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The EPA is in the process of developing a small system compliance guide and fact sheet, drawing information from the guidance document.
Please click on the link below to review slides presented by Isaac Pellerin, 120Water, at the 2022 NCRWA Leadership Summit:
How to Create and Validate Service Line Inventory for Water Systems
What Rural Water Systems Need to Know about Lead and Copper Rules
LCRR compliance deadlines are scheduled for 2024, with only three years to go, it is critical that systems are preparing now for compliance. A recent study by 120Water shows that the majority of water systems are not ready for the new rule.
It is important to understand what the new rule entails so they can begin taking action:
LSL inventory and replacement. Utilities will be required to conduct a "location-based" inventory of publicly- and privately-owned LSL materials, including all systems and connections. The inventory must be submitted to the EPA within three years. Water systems with more than 50,000 customers must make the inventory public — and this is a good practice for smaller systems as well (see Fig. 1). Results also must be resubmitted alongside annual or triennial monitoring results. Once the inventory is complete, systems must develop an LSL replacement plan if lead service lines are found or if galvanized pipes that previously were connected to a lead pipe are found.
It is important to understand what the new rule entails so they can begin taking action:
LSL inventory and replacement. Utilities will be required to conduct a "location-based" inventory of publicly- and privately-owned LSL materials, including all systems and connections. The inventory must be submitted to the EPA within three years. Water systems with more than 50,000 customers must make the inventory public — and this is a good practice for smaller systems as well (see Fig. 1). Results also must be resubmitted alongside annual or triennial monitoring results. Once the inventory is complete, systems must develop an LSL replacement plan if lead service lines are found or if galvanized pipes that previously were connected to a lead pipe are found.
Why is there lead in the water
Lead can enter drinking water when plumbing materials that contain lead corrode, especially where the water has high acidity or low mineral content that corrodes pipes and fixtures. The most common sources of lead in drinking water are lead pipes, faucets, and fixtures. In homes with lead pipes that connect the home to the water main, also known as lead services lines, these pipes are typically the most significant source of lead in the water. Lead pipes are more likely to be found in older cities and homes built before 1986. Among homes without lead service lines, the most common problem is with brass or chrome-plated brass faucets and plumbing with lead solder.
Where can small systems find assistance?
Safe Drinking Water Act Compliance Program, NRWA Training and Technical Assistance program provides accredited operator certification training, board member training, and on-site technical assistance that supports the specific needs of small water system personnel, tribal systems, and overburden systems. Training Specialists have experience working with small systems and possess expert knowledge regarding their compliance challenges.
Classroom sessions are designed to meet state-specific compliance challenges. They are geographically located in areas to reach the most significant number of small system operators. This is important because many small public water systems lack the financial resources to allow operators to travel to central or urban areas for training, and these operators have no backup to respond to emergencies while they are absent.
Partnership with 120Water
NRWA and 120Water entered a partnership in 2021 to expand the support and technical assistance available to State Rural Water Associations and to rural utilities.
This partnership provides tools and resources to State Rural Water Associations to manage water quality programs related to lead and other contaminants. Included are educational resources, ongoing training, and access to 120Water solutions - consisting of could-based software, point-of-use sampling kits and expert consulting services at a preferred price.
This partnership provides tools and resources to State Rural Water Associations to manage water quality programs related to lead and other contaminants. Included are educational resources, ongoing training, and access to 120Water solutions - consisting of could-based software, point-of-use sampling kits and expert consulting services at a preferred price.
Resources:
EPA | Lead and Copper Rule: A Quick Reference Guide
EPA | Lead and Copper Rule Long-Term Revisions
EPA | Drinking Water State Revolving Fund
EPA | Review of the National Primary Drinking Water Regulations Lead & Copper Rule Revisions
NRWA | Lead & Copper Rule Overview
NRWA/120 Water | LCRR Self-Evaluation
LCRR Compliance Timeline
EPA | Reference Guide for Public Water Systems Lead and Copper Rule Comparison
