Tap Sampling Guidance for LCRR Compliance

Tap Sampling Guidance for LCRR Compliance
Sampling protocols have changed under the Lead & Copper Rule Revisions (LCRR). What does this mean for how, when, and where your water system conducts sampling?

Sampling Site Selection

The tap sampling pool size is unchanged from the original Lead and Copper Rule; however, all tap samples must be collected from sites served by lead service lines (LSLs), if available..

System size
(number of people served)
Number of sites
(standard monitoring)
Number of sites
(reduced monitoring)
>100,000 100 50
10,001 to 100,000 60 30
3,301 to 10,000 40 20
500 to 3,300 20 10
101 to 500 10 5
≤100 5 5

The tap sampling pool size is unchanged from the original Lead and Copper Rule; however, all tap samples must be collected from sites served by lead service lines (LSLs), if available. The sampling sites will need to consist of single-family homes served by an LSL. If more than 20% of structures served by the water system are multi-family residences, the water system can then include the multi-family sites in the Tier 1 sampling pool if served by an LSL. Sites that are considered an LSL because they are of unknown material are not to be used in the sampling pool. If insuf­fi­cient Tier 1 sites are available, a water system can include Tier 2 sites, and then move on down the tier levels until the pool is complete. The tier levels are shown in the table below. A system cannot move to the next tier level until they have exhausted all possible sampling locations in the previous tier.

Tier Definition
Tier 1 Single-family residences with lead service lines
Tier 2 Multi-family residences or buildings with lead service lines
Tier 3 Single-family residences with galvanized lines downstream of a lead gooseneck, pigtail or connector or downstream of a lead service line currently or at any time in the past
Tier 4 Single-family residences with interior copper piping with lead solder
Tier 5 Single-family or multi-family residences or buildings with service line and interior piping materials repre­sen­ta­tive of the distri­b­u­tion system

With the LCRR,
there is no longer a distinction in prior­i­ti­za­tion of copper pipes with lead solder by instal­la­tion date so copper pipe with lead solder is no longer considered Tier 1.
The original LCR gave higher priority and tier to copper pipes with lead solder installed after 1982 (Tier 1) than those installed prior to 1983 (Tier 2).

First and/or Fifth Liter Tap Samples

Sampling changes per the LCRR are currently scheduled to commence in January 2025. Per the EPA’s announcement on December 16, 2021 , there is speculation that the sampling described below may change to include analysis of both a 1st and 5th liter. Further guidance is anticipated prior to October 2024.

For all water service lines other than LSLs, the sample collector (typically the resident) will continue to collect the first draw one-liter sample from the kitchen or bathroom faucet. The first draw sample will be analyzed for both lead and copper.

For LSLs, the sample collector will collect five (5) one-liter samples consec­u­tively numbered from the kitchen or bathroom faucet. Instruc­tions will need to be provided to the residents to let the water run contin­u­ously and collect the samples consec­u­tively. Systems will analyze the first draw sample (Bottle #1) for copper and the fifth sample (Bottle #5) for lead.

“Galvanized requiring replacement” (Tier 3) service lines will be sampled for lead at the first liter. Lead-lined galvanized will be considered a Tier 1 site.


Other Sample Procedures

Samples must be collected in one-liter wide mouth bottles and sample collectors shall not be instructed to remove aerators and should not conduct flushing prior to stagnation for sampling. The water must be inactive/untouched for a minimum of 6 hours prior to sampling.

Sampling Frequency

All systems with LSLs, even those previously deemed optimized and currently on reduced monitoring, must perform standard monitoring every 6 months starting in January 2025. After two consecutive 6-month tap sampling monitoring periods, systems may reduce monitoring if they meet certain criteria.

When lead sampling is required to be conducted more frequently than copper sampling, the water only needs to be collected and analyzed for lead. This would occur if the water system exceeds the lead trigger level or lead action level but not the copper action level. If the lead trigger level is exceeded, for example, annual tap sampling for lead is required at the standard number of sites while a system can continue sampling for copper triennially at a reduced number of sites if previously on reduced monitoring.

School and Child Care Tap Sampling

Water systems are required to conduct directed public education and lead sampling in schools and child care facilities in their service area with the LCRR for all facilities constructed prior to January 1, 2014. Facilities constructed after this date are exempt.

By October 2024, prepare a list of all elementary schools, licensed child care facilities and secondary schools served by your system in buildings constructed prior to 2014.

For the first 5 years starting in 2025, annually sample 20% of elementary schools and 20% of licensed child care facilities. Secondary schools will be sampled upon request. After the first 5 years, and each elementary school and child care facility being tested at least once, all further school sampling will be upon request unless additional testing is required by your State.

Sampling will consist of five (5) samples per school and two (2) samples per child care facilities at outlets typically used for consumption. 250 mL samples shall be collected after a stagnation period between 8 and 18 hours.

On an annual basis, provide information about the health risks from lead in drinking water to all elementary schools, licensed child care facilities and secondary schools in a water system.

State/Primacy Agency Reporting

All systems, regardless of size, must report their 90th percentile values (based on required monitoring frequency), current number of LSLs and service lines of unknown materials (annually or triennially depending on monitoring frequency), and the status of their optimal corrosion control to their state.

Tap Sample Noti­fi­ca­tions

If an individual tap sample exceeds 15 µg/L, notify the customer of the results within 3 days. Mailed noti­fi­ca­tions would need to be postmarked within 3 days. If an individual tap sample is below 15 µg/L, noti­fi­ca­tion is required within 30 days.

Latest News
On December 16, 2021, EPA announced the current Lead and Copper Rule Revisions (LCRR) will go into effect to support near-term actions of reducing lead in drinking water. At the same time, the agency is developing the Lead and Copper Rule Improvements (LCRI) to strengthen key elements of the rule which will be finalized by the original October 16, 2024 compliance date. 
Read EPA's Release Opens in new window.

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