Lead and Copper Sample Siting Plan Guide
A water system must develop and maintain a Lead & Copper Sample Siting Plan that identifies high-risk tap sampling locations based on service line material and plumbing type, as required by the Lead and Copper Rule Revisions (LCRR). This guide covers service line inventory, tier classification, site selection, and regulatory compliance for community and non-transient non-community systems.
Every community water system and non-transient non-community water system must collect first-draw tap samples from customer locations most likely to contain lead or copper contamination and document these sites in an approved siting plan filed with the state primacy agency. The Lead and Copper Rule Revisions (LCRR), effective October 16, 2024, require a tiered site selection framework based on service line material, plumbing type, and construction year. Lead action level is 0.015 mg/L (15 ppb); copper is 1.3 mg/L (1,300 ppb). There is no safe level of lead exposure (MCLG = zero).
The foundation of the siting plan is a complete Service Line Inventory that identifies the material of every service connection in the distribution system. For each address, document the utility-owned and customer-owned service line material (lead, galvanized, copper, plastic, or unknown), the basis for the determination (historical records, visual inspection, customer survey, excavation, or predictive modeling), and a plan to resolve any unknowns. Unknown service lines must be treated as lead for sampling purposes until material is confirmed through records, inspection, testing, or excavation. Systems must update their siting plans whenever the inventory changes.
Sample sites are classified into three tiers based on contamination risk. Tier 1 (highest priority) includes single-family homes served by lead or galvanized-requiring-replacement service lines, and single-family homes with copper pipe and lead solder installed after 1982. Tier 2 includes multi-family buildings with lead or galvanized lines, and buildings with copper and lead solder installed before 1983. Tier 3 includes structures with non-lead, non-galvanized service lines and no known lead solder. Fill all required sampling slots with Tier 1 sites first, then Tier 2, then Tier 3—do not skip tiers. Update the siting plan whenever a site is added, removed, or replaced, and review it whenever the service line inventory is updated.
Source document
WOH_Lead_Copper_Sample_Siting_Plan_Guide.pdf
application/pdf · 69.6 KB
Become a member to view the full 18 min readRelated articles
RTCR Sample Siting Plan Guide
The RTCR Sample Siting Plan is a written document required by the Revised Total Coliform Rule that specifies where routine and repeat bacteriological samples will be collected throughout a water system's distribution. It helps small, rural, and tribal water systems ensure representative sampling and comply with 40 CFR Part 141, Subpart Y.
12 min read
VOC and SOC Organic Contaminant Sampling Guide
Guide for collecting VOC and SOC samples at drinking water system entry points, covering bottle types, preservation, hold times, and critical differences in sampling technique between the two contaminant classes.
17 min read
Nitrate Sample Collection Guide
This guide covers nitrate monitoring requirements for small and medium drinking water systems under 40 CFR 141.23, including sampling locations, bottle types, collection procedures, hold times, and how to avoid errors that invalidate results.
16 min readNeed expert help with your water system?
Water Operator Hotline connects small public water systems with experienced water utility professionals who can help you stay compliant, maintain your equipment, and solve problems fast.