The revised Lead and Copper Rule is here– the clock is ticking, and it’s time to prepare.
If you’re feeling uncertain about the contents of the rule, you’re not alone. We pored through its contents to create a suggested ten-year timeline of to-dos and best practices to help utilities gear up for the significant challenges ahead.
Deadlines go into effect in 2024, but the three years leading up to that date are absolutely critical to prepare for compliance. In order to achieve compliance across the various requirements, systems must develop action plans, audit and revise current processes, get their data in order, and, perhaps most importantly, begin to create and validate their Lead Service Line inventory. 120Water’s centralized program hub provides everything you need to consolidate your data and begin to take action.
Utilities are required to conduct a “location-based” inventory of publicly-owned and privately-owned LSL material information. 120Water’s Inventorying and Reporting functionality makes it easy for a utility to create and maintain a record of all its service lines. By associating each line with the location(s) it serves, utilities can also easily create and update Tier lists. Finally, the Service Line Inventory serves as the foundation for a Public Transparency Dashboard, which can be posted by the utility to its website.
Tier Lists will be based on the inventory, and in any systems with LSLS, all “Tier 1” samples must be collected from LSL homes, requiring a 1st and 5th liter draw and analysis. Our consumer kit system automates the sampling process, freeing your team to focus on the task of protecting public health. EPA-approved kits are fulfilled and tracked through the 120Water platform so that you know where you are every step of the way. The sample bottles are delivered with clear instructions and a pre-packaged return label, making it easy for your customers to participate in the compliance process.
Utilities are required to resample for both lead and Water Quality Parameters at any home with lead levels above 15 µg/L within 5 days of receiving the result and must attempt to determine what caused the elevated lead level. In addition to automated sampling, 120Water integrates with an always-expanding network of labs, ingesting analysis results painlessly so that sample data is stored centrally in our platform, and can be exported for simplified reporting.
Utilities must sample at 20% of elementary schools and 20% of all childcare facilities in the service area each year, all non-elementary schools by request during that time and then all schools and childcare facilities upon request after five years. Our purpose-built lead sample kits for facilities save resources, and our extensive experience in this area means our services team can advise utilities on best practices in putting together a sampling plan. All sampling data will be stored in the 120Water platform for ease of results communications and reporting.
Any customers with an LCR sample result greater than 15 µg/L must be notified within three days. If the 90th percentile levels are greater than 15 µg/L, all customers must be notified within 24 hours. The 120Water communications module makes it easy to send results-based letters to customers, saving time and eliminating risk of falling out of Compliance. The Communications Module uses a templated approach, meaning the right results data will be communicated to the right customer within the right time frame.
Water systems must report LSLIs, updated tier sites, monitoring results, school and daycare testing results, public notification templates, and water quality parameter results to their state primacy agency. 120Water’s solution, from the Public Transparency Dashboard to simplified dashboards, ensures an audit trail across your programs and easy data exports for reporting.
Develop an LCRR Action Plan that addresses:
Identify LCRR internal team and external partners
Develop a data management plan to support:
Review LSL data. Develop preliminary inventory, and consider working with customers to obtain private side material info. Common sources include:
Create a draft LSLR Plan & identify pitcher/filter supply source
Identify all K-12 schools and childcare facilities in your system so you can be prepared to sample required and requested locations
Educate schools and childcare facilities on upcoming sampling in 2024
Educate your utility and customers about the changes
Review and update customer contact information with phone/email data
Update Tier Sites & identify 1st/5th Liter sampling supplies
Review CCT plan and determine if reoptimization is needed
Identify Find-and-Fix and WQP monitoring sampling supplies and approach
ANNUAL ACTIONS:
Depending on your monitoring schedule, sample at updated Tier Sites. Take 1st and 5th liter samples at LSLs.
Communicate results over 15 ppb within 3 days (individual home) or within 24 hours (90th percentile > 15 ppb)
In 2024: Submit first LSLI or prove you have zero LSLs
Conduct Find-and-Fix & WQP sampling at any homes > 15 ppb
Complete 20% of Elementary schools and childcare facilities. Share results with facilities and public health departments. Sample Middle-High schools by request.
Depending on your monitoring schedule, sample at updated Tier Sites. Take 1st and 5th liter samples at LSLs
Communicate results over 15 ppb within 3 days (individual home) or within 24 hours (90th percentile > 15 ppb)
Submit annual or triennial LSLI (based on monitoring schedule)
Conduct Find-and-Fix Sampling at any homes > 15 ppb
Complete 20% of Elementary schools and childcare facilities. Share results with facilities and public health departments. Sample Middle-High schools by request.
Sample all K-12 schools and childcare facilities by request
Depending on your monitoring schedule, sample at updated Tier Sites. Take 1st and 5th liter samples at LSLs.
Communicate results over 15 ppb within 3 days (individual home) or within 24 hours (90th percentile > 15 ppb)
Conduct Find-and-Fix Sampling at any homes > 15 ppb
Submit annual or triennial LSLI (based on monitoring schedule)
Notify any customer served by an LSL or service connection with unknown materials
Schedule a 1:1 consultation with our team to discuss your LCRR action plan.
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