Avoiding Crisis: Preparing for the Proposed Lead and Copper Rule Revisions

rusty water taps

By Megan Glover

In October 2019, the U.S. Environmental Protection Agency (EPA) released its long-awaited proposed revisions to the existing Lead and Copper Rule (LCR). The proposal would update the original 1991 rule, change the current standards and add several new responsibilities for water utilities across the country. The changes will place rigorous and costly new demands on water systems, and many are questioning how they can best prepare for the changes ahead.

The three changes I believe will have the most significant impact on community water systems are:

  • Improved Risk Communications to Customers
  • Continually Updating Lead Service Line Inventories
  • New School and Childcare Facility Sampling Programs

Water systems that haven’t already started to consider the proposed revisions are at risk of running out of time to put in place the systems needed to keep up with the changing rule. With changing current responsibilities and new requirements piling on, it’s absolutely vital to act now by building the framework necessary to succeed under the new rule.

Communications to Customers: Avoiding Crisis

Megan Glover

The proposed revisions put transparency and communication with the public front and center. While the old rule gave a water system 30 days to notify a customer with an exceedance, the new rule both lowers the trigger limit and requires notice to be given to all customers within 24 hours.

As a result, it’s likely thousands of systems will fall out of compliance out of the gate, while leaving no room for error to meet the communication timeline.

In order to meet these demands, water systems will need to have their data systems and workflows in place, ensuring that sample result, location, GIS and customer data are in one place or connected in a way that empowers them to be responsive.

Lead Service Line Inventories: Creating a Living Document

The EPA’s proposals also include a required Lead Service Line Inventory, published publicly so that it may be available to consumers and state agencies. It’s essential to understand that this needs to be a living, breathing document – it will need to be published annually with revisions, and a static map of a service area will not satisfy the rule as it’s written. Customers will also need to be notified about LSLs annually via mail.

The new LCR also takes the 7 percent annual replacement requirement upon exceedance down to 3 percent. Many industry experts believe that, despite the percentage decrease, the number of lines replaced will actually be the same volume, if not an increase, since that percentage will be based on a complete inventory (something most systems have not compiled up to this point).

The good news is that models for best practices already exist. The City of Cincinnati has an outstanding LSL inventory map of both public and private lines, updated on a regular basis and available to the public. Pittsburgh Water and Sewer Authority has a similar program to Cincinnati wherein they allow customers to report known LSLs online, collecting data from the end user for more efficient updating.

School & Childcare Facility Sampling: A New Responsibility for Water Systems

The revisions mandate that community water systems would be required to sample 20 percent of schools and daycare facilities each year, alongside providing results and remediation recommendations to the facility.

Lead in Schools Programs are complex in and of themselves – 120Water handles many of these programs at the state, city and public school system level. Putting this layer of programmatic management, execution, and communication at the water system level is a significant new burden, especially for large systems serving a possibly unknown population of schools and childcare facilities.

While the LCRR does not require all fixtures in a facility to be sampled, it’s a best practice to sample every drinking and cooking water fixture on a regular cadence in facilities such as these that serve vulnerable populations. Neglecting to sample all premise water sources can give school and childcare communities an inaccurate picture of water quality and a false sense of security.

Final Thoughts

While the new LCR and the actions required to keep your utility compliant both today and in the future may feel impossible to achieve based on already limited time and resources, there are steps you can take today to prepare.

I recommend evaluating your utility’s data systems, workflows and partners. Find out if you have inventories and communications systems that work together. Evaluate digital solutions that will ensure you can minimize the administrative burden of the work while meeting the new rule’s requirements.

Taking action now is the best way to be prepared for changes that lie ahead.

Megan Glover is the co-founder and CEO of 120Water, a software and point of use company that provides solutions to government agencies, public water systems and school districts to manage lead in drinking water programs. Prior to founding 120Water she spent nearly 15 years as an executive building and scaling various software-as-a-service products in the Midwest.

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