Revised Iowa PWS Lead & Copper Sampling Plan Requirements Template

Provided by the Iowa Department of Natural Resources

All community and non-transient non-community public water supplies are required to comply with the Lead and Copper Rule.  As part of that rule, systems are required to have a sampling plan that’s specific to Lead and Copper.  The plan is kept on-site, and reviewed during a sanitary survey.  A template plan was originally developed as a collaborative effort with Iowa Rural Water Association and Iowa Department of Natural Resources several years ago.  The Iowa PWS Lead and Copper Sampling Plan Requirements template has just been revised based on a recent EPA memo, dated February 29, 2016.

The areas of revision include:

• Clarification of Tiers
• Clarification of sampling procedure, including:
  • The water must remain unused for at least 6 hours in the home plumbing before the sample is collected.  This is called a 6-hour minimum “no use” or “stagnation” or “stand time” period.
  • In a home, the 6-hour minimum stand time applies to the whole house, not just the individual sampling tap
  • Iowa has never encouraged pre-stagnation time flushing, however normal water use prior to start of the 6-hour stand time is acceptable and preferred
  • Sample at a cold water kitchen or bathroom tap that uses hard (unsoftened) water
  • Collect the first draw sample in a one-liter bottle (similar in size to one-quart), filling the bottle to the shoulder.  EPA now recommends a wide-mouth bottle be used for sample collection.
• Encouraging water supplies to provide the consumer notice as soon as possible, even though the regulation allows 30 days.  EPA would like to see the notice within 2 business days of the system receiving the laboratory report if the analytical result for that sampling site is above the action level.

Please look at your Lead & Copper Sampling Plan and, if you haven’t already, change the mailing address for the DNR Water Supply Operation Section to the following:

Water Supply Operation Section
Iowa Department of Natural Resources
502 E. 9th Street
Des Moines, IA 50319-0034

This is the address where the change of sampling site forms should be sent.  The forms can also be faxed to 515/725-0348, or scanned in .pdf and emailed to your Water Supply Operations Section specialist (the person who’s listed on the cover letter of your most recent permit).  Remember that the new site must meet the highest Tier site (Tier 1), if at all possible.

The revised plan is available on the DNR website at http://www.iowadnr.gov/Environmental-Protection/Water-Quality/Drinking-Water-Compliance/Forms (on the Forms page under Drinking Water Compliance), as .pdf and .doc.

Also, as a reminder, the faucet aerator should not be removed before the lead and copper sample is collected.  It’s a good practice for homeowners to clean their water tap aerators on a routine basis, and remove any particulate matter that may have accumulated.  However, it should not be done just prior to the lead and copper sample collection.

When the Lead and Copper Rule was first implemented in 1991-1993, all systems had to conduct a Materials Evaluation, which was the review and inventory of the plumbing materials used in the specific water system.  The evaluation was used to determine the sampling sites, and had to be retained for at least 12 years.  We are well past that time period now, but if you do still have your inventory, please hold on to it.

Now is a great time to look at your operation permit and see when you are next scheduled to collect lead and copper samples.  If you have any questions about the Lead and Copper Rule sampling requirements, please contact the person listed in your operation permit.