Breeze Issue 188 • Winter 2021-22
American Water Works Association - MN Section PO Box 64975, St. Paul, Minnesota 55164-0975 Address service requested
MN AWWA CONFERENCE
AN IN-PERSON SUCCESS
Inside: 2022 Metro Water Operators School WUTT Program Update
The Official Publication of the Minnesota Section of the American Water Works Association
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Minnesota Section American Water Works Association Executive Board of Directors Section Chair Uma Vempati Kimley-Horn Associates Ph: 612-209-1912 uma.mnawwa@gmail.com Section Chair-Elect Rob Isabel CDM Smith Ph: 651-252-3716 isabelrs@cdmsmith.com Section Past Chair Chris Voeltz City of Saint Peter Ph: 507-934-0670 chrisv@saintpetermn.gov AWWA Director Eric Volk City of New Brighton Ph: 651-638-2110 eric.volk@newbrightonmn.gov Section Secretary-Treasurer Jim Hauth City of Columbia Heights Ph: 763-706-3711 jhauth@columbiaheightsmn.gov Assistant Secretary-Treasurer Miles Jensen SEH, Inc. Ph: 651-490-2000 mjensen@sehinc.com Disclaimer The ideas, opinions, concepts, procedures, etc. expressed in this publication are those of the individual authors and not necessarily those of the MNAWWA section, its officers, general membership, or the editor. The mention of trade names for commercial products does not represent or imply the approval or endorsement of AWWA. This magazine is presented solely for informational purposes. Breeze Magazine is published by
Ph: 866-985-9780 Fax: 866-985-9799 www.kelmanonline.com Managing Editor - Tammy Marlowe Johnson Design/Layout - Dani Goulet Marketing Manager - Jeff Kutny jeff@kelman.ca Advertising Co-ordinator - Stefanie Hagidiakow ©2022 Craig Kelman & Associates. All rights reserved. The contents of this publication may not be reproduced in whole or in part without the express consent of the publisher.
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Breeze Issue 188 • Winter 2021-22
Table of Contents
Features 2021 MN AWWA Annual Conference an In-Person Success
15
Water/Wastewater Utilities Treatment And Technology (WUTT) Program Update
19
Benefitting From Today’s Topsy-Turvy Job Market
23
What You Need to Know About the Updated AWWA G480-20
25
Biden-Harris Administration Announces Lead Pipe and Paint Action Plan
28 33
Lead and Copper Rule Revisions: Part I
Departments Message From the Chair
7
Message from the Director
9
Industry News
11
Advertiser Product & Service Center
38
This document is printed on paper certified to the standards of the Forest Stewardship Council® (FSC®).
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M N AW WA Message from the Chair
Taking the Reins as Section Chair
I
t’s hard to believe that I’ve already been Chair of the Minnesota Section AWWA for several months. It feels like just a few short weeks ago that we were in Duluth, enjoying a run of good weather and celebrating the fact that we were in person together for the first time in more than a year. At that time, we were feeling as if we’d turned a corner back toward normalcy, but the surge of a new COVID variant has made us feel like the proverbial ‘one step forward and two back.’ As an organization, we are always monitoring the situation and updating our plans with the mission of keeping the Section on track with its strategic goals and activities, yet following CDC, state, and local guidelines to keep our members as safe as we can. In December, we held our typical Board training session, but attendees remained masked. In February, we will host an in-person workshop with the Midwest Assistance Partnership (MAP), but will require attendees to be masked, in accordance with the policies of the local venue. Our goal is to keep trying to hold the important educational opportunities that you are all used to, while continually evaluating circumstances and making smart decisions. As of this moment, we are still holding our District Operator Schools, the Professional Operator Development Series, our Spring Golf
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Uma Vempati
Tournament, and of course, our Annual Conference in Duluth, September 13 to 16, 2022. The Call for Papers for the Duluth Conference just opened, and I encourage you to submit an abstract for consideration. As Chair of AWWA’s Diversity and Inclusion Committee, I have a strong interest in seeing a technical program that reflects the wide range of voices and faces of the Minnesota Section. Beyond race and gender, diversity and inclusion are about being open and welcoming to new perspectives, new ideas, and new disciplines – so please consider submitting an abstract and being part of the Annual Conference. We are also looking into offering live demonstrations as another ‘new’ and diverse way to bring educational knowledge to you. If you are interested in proposing a live demonstration of a product, process, or service, submit an abstract! Abstracts are due February 22, 2022. I’m proud to be Chair of the MN Section AWWA, and to be a leader in the world’s largest association of water professionals. Like all our municipalities and utilities that keep the water flowing, MN AWWA will keep moving forward and meeting the challenges of 2022. I look forward to seeing you at the upcoming Operator Schools, and at the Annual Conference in Duluth. Be safe and be well! •
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M N AW WA Message from the Director
‘The Minnesota Crew’
I
want to take this opportunity to thank all of the volunteers who make the Minnesota Section, one of the best Sections in the American Water Works Association. Not only do we have some outstanding volunteers here in the North Star State, but we have also had a few of our members step up and volunteer at the Association level. It is important to remember that the entire association – our section and other sections – is run primarily by volunteers. Take a look at some of the members from our MN Section who are leading on a national level: T.J. Stroebl: T.J. was recently elected as the Manufacturers/Associates Council (MAC) Chair for the Association. He will start serving as the chair of the council in June 2022 and will serve for three years. The Association MAC operates much the same way our section MAC. They work to provide quality information and technical presentations to the members of the association. Uma Vempati: Not only does Uma serve as our first minority section chair, but he is also serving as the chair for the Diversity and Member Inclusion Committee for the Association. He started serving as the DMIC Chair in June 2020 and will serve a three-year term as well. Uma has done some amazing things at the association level to promote equity, diversity, and inclusion in the water industry.
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Eric Volk
Michelle Stockness: Michelle was elected as a Director-at Large for the Association at the winter board meeting in January 2020. At the most recent winter board meeting, Michelle was also elected to serve as one of AWWA’s six vice presidents. Michelle will travel to other sections’ annual conferences and speak on behalf of the association, all the time representing our section. It is great to see Michelle being a strong leader at both the section and association level. Jon Eaton: Jon is currently serving as the AWWA Treasurer. Like Michelle, he was also elected during the January 2020 winter board meeting. Jon has had his hands full working with the association CFO during these hard COVID-19 times. He has done an excellent job of ensuring that AWWA will financially survive the pandemic and continue to be the industry leader for all things water. That’s a lot of great local volunteers serving at the Association level. In fact, we’ve even earned the moniker, ‘The Minnesota Mafia!’ When we show up to meetings, everyone knows that we are there to handle business. One of the most interesting things I have learned while serving on the AWWA Board of Directors is that, as a Section, we have done an outstanding job with our programs and being a leader in the industry – so much so that other sections will enquire about what we are doing and how we have dealt with certain issues. Great job, Minnesota! Keep it up!!! •
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M N AW WA Industry News
John Kriesel to be Keynote Speaker for 2022 Metro Water Operators School The Metro Water Operators School is back after a two-year absence because of COVID-19. It will be at the Earle Brown Heritage Center in Brooklyn Center from Tuesday, April 5, to Thursday, April 7, 2022. The keynote speaker the opening morning will be John Kriesel, who is a former member of the Minnesota House of Representatives and currently a motivational speaker, author, and part-time personality on KFAN Radio.
“In 2006, Kriesel lost his legs in Iraq when an improvised explosive device detonated. He was at Walter Reed Army Medical Center for nine months and will share his stories and lessons with the water operators on April 5.” A study class for those taking the exams for Class C and D licenses will be Wednesday with exams for all classes on Thursday morning, April 7. Special Session for Superintendents: The annual vendor exposition will happen Thursday morning, along with minisessions and Gimmicks and Gadgets. In addition, all superintendents are invited to attend on Thursday morning at a special price. In addition to admission to the vendor exposition and lunch that day, a special session for supervisors and superintendents will be held.
In 2006, Kriesel lost his legs in Iraq when an improvised explosive device detonated. He was at Walter Reed Army Medical Center for nine months and will share his stories and lessons with the water operators on April 5. He is the author of the book, Still Standing: The Story of SSG John Kriesel, which will be available to buy at the school. Classes will cover half-day sessions on distribution, treatment, leadership, regulatory issues, operations, and emerging technologies. The breakfast and lunch on Wednesday, April 6, will include speakers on the topics of an update on commercial driver’s licenses and on diversity and inclusion.
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Registration Details for Metro School Fee: $290 ($340 after March 21, 2022) Register and Pay Online at www.mnawwa.org/events/event_list.asp. In addition, superintendents are invited to attend the product exposition and minisessions on Thursday morning, as well as have lunch. There will be a session for supervisors only at 8:30 a.m. that morning. Registration for supervisors and superintendents for Thursday only is $25.
Applications for the certification exam must be received by the Minnesota Department of Health at least 15 days before the exam. Download the exam application at www.health.state.mn.us/ communities/environment/water/docs/ wateroperator/opexamapp.pdf or contact Noel Hansen at noel.hansen@state.mn.us or 651-201-4690. Lodging Many hotels are in close proximity to the Earle Brown Heritage Center to serve those needing guest rooms. Please direct your questions to Stew Thornley at stew.thornley@state.mn.us, 651-201-4655, or Erin Culver at erin. culver@state.mn.us or 651-201-4697. Tentative Agenda TUESDAY, APRIL 5 Registration begins at 6:45 a.m. Morning Session Welcome: Uma Vempati, Chair, Minnesota AWWA Keynote Speaker: John Kriesel, Still Standing Updates: Water Utilities Treatment and Technology (WUTT) program, Certification, Water Equation, Professional Operator Development
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M N AW WA Industry News Afternoon Sessions Leadership Session or Distribution Session Hydrant Inspection: Bob Meyer, St. Paul Regional Water Services ESRI Collector Applications: Matt Harding, City of Eagan Bloomington 42-inch PCCP Watermain Break: Ben Whitcomb WEDNESDAY, APRIL 6 Morning Session Breakfast Commercial Driver’s License Updates: Minnesota State Patrol Class C or D Study Class (all day): Kurt Haakinson and Lance Loverink, Minnesota Rural Water Association
OR Regulatory Session Lead and Copper Rule Revision (LCRR): Michael Bourland, Minnesota Department of Health (MDH) Drought and Water Conservation: Carmelita Nelson, Minnesota Department of Natural Resources MDH Update: Karla Peterson, MDH LCCR Inventory and Replacements: Michael Bourland, MDH OR Operations Session Load Securement: Olson Chain and Cable Minneapolis Watermain Break: Brian Olson, City of Minneapolis, Department of Public Works, Water Plant Operations Lunch with Speaker on Diversity and Inclusion
Afternoon Sessions Emerging Technologies Session GPS Solutions: Katy Rudolph, Frontier Precision Augmented Reality GIS: Kevin Freiberger, Apple Valley OR Treatment Session THURSDAY, APRIL 7 Vendor Exposition Supervisor Sessions Mini Sessions Gimmicks and Gadgets OR Certification Exams (8:30 a.m.) •
The World's Premier Water Conference In-Person or Online – ACE22 Has You Covered After two years, AWWA is thrilled to be returning to an in-person format where water sector professionals can come together and learn, connect and be inspired to solve today’s global water challenges. And for those who are not able to be physically present - our event will include a hybrid feature where we stream content from our most essential tracks. • • • • •
10 Tracks, with Four Streamed Virtually Fan-Favorite Competitions, like AWWA Meter Challenge Networking Opportunities The Innovation Lounge The Exhibit Hall Featuring Current Solutions
ACE22 provides an opportunity to connect with global water experts in every segment of the water sector. Whether at the Water Industry Luncheon or pre-conference workshops providing hands-on learning experiences, AWWA cannot wait to welcome back the water sector to San Antonio in June 2022 for a highly anticipated ACE22, showcasing smart technologies and new programs that address critical issues to protect the world's most important resource!
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2021 MN AWWA ANNUAL CONFERENCE
AN IN-PERSON SUCCESS
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After hosting almost entirely virtual events since March 2020, it was a welcome change to be able to talk to people, facemask to facemask. AWARDS AND RECOGNITION The Annual Conference is always a showcase to announce and recognize recipients of our annual awards. This year, we were able to recognize the 2020 winners in person, and announce our 2021 winners: • Fuller Award: Rick Wahlen, City of Eden Prairie • Leonard Thompson Award: Chris Glassing, AMERICAN Cast Iron Pipe • Jon Eaton Excellence in Volunteering Award: Michelle Stockness, Barr Engineering • Operators Meritorious Service Award: George Springer, City of New Brighton
• Benjamin Mason Award: Dave Harris, Fischer Harris & Associates • Next Generation Award: Kevin Young, SEH, Inc. • Andrew Sullivan Leadership Award: Presented to the WUTT Committee Outgoing Chair Chris Voeltz passed the gavel to incoming Chair Uma Vempati, and announced the election of new chairelect Rob Isabel and Trustee-at-Large Kathryn (Kabby) Jones. Despite the planning challenges created by shifting circumstances, the Conference team worked diligently and collaboratively to ensure a successful and safe event. Well done, and thanks to all our amazing volunteers!
2021 Annual Conference | Duluth, MN
A
fter a year-plus hiatus, MN AWWA welcomed members and colleagues for the 2021 Annual Conference – in person – in Duluth! After hosting almost entirely virtual events since March 2020, it was a welcome change to be able to talk to people, facemask to facemask. And while not as highly-attended as some recent years, the Conference still drew more than 500 attendees from all across MN’s water sector! MN AWWA followed local, state, and CDC guidelines by recommending indoor mask-wearing for all attendees and modifying session rooms to space seating, but the Section was able to adhere to the same program and activities that are normally part of the Annual Conference. Highlights of the Conference included the Tuesday sporting events, Keynote Speaker, a full Trade Show, competitions in the Exhibit Hall, MAC Social Networking event at the Garden Event Center (formerly’s Grandma’s Sports Garden), multi-track technical sessions, Annual Awards Luncheon, election of new ChairElect and Trustee-at-Large, and member appreciation dinner.
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2021 Annual Conference | Duluth, MN
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! 2 2 0 2 R O F E T A D E H T SAVNEAWWA ANNUAL CONFERENCE
2021 Annual Conference | Duluth, MN
2022 M | Duluth, MN September 14-16, 2022
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Water/Wastewater Utilities Treatment and Technology (WUTT) Program Update
A
newly created water and wastewater training and education training program is underway at St. Paul College. This program was created, in part, due to the immediate and long-term need to hire qualified and competent water/ wastewater professionals. The need for candidates is growing due to the increased number of job openings relating to retirements. Endorsed by the MN Health Department (MDH) and the MN Pollution Control Agency (MPCA), the Water Wastewater Utility Treatment and Technology (WUTT) program provides students with a water/wastewater-focused education and training opportunity. The WUTT program provides the following benefits: • Provides training for people on the basic water distribution, water treatment, wastewater collection, and wastewater treatment. Also provides supplemental training for working water/wastewater professionals. • Provides a college training facility that is centrally located. The college is located on the bus line, near the LRT, convenient vehicle parking. • Offers an improved set of options in the course schedule. The program
schedule provides more flexibility, such as: online, nights. • Offers more diversity. The program is focused marketing aimed for all potential students. This focus includes people of all backgrounds, genders, economic status. Partnerships between the Advisory Board, the College, counties and non-profits allow an expanded network for recruitment opportunities. • Hands-on experience in the laboratory and in the field. Centrally located in the metro area provides greater access to partnering agencies such as the City of St Paul Regional Water, City of Minneapolis, and others. • Provides a career pathway, with curriculum, that meets the needs of cities and other agencies for their continuous and critical hiring needs. Students who successfully complete the WUTT program and pass the Water D and/or Wastewater D examination will become certified Operators. Cities will have their needs employment needs addressed and fulfilled, once again. Overall, the WUTT program is an innovative, relevant, and vital career pathway for people new to the water/ wastewater industry, as well as a training option for current industry professionals.
Students and water/wastewater agencies will also benefit greatly from this program. Next Cohort Begins Two cohorts are underway. The goal is to begin another one in March 2022. WUTT Advisory Chairperson, Carol Kaszynski states, “a new cohort will begin if eight students register.” Kaszynski is hopeful people will share the information of the WUTT program with friends, family members, peers, etc. Donation Requests The WUTT program is always seeking donations of materials, equipment, parts. If you are able to contribute, please contact Steve Grossman, City of Lakeville, at sgrossman@lakevillemn.gov. Financial support of the WUTT program is also needed. As a non-profit, the WUTT program seeks funds to support students with conference registration, travel arrangements and scholarships. If you are interested and would like additional information or details, please contact the MN WUTT Advisory Board Chairperson Carol Kaszynski at carol. kaszynski@ci.stpaul.mn.us. Thank you! •
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BENEFITTING FROM TODAY’S
TOPSY-TURVY JOB MARKET By Stuart Karasik, Ph.D., AWWA Connections
A
t this point in the pandemic roller coaster, hiring employees is a sink-or-swim proposition for many organizations. The stresses of managing virtual school and work, changing mask and vaccination requirements, and dealing with illnesses and quarantines have contributed to employees either looking for better paying positions, quitting, or retiring early. What some call the ‘Great Resignation’ is leaving many operations short-handed. I recently attended training to support the hiring needs of non-mainstream companies. I was surprised to learn that a key topic of discussion was job candidates over age 40. These workers offer valuable experience, skills, knowledge and dependability, yet they may struggle with today’s mostly-virtual hiring process. This process requires preparing a digital resume, going online to research job openings and employers, submitting online applications, and even tracking your applications through the internet. It can be impersonal, time consuming, and frustrating. Here are four simple tips to help ageproof your job search:
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UPDATE YOUR RESUME. If you're using the same resume from your last job search, you are seriously dating yourself. Check online for the latest formats. Email addresses that end in aol.com or yahoo.com, rather than gmail.com, are ancient by today’s standard. Do not include dates that may reflect your age, such as college and high school graduations. NETWORK. More experienced employees have a more extensive, effective network, so use it. Your contacts can provide references that validate your knowledge, skills and abilities. They also know who is hiring before positions are publicly announced. They also can refer you to others in their network. PREPARE. Rehearse answers for age-related interview questions. A recent AARP survey indicated that 41% of job applicants were asked age-related questions during pre-screening, interviews, or written questionnaires. Examples include: • Do you think you’re overqualified? • How old are you? • Why do you want to work?
• Why are you unemployed?’ Answer calmly and be proud of your age, your achievements, and capabilities. FOLLOW UP. Send the interviewer an email thanking them for their time and reinforcing your strong points. Check in at a later date to determine the status of your application. Even if you aren't a job seeker now, it’s a good idea to compare your resume to newer templates. You never know when you may need to use it! ABOUT THE AUTHOR Stuart Karasik spent most of his career in the human resources/personnel arena. He has a Ph.D. in education, a master’s in biology, and was the training program manager for the City of San Diego. More career resources and job opportunities are available at AWWA’s Career Center and at Work for Water. For more career resources and job opportunities, visit AWWA’s Career Center at careercenter.awwa.org/careerresources/?msessid=w9wcm and Work for Water at www.workforwater.org. •
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WHAT YOU NEED TO KNOW ABOUT THE UPDATED WATER CONSERVATION AND EFFICIENCY PROGRAM OPERATION AND MANAGEMENT STANDARD (AWWA G480-20) By Jennifer Shimmin, Vice-Chair, AWWA Standards Committee on Water Conservation Practices
Given the heightened interest in conservation, the AWWA G480-20 standard will prove helpful for any water provider interested in increasing the level of water conservation and efficiency among its customer base.
T
hroughout North America, water conservation and efficiency programs play an increasingly prominent role for water providers as climate change, rising costs, and environmental and legislative constraints put pressure on water supplies. To contend with these challenges, water providers need assurance that their conservation efforts are meaningful and effective. Some may need guidance on the core components that comprise successful and effective conservation and efficiency programs, and others may need a way to evaluate how their water conservation and efficiency program measures up. For the past eight years, the ANSI/AWWA G480 Utility Management Standard on Water Conservation and Efficiency Program Operation and Management has offered an industry-standard metric for evaluating programs of all sizes and budgets. The first edition of the standard was issued in 2013, and a revised version of the standard is now available, offering utilities a fresh opportunity to assess their programs. The new edition, AWWA G480-20, which was released Feb. 1, 2021, and is available from the AWWA Store, updates and expands on the 2013 edition, including important new provisions relating to metering, water loss control, outdoor water planning and management, and many other areas.
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Updates to the Standard The AWWA G480-20 standard is entirely voluntary and offers a comprehensive set of program measures that utilities can choose to adopt and use to evaluate their own offerings. Utilities may formally adopt AWWA utility management standards and seek to conform to each specific requirement or simply use the standards as guidance. AWWA G480-20 includes the following sections:
• Regulatory requirements. • Top-level organizational functions, such as staffing and planning. • Internal utility actions and requirements, such as metering, billing practices, and nonpromotional rates. • Program components, such as landscape efficiency and transformation, landscape water budgets, and water loss control programs.
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• External policy requirements, such as water efficiency in building codes and standards. • Specific requirements for wholesale water agencies. In building on the 2013 first edition, AWWA G480-20 includes significant updates and refinements. These include a new section on the integration of water efficiency and land use planning, along with detailed recommendations related to water shortage and drought planning, metering practices, water loss auditing, and audit validation. Verification of Compliance The new standard includes a section focused on documentation and verification of conservation and efficiency program compliance. Compliance requires a verification update every five years, which should be made available to the public. It includes transparency and full accountability, which are core components of all AWWA utility management standards. Utilities may seek an independent review to determine how they measure up to the standard. One way to do this is by working with the Alliance for Water Efficiency (AWE), which offers an independent compliance verification service for its member agencies. AWE uses a compliance checklist, the components of which include utility conservation planning documents, water resources plans, water shortage plans, and more. The AWE G480 Leaderboard recognizes exemplary water utilities that have adopted and complied with the voluntary AWWA G480 Standard and establishes compliance at Bronze, Silver, Gold, and Platinum levels. AWE staff look forward to submissions for review and to get agencies listed on the new leaderboard. Utilities are encouraged to reach out to AWE for the checklist in order to begin the process. Given the heightened interest in conservation, the AWWA G480-20 standard will prove helpful for any water provider interested in increasing the level of water conservation and efficiency among its customer base. For more information on the standard, contact Frank Kurtz at fkurtz@awwa.org. •
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Winter 2021-22 | Breeze
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Biden-Harris Administration Announces
LEAD PIPE AND PAINT
ACTION PLAN By AWWA Connections
AWWA is pleased that the newly announced Biden-Harris Lead Pipe and Paint Action Plan seeks to address lead exposure in a whole-of-government approach.
I
n a press event last month, US Vice President Kamala Harris and Environmental Protection Agency Administrator Michael Regan announced that the January 2021 Lead and Copper Rule Revisions (LCRR) are now final, and that EPA will promulgate further revisions prior to Oct. 16, 2024. The rulemaking plans are part of a broader Biden-Harris Lead Pipe and Paint Action Plan, which the White House describes as ‘an historic effort of unprecedented ambition that will deploy catalytic resources from the Bipartisan Infrastructure Law while leveraging every tool across federal, state, and local government to deliver clean drinking water, replace lead pipes, and remediate lead paint.’ AWWA CEO David LaFrance, who attended the event, issued a statement that read in part: “Today’s announcement from US EPA recognizes that the January 2021 Lead and Copper Rule Revisions (LCRR) are an important step forward in lead risk reduction, and utilities are already hard at work implementing that rule in their communities. The required development
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Breeze | Winter 2021-22
of lead service line inventories will help communities understand the scope of the challenge and accelerate lead service line replacement. This is a tremendous and necessary undertaking, and many utilities are already advancing this goal and serve as excellent models for others. AWWA looks forward to helping communities find collaborative ways to overcome barriers to lead service line replacement.” Key components of the announcement include: • The Jan. 15, 2021, LCRR Revisions are effective as of Dec. 16, 2021. • Water systems must comply with the LCRR deadlines unless a future rulemaking changes them. The first of those deadlines is Oct. 16, 2024. • EPA intends to propose and then promulgate further revisions – the Lead and Copper Rule Improvements (LCRI) – prior to Oct. 16, 2024. Because of the LCRI rulemaking, EPA anticipates proposing a delay in the compliance dates for submittal of Lead Service Line Replacement Plans and Tap Sampling Plans. The announcement calls out the potential for recent federal infrastructure
appropriations as well as legislative funding proposals currently in development as being important resources. EPA emphasizes: • Timely development of initial lead service line inventories. EPA does not expect to propose changes to the requirements for information to be submitted in the initial inventory. • Avoiding partial lead service line replacement. • Prioritization of lead service line replacement for the most vulnerable populations by focusing on schools, child-care facilities, homes where children are living, other locations where children are present, and households of those who historically have been disproportionately exposed to lead from water and other media. While it’s not yet clear what the future revisions will include, the notice outlines specific areas of focus, including: • Re-evaluation of the action and trigger levels. • Re-evaluation of the required tap sample compliance data set; perhaps including observed lead concentrations from both first and fifth liter samples
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in those calculations when samples are drawn from homes with lead service lines, as is current practice in Michigan. • Provisions that would result in all lead service lines being replaced as quickly as is feasible. • Provisions to prioritize the removal of lead service lines in historically disadvantaged communities. “Beyond EPA’s rulemaking, AWWA is pleased that the newly announced Biden-Harris Lead Pipe and Paint Action Plan seeks to address lead exposure in a whole-of-government approach,” LaFrance said in the AWWA statement. “Increased collaboration among federal agencies can help reduce lead risks from all potential sources. Tremendous progress has been made in lead risk reduction since the first Lead and Copper Rule was introduced in 1991, but more work remains. ... We look forward to working closely with the Administration, states, and partners to accelerate lead service line replacement in a collaborative and efficient manner.” •
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AWWA CEO David LaFrance with EPA Office of Water Assistant Administrator Radhika Fox.
Winter 2021-22 | Breeze
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Advance Our Profession by
SHARING YOUR KNOWLEDGE, EXPERTISE, AND EXPERIENCE. Contribute an article to Breeze!
Breeze magazine is the official publication of our Minnesota Section of AWWA. Distributed in print to all of our members and industry stakeholders as well as online in a mobile-friendly digital edition, our industry-specific magazine will be instrumental in helping water professionals across our great state stay informed and current on the industry’s latest trends, techniques and important news. We are looking for topical, timely and informative articles provided by operators, managers, engineers, consultants, environmentalists, etc. who are willing to share their knowledge and expertise by contributing an article to the Breeze magazine. It is an ideal way to: ✓ enhance the knowledge of your colleagues ✓ advance the water profession throughout Minnesota ✓ gain exposure and recognition with your peers * Note: We will provide additional details and any assistance you require to ensure a smooth and efficient contribution process.
If you are interested in being published in a future issue of Breeze magazine and contributing significantly to the advancement of our profession, please contact:
Tammy Marlowe Johnson, Managing Editor • tammy@kelman.ca • 1-844-985-9717
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Developing Effective Funding Strategies for Compliance with
THE LEAD AND COPPER RULE REVISIONS PART I By Christopher Hill, Quirien Muylwyk, John Konkus, and Tom Loto, AECOM Technical Services
Understanding the potential impacts of the Lead and Copper Rule Revisions (LCRR) and having an effective compliance and funding strategy to address the impacts of the rule are critical to meeting the rule requirements. The federal government is currently negotiating a US infrastructure plan and as details emerge, funding for lead service line replacement remains a priority of any future bill. While the details continue to evolve, Drinking Water State Revolving Funds (DWSRF), Water Infrastructure Finance and Innovation Act (WIFIA), and federal earmarks are likely vehicles for funding to water systems. As such, it is important to understand how those programs work and what it will take to apply for and administer funds received under those programs to support LCRR compliance. INTRODUCTION The Lead and Copper Rule Revisions were finalized in January 2021. In June, the United States Environmental Protection Agency (USEPA) affirmed the rule requirements and extended the effective date of the LCRR to December 16, 2021, and the compliance date to October 16, 2024. The LCRR includes a number of key provisions that will impact water systems, including changes in corrosion control treatment (CCT) requirements, find-and-fix provisions for homes with elevated lead levels, sampling requirements for schools and childcare facilities, and additional public outreach and education requirements. This article focuses on three specific areas of the LCRR: service line inventories, lead service line replacement (LSLR) planning and changes in compliance monitoring – and strategies to take advantage of available funding for LSLR. DEVELOPING A SERVICE LINE INVENTORY AND UNDERSTANDING LCRR COMPLIANCE RISK All water systems, including those that do not have lead service lines (LSLs), are required to create a publicly accessible service line inventory by October 16, 2024. Service lines will be given one of four possible designations. Known LSLs will be labeled as ‘lead service lines.’ Galvanized service lines that are or were previously downstream of an
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Machine learning can be an effective means of identifying LSL locations and prioritizing replacement.
LSL will be designated ‘galvanized requiring replacement.’ Service lines of unknown material are to be labeled ‘lead status unknown service lines’ and those known to be ‘non-lead’ can be designated as such. A ‘non-lead’ designation does not require the water system to identify the
exact material of a service line, such as plastic or copper, if it is not an LSL or galvanized requiring replacement service line. It is also worth mentioning that the LCRR does not require water systems to investigate or inventory lead connectors (i.e. goosenecks or pigtails).
Winter 2021-22 | Breeze
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THE LEAD AND COPPER RULE REVISIONS PART I Observed increases in lead concentration in samples collected away from the water main can be indicative of an LSL. However, a system using an orthophosphate inhibitor might see little variation in lead and should be cautious about assuming a service line is non-lead based solely on water quality. The threshold lead concentration used to indicate lead will vary by water system and thus calibration will be necessary to demonstrate the efficacy of water quality sampling to find lead.
Lead Service Line Replacement Plans are due by October 2024. Though replacement may not be required, the availability of funding should make LSL replacement a priority for most systems.
TABLE 1. LCRR SAMPLE SITE TIERING CRITERIA. TIER
DEFINITION
Tier 1
SFSs served by LSLs.
Tier 2
Buildings, including multi-family residences served by LSLs.
Tier 3
SFS served by galvanized service lines that are/were downstream of an LSL.
Tier 4
SFS service by copper service line with lead solder.
Tier 5
Representative sites.
SFS = Single Family Structure
However, the replacement of lead connectors is expected to be undertaken opportunistically when discovered in the system. Developing an inventory will be an iterative process due to the availability of records that may be incomplete or erroneous, the presence of unknown service lines, and the need to update the inventory over time. The inventory must be updated over time to reflect changes, such as verification of unknown service line materials or LSLs that have been replaced. Water systems with only non-lead service lines are required to conduct an initial inventory, but are not required to provide inventory updates and may fulfill the requirement to make the inventory publicly accessible with a statement that there are no LSLs, along with a general description of the methods used to make that determination. Our experience helping multiple utilities find and document lead services has involved a range of different methods, including:
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Breeze | Winter 2021-22
• Desktop reviews of historical data, building codes and ordinances, maintenance records, staff knowledge, and other sources of data, such as geographical information system (GIS) and asset management information. • Field investigations, including nondestructive testing or visual check of the interior, observations at the meter, and pothole investigations. Our experience has shown multiple pothole excavations may be necessary, particularly where there is a history of partial LSL replacements or where there is evidence of a service line repair. • Water quality sampling as an indicator of lead. If using water quality data to identify possible LSL locations, it is important to consider the role of CCT and its potential impacts on water quality. For example, a water quality profile can be used to observe changes in lead concentrations from the tap to the water main.
CONFIRMATION OF NON-LEAD STATUS One of the most challenging things about the LCRR may be confirming the non-lead status for an individual property or water system. As USEPA has not yet released guidance related to conducting a service line inventory, a recommended first step is to meet with the state or primacy agency to establish expectations for the LSL inventory, including what is required to demonstrate a service line is non-lead versus lead status unknown. While there is no deadline to investigate the material of all lead status unknown service lines, water systems must include a strategy in their LSLR Plan for investigating the unknowns in their inventory. This strategy, coupled with the incentive to investigate unknowns to ease the burden of future LSLR, will encourage water systems to verify unknown service line materials in a timely manner. USEPA states in the LCRR that service lines installed after a state or federal ban on the use of lead may be designated as non-lead, but provides no real guidance beyond that criterion. In the absence of additional guidance, a pragmatic approach is to balance the risk of lead exposure and the cost to conclusively determine that there is no lead (conduct water quality sampling, perform interior and pothole inspections, etc.), and prioritize service line material confirmation based on that risk. For example, a household childcare facility located in an area where LSLs are known to exist is a relatively higher priority for confirmation. Alternatively, a service line at a home near an area where a water main was recently replaced and all of the homes were observed to have
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copper service lines is a lower priority for investigation (or could even be designated ‘non-lead’ based on discussions with the state or primacy agency). LEAD SERVICE LINE REPLACEMENT PLANNING TO REDUCE THE RISK OF LEAD EXPOSURE Though USEPA opted not to lower the lead action level (AL) from its current value of 15 ug/L, the revisions establish a new lead trigger level (TL) of 10 ug/L. Compliance and associated actions by a water system are based on the 90th percentile of lead monitoring results in comparison to the AL and TL. Water systems with LSLs are required to submit a LSLR Plan by October 16, 2024. The rule does not require mandatory LSL replacement unless a system exceeds the AL or TL, however, replacement of the publicly-owned portion of the service line is required when replacement of the privately-owned portion is initiated by a customer. As such, water systems should develop service line replacement policies and procedures, inclusive of construction materials and methods, customer outreach, and funding strategy before October 2024. A water system that exceeds the AL must implement full LSLR at a rate of 3% per year. A water system that exceeds the TL must implement LSLR at an annual rate approved by the State. In both scenarios, LSLR can be discontinued after two consecutive years of monitoring below the TL. The LSLR Plan must describe how replacements are prioritized. It is recommended that LSL replacement be prioritized based on risk. However, risk is relative. A water system with relatively few LSLs may prioritize individual replacements based on lead levels at a particular home and/or based on the risk to occupants. On the other hand, a system with a significant number of replacements may prioritize both individual sites and geographic areas based on risk. It is recommended the following factors be considered to prioritize replacements: • Location, distribution, and density of LSLs.
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• Sociodemographic factors that reflect the consequence of lead exposure. • Construction constraints and opportunities to minimize community disruption. When all three are considered, a balance between public health protection and construction efficiencies can be realized. Experience suggests that LSL occurrence often coincides with household income and therefore sociodemographic indicators for poverty, education, and other factors can be used with the lead inventory to
determine which areas of a water system might be given higher priority. Consideration should also be given to construction opportunities (e.g. water main rehabilitation projects) to realize cost efficiencies. A transparent prioritization framework can be shared with the public and city leaders, so that customers know when the lead at their home or in their neighborhood will be replaced and why. • PART II: Coming up in the Spring 2022 edition of Breeze.
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M N AW WA Advertiser Product & Service Center Breeze is made possible by the companies below who convey their important messages on our pages. We thank them for their support of The Minnesota Section of the American Water Works Association (MN AWWA) and its publication and encourage you to contact them when making your purchasing decisions. To make it easier to contact these companies, we have included the page number of their advertisement, their phone number, and, where applicable, their website. Company
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38
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Janssen Machine Co.
13
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Water Conservation Services, Inc.
30
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22
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