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THE KANSAS LIFELINE
July 2018
If such a system is conducting reduced monitoring and
then exceeds the lead or copper action level, then the
system must resume sampling ten (10) sites on a six-
month monitoring frequency. The system that exceeds
the lead or copper action level will also have to monitor
water quality parameters at the entry point(s) and
distribution system's tap samples.
Unnecessary sampling and costs
Since 1995, one example Kansas system was on a
reduced number of monitoring sites at a reduced
monitoring frequency of once every three years. Then in
2014 the system exceeded the lead action level. KDHE
placed the system on six-month monitoring periods in
2016 instead of 2015 when the system sampled only six
(6) sampling sites.
The system met lead and copper action levels in the
2015 yearly monitoring period as well as met the action
levels in both six-month monitoring periods in 2016 and
2017 and in the first monitoring 6-month period in 2018.
The system will be monitoring again this summer either on
a yearly or six-month schedule. All yearly monitoring must
be during the months of June - September for this system.
KDHE did not discover that the system could have been
placed on yearly monitoring in 2017 with a reduced number
of sampling sites. The water system had two six-month
monitoring periods in 2016 that had no lead or copper levels
above the required action levels.
Also, since the system had three years (2015, 2016 and
2017) when all monitoring data was below the lead and
copper action levels, the system at the end of 2017 could
have been put on a monitoring schedule of every three years
beginning with the next monitoring in 2020.
Thus, the system has taken an estimated 36 samples that
should not have been required in 2015-2018. See the table
“Samples Collected vs. Required” that shows the number of
actual samples collected versus the number required.
Lead and copper monitoring record
Since 1993 this system has sampled distribution sites 118
times for lead and copper. One lead sample in 2008, three
lead samples in 2014, and no copper samples at any time
were above the action levels. The three high lead samples in
2014 are uncharacteristic when compared to all the other
samples. KRWA staff believe that those three samples may
have been from unoccupied residences or incorrect faucets.
Table for Federal Requirements