Preparing for LCRR Compliance

Why Such a Big Deal?

The LCRR is the first major change to the LCR since it was established in 1991 to protect public health and reduce exposure to lead in drinking water. The LCR has resulted in major improvements in public health, and the revisions will go even further. Water providers are required to make changes in six key areas:

• Identify the most impacted areas and deliver a publicly available inventory of lead service lines. Water systems will be required to find and fix sources of lead when a sample in a home exceeds 15 ppb.
• Strengthen treatment requirements for corrosion and establish a new trigger level of 10 ppb.
• Replace public lead service lines when customers replace their portion of the lines, and mandatory replacement of lines above the trigger level.
• Make drinking water sampling more reliable by requiring water systems to follow improved sampling procedures and better target sampling sites.
• Improve risk communication to customers by requiring water systems to notify customers within three days if a sample collected in their home shows lead levels above 15 ppb, or 24 hours if the 90th percentile is above the action level of 15 ppb.
• Protect children in schools and childcare facilities by requiring water systems to test drinking water in these facilities.

Additionally, water systems should begin preparing to meet the new rules in three areas.

Area 1: Data Management and Consolidation

Consolidating and digitizing data is the foundation for staying compliant with the new Rule for several reasons. Water systems will need to know where lead service lines and fixtures exist within the system to meet new testing and reporting requirements. In addition, water systems will need to know how to reach customers with information about test results within the required timelines, and to provide information around remediation efforts.

To start, water systems will need to digitize their lead service line data and devise a way to keep this inventory current. Systems are required to submit a location-based inventory either on an annual or triennial basis, depending on their compliance schedule. The revised Rule requires water systems to make this data available to the public, so inventories will need to be updated in real time. This will require the use of new digital solutions that can predict locations of lead service lines (LSL) cost-effectively using a combination of existing inventories, GIS and predictive modeling.

At the same time, customer data needs to be updated, accessible and linked to the LSL inventory. This is helpful for knowing where to send pre-replacement sample kits and/or pitcher filters, tracking which lines have been replaced and which need replacing, and for sending post-replacement tap water testing kits and/or pitcher filters.

Finally, the revised Rule includes a three day notification requirement if an exceedance is found, or 24 hours if the 90th percentile is above the action level. This compressed notification timeline (down from 30 days) means that water systems must understand who their customers are and how best to communicate with them across multiple channels, including traditional methods like direct mail and telephone, as well as digital channels such as company websites, social media, email, and text. Digitizing and managing customer data is the only way water systems will be able to meet the new notification rules.

Area 2: Proactive Communication

Since the lead crisis in Flint, Mich., trust in water systems among the public has taken a hit. The way to earn back that trust is by communicating proactively and transparently with customers, public officials, and the media. This takes on even greater importance with the revised LCR.

The new Rule will generate a lot of interest from the media, and that interest is bound to lead to questions. Water systems can get ahead of these questions by proactively educating stakeholders about the proposed rule changes, and how the new Rule will impact the community. This gives water systems the opportunity to educate residents about lead, how it gets into drinking water, why it’s dangerous, and the steps you are taking to eliminate lead in drinking water. In fact, the Final LCRR requires water systems to communicate to residents with known lead service lines annually.

There are a few aspects of the LCRR that will make proactive communications and planning even more important:

• The trigger level for notifications has been reduced to 10 ppb, so new exceedances are probable. Residents may be confused about why testing is now indicating they have a problem.
• The new Rule requires three day notification of exceedances — down from 30 days, or 24 hours if the 90th percentile is above the action level. Water systems need to have a plan to meet these compressed time mandates.
• Schools and daycares will be tested as part of the new Rule. Even if these facilities are not part of your water system, parents and others won’t necessarily differentiate them from your utility.
• Targeted testing of at-risk residences could leave the false impression that there is a broader lead problem throughout the community unless customers understand how and why certain locations are being tested.

These issues can be mitigated first by proactively educating residents about changes in the Rule, and then by having a communications plan and clear messaging to manage the news.

AREA 3: Automation is Necessary

The time involved in managing the LCRR, as well as new reporting mandates, will require water systems to automate as much as possible. Integrating customer, GIS, billing, and other data on a digital water platform will allow water systems to save significant time and money by automating processes that typically are fulfilled by field staff.

A digital water platform can help meet new mandates by:

• Keeping a real time inventory of LSLs and fixtures that can be displayed on a public dashboard to meet reporting rules.
• Triggering automatic customer notifications if an exceedance is found. This can be done digitally by email or text to meet the three day notification window, and followed up with a letter later on.
• Automatically sending testing kits to residences to meet the mandate for increased testing, and to help identify where lead service lines may exist.
• Fulfillment of pitcher/filter kits to affected residents, along with replacement filters until the water is tested and confirmed to be lead-free.
• Managing the six-month post-LSL replacement tap test to ensure the remediation worked.

The City of Asheville, N.C., is using digital water solutions to power a comprehensive approach to quickly comply with new EPA mandates for delivering safe drinking water to residents. Asheville is developing a comprehensive inventory of service line connections and materials using a software tool that centralizes GIS, historical paper data, customer information, and demographic information to more easily predict where lead service lines exist. They also are using digital water solutions to automate water sampling services for areas with lead service lines, and meet the LCR’s new requirement to notify customers of exceedances within 24-72 hours, depending on the lead level in the drinking water. Asheville will be enabled to remain compliant with new rules around school and daycare fixture inventory and sampling using digital tools that also provide a Public Transparency Dashboard to keep parents and other key stakeholders informed of testing activity and results. Finally, the city is automating water sample kit delivery and resident education using digital water tools, reducing the resources needed to comply with improved sampling procedures.

It’s clear that the LCRR will significantly shift how water systems operate. Water systems can meet the new mandates by embracing digital solutions and proactively educating stakeholders today. WW

About the author: Megan Glover is CEO of 120Water, a digital water company that provides modern solutions to solve complex wastewater and drinking water initiatives, including LCRR.