total
number
of
samples
submitted.
If
the
system
does
not
submit
the
required
number
of
samples
a
telephone
call/
letter
is
sent
requesting
the
missing
samples
and
the
90
th
percentile
is
calculated
once
the
sample(
s)
is
received.
The
State
has
accepted
samples
taken
outside
of
the
official
monitoring
periods.

MN
Use
all
samples
(
designated
number
or
required
number
of
samples)
collected
through
a
designated
monitoring
round,
though
rarely
done,
may
include
samples
collected
outside
of
monitoring
period.
For
NTNC
systems
collecting
less
than
5
samples
(
from
MDH
designated
taps),
the
90th
percentile
lead/
copper
levels
are
simply
the
highest
lead/
copper
values.

OH
Results
from
all
samples
collected
within
the
monitoring
period
are
used
when
calculating
the
90th
percentile.
If
less
than
the
required
minimum
is
received,
the
90th
percentile
is
not
calculated
and
a
monitoring
violation
is
issued.

WI
The
90
th
percentile
is
calculated
using
the
results
of
all
valid
samples
collected
within
the
monitoring
period.
If
the
number
collected
is
less
than
the
required
minimum,
compliance
is
based
on
the
highest
sample
result.

AR
All
routine
samples
collected
are
counted,
unless
invalidated.
They
sample
until
they
get
the
minimum
number
or
they
get
a
violation.

LA
The
state
uses
all
of
the
results
of
all
of
the
samples
that
are
submitted
for
a
given
monitoring
period
when
calculating
the
90
th
percentile.
However,
if
less
than
the
required
minimum
number
of
samples
is
submitted,
the
state
will
not
calculate
the
90
th
percentile.
In
such
cases,
the
systems
are
sent
a
copy
of
the
results
of
the
samples
submitted
along
with
a
letter
notifying
them
that
more
samples
are
required.

NM
All
samples
collected.
State
calculates
90
th
percentile
based
on
number
of
samples
taken
OK
All.
Sample
set
is
declared
"
Insufficient"
and
System
is
notified
to
provide
correct
number.

TX
If
a
set
of
required
samples
is
incomplete,
the
TCEQ
sends
reminder
letters
to
get
the
missing
samples
collected
as
soon
as
possible.
There
are
a
few
systems
each
year
that
are
short
by
1
or
2
samples.
In
this
situation
a
90%
calculation
is
done
on
the
samples
that
have
been
received.

Those
with
more
missing
samples
or
with
5
required
samples
in
which
one
is
missing
are
sent
a
notice
of
violation
and
are
required
to
collect
a
complete
set
on
an
alternative
schedule.
IA
We
use
all
data
from
samples
collected.
If
the
samples
are
less
than
the
required
minimum,
the
system
receives
a
monitoring
violation.

KS
When
calculating
the
90th
percentile,
the
state
uses
the
results
from
all
samples
collected
and
reported
by
the
system.
If
the
number
of
samples
is
less
than
the
required
minimum,
the
90th
percentile
is
not
calculated,
and
the
system
receives
a
monitoring
violation.

MO
The
state
uses
all
samples
collected
to
determine
90th
percentile
lead
levels.

NE
Nebraska
uses
all
samples
collected
when
calculating
90
th
percentiles
as
long
as
those
samples
were
pre­
designated
as
"
routine"
samples
at
the
time
they
were
sent
from
the
Lab
to
the
water
system.
(
Water
systems
can
pre­
designate
samples
as
"
special"
if
they
do
not
want
the
results
to
be
used
in
calculating
90
th
percentiles)
90
th
percentiles
for
incomplete
rounds
of
samples
consisting
of
fewer
than
10
samples
are
recorded
as
the
highest
individual
result
if
none
of
the
samples
exceeds
Action
Levels.
In
other
cases,
90
th
percentiles
are
calculated
on
the
actual
number
of
results
using
straight­
line
interpolation.

CO
The
State's
current
policy
is
to
use
the
required
number
of
samples
for
calculation
of
90
th
percentile
­
no
more
and
no
less.
Prior
to
State's
revision
of
the
drinking
water
regulations
in
2004,
the
Regulations
provided
for
less
than
five
samples
required
of
non­
community
systems
with
less
than
five
buildings.
In
those
cases
the
90
th
percentile
was
calculated
by
multiplying
the
number
of
samples
by
0.9
and,
if
the
result
of
the
calculation
was
an
integer,
the
contaminant
at
this
number
position
was
the
90
th
percentile;
if
the
result
of
the
calculation
was
not
an
integer
than
an
interpolation
between
the
sample
results
above
and
below
the
number
position
was
performed
in
order
to
derive
the
90
th
percentile.

MT
The
LCR
does
not
limit
a
system
to
collecting
only
the
required
number.
Although
the
LCR
sets
a
minimum
sample
number
at
5,
the
department
has
allowed
systems
with
less
than
5
sample
taps
to
collect
samples
based
on
the
number
of
sample
taps.
We
believe
that
although
this
is
less
stringent
than
the
standard
based
on
the
number
of
samples
required,
it
is
more
stringent
in
terms
of
the
90
th
percentile
results
as
it
reduces
the
amount
of
"
dilution"
factored
into
the
calculation.
ND
We
use
all
the
results
collected,
even
if
outside
of
the
June
­
September
monitoring
period.
We
try
to
get
all
systems
to
collect
their
samples
during
those
four
months,
but
occasionally
a
few
systems
fail
to
do
so
and
rather
than
issue
a
failure
to
monitor
violation,
we
will
accept
samples
after
September
30.

SD
We
normally
don't
see
any
extra
samples
collected
so
we
base
our
90
th
percentile
off
of
the
required
number
of
samples.
If
the
number
of
samples
collected
is
less
than
the
required
minimum,
a
Failure
to
Monitor
Violation
is
issued.
The
90
th
percentile
is
only
calculated
on
the
samples
that
were
collected
for
that
monitoring
period.

UT
The
State
uses
the
results
from
all
samples
collected.
If
the
number
of
samples
is
more
or
less
than
the
required
number,
the
State
calculates
the
actual
90
th
percentile
for
the
given
data
set.

WY
Region
8
uses
all
of
the
results
that
are
submitted
by
a
water
system
to
calculate
90
th
percentile.

The
only
exception
would
involve
repeat
samples.
We
use
the
first
sample
collected
as
part
of
the
90
th
percentile
calculation.
If
a
water
system
does
not
collect
enough
samples,
they
are
asked
to
collect
additional
samples.
If
the
monitoring
period
has
already
passed,
the
system
would
be
notified
that
they
failed
to
collect
enough
samples
and
would
be
asked
to
repeat
monitor
during
the
next
monitoring
period.
Homeowners
served
by
the
water
system
shall
be
notified
that
the
water
system
failed
to
collect
enough
samples.

AZ
All.
All.

CA
No
answer.

HI
The
State
requires
all
samples
drawn
(
unless
the
sample
is
invalidated)
be
included
in
the
90th
percentile
calculation.
If
the
number
of
samples
is
less
than
the
required
minimum,
the
water
system
is
requested
to
obtain
the
required
number
of
samples.
In
Hawaii,
the
State
Laboratory
performs
the
analyses
for
most
of
the
water
systems,
which
enables
the
SDWB
to
track
whether
the
minimum
number
of
samples
were
provided
for
analyses.
The
state
does
not
use
samples
collected
outside
of
the
monitoring
period.

NV
All
samples
are
used
in
determining
the
90th
percentile
value.
We
require
additional
sampling
to
get
the
minimum
required
number
of
samples
before
determining
90th
percentile
Amer
Sam
All
sample
results
are
used
in
calculating
the
90th
percentile
as
long
as
representative
sampling
sites
were
used.
In
the
absence
of
the
required
minimum
number
of
samples,
the
available
samples
would
be
used
to
calculate
the
90th
percentile.
Due
to
the
distance
from
certified
laboratories
(
Hawaii
is
the
closest)
and
very
limited
plane
service
to
the
Territory,
sample
collection
and
analysis
cannot
be
readily
accomplished.
This
situation
has
not
yet
occurred.

Navajo
If
a
sample
was
invalidated,
then
replacement
samples
are
used
to
meet
the
minimum
required
samples
for
the
public
water
system.
The
minimum
required
samples
are
then
calculated
in
the
90th
percentile.
PWSSP
notifies
the
public
water
system
owner/
operator
of
their
noncompliance
of
the
minimum
number
of
required
samples.
The
90th
percentile
is
calculated
of
the
minimum
number
of
samples
only.

AK
The
90
th
percentile
is
calculated
from
all
samples
submitted
unless
the
set
contains
too
few
samples
(
less
than
the
required
minimum).
If
adequate
samples
sets
are
received,
the
90
th
percentile
is
calculated
on
the
actual
number
of
samples;
however,
the
results
are
entered
as
"
not
for
compliance."

WA
Currently
the
new
DOH
data
management
system
calculates
90th
percentiles
with
as
little
as
two
of
the
required
number
of
samples.
This
calculation
uses
an
average
of
the
highest
and
second
highest
result
to
determine
the
90th
percentile.
This
method
of
calculation
using
less
than
the
number
of
required
samples
is
performed
to
alert
staff
to
"
possible"
Action
Level
incidents
to
facilitate
faster
coordination
between
the
system
and
DOH.
If
a
system
took
more
than
the
minimum
number
of
samples,
then
all
sample
results
would
be
used
in
calculating
the
90
th
percentiles.
For
the
purpose
of
reporting
these
values
to
EPA,
DOH
only
reports
90
th
percentile
for
sets
that
have
100%
or
greater
of
the
required
samples.
DOH
reports
sets
that
are
not
100%

as
monitoring
violations.

ID
If
the
number
of
samples
is
not
either
5
samples
or
some
multiple
of
10
samples,
Idaho
does
not
normally
interpolate
between
two
results
to
calculate
the
90
percentile
level.
However,
if
the
action
level
lies
within
the
range
we
would
use
in
an
interpolation,
then
we
would
interpolate.

The
avoidance
of
interpolation
when
interpolation
would
not
make
a
difference
in
meeting
the
action
level
is
the
only
time
Idaho
does
not
use
all
sample
results
in
the
calculation
of
the
90
th
percentile.
OR
Use
all
results
when
calculating
the
90th
percentile.
They
did
not
calculate
the
value
if
there
are
not
the
minimum
number
of
samples.
Usually
they
make
the
system
collect
the
additional
samples
needed
and
are
then
able
to
calculate
the
90th
percentile.

If
a
system
re­
samples
at
a
location
to
verify
a
sample
with
a
high
lead
concentration,
does
the
state
use
the
second
sample
or
both
samples
in
calculating
the
90th
percentile?
CT
All
tap
water
lead
and
copper
samples
collected
during
the
current
monitoring
period
are
required
to
be
considered
by
the
Public
Water
System
and
the
CTDPH
 
DWD
in
making
any
compliance
determinations
pursuant
to
the
B102
regulations
and
40
CFR
141.86(
e).
All
tap
water
lead
and
copper
samples
submitted
to
the
CTDPH
 
DWD
for
compliance
purposes
are
considered
in
calculating
the
90
th
percentiles
and
determining
compliance
with
the
lead
and
copper
ALs.

MA
DEP
uses
both
samples
based
on
instructions
from
EPA
Region
1.

ME
Sample
results
cannot
be
challenged
based
on
previous
or
additional
samples.
Each
first
draw
sample
is
considered
a
valid
sample;
both
sample
results
would
be
used.

NH
The
WSEB
uses
only
the
confirmation
sample.
The
database
will
not
allow
two
samples
from
the
same
site
and
same
compliance
period
to
be
used.

RI
No
answer.

VT
Yes.

NY
Unless
one
of
these
sample
are
invalidated,
both
would
be
used
in
calculating
the
90%
result.

NJ
Both
samples.

DE
We
use
the
second
sample.

MD
Unless
the
first
sample
is
invalidated,
the
second
sample
cannot
be
counted
towards
compliance.

WV
Only
use
the
results
of
the
second
sample.
PA
PA
DEP
only
recognizes
replacement
samples
when
the
samples
are
collected
in
response
to
an
invalidation
event
(
described
above).

VA
As
noted
previously,
we
would
normally
use
the
results
of
all
samples
submitted
during
the
monitoring
period
to
determine
the
90
th
percentile
concentration.
There
may,
however,
be
special
or
unique
circumstances
where
we
would
invalidate
the
original
sample
result.
As
an
example,
suppose
we
have
a
waterworks
with
a
long
history
of
lead
and
copper
tap
sample
results
indicating
all
individual
lead
samples
are
less
than
0.005
mg/
L.
The
owner
submits
a
set
of
sample
results
and
one
site
indicates
an
elevated
lead
concentration.
Our
Field
Office
staff
would
most
likely
request
that
the
owner
collect
a
resample
to
verify
the
elevated
lead
result.
If
the
resample
indicates
a
lead
concentration
of
less
than
0.005
mg/
L,
we
would
most
likely
consider
the
original
lead
result
as
an
anomaly
based
upon
the
monitoring
history
of
the
waterworks
and
not
include
that
result
in
the
90
th
percentile
determination.

AL
Depends
on
the
situation.

FL
Only
the
initial
result
is
used
in
determining
the
90
th
percentile.

KY
The
state
would
use
both
the
first
and
the
second
samples
in
calculating
the
90
th
percentile.

MS
The
state
utilizes
both
samples
to
calculate
the
90th
percentile.

NC
In
this
circumstance,
assuming
that
sample
invalidation
is
not
involved
and
the
water
system
is
attempting
to
rule
out
the
possibility
of
poor
sampling
procedures,
the
results
of
the
first
and
second
(
confirmation)
samples
at
the
same
location
code
will
be
averaged
and
this
average
value
would
then
be
used
in
the
calculation
of
the
90
th
percentile
value.

SC
If
the
proper
sampling
protocol
is
followed
for
both
samples,
the
Department
uses
the
sample
testing
lower.

TN
Without
invalidation,
we
would
use
the
average
of
the
samples
from
the
same
site.

GA
If
a
system
re­
samples
at
a
location
to
verify
a
sample
with
a
high
lead
concentration,
the
original
sample
is
utilized
in
the
90th
percentile
calculation,
unless
that
sample
can
be
invalidated
under
40
CFR
141.86(
f)(
1­
6).
MI
If
the
second
sample
was
collected
within
the
same
monitoring
period,
and
the
first
sample
was
not
declared
invalid
for
good
reason
by
the
state,
water
systems
are
expected
to
report
both
results
in
the
data
used
to
calculate
the
90
th
percentile.
However,
it
is
possible
that
some
staff
have
told
water
systems
that
only
the
first
sample
may
be
used
if
it
is
not
declared
invalid.

IL
Both.

IN
The
state
will
use
the
second
sample.

MN
The
second
sample
result
is
used
for
the
calculation
of
the
90th
percentile
level
for
lead
and
copper.
(
Questionable
results/
samples
are
first
approved
to
be
invalidated
before
re­
sampling
take
place.)

OH
Both
samples
are
used
in
calculating
the
90th
percentile.

WI
The
results
of
both
samples
are
used
to
calculate
the
90
th
percentile,
unless
one
is
invalidated.

AR
At
sites
that
exceed,
the
first
or
exceedance
sample
counts.
If
another
sample
is
collected,
it
would
be
for
investigative
purposes
and
would
not
count.

LA
Because
the
state
does
not
allow
re­
sampling
of
sites
for
reason
other
than
invalidation,
only
one
sample
will
be
available
for
use
in
calculating
the
90
th
percentile.

NM
Both
samples.

OK
System
draws
a
complete
new
set
of
samples
and
90%
is
calculated
on
ALL
samples.

TX
All
samples
from
the
same
year
and
sampling
period
are
used
unless
the
sample
IA
We
can't
recall
if
this
has
occurred
in
Iowa.

MO
The
replacement
sample
is
used
if
it
was
determined
that
the
original
should
be
invalidated.
A
replacement
sample
is
not
ordered
unless
there
is
good
reason
to
suspect
site
or
sampling
error.

NE
No.
We
continue
to
use
the
results
of
only
the
first
sample
unless
there
was
justification
to
invalidate
that
sample.

CO
It
is
the
State's
policy
not
to
use
a
"
re­
sample"
such
as
the
one
described
above
for
calculation
towards
the
90
th
percentile;
however
the
State
would
require
that
a
public
water
system
report
this
type
of
result
nonetheless.

MT
That
determination
is
based
on
the
reasons
for
allowing
the
re­
sampling
and
department
determinations.

ND
We
use
both
samples,
the
results
are
averaged
to
determine
the
result.
SD
If
we
feel
it
is
due
to
lab/
sampling
error
(
as
mentioned
in
question
#
2)
then
we
use
the
second
sample,
otherwise
we
would
use
both
samples.

UT
In
the
situation
cited,
the
State
would
require
two
samples
with
comparable
results
to
show
that
the
"
high
lead"
sample
result
was
anomalous.
The
anomalous
sample
would
be
declared
invalid
(
lab
error,
or
sample
did
not
meet
selection
criteria,
i.
e.:
significantly
longer
than
six
hours
of
non
water
use)
and
as
such
would
not
count
toward
determining
Lead/
Copper
90
th
percentile
levels
or
toward
meeting
minimum
monitoring
requirements.
The
two
replacement
samples
would
be
averaged,
with
the
result
included
with
all
other
samples
for
the
compliance
period
in
calculating
the
90
th
percentile.

WY
Usually,
the
second
sample
is
not
used
as
part
of
the
90
th
percentile
calculation
AZ
No
verification
only
invalidation.

CA
We
handle
such
re­
sampling
situations
on
a
case­
by­
case
basis.
For
example,
we
may
use
the
second
sample
if
all
previous
data
showed
no
exceedance
of
the
action
level.

HI
The
State
does
not
draw
a
second
sample.
The
home
with
the
high
lead
sample
is
called
by
the
water
system
and
if
the
sample
is
drawn
from
an
incorrect
location
(
e.
g.,
backyard
tap),
the
sample
is
invalidated
and
a
sample
is
drawn
from
the
correct
tap
(
bathroom
or
kitchen
cold
water).
If
the
correct
tap
was
used,
the
homeowner
is
informed
of
the
high
levels
and
the
tap
results
are
used
in
the
90th
percentile
calculation.

NV
The
only
reason
we
consider
a
second
sample
is
if
we
have
invalidated
the
first
sample,
in
which
case
the
replacement
(
second)
sample
is
used
in
the
calculation.

Amer
Sam
ASEPA
uses
both
samples
in
calculating
the
90th
percentile.

Navajo
The
second
sample
is
used.
PWSSP
verifies
the
resample
through
the
invalidation
process
described
in
§
710
(
F)
of
the
NNPDWR.

AK
The
state
replaces
the
high
lead
sample
result
with
the
new
sample
result
and
recalculates
the
90
th
percentile
(
i.
e.
we
use
the
second
sample).

WA
If
both
samples
are
valid,
DOH
uses
both
samples
to
calculate
the
90
th
percentile.
If
the
original
sample
is
invalid
(
with
described
justification)
then
the
second
or
replacement
is
used.
ID
Idaho
prefers
to
average
samples
collected
at
a
single
location
then
use
the
average
as
a
single
result
in
the
calculation
of
the
90
th
percentile.
This
is
to
avoid
bias
introduced
by
collection
of
multiple
samples
from
a
site
that
tests
either
higher
than
other
sites
or
lower
than
other
sites.

Recent
EPA
guidance
addressing
requirements
for
water
systems
that
do
not
have
the
minimum
5
sites
that
the
rule
requires
be
sampled
has
introduced
confusion
about
the
consistency
of
our
historic
method
of
calculation.
EPA
guidance
suggests
that
systems
without
enough
sample
sites
must
sample
multiple
times
from
enough
sites
to
complete
a
total
of
at
least
5
samples.
The
justification
given
was
that
there
can
be
variation
between
one
sample
and
the
next
at
a
given
sample
tap.
Idaho
unsuccessfully
argued
that
the
guidance
disagreed
with
reasons
given
in
the
preamble
to
the
rule
(
56FR26523)
for
the
collection
of
multiple
samples.

ID
(
cont.)
The
preamble
states
that
multiple
samples
are
justified
because
of
variability
between
different
sample
taps
and
implies
that
multiple
samples
are
collected
as
a
statistical
sampling
to
account
for
variability
between
households
(
sample
taps).
The
fact
is
that
small
businesses
with
only
two
or
three
taps
can
indeed
feasibly
sample
from
all
sample
taps
to
account
for
variability
between
different
taps.
Variability
for
samples
coming
from
the
same
tap
is
accounted
for
in
the
regulation
by
requiring
periodic
repeat
monitoring.
Idaho
continues
to
argue
that
requiring
multiple
samples
from
the
same
tap
to
complete
the
requisite
number
of
samples
for
a
particular
sampling
period
serves
no
practical
purpose,
is
in
disagreement
with
the
preamble
to
the
rule,
and
presents
states
with
the
need
to
decide
whether
to
calculate
90
th
percentile
levels
in
an
inconsistent
manner
or
to
be
consistent,
follow
the
guidance
and
allow
the
introduction
of
bias
into
the
results
by
water
systems
that
intentionally
collect
multiple
samples
from
a
tap
that
measures
low
in
lead
levels.

OR
Or
does
not
allow
replacement
of
a
sample
unless
the
original
one
is
invalidated.
The
state
will
invalidate
the
original
sample
and
then
use
a
2nd
sample.
OR
does
not
allow
systems
to
take
multiple
samples
from
the
same
site.
If
this
does
occur,
both
samples
are
used
to
calculate
the
90th
percentile
value.
nt.
has
been
invalidated.
DCTM_
ARP.
xls
Page
125
Questions
on
State
Implementation
of
the
Lead
and
Copper
Rule
July,
2004
Treatment
Issues
State
Full
Response
Have
all
systems
met
the
required
deadlines
to
install
optimal
corrosion
control
treatment
[
40
CFR
141.81(
d)(
4);

40
CFR
141(
e)(
5)]?
If
not,

describe
how
the
state
is
working
to
address
systems
that
have
not
met
the
requirements.
CT
All
ten
large
Public
Water
Systems
in
CT
have
installed
corrosion
control
treatment
into
their
water
treatment
process.
Currently,
there
are
1,262
small
or
medium­
sized
PWS,
of
which,
264
have
installed
corrosion
control
treatment.
All
small
or
medium­
sized
PWS
that
exceed
the
lead
and/
or
copper
ALs
are
issued
a
LCR
Exceedance
letter
and
required
to
perform
all
applicable
actions,
as
previously
stated,
which
includes
proceeding
with
the
Corrosion
Control
Treatment
Steps
and
eventually
installing
corrosion
control
treatment.
However,
if
the
PWS
is
deemed
optimized
at
any
point
in
proceeding
through
the
Corrosion
Control
Treatment
Steps,
the
PWS
may
cease
proceeding
through
the
Corrosion
Control
Treatment
Steps
and
continue
with
tap
water
monitoring
for
lead
and
copper.
It
should
be
noted
that
if
the
PWS
deemed
optimized
in
the
previous
sentence
exceeds
the
lead
and/
or
copper
ALs
from
that
point
forward,
the
PWS
shall
proceed
with
the
Corrosion
Control
Treatment
Steps
from
the
point
in
which
the
PWS
was
at
when
deemed
optimized.
All
PWS
that
fail
to
comply
with
the
Corrosion
Control
Treatment
Steps
and
are
not
otherwise
deemed
optimized
face
informal
and/
or
formal
enforcement
actions.

MA
Not
all
systems
in
MA
have
met
the
deadlines
to
install
optimal
corrosion
control.
When
a
system
failed
to
meet
the
deadline,
in
the
majority
of
cases,
DEP
issued
an
Administrative
Order
with
an
enforceable
schedule
that
described
the
actions
the
system
had
to
take
and
the
time
period
for
completing
the
actions.
DEP
also
offered
technical
assistance.
DCTM_
ARP.
xls
Page
126
ME
No.
The
State
has
taken
enforcement
action
against
several
water
systems
that
failed
to
install
treatment
or
failed
to
optimize
the
corrosion
control
treatment
by
the
due
dates.
The
State
entered
into
Consent
Agreements
with
the
water
systems
until
they
demonstrated
the
corrosion
control
treatment
is
optimized.

NH
Most
systems
have
met
their
treatment
deadlines
but
a
few
have
not.
The
systems
that
have
not
met
their
deadlines
have
been
issued
violations
and
public
notice
has
been
required.

Unfortunately
for
a
few
systems
(
approximately
8
to
14
systems
out
of
1140
systems
in
the
lead
and
copper
program)
proper
corrosion
control
treatment
that
completely
controls
their
lead
and
copper
issues
may
be
difficult
to
achieve
because
of
system
configuration
and
treatment
concerns
as
the
result
of
water
quality
issues
with
regards
to
other
required
treatment
techniques.
Another
number
of
systems
(
approximately
20+)
need
treatment
or
an
upgrade
of
existing
treatment
in
order
to
stay
below
lead
and
copper
action
levels
or
to
remains
under
those
levels.
However
these
systems
don't
have
the
funds
necessary
to
install
or
properly
maintain
existing
treatment
facilities.
The
WSEB
has
worked
individually
with
these
systems
in
order
to
help
them
solve
their
treatment,
management
and
financial
concerns
but
it
has
been
a
time
consuming
process.
In
addition
the
WSEB's
Capacity
Program
is
now
assisting
these
systems.

RI
Yes.

VT
No.
The
Division
issues
a
Temporary
Permit
to
Operate
(
TOP)
with
milestones.
If
a
water
system
violates
the
TOP
then
the
WSD
issues
an
NOAV
to
the
system.
Those
systems
which
do
not
comply
are
referred
to
the
Agency
of
Natural
Resources
Enforcement
Division.

NY
There
are
a
small
number
of
systems
statewide
that
are
not
in
compliance
with
optimal
corrosion
control
requirements,
some
of
which
have
vacillated
above
and
below
lead
and
copper
action
levels.
Systems
not
meeting
optimal
corrosion
control
requirements
are
cited
with
the
appropriate
type
58
violation.
Forty­
six
violations
at
forty­
three
systems
have
been
issued
since
1996.
Of
these
systems,
nineteen
are
currently
inactive.
The
State
is
evaluating
the
status
of
each
of
these
systems
and
has
directed
local
health
offices
to
verify
and
update
sampling
and
compliance
data.
Follow
up
is
being
provided
to
bring
systems
into
compliance
and
to
ensure
that
required
actions,
such
as
public
education,
continue
to
be
met.

NJ
Yes.
N/
A.

DE
Yes.
DCTM_
ARP.
xls
Page
127
MD
No,
all
water
systems
have
not
met
the
required
deadline
to
install
optimal
corrosion
control
treatment.
Violations
are
reported
to
SDWIS.
Systems
are
referred
for
technical
assistance
to
the
Engineering
and
Technical
Assistance
Division,
and
to
the
Maryland
Rural
Water
Association
circuit
rider
for
on­
site
assistance.

VA
The
vast
majority
of
waterworks
required
to
install
optimum
corrosion
control
treatment
have
installed
treatment
within
the
established
deadline.
For
the
few
waterworks
failing
to
meet
the
treatment
requirements,
our
Field
Office
staff
works
with
the
individual
waterworks
owners
to
ensure
that
the
required
treatment
is
installed.
This
work
includes
routine
inspections
and
sanitary
surveys,
developing
an
optimum
corrosion
control
desktop
evaluation
for
the
specific
waterworks,
and,
where
necessary,
initiation
of
appropriate
enforcement
actions.

WV
No.
Work
with
the
system
to
try
and
get
them
to
comply
informally.
If
the
system
does
not
make
adequate
progress,
then
an
Administrative
Order
is
issued
to
the
system,
establishing
deadlines
with
appropriate
penalties
for
not
complying.

PA
According
to
PADWIS,
thirty­
three
(
33)
systems
have
type
58
violations
for
failure
to
install
OCCT.
Of
those
systems,
ten
(
10)
have
submitted
a
permit
application
to
install
treatment
and
nine
(
9)
have
received
approval
to
construct
treatment.
These
systems
are
being
addressed
through
appropriate
enforcement
actions.

AL
Yes.

FL
The
vast
majority
has
met
the
required
deadline.
A
couple
systems
with
unique
service
areas
are
allowed
additional
time
to
install
optimal
corrosion
control.
These
cases
reflect
non­
traditional
corrosion
control
optimization
techniques,
such
as
"
Small
System
Technology",
otherwise
known
as
point­
of­
use
and
point­
of­
entry
filtration,
and
complete
plumbing
system
replacement
programs.
There
have
also
been
a
couple
systems
that
had
been
deemed
optimized
that
later
exceeded
either
the
lead
or
copper
action
levels.
Those
systems
were
directed
to
implement
the
procedures
of
40
CFR
141.81(
d)
or
(
e).

KY
Yes.
DCTM_
ARP.
xls
Page
128
MS
27
systems
were
initially
required
to
install
corrosion
control.
The
ongoing
review
of
the
lead
and
copper
program
has
identified
several
systems
that
did
not
install
treatment
as
required.

These
systems
were
recently
acquired
by
a
privately
owned
operating
company.
The
state
is
working
with
this
new
owner
to
address
these
issues.

NC
One
large
system,
the
Onslow
County
Water
System,
is
still
in
the
process
of
completing
the
installation
of
corrosion
control
treatment.
The
recommendation
of
corrosion
control
treatment
(
CCT)
for
this
system
consisted
of
adding
orthophosphate
at
dosed
levels
and
was
approved
in
March,
2004.
As
of
approximately
one
month
ago,
the
system
was
in
the
bidding
stage
of
contract
award
for
the
installation
of
corrosion
control
treatment.
Of
the
medium
and
small
systems
that
we
are
aware
of
that
have
not
met
the
deadlines,
our
plan
is
to
monitor
this
situation
more
closely
in
the
future
by
crosschecking
the
in­
house
CCT
database
with
the
sampling
results
database
to
determine
if
some
systems
have
gone
beyond
the
time
limitations
and
to
use
our
tracking
program
to
cite
violations
as
needed.

SC
Yes.

TN
Yes.

GA
No.
Systems
that
continue
to
exceed
lead
and/
or
copper,
continue
to
receive
Pb/
Cu
sample
kits
every
six
months.
Services
are
offered
through
a
contract
with
GRWA
for
continued
WQP
monitoring
at
the
systems
request.
Treatment
techniques
are
discussed
with
the
system
by
the
DWP.

MI
All
small
and
medium
sized
systems
that
exceeded
either
the
lead
or
copper
action
level
after
consecutive
rounds
of
monitoring
were
required
to
complete
a
corrosion
control
study
and
install
treatment
in
accordance
with
the
study
recommendations.
All
large
systems
not
designated
as
already
practicing
optimal
corrosion
control
were
also
required
to
conduct
a
corrosion
control
study
and
install
the
recommended
treatment.
To
our
knowledge
at
this
time,

all
systems
(
except
one)
in
Michigan
have
installed
treatment
by
the
required
deadlines.
The
one
exception
is
a
small
apartment
complex
that
failed
to
complete
the
study
and
install
treatment
by
the
required
deadlines.
The
state
has
again
asked
the
system
owner
to
complete
a
corrosion
control
study
and
submit
a
treatment
plan
within
90
days.
DCTM_
ARP.
xls
Page
129
IL
No.
Water
systems
are
initially
notified
when
an
OCCT
recommendation
is
required
and
the
type
of
documentation/
information
that
must
be
submitted
as
part
of
their
OCCT
recommendation.
If
the
system
is
overdue
in
submitting
the
OCCT
recommendation,
a
second
notice
is
sent.
If
the
water
system
still
does
not
submit
the
OCCT
recommendation,
a
violation
notice
is
issued.
As
of
January
2004,
all
OCCT
recommendation
tracking
is
maintained
in
SDWIS/
State
and
monthly
reports
are
generated
to
identify
overdue
OCCT
recommendations
that
require
follow­
up
action.

IN
Systems
who
demonstrate
that
they
can
meet
the
action
levels
by
submitting
two
consecutive
6­

month
rounds
of
sampling
before
the
time
specified
by
the
rule
are
not
required
to
install
treatment.
Systems
who
have
not
met
these
requirements
and
are
not
actively
working
with
the
state
to
address
the
exceedance
are
referred
to
enforcement.

MN
Except
for
one
facility
which
the
MDH
had
issued
a
NOV
for
failure
to
install
OCCT
by
the
deadline,
all
systems
with
lead
exceedance
met
the
deadlines.
Among
the
ones
with
copper
exceedance,
the
majority
of
them
installed
OCCT
before
the
LCR
deadlines
with
the
exceptions
for
some
systems
­
serving
pop.
<
1,000
and
with
90th
percentile
Cu
<
2.0
mg/
L
in
which
the
MDH
allowed
them
to
used
a
public
education
program
for
the
reduction
of
copper
in
drinking
water
as
an
alternative
to
chemical
treatment.

OH
Not
all
systems
have
met
the
required
deadlines
to
install
optimal
control
treatment.
Public
water
systems
that
do
not
meet
the
deadline
are
issued
a
"
failure
to
install"
violation
letter.

WI
The
City
of
Madison,
which
is
a
large
system,
has
not
installed
corrosion
treatment,
but
has
worked
with
the
Department
and
USEPA
Region
5
on
an
alternate
solution
to
optimize
corrosion
control.

AR
No.
Technical
assistance
and
violations.
DCTM_
ARP.
xls
Page
130
LA
No,
all
systems
have
not
met
the
required
deadlines
to
install
optimal
corrosion
control.
The
state
is
using
the
results
of
tap
samples
to
determine
those
systems
that
need
to
further
optimize
their
corrosion
control
techniques.
Upon
exceedance
of
an
action
level,
the
state
requires
the
system
to
conduct
corrosion
control
studies
and
to
make
a
treatment
recommendation
to
the
state.
Once
the
treatment
is
approved
and
implemented,
the
state
re­
initiates
first­
draw
sample
collections
from
homeowners'
taps.
Upon
meeting
the
action
levels
for
two
consecutive
6­

month
periods,
the
systems
are
determined
to
have
optimal
corrosion
control
treatment.

NM
At
this
time
the
state
has
not
had
a
system
that
has
had
to
install
optimal
corrosion
control
treatment.

OK
Yes.
(
would
use
NOV
or
Consent
Order)

TX
All
have
complied,
if
a
system
did
not
it
would
been
sent
TCEQ's
enforcement
division.

IA
Over
300
systems
have
failed
either
lead
or
copper
over
the
past
12
years.
Many
of
these
collected
the
two
follow­
up
rounds
of
samples
and
did
not
do
a
report
or
install
treatment.

KS
Not
all
systems
have
met
the
required
deadline
to
install
optimal
corrosion
control
treatment.

Systems
failing
to
install
optimal
corrosion
control
treatment
by
the
required
deadline
receive
a
treatment
technique
violation
and
are
required
to
perform
public
notification.
Systems
still
failing
to
install
corrosion
control
treatment
receive
a
violation
reminder
notice,
and
the
district
staff
are
notified
to
contact
the
system.
System
still
failing
to
install
treatment
are
issued
a
directive
which
is
followed­
up
with
and
administrative
order
if
treatment
is
not
installed.

MO
All
systems
have
met
the
required
deadlines.

NE
No.
Several
were
late
in
installing
OCCT.
The
State
took
enforcement
action
against
those
systems
in
the
form
of
administrative
penalties
(
fines).
Monitoring
and
enforcements
by
the
State
continue
until
systems
are
back
in
compliance.
DCTM_
ARP.
xls
Page
131
CO
Regarding
the
systems
addressed
in
40
CFR
141.81(
d)(
4);
40
CFR
141(
e)(
5)
all
systems
in
the
State
of
Colorado
have
completed
installation
of
optimal
corrosion
control
treatment.
There
are
new
systems
or
recently
reclassified
systems
which
are
currently
in
the
initial­
sampling
phase
in
order
to
determine
if
an
optimal
corrosion
control
treatment
plan
is
in
place.
In
addition,
there
are
some
system
which
are
in
follow­
up
studies
following
an
exceedance
and
a
desk
top
study
in
order
to
determine
if
an
optimal
corrosion
control
treatment
plan
has
been
achieved.

MT
No.
The
process
to
require
compliance
with
all
LCR
requirements
is
on
going,
including
enforcement
actions.

ND
No,
we
have
nine
(
9)
systems
that
still
have
a
copper
action
level
exceedance.
We
are
working
with
these
nine
systems
to
adjust
their
treatment
and
to
continue
to
conduct
follow­
up
lead/
copper
monitoring.
We
have
no
systems
in
North
Dakota
that
have
a
lead
action
level
exceedance.

SD
Yes,
we
currently
only
have
one
system
that
is
trying
to
optimize
their
corrosion
control
treatment,
but
they
have
not
passed
their
deadline.

UT
Water
systems
valid
action
level
exceedences
have
installed
optimal
corrosion
control
treatment.

The
water
systems
with
existing
corrosion
treatment
are
sampling
to
verify
that
adequate
treatment
is
occurring.
For
water
systems
that
have
never
sampled,
enforcement
actions
are
being
taken
to
see
if
corrosion
control
treatment
is
needed.

WY
No.
Wyoming
has
a
few
systems
that
have
exceeded
the
lead
and/
or
copper
action
levels.
An
optimal
corrosion
control
treatment
plan
was
approved
by
Region
8
for
some
of
these
systems
but
the
systems
have
failed
to
notify
Region
8
as
to
whether
or
not
corrosion
control
has
been
installed.
We
are
in
the
process
contacting
these
systems
to
learn
the
current
status
of
their
corrosion
control
treatment.
Other
systems
were
requested
to
submit
an
optimal
corrosion
control
treatment
plan
and
have
not
done
so.
We
are
also
contacting
these
systems.
Systems
that
refuse
to
work
with
Region
8
are
referred
to
enforcement.

AZ
Yes.

CA
No,
many
small
water
systems
are
still
evaluating
various
corrosion
control
techniques.
These
systems
are
given
citations
with
timelines
for
compliance.

HI
All
systems
have
met
the
deadlines
to
install
treatment.
DCTM_
ARP.
xls
Page
132
NV
Yes,
except
one
(
Jarbidge).
Jarbidge
is
very
near
start­
up
of
a
new
treatment
plant
(
required
under
surface
water
treatment
requirements)
which
includes
the
capability
to
implement
corrosion
control
processes.

Amer
Sam
No.
One
small
satellite
system
exceeded
the
action
level
and
we
are
now
into
the
corrosion
control
evaluation
and
implementation
phase
outlined
in
40
CFR
141.81
(
a)(
2).

Navajo
No,
not
all
systems
met
the
deadline.
PWSSP
writes
letters
of
noncompliance
and
meets
with
the
public
water
system
owner/
operator.
PWSSP
elevates
the
letters
to
Notices
of
Violations
(
NOVs),
Compliance
Agreements
and
Administrative
Orders
to
Comply
as
necessary.

AK
No,
some
systems
that
have
failed
to
meet
their
deadline
have
been
issued
NOVs;

Administrative
Penalties
is
the
next
step
if
they
fail
to
comply.

WA
No.
The
lead
and
copper
rule
allow
approximately
48
months
for
water
systems
to
complete
the
entire
corrosion
control
process.
DOH
monitors
progress
with
corrosion
control
milestones
on
a
quarterly
basis
and
works
with
systems
when
a
major
milestone
is
missed.

ID
Idaho
has
started
or
completed
enforcement
actions
against
all
water
systems
that
we
have
determined
to
be
late
with
the
installation
of
optimal
corrosion
treatment
for
lead.
Presently
we
have
6
fully
executed
enforcement
actions
for
lead
corrosion
optimization
and
2
more
actions
being
routed
for
signatures.

OR
While
the
majority
of
systems
have
installed
the
required
corrosion
control,
the
state
is
still
working
with
a
few
systems
who
have
not
found
a
successful
method
of
corrosion
control.

How
do
systems
notify
the
state
of
treatment
changes?
Does
the
state
require
that
systems
provide
information
about
potential
effects
of
treatment
changes
on
corrosion
control?
DCTM_
ARP.
xls
Page
133
CT
Public
Water
Systems
notify
the
CTDPH
 
DWD
of
treatment
changes
in
writing.
All
Public
Water
Systems,
pursuant
to
the
B102
regulations,
are
required
to
notify
and
gain
the
approval
of
the
CTDPH
 
DWD
prior
to
any
construction
of
sanitary
significance,
this
would
include
any
changes
in
water
treatment.
The
B102
regulations
also
incorporate
similar
rhetoric
as
the
40
CFR
141.81(
b)(
3)(
iii)
requiring
that
any
Public
Water
System
deemed
to
have
optimized
corrosion
control
shall
obtain
the
approval
of
the
CTDPH
 
DWD
in
writing
prior
to
any
change
in
treatment
or
the
addition
of
a
new
source.
In
regards
to
the
Public
Water
Systems
being
required
to
provide
information
about
the
potential
effects
of
such
treatment
changes
on
corrosion
control,
the
Public
Water
Systems
are
not
required
to
provide
such
information,

however,
the
information
is
gained
by
the
CTDPH
 
DWD
through
technical
assistance
or
research.

MA
Systems
are
required
to
seek
approval
for
all
changes.
DEP
requires
information
about
potential
effects
of
treatment
changes
on
corrosion
control.

ME
Water
system
must
inform
the
state
prior
to
making
any
treatment
changes.
The
State
requires
the
water
system
to
collect
water
quality
parameters
prior
to
a
treatment
change
and
again
after
the
treatment
is
installed
to
determine
if
the
system
is
maintaining
their
optimum
corrosion
control
treatment.

NH
Systems
are
required
to
inform
the
WSEB
of
treatment
changes
in
writing.

RI
Systems
are
required
to
submit
plans
stamped
by
a
registered
engineer
for
any
treatment
installation
/
change
in
treatment.
Yes.

VT
The
system
may
or
may
not
notify
the
State
of
treatment
changes.
Notification
occurs
in
writing,
via
phone
calls,
or
is
documented
during
sanitary
surveys.
Per
the
VT
Water
Supply
Rule,
water
systems
are
required
to
apply
for
a
construction
permit
for
any
improvements
which
affect
water
quality
and
quantity
of
water
service
rendered.
DCTM_
ARP.
xls
Page
134
NY
Purveyors
are
required
by
regulation
to
obtain
approval
for
modifications
to
a
public
water
supply
before
the
modifications
are
implemented,
including
any
change
in
treatment.
If
the
proposed
treatment
changes
could
affect
water
chemistry,
state
and
local
health
offices
request
information
on
potential
effects
of
the
changes
on
corrosion
control,
and
after
implementation
of
the
changes
require
re­
testing
for
lead
and
copper.
Changes
to
coagulation
or
water
softening
are
probably
the
most
common
treatment
changes
that
require
new
evaluations
for
lead
and
copper.

NJ
By
State
regulation,
N.
J.
A.
C.
7:
10­
2.4,
a
supplier
of
water
shall
notify
in
writing
the
Bureau
of
Safe
Drinking
Water
at
least
5
working
days
before
undertaking
any
planned
change.
Yes,

implicitly.
State
Regulation,
N.
J.
A.
C.
7:
10­
11.5(
a)
requires
"
No
person
shall
construct
or
modify
a
public
community
water
system
prior
to
obtaining
a
permit
from
the
department"
and
in
~
(
b)
"
the
permit
application
shall
include
an
engineer's
report"
which
in
~(
5)
include
"
a
description
of
proposed
treatment
processes,
including
data
demonstrating
that
the
processes
will
produce
treated
water
that
meets
the
requirement
of
the
State
primary
and
secondary
drinking
water
regulations".

DE
Systems
are
required
to
submit
plans
before
making
any
changes
to
their
treatment
processes.

Yes,
the
idea
of
installing
treatment
is
to
reduce
corrosion.

MD
The
water
systems
are
asked
to
notify
the
State
in
writing
when
treatment
has
been
installed.
In
some
cases,
field
staff
identify
the
treatment
change
during
a
sanitary
survey.
If
a
major
treatment
change
is
expected
to
impact
corrosion
control,
a
water
system
may
be
asked
to
perform
lead
and
copper
monitoring
before
the
next
scheduled
sample
period.

VA
The
Commonwealth
of
Virginia
Waterworks
Regulations
require
that
the
State
Health
Commissioner
issue
a
Waterworks
Construction
Permit
for
any
water
treatment
unit
processes
to
be
installed
or
modified.
Before
a
Construction
Permit
can
be
issued,
plans
and
specifications
must
be
prepared
by
a
professional
engineer
and
submitted
to
the
respective
Office
of
Drinking
Water
Field
Office
for
review.
During
our
review
of
the
proposed
treatment,
any
potential
impact
on
corrosion
control
is
evaluated.
If
deemed
necessary,
we
will
require
that
additional
lead
and
copper
tap
samples
be
collected
by
the
waterworks
owner
after
any
treatment
modifications
to
demonstrate
that
optimum
corrosion
control
treatment
is
maintained.
DCTM_
ARP.
xls
Page
135
WV
Any
significant
change
to
treatment
must
be
submitted
through
the
construction
permit
process.

Information
about
potential
corrosion
control
effects
may
be
required
to
be
addressed
in
the
permit
process.

PA
Water
suppliers
are
required
to
obtain
a
permit
prior
to
installing/
modifying
any
treatment
scheme.
Through
the
permitting
process,
systems
are
required
to
address
any
simultaneous
compliance
issues
that
may
result
from
a
treatment
change.

AL
In
writing.
No,
but
they
are
required
to
inform
us
in
writing
of
any
treatment
changes.

FL
Systems
are
required
by
rule
to
notify
the
state
in
the
event
they
change
any
treatment
technique.
In
the
past,
the
treatment
changes
were
primarily
corrosion
control
treatment
changes,
i.
e.,
changing
from
one
orthophosphate
to
another.
However,
recently
we
are
seeing
an
increasing
number
of
systems
switching
from
gas
chlorine
to
hypochlorite
and
from
traditional
chlorination
to
chloramines.
As
a
general
rule,
we
require
systems
to
increase
lead
and
copper
monitoring
until
we
are
sure
there
have
been
no
changes
in
the
corrosivity
of
the
water.

KY
Water
systems
are
required
to
request
treatment
changes
through
the
Drinking
Water
Branch's
Plans
Review
Section.
The
proposed
changes
are
evaluated
to
determine
if
there
would
be
any
impact
on
the
system's
corrosion
control
program
and
whether
the
system
will
need
to
return
to
initial
monitoring
after
the
treatment
change
is
in
place.

MS
Treatment
changes
are
identified
during
the
annual
sanitary
survey
or
communicated
by
the
system
to
regional
MSDH
staff.
If
regional
staff
determine
that
treatment
process
changes
may
affect
corrosion
control,
systems
are
alerted
so
that
adjustments
can
be
made.
DCTM_
ARP.
xls
Page
136
NC
As
specified
in
40
CFR
141.90(
a)(
3),
certain
water
systems
are
required
to
notify
the
state
in
writing
no
later
than
60
days
after
any
treatment
changes
or
the
addition
of
a
new
water
source.

These
systems
are
encouraged
to
notify
the
state
prior
to
making
any
changes
and
to
consider
the
effect
the
changes
may
have
on
corrosion
control
and
to
minimize
the
risk
of
undesirable
effects.
Water
systems
are
required
to
consider
the
interactions
between
treatment
processes
and
corrosion
control
when
completing
their
corrosion
control
studies.
Often,
this
task
is
handled
by
consulting
engineers
completing
the
study.
Generally,
the
submittal
of
engineering
reports,
plans
and
specifications
is
required
for
approval
prior
to
making
any
changes
that
affect
the
functioning
of
treatment
processes.
Based
on
input
from
our
regional
offices,
some
small
water
systems
do
not
follow
the
notification
requirements
addressed
in
this
question
and,

subsequently,
exceed
the
action
levels
after
making
these
"
adjustments."

NC
(
cont)
Other
small
water
systems
subject
to
triennial
monitoring
make
treatment
changes
without
notification
and
without
sampling
to
determine
the
effects
of
the
changes.
These
circumstances
are
often
discovered
during
inspection
visits
and
sanitary
surveys.
The
large
and
medium
water
systems
tend
to
be
more
conscientious
about
discussing
treatment
changes
and
the
possible
effect
on
corrosion
control
with
the
regional
offices
prior
to
implementation
of
the
changes.

SC
A
system
that
is
using
treatment
as
a
means
of
complying
with
the
LCR
must
submit
a
request
to
change
that
treatment
along
with
their
reasoning
for
that
change.
The
Department
will
then
determine
whether
or
not
to
approve
the
change
and
if
approved,
will
provide
the
system
with
a
timeframe
for
making
the
change.
The
Department
generally
will
not
request
the
system
to
provide
any
potential
health
affects
as
a
result
of
the
change.

TN
TN
requires
systems
to
obtain
state
approval
before
changing
any
processes
affecting
the
quality
or
quantity
of
water
produced.
T.
C.
A.
68­
221­
706
requires
the
Department
to
review
and
approve
any
change
planned
for
a
public
water
system
that
may
affect
the
quality
or
quantity
of
water
produced.
State
regulation
1200­
5­
1­.
05
also
addresses
the
issue.
Changes
may
result
in
systems
being
directed
to
resume
standard
or
accelerated
monitoring.

GA
Requests
for
treatment
changes
are
made
to
the
State
in
writing.
Yes
DCTM_
ARP.
xls
Page
137
MI
Systems
are
to
notify
MDEQ
staff
either
in
writing
or
verbally
to
request
permission
to
change
treatment
processes
or
alter
chemicals
applied
to
the
water
system.
When
a
treatment
change
request
is
submitted,
MDEQ
staff
review
the
request
to
make
certain
that
the
change
will
work
for
its
intended
purpose,
and
also
for
its
effect
on
the
corrosivity
of
the
water.
If
the
change
involves
significant
modifications
to
facilities
or
equipment,
a
construction
permit
will
be
issued.

If
the
changes
are
primarily
in
the
chemical
compound
being
applied,
approval
may
be
given
in
writing
or
verbally.
It
is
possible
staff
may
not
find
out
about
minor
treatment
changes
until
after
they
are
already
in
place.
In
this
situation,
a
review
of
the
changes
is
still
conducted
by
staff.

IL
Regional
Offices
are
notified
of
treatment
changes
through
notification
by
the
water
system
or
through
inspections.
The
Regional
Offices
notifies
the
Central
Office
where
updates
are
made
to
SDWIS/
State.
In
addition,
systems
are
required
to
obtain
a
construction
and
operating
permit
from
the
state
whenever
a
treatment
change
is
made.
The
supplier
shall
evaluate
the
effect
of
the
chemicals
used
for
corrosion
control
treatment
on
other
water
quality
treatment
processes
in
the
Desktop
Evaluation.

IN
Systems
are
require
to
notify
the
state
by
letter
of
any
treatment
changes
if
it
could
potentially
effect
the
corrosion
control
treatment
already
in
place
to
treat
their
lead/
copper
problem.

MN
The
large
and
medium­
sized
systems,
in
general,
do
consult
with
the
MDH
when
considering
making
treatment
changes
and/
or
switching
from
a
corrosion
inhibitor
blend
to
another,

particularly
when
there
is
a
change
in
the
make­
up
of
the
ortho/
poly
ratio.
Otherwise,
treatment
changes
are
identified
via
plan
review
approval
process
or
via
sanitary
survey.
The
MDH
does
require
systems
proposing
making
treatment
changes
to
address
the
potential
effects
on
Pb/
Cu
corrosion
control.

OH
Public
water
systems
must
submit
detail
plans
for
approval
prior
to
making
treatment
changes.

There
is
no
formal
requirement
that
systems
provide
information
about
potential
effects
of
treatment
changes
on
corrosion
control.
The
system
may
include
potential
effects
with
their
detail
plans
if
they
are
known
to
the
system.

WI
The
chemical
feed
change
requires
written
notification
as
part
of
the
plan
review
process.

Systems
must
provide
information
on
the
chemical
currently
used,
the
proposed
chemical,
and
justification
for
the
change.
DCTM_
ARP.
xls
Page
138
AR
In
general
they
do
not.
Regional
staff
inform
Tech
Staff
of
changes
directly
or
through
searchable
databases
updates.
Systems
are
required
to
notify
the
State
of
changes,
but
there
is
no
tracking
mechanism
to
ensure
that
they
do.

LA
The
systems
are
required
to
submit
a
request
for
treatment
changes
to
the
state's
regional
engineering
offices
for
review.
Upon
review
of
such
a
request,
the
regional
engineering
office
may
request
information
about
potential
effects
of
treatment
changes
on
corrosion
control
if
any
significant
effects
are
expected
or
suspected.

NM
No
answer.

OK
In
writing.
Yes.

TX
Notification
of
all
treatment
changes
is
required
in
writing
by
Rule
and,
if
applicable,
corrosion
control
effects
must
be
included.

IA
The
question
is
not
clear.
Once
we
have
designated
a
specific
corrosion
control
technique
and
treatment
has
been
installed,
any
request
to
change
or
modify
that
process
must
be
submitted
in
writing
for
approval.
For
other
treatment
plant
changes,
we
typically
do
not
require
an
assessment
on
its
impact
on
corrosion
control.

KS
Systems
are
required
to
notify
the
state
in
writing
of
any
treatment
changes
and
potential
effects
on
corrosion
control.

MO
No
procedure
established
for
changes
in
treatment
process,
and
changes
within
a
treatment
process
are
not
monitored.
All
water
treatment
plants
run
a
saturation
test
that
would
show
corrosion
regardless
of
treatment
process.
We
would
learn
of
treatment
process
changes
through
discussion
with
the
public
water
system,
submission
of
plans
and
specs
to
install
a
treatment
process
change,
and
regular
inspections
and
contact
by
our
regional
office
staff.

NE
Systems
are
required
to
notify
the
State
when
changes
in
treatment
include
any
installation
of
new
equipment
(
feeders,
pumps,
tanks,
etc.)
and
when
any
change
in
treatment
will
affect
monitoring
and
reporting
requirements.
So
far,
Nebraska
has
not
required
specific
information
from
systems
on
the
potential
effects
of
treatment
changes
on
corrosion
control.

CO
The
Colorado
Primary
Drinking
Water
Regulations
require
public
water
systems
to
notify
the
State
in
writing
of
any
treatment
changes
that
occur
or
new
sources
that
come
on
line
that
would
potential
effect
the
systems
optimal
corrosion
control
treatment
plan.
DCTM_
ARP.
xls
Page
139
MT
A
PWS
may
not
modify,
alter,
or
extend
its
system
without
prior
department
plan
review
and
approval.
That
is
addressed
by
the
reviewing
engineer.

ND
Systems
are
required
to
notify
us
of
any
changes
in
their
treatment
process
through
plan
and
specification
review.
No
information
is
required
about
the
potential
effects
treatments
changes
may
cause.

SD
All
systems
get
a
sanitary
survey
every
three
years
and
we
can
catch
changes
at
a
minimum
at
least
that
often.
Most
systems
call
us
when
they
are
making
a
change
to
their
system.
If
they
change
water
sources
or
if
they
hookup
to
rural
water
we
usually
catch
those
right
away
and
get
them
back
on
routine
monitoring.

UT
The
State
identifies
construction
and
treatment
modifications
including
corrosion
control
treatment
and
treatment
chemical
changes
as
"
public
drinking
water
project"
see
Utah
Rule
R309­
500­
5(
1).
The
State's
require
that
notification
for
all
projects
be
made
by
the
public
water
system
on
a
form
provided
by
the
State.
Further,
the
State
rules
require
plan
approval
before
commencement
of
construction
or
treatment
chemical
change.
For
non­
corrosion
control
types
of
treatment
that
might
affect
corrosivity,
the
State
is
currently
looking
at
rule
changes
to
ensure
that
the
proposed
treatment
will
not
increase
the
corrosive
nature
of
the
water.
In
the
interim,
before
rule
changes
are
finalized,
staff
will
encourage
the
design
community
to
properly
evaluate
the
effects
of
the
proposed
treatment
on
water
corrosivity.

WY
By
letter,
by
telephone
or
through
sanitary
surveys.
No
AZ
Approval
from
State
required.
It
is
evaluated
in
the
approval
process.

CA
System
are
required
to
obtain
an
amended
operating
permit
before
any
treatment
changes
can
be
made.
The
proposed
changes
would
be
contained
in
their
application
to
amend
their
permit.

Yes,
the
potential
effects
are
evaluated
as
part
of
the
issuance
of
the
amended
permit.

HI
Water
systems
are
required
to
notify
the
State
of
treatment
changes
in
writing.
The
water
system
is
not
required
to
notify
the
State
if
a
change
in
disinfection
is
implemented.
No.
DCTM_
ARP.
xls
Page
140
NV
Changes
involving
process
equipment
or
facilities
changes
require
submittal
of
plans
and
specifications;
changes
involving
chemicals
used
in
treatment
also
require
submittal
of
specifications
of
the
chemicals
to
be
used.
These
requirements
are
in
the
Nevada
Administrative
Code
(
NAC)
in
the
sections
dealing
with
Design,
Construction,
Operation
and
Maintenance
of
Public
Water
Systems.
When
changes
in
process
equipment,
facilities,
or
chemicals
are
proposed
and
submitted
for
required
approval,
our
review
can
require
that
information
about
potential
effects
on
corrosivity
and
corrosion
control
be
addressed.
Systems
are
required
to
operate
a
system
for
the
control
of
corrosion
that
minimizes
the
concentration
of
lead
and
copper
at
the
consumers'
taps
where
warranted
(
NAC
445A.
66675),
and
this
requirement
can
be
re­
evaluated
in
light
of
any
other
changes
in
treatment.

Amer
Sam
ASEPA
works
closely
with
ASPA,
the
utility,
on
all
matters
related
to
drinking
water
treatment.

Treatment
changes,
should
they
occur,
would
be
implemented
in
consultation
with
ASEPA.

Navajo
§
706(
H)
of
the
NNPDWR
describes
the
requirement
that
the
system
notify
the
Director
of
treatment
changes.
The
systems
are
required
to
notified
the
Director
and
undocumented
changes
are
"
found"
during
regular
sanitary
survey
inspections.
The
PWSSP
does
not
require
the
system
to
provide
information
about
potential
effects
of
treatment
changes
on
corrosion
control.
This
is
not
required
but
if
a
PWSSP
staff
is
working
with
the
system
and
the
potential
effects
along
with
other
potential
effects
of
other
NNPDWR
are
evident,
the
information
about
the
treatment
change
is
requested.

AK
Yes,
the
systems
are
required
to
submit
all
design
modifications
to
the
DW
Program
for
review
and
approval.

WA
DOH
most
frequently
learns
of
treatment
changes
when
a
water
system
submits
an
engineering
project
for
treatment
change
for
corrosion
control
or
other
treatment
processes.
DOH
may
also
learn
of
the
change
through
conversation
between
DOH
staff
and
the
utility,
or
through
the
sanitary
survey
process.
As
stated
in
the
CFR,
the
utility
has
the
obligation
to
inform
the
state.

ID
Changes
that
involve
physical
facility
changes
are
required
to
undergo
engineering
review
by
the
state.
Idaho
does
not
have
rules
requiring
the
reporting
of
operations
changes
so
long
as
the
changes
do
not
require
any
plant
hardware
changes.
DCTM_
ARP.
xls
Page
141
OR
Yes,
the
systems
notify
the
state
through
letters,
phone
calls,
email,
etc.
They
usually
notify
before
they
make
a
change
in
treatment
but
sometimes
the
states
learns
of
these
changes
after
they
are
made.
Systems
often
ask
the
state
for
advice
on
what
the
potential
effects
of
treatment
changes
may
be
on
corrosion
control.

Has
the
state
ever
adjusted
corrosion
control
treatment
decisions
because
of
concerns
with
simultaneous
compliance
with
other
national
primary
drinking
water
regulations,
or
because
of
changes
in
lead
levels?
CT
The
CTDPH
 
DWD
has
not
officially
adjusted
any
corrosion
control
treatment
decisions
besides
alterations
to
the
designated
water
quality
parameters
for
optimized
corrosion
control
per
the
language
within
the
B102
regulations
and
40
CFR
141.82(
h).
The
CTDPH
 
DWD
has
made
unofficial
"
minor"
alterations
to
corrosion
control
treatment
decisions
while
providing
technical
assistance
on
overall
compliance
concerns.
The
Public
Water
Systems
are,
in
large
part,
responsible
for
maintaining
compliance
with
the
National
Primary
Drinking
Water
Regulations
and
the
State
of
Connection
regulations
that
follow
with
the
CTDPH
 
DWD
providing
detailed
technical
assistance
to
all
Public
Water
Systems
ensuring
that
compliance
is
maintained
and
pursuing
appropriate
enforcement
actions
when
compliance
is
not
achieved.

MA
Yes.

ME
Yes.

NH
Yes.

RI
Yes.
DCTM_
ARP.
xls
Page
142
VT
WSD
is
concerned
with
the
impact
treatment
has
on
compliance
with
other
national
primary
drinking
water
regulations,
particularly
DBP
Rule.
The
WSD
does
revisit
corrosion
control
treatment
when
the
action
level
is
exceeded
in
all
cases.
If
a
system
fails
again
they
are
required
to
revisit
their
treatment
and
re­
sample
for
the
water
quality
parameters.

NY
State
and
local
health
offices
occasionally
receive
requests,
or
make
requirements,
for
systems
to
adjust
or
change
corrosion
control
treatment
based
on
lead
and
or
copper
results.
It
is
more
common
that
treatment
modifications
made
to
meet
surface
water
treatment
rules
lead
to
changes
in
corrosion
control
requirements.
Systems
that
need
to
change
treatment
to
meet
disinfection
byproduct
standards
and
systems
constructing
new
filtration
plants
are
prime
examples.
Several
systems
in
Westchester
County
that
are
under
consent
order
for
improvements
required
under
surface
water
treatment
rules
have
been
permitted
to
delay
some
lead
and
copper
rule
requirements
in
anticipation
of
planned
changes
to
water
treatment.
These
systems
rely
on
New
York
City's
Croton
water
supply
and
are
awaiting
completion
of
filtration
treatment
by
New
York
City.
These
systems
have
not
yet
met
optimal
corrosion
control
requirements,
but
are
implementing
the
public
education
requirements
of
the
rule.
These
systems
will
be
required
to
address
all
lead
and
copper
requirements
upon
implementation
of
required
improvements.

NJ
Yes.

DE
Not
to
my
knowledge.

MD
Corrosion
control
treatment
decisions
have
been
modified
based
on
other
related
compliance
decisions
such
as
NPDES
permits
(
phosphate
addition);
consecutive
water
system
coordination
of
treatment.

VA
There
have
been
several
occasions
where
we
have
made
modifications
to
corrosion
control
treatment
decisions
to
reduce
lead
levels
at
waterworks.
These
modifications
have
usually
been
to
change
the
method
of
corrosion
control
treatment
at
specific
waterworks.
We
are
not
aware
of
situations
that
required
a
need
to
modify
corrosion
control
treatment
decisions
due
to
concerns
of
compliance
with
other
primary
drinking
water
regulations.

WV
No.

PA
Yes.
DCTM_
ARP.
xls
Page
143
AL
No,
the
state
has
not
adjusted
corrosion
control
treatment
but
has
required
systems
to
adjust
existing
corrosion
control
based
on
lead
or
copper
action
level
exceedances.

FL
Generally
the
state
does
not
change
corrosion
control
treatment
decisions
made
by
water
systems.
If
the
decision
the
system
makes
turns
out
not
to
work,
the
state
requires
further
study
and
the
selection
of
a
different
CCT
method.

KY
No.

MS
Only
one
system
(
surface
water)
has
had
to
make
changes
to
corrosion
control
treatment
in
order
to
maintain
compliance
with
the
Stage
1
DBP
Rule.
This
change
in
treatment
has
not
affected
lead/
copper
levels
NC
Adjustments
to
corrosion
control
treatments
because
of
concerns
with
simultaneous
compliance
with
other
national
primary
drinking
water
regulations
were
initiated
by
the
water
systems
and
were
not
directed
by
the
state.
Based
on
input
from
our
regional
offices,
once
compliance
standards
are
achieved,
the
water
systems
generally
do
not
make
treatment
changes.
During
initial
implementation
of
the
Lead
and
Copper
Rule,
systems
reviewed
the
various
chemical
products
and
their
effects
on
treatment
processes.
Chemical
products
and/
or
vendors,
as
well
as,
dosage
rates
were
changed
by
the
systems
to
achieve
compliance
with
action
levels.
Some
systems
also
stopped
using
zinc­
orthophosphate
compounds
because
of
concerns
with
toxicity
at
their
wastewater
treatment
facilities.

SC
No.
However,
in
the
case
where
a
system
has
implemented
an
OCCT
recommendation
and
continues
to
exceed
either
action
level,
the
Department
will
require
the
system
to
provide
the
Department
with
a
new
OCCT
recommendation.
If
the
system
fails
to,
or
cannot
provide
an
approvable
OCCT,
then
the
Department
will
designate
an
appropriate
OCCT
recommendation.

TN
No
specific
examples
come
to
mind,
but
it
is
an
issue
that
is
given
consideration.
Systems
that
cannot
meet
the
action
level
are
reviewed
and
changes
are
made
to
achieve
compliance
with
the
action
level.
If
this
means
adjusting
or
modifying
the
corrosion
control
treatment,
it
is
changed.

GA
Yes.

MI
The
answer
to
the
first
part
is
no.
The
answer
to
the
second
part
is
yes
­
there
have
been
a
few
cases
where
the
state
has
advised
the
water
supplier
to
adjust
or
modify
the
chemical
feed
system
based
on
lead
and/
or
copper
levels
getting
near,
but
not
exceeding
the
action
levels.
DCTM_
ARP.
xls
Page
144
IL
The
Agency
has
modified
a
previous
corrosion
control
treatment
decision
when
it
has
been
determined
that
such
change
is
necessary
to
insure
that
the
supplier
continues
to
optimize
corrosion
control
treatment,
such
as
a
change
in
pH
or
the
addition
of
a
treatment
process.

However
to­
date,
a
corrosion
control
treatment
decision
has
never
been
modified
due
to
concerns
with
simultaneous
compliance
with
other
national
primary
drinking
water
regulations.

IN
The
PWS
is
required
to
submit
a
revised
OCCTR
each
time
they
continue
to
exceed
the
action
level
during
a
monitoring
period.

MN
In
few
incidents,
after
the
MDH
had
specified
the
OWQP
and
systems
were
operating
within
the
specified
OWQP
limits
yet
exceeded
the
lead
A.
L.
and/
or
experienced
increases
in
copper
levels,
the
MDH
did
adjust
the
OWQP
specifications,
such
as
requiring
systems
to
increase
the
feed
rate
or
to
maintain
a
higher
orthophosphate
residual
level
in
their
water
distribution
systems.

OH
No,
the
state
does
not
adjust
corrosion
control
treatment
decisions
because
of
concern
with
simultaneous
compliance
with
other
national
primary
drinking
water
regulations.
Systems
typically
propose
treatment
recommendations
and
the
state
evaluates
them
based
in
part
on
the
system's
submittal
of
US
EPA
Form
141­
C
"
Desktop
Evaluation
Short
Form
for
Small
and
Medium
PWS
Treatment
Recommendations".

WI
No.

AR
Corrosion
control
treatment
strategies
are
reviewed
in
context
with
other
competing
rules.

LA
As
stated
previously,
the
state's
regional
engineering
offices
review
all
requests
for
treatment
changes,
including
corrosion
control
treatment.
To
our
knowledge,
no
regional
office
has
ever
adjusted
corrosion
control
treatment
decisions
because
of
concerns
for
compliance
with
other
national
primary
drinking
water
regulations.
However,
a
few
systems
are
currently
undergoing
a
re­
evaluation
process
to
determine
if
their
corrosion
control
treatment
is
sufficient
to
maintain
low
levels
of
lead.

NM
No
answer.

OK
No.

TX
Yes,
the
TCEQ
has
adjusted
corrosion
control
treatment
for
PWSs,
but
not
because
of
pH
level
changes.
DCTM_
ARP.
xls
Page
145
IA
We
have
not
had
any
system
request
a
change
due
specifically
to
concerns
about
simultaneous
compliance
with
other
NPDWR.
We
have
had
systems
where
the
state
has
changed
or
adjusted
corrosion
control
treatment
decisions,
but
these
have
primarily
been
due
because
the
original
treatment
option
was
not
working.
The
system
wished
to
try
another
option
to
see
if
that
option
might
be
more
effective.

KS
The
state
has
not
adjusted
corrosion
control
treatment
decisions
because
of
concerns
with
other
national
primary
drinking
water
regulations
of
because
of
changes
in
lead
levels.

MO
No.

NE
No.

CO
The
State
does
not
initiate
adjustments
to
a
public
water
system's
corrosion
control
treatment
plan.
However,
if
a
public
water
system
has
exceeded
a
lead
or
copper
action
level
and
is
undergoing
a
corrosion
control
study
the
State
provides
direct
technical
assistance
to
help
the
system
to
make
adjustments
in
order
to
obtain
an
optimal
corrosion
control
treatment
plan.
In
addition,
if
a
system
is
requesting
or
applying
for
a
plan
review
because
of
a
treatment
change
or
added
source
the
State
might
also
direct
decisions
concerning
adjustment
of
corrosion
control.

MT
Not
to
my
knowledge.

ND
Yes,
we
always
encourage
systems
to
evaluate
their
corrosion
control
treatment
if
an
action
level
is
exceeded
on
an
ongoing
basis,
or
if
they
previously
met
the
action
levels
and
subsequently
have
an
exceedance.
Water
Quality
Parameters
can
not
be
exceeded,
as
these
results
only
provide
information
on
the
water
chemistry
for
the
system
so
they
can
provide
an
effective
treatment
for
their
corrosion
problem,
specific
to
their
water
chemistry.

SD
No.

UT
The
State
does
adjusted
corrosion
control
treatment
decisions
because
of
changes
in
lead
levels.

In
the
case
of
a
system
that
completed
lead
service
line
replacement,
corrosion
control
treatment
was
eliminated
when
the
lead
levels
dropped
below
the
action
level.
If
the
action
level
is
exceeded
the
State
begins
a
process
of
evaluation,
advise
and
counsel
to
ensure
optimal
corrosion
control.

WY
No.
DCTM_
ARP.
xls
Page
146
AZ
Situation
has
not
occurred
yet.
This
is
something
EPA
should
be
considering
when
promulgating
rules.

CA
No.

HI
Yes.
Corrosion
control
treatment
was
revised
because
the
phosphate
chemical
did
not
reduce
lead
levels
below
the
lead
action
level,
or
because
of
community
concerns
that
the
phosphate
addition
caused
health
problems.

NV
No.

Amer
Sam
No.

Navajo
No,
but
PWSSP
may
be
interested
in
the
affects
relating
to
compliance
of
other
NNPDW
Regulations.

AK
Answer
unknown,
not
automatically
tracked.
Under
these
circumstances,
the
state
would
ask
for
a
change
in
design
modifications.

WA
Yes
when
higher
health
risk
issues
are
present
(
i.
e.,
surface
water
treatment,
disinfection,

ground
water
under
the
influence
of
surface
water,
etc.),
DOH
has
adjusted
schedules
so
utilities
can
meet
other
rule
requirements.
Additionally,
the
LCMR
allows
small
and
medium
systems
to
conduct
special
monitoring
after
an
exceedance
to
verify
results.
If
two
rounds
of
six­
month
sampling
are
below
the
action
level,
the
system
is
considered
to
have
optimized
for
corrosion
control
through
monitoring.
Lastly
a
system
can
investigate
switching,
replacing,
or
blending
sources;
or
have
a
water
line
extension
to
another
system
in
lieu
of
corrosion
control.

Has
the
state
ever
required
a
system
to
conduct
more
frequent
monitoring
to
evaluate
the
potential
effects
of
treatment
changes?

ID
No.

OR
No.
DCTM_
ARP.
xls
Page
147
Has
the
state
ever
required
a
system
to
conduct
more
frequent
monitoring
to
evaluate
the
potential
effects
of
treatment
changes?
CT
Increases
in
tap
water
monitoring
or
the
return
to
initial/
standard
monitoring
is
a
common
action
taken
by
the
CTDPH
 
DWD
to
evaluate
the
effects
of
treatment
changes
and
other
changes
of
significance
relative
to
lead
and
copper.

MA
Yes.

ME
No,
but
we
have
recommended
increased
monitoring
several
times
after
treatment
changes
have
been
implemented
NH
No,
the
WSEB
has
not
required
a
system
to
conduct
more
frequent
monitoring
but
the
WSEB
has
requested
that
systems
conduct
noncompliance
sampling
in
order
to
determine
the
effectiveness
of
existing,
new
and
changes
to
treatment.

RI
Yes.

VT
Only
when
treatment
has
failed.
Water
systems
will
make
changes
to
treatment
and
in
these
cases
conduct
increase
monitoring.

NY
Yes.
For
treatment
modifications
designed
or
expected
to
impart
changes
to
water
quality,
post
modification
monitoring
for
lead
and
copper
is
required
even
if
not
scheduled
under
the
system's
monitoring
schedule.
A
typical
example:
as
a
condition
of
approval
to
add
polyphosphate
to
sequester,
a
system
is
required
to
redo
the
initial
lead
and
copper
monitoring
required
by
rule.

NJ
No.

DE
We
have
recommended
that
system
conduct
monitoring
but
I
don't
believe
we
have
mandated
it.

MD
Yes.

VA
See
our
response
to
question
C2.
If
deemed
necessary,
we
will
require
that
additional
lead
and
copper
tap
samples
be
collected
by
the
waterworks
owner
to
demonstrate
that
optimum
corrosion
control
treatment
is
maintained.
DCTM_
ARP.
xls
Page
148
WV
No.
We
do
have
a
policy
in
place
where
the
system
must
conduct
two
six
month
monitoring
periods
when
a
change
in
source
(
specifically
was
a
producing
system
and
changed
to
a
purchase
system,
or
vice
versa).
If
both
periods
are
below
the
action
level,
then
can
go
directly
to
triennial
sampling
at
reduced
number
of
sites.

PA
Yes.

AL
Yes.

FL
There
have
been
occasions
where
the
state
has
required
additional
monitoring.
For
instance,

systems
changing
from
chlorine
to
chloramines
are
asked
to
increase
monitoring
until
we
are
sure
the
chloramines
are
not
adversely
affection
the
Lead
and
Copper
Rule.
Also,
we
have
had
occasions
where
the
treatment
process
is
changed
or
additional
treatment
is
added.
For
example,
we
had
a
plant
whose
treatment
process
was
lime
softening.
The
plant
added
a
reverse
osmosis
facility
and
blends
the
water
from
the
two
treatment
processes.
When
these
kinds
of
changes
occur,
the
state
requires
increased
monitoring.

KY
Yes.
In
certain
instances,
the
state
has
made
water
systems
that
have
initiated
a
significant
change
in
treatment
to
go
back
to
the
initial
lead
and
copper
monitoring
(
sampling
for
2
consecutive
6
months
periods)
at
full
sample
set
collection.

MS
No.

NC
Yes,
the
rule
manager
has
required
systems
to
conduct
more
frequent
monitoring
to
evaluate
the
potential
effects
of
treatment
changes.
These
circumstances
have
been
addressed
on
a
case­

bycase
basis
SC
No.

TN
Yes.
This
also
includes
a
change
of
source
water(
s).

GA
Yes.

MI
Yes,
there
have
been
cases
after
a
treatment
change
was
made
that
MDEQ
required
additional/
more
frequent
monitoring
to
assure
that
the
change
did
not
impact
lead/
copper
levels
in
the
finished
water.
Chelsea,
Hudson,
Coldwater
and
Battle
Creek
are
examples
of
water
systems
where
additional
monitoring
was
imposed
after
treatment
changes.

IL
If
it
is
felt
warranted.
To­
date,
one
large
system
was
required
to
conduct
a
study
that
involved
additional
lead/
copper
sampling.
DCTM_
ARP.
xls
Page
149
IN
Systems
implementing
corrosion
control
or
making
significant
changes
to
their
already
existing
corrosion
control
are
required
to
conduct
initial
sampling
(
6­
month
rounds)
to
evaluate
the
effectiveness
of
the
treatment.

MN
In
most
cases,
the
MDH
worked
with
systems
to
establish
testing
protocols
to
evaluate
the
treatment
effectiveness.
Typically
involve
collecting
additional
first­
draw
Pb/
Cu
and
WQPs
samples
at
4
­
6
demo
sites,
on
a
monthly
or
bimonthly
basis.
(
Since
the
MDH
pays
for
the
additional
testing,
systems
almost
always
follow
the
established
protocols.

OH
Yes,
the
state
has
required
this
of
at
least
one
system.
That
particular
system,
a
middle
school,

was
required
to
conduct
two
additional
6
month
monitoring
periods
over
the
original
two
6
month
monitoring
periods
to
assure
that
the
orthophosphate
feed
system
was
operating
properly
and
correcting
the
exceedance
as
anticipated.

WI
Yes.

AR
Systems
monitor
as
per
141.80­
141.90.

LA
The
state
requires
a
system
to
conduct
more
frequent
monitoring
in
order
to
evaluate
the
potential
effects
of
treatment
changes
only
when
the
Lead
and
Copper
sampling
event
following
the
change
indicates
levels
near
the
action
levels.

NM
No
answer.

OK
Yes.
Daily
MOR
sampling
at
WTP.

TX
Yes,
we
require
additional
sampling
if
treatment
is
questionable.

IA
No.

KS
The
state
has
required
systems
to
resume
standard
monitoring
after
adjustment
of
treatment.

MO
No.

NE
No.

CO
The
State's
plan
review
process
for
changes
to
treatment
includes
a
requirement
for
the
public
water
systems
to
indicate
whether
the
treatment
change
has
been
evaluated
for
impacts
to
lead
and
copper.

MT
Some
treatment
changes
have
resulted
in
the
system
being
returned
to
initial
monitoring.

ND
No,
we
do
not
require
systems
to
conduct
more
frequent
monitoring
when
changes
are
made
to
treatment.
We
feel
this
is
the
responsibility
of
the
system,
although
we
do
strongly
encourage
them
to
conduct
their
own
monitoring
to
ensure
that
the
treatment
is
effective.
DCTM_
ARP.
xls
Page
150
SD
No,
we
are
now
considering
it
for
systems
that
are
switching
from
chlorine
to
chloramines.

UT
Increase
monitoring
will
be
imposed
in
cases
where
there
is
insufficient
analytical
data
to
enable
the
State
review
engineer
to
make
a
proper
evaluation.

WY
No.

AZ
This
is
embedded
in
the
approval
process.

CA
No.

HI
The
state
specifies
when
lead
and
copper
monitoring
should
be
conducted
after
changes
to
treatment
are
made.
This
is
specified
in
all
cases.

NV
No.

Amer
Sam
No.

Navajo
No,
not
to
date.
Currently,
PWSSP
is
working
with
a
purveyor
in
a
community
showing
elevated
levels
of
copper.
Corrosion
control
is
not
requested
yet
and
PWSSP
has
required
the
purveyor
to
collect
confirmation
samples.
Pipe
replacement
will
be
recommended.

AK
Satisfactory
Pb/
Cu
results
are
required
to
test
for
corrosion
control
treatment
effectiveness
prior
to
an
Approval
to
Operate
is
granted.

WA
No.
However,
some
systems
do
investigative
monitoring
and
DOH
has
developed
guidance
to
assist
them
when
systems
collect
investigative
samples,
in
response
to
treatment
coming
on
line,

a
new
source,
or
when
complaints
are
received.

ID
No.

OR
The
state
usually
requires
the
system
to
start
over
with
initial
monitoring.
It
depends
on
exactly
what
the
change
is
but
usually
they
need
to
do
at
least
two
rounds
of
6­
month
monitoring
to
make
sure
the
changes
are
not
going
to
cause
a
problem.
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