The U.S. Environmental Protection Agency’s (EPA) updated Lead and Copper Rule Revisions (LCRR) present significant new requirements for public water systems. EDGE understands these regulations introduce operational challenges alongside the crucial goal of further reducing lead and copper in drinking water, particularly for vulnerable populations like children.
These federal revisions and specific regulations from the Texas Commission on Environmental Quality (TCEQ) apply to community and non-transient non-community public water systems. Ensuring compliance is essential for protecting public health and maintaining regulatory standing.
Key LCRR Requirements Impacting Your System:
The LCRR mandates enhanced actions to control lead contamination. Public water system owners and operators should be aware of these primary obligations:
- Lead Service Line (LSL) Inventory: A primary requirement is the development and submission of a comprehensive LSL inventory. This involves identifying service lines as lead, galvanized requiring replacement, non-lead, or lead status unknown. The initial federal deadline for submission was October 16, 2024. For Texas systems, TCEQ recommends submission and maintenance of this inventory by utilizing their SWIFT online portal. This inventory is critical for identifying and prioritizing areas for lead mitigation efforts.
- Lead Trigger and Action Levels: The rule introduces two key thresholds for lead concentrations that necessitate specific responses:
- Trigger Level (10 µg/L): Reaching this level requires systems with existing Corrosion Control Treatment (CCT) to re-optimize their treatment. Systems without CCT must conduct studies to prepare for potential future CCT implementation.
- Action Level (15 µg/L): Exceeding this level mandates LSL replacement (LSLR) at a minimum rate (typically 3% annually) and requires public notification within 24 hours.
- Corrosion Control Treatment (CCT): Enhanced focus is placed on optimizing or implementing CCT based on lead levels and the presence of LSLs. Effective CCT is crucial for minimizing lead leaching. TCEQ actively monitors Texas systems to ensure adherence to optimized treatment protocols.
- Revised Tap Sampling Protocols: The LCRR modifies tap sampling procedures, emphasizing locations with LSLs and requiring fifth-liter samples. To ensure a more accurate risk assessment, practices like pre-stagnation flushing and aerator removal during sampling are prohibited.
- Expanded Public Education and Outreach: Communication requirements are expanded. This includes prompt notification (within 24 hours) for Action Level exceedances and annual notification with educational materials for customers served by known or potential LSLs. Texas systems must adhere to TCEQ’s specific timelines and communication templates.
- Testing in Schools and Child Care Facilities: Community water systems are now obligated to conduct lead testing in elementary schools and licensed childcare facilities within their service area, typically phased over five years. Reporting results and distributing educational material are required.
How EDGE Supports Your LCRR Compliance Efforts
Meeting these LCRR demands requires significant resources and expertise. EDGE provides targeted consulting services to help Texas water systems navigate EPA and TCEQ regulations efficiently. Our support includes:
- Lead Service Line (LSL) Inventory Development and Support:
- Comprehensive Inventory Creation: We assist in compiling the initial LSL inventory by thoroughly reviewing historical records (plumbing codes, system maps, permits) and classifying service lines according to regulatory requirements.
- Resolving Unknown Line Status: We develop strategic approaches to investigate and verify the materials of “lead status unknown” lines, improving inventory accuracy and informing replacement planning.
- Public Accessibility Compliance: We help ensure your inventory meets TCEQ and EPA guidelines for public access.
- Assistance for Systems Needing Post-Deadline Compliance:
- Expedited Inventory Completion: If your system did not meet the October 16, 2024, inventory deadline, we offer prioritized services to complete the inventory and associated LSL Replacement Plan development where necessary.
- Strategic Compliance Navigation: We guide you through the consequences of delayed compliance and develop strategies to achieve regulatory requirements efficiently, aiming to mitigate potential enforcement actions.
The Importance of Timely LCRR Compliance
Failure to comply with LCRR requirements, particularly the LSL inventory submission, carries significant risks, including:
- Potential Enforcement Actions: EPA and TCEQ may issue fines, administrative orders, or other enforcement measures.
- Mandatory Public Notifications: Systems may be required to notify residents of their non-compliance status.
- Ineligibility for Funding: Non-compliant systems risk losing access to crucial federal and state funding designated for LSL replacement projects.
- Impact on Public Confidence: Delays or failures in compliance can undermine the community’s trust in the safety and management of their drinking water.
Partner with EDGE for LCRR Success
The LCRR presents operational challenges but also a vital opportunity to enhance public health protection. EDGE is equipped with the expertise to guide your water system through the complexities of LCRR and TCEQ regulations. We focus on practical solutions to ensure compliance and safeguard your community’s drinking water.
Contact EDGE today to learn how our tailored services can help your water system achieve and maintain LCRR compliance.