Technical Assistance Corner: What Do We Need to Do to Get the Lead Out? By Jason Knobloch, Environmental Services Director, Texas Rural Water Association At the time of publication, the Biden Administration has placed a 60-day freeze on the Lead and Copper Rule revisions. The administration will take this time to review the revisions and decide how they would like to proceed. If there are any changes to the rule as it currently reads, we will address them in a future issue of Quench.
T
he verdict is in! As of December 22, 2020, U.S. Environmental Protection Agency (EPA) released the long-awaited final revisions to the Lead and Copper Rule. This revision is the first major overhaul to the Lead and Copper Rule in nearly 30 years and it comes with a lot of changes. To better grasp these changes, it is important to understand the intent and goals behind these revisions. The first goal is to better protect children and communities from the risks of lead exposure at schools and childcare facilities by conducting more testing at these facilities where children spend a large part of their day. The second goal is to identify where lead exists within the water system and remove it. This can be accomplished by inventorying all the potential locations where lead service lines may be and set up a program to replace them. Lastly, this rule is to provide more education and transparency to the public about the locations of lead lines and the adverse health effects of exposure. This rule will force a community water system to take actions sooner to remove lead concerns from the system. As water professionals, we cannot deny that protection of public health is a primary goal in our line of work. To ensure we are carrying out this job function effectively and efficiently, we need guidelines that are based on testing and science that give direction and set limits to what is acceptable in our water. Watching the news over the past few years and seeing cases such as Flint, Michigan, and the negative impact it had on the public, it is easy to understand why the EPA feels tightening up requirements is necessary. Unfortunately, it can 10
Quench — 2021 - Issue 1
cause added burdens to the daily processes of the community water system. The new rule revision will regulate 67,672 U.S. public water systems, of which 63,231 serve populations less than 10,000 people. Large PWS and cities are also impacted by this rule revision, but small and rural communities may have more difficulty complying to the new rule due to limited economies of scale and technical staff. So, what does this mean for your water system? Testing in Schools and Childcare Facilities Since children under the age of seven are at most risk of significant harm from lead exposure, EPA has included requirements that the community water system (CWS) take on the responsibility of testing elementary schools and childcare facilities. This is the first time it has been the role of a water system to test these types of facilities. Samples taken from schools are not to be included in the mandatory sample set for the system. This means that if there is high lead in the schools, this will not be included in the 90th percentile of your samples. The intent of this rule is to identify and provide education to these facilities using the technical expertise of the CWS staff. The CWS requirements for testing schools are: •
Test 20 percent of the elementary schools and childcare facilities the system serves each year over five years so that over a five year cycle all facilities are tested. The samples are to be a representative set of samples, not every point of use on the facility. After all facilities have been tested over the five-year period, no further testing will be required. A refusal or non-response to test
