Monthly Operational Reports

EPA Issues Guidance for Public Water System Sampling During COVID-19

EPA has provided a compliance and enforcement guidance document during the COVID-19 pandemic. In it, the EPA outlines its expectations that operators of water systems continue normal operations and maintenance, as well as required sampling to ensure the safety of our drinking water. The document also identifies monitoring and reporting priorities. Those are Total Coliform (TCR) sampling, Lead and Copper sampling, Nitrate, and Nitrite.

EPA guidance language:
"Of highest priority is monitoring required under National Primary Drinking Water Regulations to protect against microbial pathogens. Additional priorities include nitrate/nitrite and Lead and Copper Rule monitoring followed by contaminants for which the system has been non-compliant. States may wish to adopt similar priorities."

The health and safety of water system operators and water customers should be of highest priority; the WV Office of Environmental Health Services can provide instructions for water systems to follow during this pandemic which may minimize risk to the operator and the customer.

TCR sampling: Samples should be collected as required. In the event that sampling cannot be performed safely, operators should collect at a location that is more accessible, including an outside tap, if necessary. After sample collection is complete, operators should note any deviation from their approved plan in a sample plan addendum submitted to their district office. Operators should note on this addendum that sites were selected because of the COVID-19 pandemic.

Lead and Copper sampling: These samples must be collected as required, but these can be collected any time between 6/1 and 9/30, so there is still time to identify sites that may not be accessible. In the event a sample site is not available or cannot be accessed safely, a new site must be identified and approved by the district office prior to sampling.

Disinfectant By Product (DBP) sampling: Samples are location specific but if sampling cannot be performed safely, operators should collect at a location that is more accessible, including an outside tap, if necessary. If this is still not an option, operators should collect samples at the closest location to the required site. In either case, operators must note on the lab report that the sample location was collected at the "Closest Tap to Approved Location due to COVID-19 pandemic."

Other sampling, such as Nitrate and Nitrite, is collected at the treatment plant and should not pose the safety challenges of those collected in the distribution system, as listed above.