A Drop of Knowledge

The Lead and Copper Rule Revisions (LCRR) mandate that all Community Water Systems (CWS) and Non-Transient, Non-Community Water Systems (NTNCWSs) submit an initial inventory of their service lines by October 16, 2024. This can be a significant undertaking for many small, rural water systems that often lack historical records, adequate staffing, or other resources to assist with completing their inventory. Many small water systems are just beginning their inventory efforts, while others have made considerable progress or have even completed the initial inventory.

The EPA and state primacy agencies offer detailed guidance on their respective inventory requirements and methodology that must be followed. Despite differences in EPA and some state requirements, there are some common practices that can assist a small system in its initial stages with minimal effort.

First, it is critical to have a complete customer list that accounts for each service line. Ideally, this information should be readily accessible or require minimal effort to acquire from the utility’s billing system. Depending on each state’s template, certain required or optional information may be easy to determine, including unique service line IDs, other location identifiers, sensitive population data, current Lead and Copper Rule (LCR) sampling sites, and building types.

Once this information is incorporated into the required inventory template, water systems must conduct an initial records review. This may involve reviewing system maps, records, construction and plumbing codes, or other pertinent information. Parcel boundary data can be useful when containing characteristics like address, owner names, and home built year, which is used to identify older homes and neighborhoods that are more susceptible to having lead service lines.

Another strategy used for inventorying service line materials is providing customers with a public survey form. The survey form would provide instructions to inspect the service line coming into their home. The survey form should encompass all relevant information needed for the customer side of the service line inventory. It should also include instructions on identifying material types by scratch and magnet testing, along with tips for capturing good photos.

The customer survey approach also allows the collection of contact information, such as owner or tenant names, phone numbers, email addresses, or even water meter serial numbers. There can also be a scheduling option where the customer requests the utility staff to complete the home service line inspection. Public surveys can be advertised on utility or town websites, emailed to customers, shared on Facebook, door hangers, or flyers attached to bill stubs with scannable QR codes.

Deploying a customer survey is also an excellent way to show engagement with customers, inform them about the significance of the new EPA lead service line inventory requirements, and share any other pertinent system information. In many states, a completed and well-documented public survey can serve as proper verification of the service line material on the customer side.

Following the public customer survey, a water utility system may be off to a solid start and pleasantly surprised with their progress, but often utilities may only report about a 5-10% response rate from their customers. A water utility may look next to identify sensitive populations such as schools and daycares, or target efforts in areas where lead is most likely located. At this juncture, excavation or other investigative methods will need to be explored.

Completing the service line inventory will undoubtedly demand a substantial investment of time, effort, and money for most small systems. There are few shortcuts in this process and there are some strategies that can aid a small, rural water system in making progress if they are feeling anxious about the October 2024 deadline. Following these steps, a water system may end up with an adequate inventory to submit, but efforts will still be needed to identify any remaining unknown service lines in accordance with state or EPA regulations.

Disclaimer – This article is intended solely for informational purposes. For details regarding specific processes, completion, or submission of the service line inventory, kindly consult your state primacy or EPA.

This article was funded under the EPA NPA 1 22 – 24 Grant. 

Location: Dickson, Tennessee

Issue: Bluebird Hills Water System was out of compliance with the Tennessee Department of Environment and Conservation (TDEC).

Outcome: Communities Unlimited (CU) provided onsite operational technical assistance, addressing all compliance issues.

Communities Unlimited was referred to Bluebird Hills Water System (BHWS) by TDEC. Annie Chiodo, a CU staff member, began working with BHWS in October 2017. The owner and operator, Charles Elston, had a history of submitting Monthly Operating Reports (MORs) late, failing to notify TDEC of significant problems and not following sampling procedures.

Mr. Elston said, “I struggled to meet TDEC requirements for recordkeeping and planning, and I failed to make deadlines for several reports. I was regularly late in submitting Monthly Operator Reports. Further, I missed some monitoring deadlines. I was made to pay over $6,000 in fines.”

Annie and Mr. Elston went to work on a calendar of what and when items needed to be submitted by, and both wrote and updated programs. Then in February 2018, the well collapsed. Mr. Elston notified the TDEC immediately. He and Annie went to work on getting the water back up online. BHWS was under a boil order for approximately three weeks until everything was in place. TDEC, Nashville Field Office donated several filter housings to help, and a team had developed to install the filtration and disinfection.

Thomas Killion from TDEC wrote:

“Under Ms. Chiodo’s assistance Mr. Elston has provided MORs on time since July 2018 and has received significant education on the proper operation of his water system. Thank you for your commitment to excellence in drinking water and to the people of Tennessee. It was a pleasure to work with you in regards to this water system, and we look forward to your assistance with other water systems in our area.”

Mr. Elston added, “Annie has made the difference. She is fully competent, uncompromisingly professional, and thoroughly approachable. She has stood with me through difficult times, been hugely encouraging, all while being firm in her ability to hold me accountable. Her example has made me a better water operator and a better person. Bluebird Hills SCWD has been fully compliant with TDEC Rules since Annie and Communities Unlimited came to my aid. I will forever be grateful to Annie, Communities Unlimited, and TDEC for offering such effective and beneficial assistance.”

Location: Second Mesa, Arizona

Issue: Second Mesa Day School’s existing arsenic removal system was non-functional and the school’s water system had arsenic levels of 18ppb, exceeding EPA’s maximum contaminant level (MCL)

Outcome: RCAC staff assisted the system operator to troubleshoot the system and bring it back into compliance with arsenic levels below the MCL

Second Mesa Day School is a K-6 elementary school on the Hopi Reservation in northern Arizona. The school has its own water system that the U.S. Environmental Protection Agency (EPA) considers as a community water system. It serves 376 people (students, staff, and teacher housing). The system uses groundwater from an aquifer that has elevated arsenic levels.

To mitigate the situation, the school installed an arsenic removal plant in 2008. The plant’s arsenic removal system has components that need to be routinely maintained, calibrated, and replaced. The system had not received the requisite maintenance for 10 years, and when RCAC arrived in March 2017, it was out of compliance with EPA’s Arsenic Rule.

RCAC worked very closely with the newly hired system operator, Melvin Pooyouma. The plant is relatively complex with several automated pieces that need to be working correctly and in harmony for effective arsenic removal. Starting at the upstream end of the system, the team began to explore and troubleshoot each component down the line.

During the next three months, RCAC and the operator were able to diagnose and fix the system’s broken components. RCAC helped the operator bring the pH to 7.0 and trained the team on the importance of keeping the pH near 7.0.

The second major improvement to the system was removal and inspection of the filter cartridges. The team repaired and reset all the cartridges.

Finally, the team replaced the calcium chloride injection pump that was no longer working and set the pumping rate to the newly calculated correct rate.

The plant now has non-detect levels of arsenic in its treated water and the system can provide safe drinking water to the students and staff.

As many communities prepare for the Lead and Copper Rule revisions, which focus on improving lead sampling to better protect public health, Allamuchy Township joins numerous others as they work to strengthen their understanding and implementation of the rule and its requirements. Allamuchy Township is located in Warren County, in the northwestern part of New Jersey. The township has a growing population of 5,423, which is up almost 25% from the 2010 census count. Allamuchy Township Water and Sewer operates and maintains their community ground water system, which is characterized as a Class-1 drinking water treatment (T-1), Class-2 drinking water distribution (W-2), Class-2 wastewater treatment (S-2), and Class-2 wastewater collection system (C-2).

The purpose of lead and copper regulations is to protect public health through the minimization of lead and copper levels in drinking water. Due to the nature of the occurrence of both metals, their presence in drinking water is mainly due to the corrosion of distribution lines and plumbing materials. This requires the appropriate identification, monitoring, and sampling of lead and copper throughout a system’s service area in order to protect its customers from exposure at levels unsafe for consumption.

Allamuchy recently underwent a change in licensed operator at their drinking water and sewer system. With the change in staff, RCAP Solutions has been providing assistance to make sure the system is up to date with the statute and to ensure the community continues to provide optimal operation and maintenance that furthers their goal of protecting public health.

In an effort to provide technical assistance to Allamuchy Township Water and Sewer, RCAP met with the system  to discuss the their current capacity after the transfer in licensed operator responsibility. RCAP was able to identify the need for an updated and approved lead and copper sampling plan as a priority for Allamuchy Township Water and Sewer. RCAP guided the community through the original Lead and Copper Rule (LCR), so they were apprised of the history and were given a comprehensive summary. Following an overview, the associated requirements, the revisions and updates to the rule (LCRR) to ensure that the new sampling plan encompassed current requirements.

RCAP helped guide the operator through the completion of the Lead and Copper Sampling Plan, while undergoing the dissemination of a comprehensive training for Allamuchy Water and Sewer’s operator on how to comply with the lead and copper rule revisions and associated regulations. The township’s lead and copper sampling plan review was finalized, and RCAP continues to be in communication with the system’s operator to ensure awareness and knowledge retention as the Lead and Copper Rule continues to be revised.

A cross connection can be defined as any actual or potential connection between the public water supply and a source of contamination or pollution. Cross connections with potable piping systems have resulted in numerous cases of illness and even death. Historically, cross connections have been one of the most serious public health threats to a drinking water supply system and many times are present in a residential water system. In order for public water systems to deal with cross connections effectively, not only must laws regarding cross connections be enforced, but customers of those systems must be educated on potential cross connections and how to neutralize those hazards.

Kentucky water utilities are required by state law to determine if or where cross connections exist and to immediately eliminate them. Kentucky RCAP has assisted rural cities with drafting cross connection control prevention program ordinances to protect the health of their water customers. An effective cross connection control prevention program ordinance should include the following:

Purpose and Authority – Clearly state the purpose of the ordinance and the authority to enforce it.
Definitions – Clearly define terms in the ordinance like cross connection, auxiliary water supply, backflow, backflow prevention assembly, contamination, residential, non-residential, etc.
Requirements – Clearly communicate the requirements that the system will implement to protect the public water system against backflow for both residential and non-residential customers.
Inspections – The customer’s water system shall be open to inspection at all reasonable times to authorized representatives to determine whether cross connections or other structural or sanitary hazards exist.
Penalties – Water services to any premises shall be discontinued if it is discovered that a backflow prevention assembly required by this ordinance has been removed, bypassed, or if an unprotected cross connection exists on the premises. Service will not be restored until such conditions or defects are corrected.

As stated earlier, enforcing cross connection laws/ordinances is just part of the equation. Water customer education is paramount for a cross connection control program to be successful. What are some examples of educational materials that can be utilized to inform water customers regarding cross connections in the home? RCAP provides system specific cross connection brochures for water systems to distribute to their customers. An effective cross connection brochure should include the following.

Definition of Terms – Customers need to know what a cross connection is, the concept of backflow, the two types of backflow (backpressure and back siphonage), and corresponding definitions.
What is Considered a Potential Hazard? – Any connection between a customer’s drinking water and another source of water that combines the two when a backflow condition occurs is a potential hazard and can cause contamination. The common household garden hose is a prime example. Customers can unknowingly create a cross connection by:

Putting an attached hose into a full bathtub;
Putting the garden hose in a swimming pool to fill it;
Putting the garden hose down the drain to flush out debris when it is backed up; or
Connecting your garden hose to a plant fertilizer or bug spray unit.

What are the Dangers of Cross Connections? – Backflows due to cross connections can cause sickness and death. If a drop in water pressure occurs, the hose could act as a siphon and backflow contaminants back up into the water supply. This makes the water unsafe for the customer, their family, and their neighbors. In fact, over half of the nation’s cross connections involve unprotected garden hoses.
Tips for Customers to Protect Their Drinking Water

Check all plumbing connections to discover water uses that may pose a hazard to the public water supply.
Never place the end of a hose where it can backflow contaminants into your drinking water.
Leave at least a one-inch air gap between the end of a tap and a source of contamination.
Attach a hose connection vacuum breaker to threaded taps to prevent contaminated water from being siphoned through a hose. Vacuum breakers are relatively inexpensive and can be found at hardware and plumbing supply stores.

In addition to brochures, Kentucky RCAP has created and provided a static “hands-on” cross connection public education display to water systems. The static display contains potential cross connection home hazards (i.e. spigots/hoses, toilet components, cattle feeders, etc.) and the devices that can be used to neutralize those hazards. The static display can be utilized in a public place or in a classroom setting.

With all the challenges that we are facing with the ongoing pandemic, it is quite evident that we are all in this together. Water systems, water customers, and RCAP must continue to work collaboratively to eliminate cross connections to protect public health.

In August 2021, RCAP Solutions received a referral from Maine Center for Disease Control for assistance regarding a confirmed cluster of illness in the rural western Maine town of Temple. Eight people had been hospitalized with intestinal illness associated with drinking water from a private spring, to include Jo, an 80-year old woman whose home has been directly supplied by the spring for over 40 years. At least a dozen other families rely on water from the spring collected at a roadside tap.  

THE CHALLENGE 

Upon meeting with Jo, RCAP learned that a sample collected at her house tested positive for total coliform bacteria, and specifically for E. coli. Jo had been stricken on her 80th birthday and endured eight days of illness.  Her stool tested presumptive positive for Campylobacter bacteria.   

Jo and her partner had built their home and sanctuary on a quiet dirt road in Temple over 40 years ago. It had always been gravity-fed water by a supply line from the spring on a neighboring property, to which they had deeded access. Jo loved the sweet, clear water, despite the occasional salamander that plopped out of her tap. To her knowledge, the water had never been tested prior to this incident. Now, a single woman, on a fixed income, Jo was concerned about the safety of her home’s water supply – as well as for the safety of other people of the community she knew relied on the spring. She knew there were additional unreported illnesses among the users who were reluctant to come forward, fearing they would lose access to the spring’s roadside tap. 

Temple’s Town Clerk joined RCAP and Jo on an inspection of the spring, located up a wooded trail across the road from Jo’s home. The concrete casing spring box set low in a depression, on a sloped grade. Around the spring box, the depression collected rain run-off and other organic debris. The spring box lid was not secure, which allowed contaminated water inflow and the casing did not appear to go deep enough into the ground to prevent surface water seepage infiltration. Looking inside the spring box, one could see the two lines that gravity feed Jo’s home and the roadside tap. Debris floated on the surface of the water, and roots and vegetation had grown in under the cover and penetrated the casing. There was no protection of the water from natural sources of bacteria or harmful organisms. The water was not safe to drink. 

THE APPROACH & SOLUTION 

RCAP worked with the Maine Drinking Water Program to obtain appropriate signage and the Town Clerk posted the roadside tap, indicating the water was non-potable and should be boiled for at least 5 minutes before consuming. Efforts were underway to locate the elderly out-of-town owner of the property to encourage the removal of the roadside tap.   

At Jo’s home, it was strictly bottled water for drinking, and boiling water for other uses, such as dish washing. Jo decided she needed a reliably safe source of drinking water for her home. RCAP discussed with Jo options that included installing filtration and disinfection treatment of the spring water or obtaining a new drinking water source. Jo decided to have a well drilled on her own property. RCAP provided assistance in collecting and evaluating proposals to drill the well and exploring funding opportunities available to Jo to complete its installation and directly supply her house. At the height of summer, following two years of drought and Covid-related shortages, well drillers were in high demand and under significant backlog.   

The well was finally drilled November 10, 2021. After the initial flushing and disinfecting by the well driller, RCAP conducted an on-site assessment of the well and collected water quality samples from Jo’s kitchen.  The results showed elevated coliform bacteria. The water system would need to be disinfected again, with particular attention to the internal plumbing, which likely had some stubborn contamination after over 40 years of using the spring. After the second disinfection, conducted by a local plumber, the bacteria count was down from 276 colonies to 28 colonies, but the system was still not clean. RCAP noted that the pH of the water was slightly high and was likely interfering with the disinfecting chemical, and recommended an additional disinfection using a pH-buffered product. 

It took a village, but on December 20th, RCAP supervised a successful buffered disinfection of the well and plumbing. This effort was made possible due to generous contributions of time and material by a local plumbing firm, a supply company, and a water treatment contractor. After a final confirmation test indicated the water source and system was free of bacteria, Jo was finally able to drink from her kitchen faucet with confidence. 

RCAP issued a comprehensive assessment report to Jo, complete with recommended monitoring of the water quality and an initiated well head protection plan.    

THE IMPACT 

After over 40 years of drinking from a spring with unreliable water quality, and at least once being severely ill due to it, this 80-year old resident of rural Temple, Maine continues to live independently in her wooded retreat, able to drink from her kitchen tap confident that her water is safe.  

At this time, the roadside tap remains “posted”. The owner has not elected to shut it down. RCAP continues to work with Temple town officials, encouraging them to stay diligent in educating and warning residents of the risks of using water from unreliable sources, and suggesting that they consider providing an alternate safe drinking water supply for public use.  

RCAP continues to support rural communities and private well owners with training on using and maintaining private water sources, on-site private well and spring assessments and source water testing.  

Is your community effectively operating profitable and sustainable water and sewer systems, or are you simply getting by? With our communities’ ever-changing dynamics, our rural drinking water and wastewater systems will need to implement new administrative strategies and management tools to adapt to the increased regulatory requirements and environmental complexities they face daily and into the future. As responsible community leaders, we must allow the systems to operate using a “business model” for long-term sustainability. Sustainability will help address new and stricter regulatory requirements, changing populations, increased service demands, limited water supplies, a highly variable climate, aging infrastructure, and limited state and federal funding.  

Cost estimates for water and wastewater system needs in the rural U.S. total billions of dollars nationwide. The existing state and federal funding sources can only meet a fraction of this need, even with the new influx of infrastructure dollars through the Bipartisan Infrastructure Law (BIL). Therefore, approaches to reducing the gap between what is needed and what funds are available will need to be adopted. In addition, funders want assurance their investments  in water and wastewater infrastructure will be adequately managed and maintained to ensure long-term sustainability and security. This assurance will require water and wastewater systems to present convincing evidence that they possess adequate financial, technical, and managerial capacity to maintain/sustain the infrastructure necessary to provide the service their customers expect. State and Federal funds only cover the cost of capital outlays, but not ongoing operation and maintenance over time. In addition, the new or upgraded system must remain in full compliance with the Safe Drinking Water Act (SDWA) or the Clean Water Act (CWA), and any additional state or local regulations.   

It is recommended that systems adopt a “business model” for managing the delivery of services. This plan should include: 

A five-year financial plan with a fully allocated rate structure;
An asset management plan;
A water accounting system with full metering;
Full compliance with the Safe Drinking Water Act (SDWA) or the Clean Water Act (CWA), and your state primacy/regulatory agency requirements ;
A governance structure adequate for proper management and oversight; and 
Participation in regional efforts to collaborate on long-term solutions. 

 A financial plan has two components: a forecast of the utility’s future financial needs (such as operating and capital needs) and an identification of how to fund those future financial needs. 

 A Capital Improvements Plan (CIP) is a written document that specifies and satisfies the following questions and is typically based on a utility’s asset management program: 

What facility improvements will be needed in the future?
When will the improvements be needed, and when will they be undertaken?
How much will the improvements cost?
What financing options are available for the improvements?

 A CIP is a multi-year planning document that identifies capital improvement needs and is usually done in 5-, 10- and even 20-year increments. This will help your utility’s board and management make informed decisions about rate setting, future debt-service requirements, and future revenue requirements. In preparing a CIP, there are several things to consider:  

Will current facilities reach their design capacity soon?
What new equipment, services, or facilities are needed to meet the demand of your customers?
What current system components will require significant repair, rehabilitation, or replacement?
Will failure to upgrade existing facilities result in regulatory violations or enforcement actions?
What are the most critical improvement needs, and what is the urgency of meeting those needs?
What benefits do the improvements provide to the system and its customers?
What are the available options for financing the improvements?
Can regular resources of the systems fully fund future capital projects, and which projects will require outside financing?
How do financing options for improvements relate to the annual budgeting process?

 Use the assistance of a consulting engineer to prepare cost estimates for major capital improvement projects that the community will need in the future. 

 RCAP and Midwest Assistance Program, Inc. (MAP), RCAP’s regional partner, assists communities by being a resource to help plan, prepare, and execute a comprehensive strategy to sustain your community’s system(s) now and into the future. To be a good steward of your infrastructure, technical, managerial, and financial responsibilities are interconnected – one cannot be sustainable without the other. As a community leader, you need to enable the community to “look around corners” to identify potential expenses and maintenance to their systems and provide a fair and equitable rate structure for the community to “invest” in the future of your most valuable resource.  

RCAP’s Managerial and Financial Hub has resources on  management, rate setting, applying for infrastructure funds, and regionalization. 

REFERENCES

A Guidebook of Financial Tools. USEPA, Environmental Finance Program.
The Basics of Financial Management for Small-communities Utilities. RCAP Rural Communities Assistance Partnership.
Small System Guide to Developing and Setting Water Rates, Rural Community Assistance Program, Inc. 
Rate Setting and Capacity Development, the Environmental Finance Center at the University of Maryland.

Many contaminants that can cause both short-term and long-term health effects have no taste, odor or color. If they are present in well water, a consumer — even one who has been drinking the water for years — would never know it. The only way to find out for sure is to test the well periodically.  

And yet, how many times have we heard a well owner say one of the following? 

“I’ve been drinking that water my whole life, and I’m not sick.”
“My well water is so much better tasting than town water.”  
“There’s nothing wrong with my water; it doesn’t need testing.” 
“MY water is FINE!”

To help these consumers continue to enjoy their water safely, Delaware’s Division of Public Health (DPH) has offered a program for several years where well owners can purchase a two-bottle well test kit for $4. This allows them to sample their well water and have it tested by the state’s own lab for the most common contaminants found in the area: bacteria, nitrates, sulfur, manganese and the like.  

In 2019, DPH’s Drinking Water State Revolving Fund (DWSRF) program contracted with SERCAP to provide a series of workshops for well owners and to distribute these same test kits for free to all who requested them. SERCAP held seven in-person workshops for well owners in different locations in the two lower Delaware counties. Despite best attempts, the attendance was disappointing overall, with most workshops serving less than six (6) people. SERCAP resolved to alter the program in the second year, using lessons learned from the 2019 efforts.  

Part of the original intent of the program was for SERCAP to plot the water test results in order to identify any contaminant plumes. However, a disconnect with the state lab resulted in only the owners receiving the test reports, not SERCAP.  

When 2020 came around, so did COVID, and the program was delayed by state-required isolation and SERCAP restrictions on staff contact from March to mid-June. Workshops were switched to a virtual format and attendance improved, with evening sessions being the most popular. Without the need to travel to on-site locations for the workshops, staff time was reduced, and budgeted funds were re-purposed to buy padded envelopes and pay postage to mail out the test kits, along with instructions for proper bacteria sampling.  

When Senator Tom Carper visited the SERCAP office in Frankford, he gave the program a tremendous boost because the event was covered by all the local TV stations. This helped spread the message that the free sample kits were available to the public. Between the news broadcasts in late November and the end of the grant in December, SERCAP’s Delaware office handed out 184 well test kits.  

The plan for a future grant round is to use the 2019 mailing list to survey recipients on whether they actually used their kits, and to ask if they will share a copy of their results with SERCAP for the purposes of mapping results and identifying potential problem areas.  

Well experts recommend testing private wells every year for bacteria and pH, and every year or two for nitrate — especially in agricultural areas or places where nitrogen might be more prevalent. Private labs can charge upwards of $100 for the same array of tests that the Delaware private well kits cover, so the $4 test kits are a bargain any time of the year. Still, advertising that a $4 test was available for free apparently made a big difference in people’s willingness to test their well water.  

Not all states have robust, subsidized programs as is the case with Delaware. Because of this, RCAP has developed a national private well program to help educate and serve the more than 23 million well owners across America. The program, funded by the Environmental Protection Agency, provides outreach, education, and technical assistance to well owners, private well professionals and key stakeholders. Because most well owners have no idea what is in their water, in 2020, RCAP added a free well test kit addition to our existing programming based on feedback around homeowner demand. For more information on this program and to find out who to contact for private well support in your state, please check out our private well webpage: https://www.rcap.org/environmental-programs/private-wells/.  

Over the last 50 years, a variety of rules have impacted the amount of lead in drinking water, in addition to monitoring requirements imposed on public water systems (PWS). One might ask, “Why is so much emphasis placed on monitoring and controlling lead levels in drinking water?”  

The answer is simple: Lead can negatively affect almost every organ and system in your body. This issue entered into the national spotlight more recently with lead seepage into the drinking water in Flint, Michigan causing a major public health emergency. The Flint water crisis revealed dangerous levels of lead in the drinking water, further propelling the conversations around the dangers of lead. Flint is just one of thousands of communities facing similar challenges.  

Lead exposure is especially harmful to young children, pregnant women, and those with compromised immune systems. The Environmental Protection Agency (EPA) has not identified any safe blood lead levels in children, and it can cause impaired mental development, IQ deficits, shorter attention spans, and low birth weights. Lead exposure can also cause increased blood pressure in adults. The degree of harm done to one’s body from lead exposure depends on several factors. A few determining factors to consider are the frequency and dose amount of the exposure, age, and an individual’s susceptibility factors as a whole. Lead is not only found in drinking water, but is also present in the air, dust, soil, and foods we consume, as well as in the paint in homes 

 The Safe Drinking Water Act (SDWA) of 1974 set a lead maximum contaminant level (MCL) of 50 parts per billion (ppb). In 1986, the Lead Ban amendment took effect, requiring PWS to use “lead-free” pipe, solder, and flux to install or repair any public water supply lines. This Lead Ban included “lead-free” materials in residential homes or commercial facilities connected to a public water supply. Before this ban, solders used for water pipe joints typically contained about 50 percent lead. In 1991, EPA implemented the first Lead and Copper Rule or (LCR) requiring utilities or PWS to monitor for lead contamination in drinking water and to provide corrosion control treatment if lead levels exceed an action level of 15 ppb.  

Since 1991, there have been several revisions to the LCR that impose greater responsibilities on utility operators. Why are we talking about this now? Recent actions by the EPA and current administration are accelerating the push to more effectively remove lead from the nation’s drinking water. The reduction of lead levels found in drinking water is at the forefront of the EPA’s current initiative to ensure all Americans receive safe potable drinking water straight from the tap. A Lead and Copper Rule Revision (LCRR) has been in the works for a few years now, changing the roles and responsibilities of utility operators and PWS. On January 15, 2021, the EPA published a regulatory revision to the National Primary Drinking Water Regulation for lead and copper under the authority of the SDWA. A summary of the revision states:  

These revised requirements provide greater and more effective protection of public health by reducing exposure to lead and copper in drinking water. The rule will better identify high levels of lead, improve the reliability of lead tap sampling results, strengthen corrosion control treatment requirements, expand consumer awareness and improve risk communication. 

For the first time, the summary goes on to state that public water systems will be required to test for lead levels in water at schools and childcare facilities.  

Later in January 2021, President Biden issued “Executive Order 13990,” placing a ‘freeze’ on the LCRR published by EPA pending a 60-day review by the Biden Administration. On March 12, 2021, EPA published revisions to the LCRR after the ‘freeze’, which extended the effective date and compliance dates for PWS nationally. If you are not familiar with the Lead and Copper Rule Long-Term Revision, you can find additional information here.  

In December 2021, the White House launched the Lead Pipe and Paint Action Plan to deliver clean drinking water through the replacement of lead pipes. The President’s action plan allocates the EPA $15 billion over five years through the Drinking Water State Revolving Funds authorized in the Bipartisan Infrastructure Law for lead service line replacement.

RCAP provides training and technical assistance on these issues. You can reach out to our regional partners for further assistance. If we all work together, we can continue to better protect our youth and community members from the risks of harmful lead exposure!