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