journey-to-clean-water-mapping-paths-for-sampling

In the U.S., an estimated 9 million service lines still contain lead, which can end up in our drinking water, according to the Environmental Protection Agency (EPA). The Lead and Copper Rule Improvements (LCRI) are changing how utilities and water systems address this crucial issue. Some of the most notable changes brought about by LCRI include improved communications, faster lead service line replacements, and the topic of today’s blog—sampling.

The EPA has evolved and strengthened their approach to sampling as the regulations have evolved from the LCR, to the LCRR, and finally to the recently promulgated LCRI. The changes in these regulations have included updates to compliance sampling methodology, timelines, and the lead action level is reduced to 10 ppb. Additionally, the EPA has placed a stronger emphasis on public outreach and relations by requiring tap sample results to be distributed within 3 days, regardless of the result, and requiring utilities to offer free water sampling to properties with lead, GRR, or unknown service lines.

Updates to Tap Monitoring Requirements

Under the LCRI, the criteria for tiering tap sample sites have been updated to prioritize sites where the highest lead levels are likely to be observed. These tiers will take effect with the first compliance monitoring period under LCRI, in 2028. Here’re more details as shared by the EPA.

Additionally, the 90th percentile calculation has been updated to place an emphasis on samples collected at the highest tier sites. Tap samples are also required to be first- and fifth-liter samples when the site is served by a lead service line with the higher lead concentration being applied towards the 90th percentile calculation.

Testing at School & Childcare Facilities: New Changes with the LCRI

The main updates for school and childcare sampling are the timeline, now expected to start in 2028, and the waiver exemption process. Systems may now consider, with state approval, any sampling consistent with EPA methods conducted between 2021 and the compliance period of 2028 toward a waiver. This includes sampling done through voluntary programs funded by EPA WIIN Grants.

Post-Replacement Sampling

The LCRI mandates that all lead and GRR lines be replaced over a 10-year period. After a replacement has occurred, utilities are required to offer sampling to residents between 3- and 6-months later to test for lead. This sampling effort helps build public trust and ensures that the lead is out after replacement is completed.

Strengthening Public Trust Through Sampling

Providing clear, balanced information on sampling is key to building public trust. Too much data can lead to confusion, while too little raises concerns.

Here are some practical actions for utilities to meet LCRI sampling requirements and support transparent communication with communities:

Update sampling instructions: Ensure instructions are clear and LCRI-compliant.
Share FAQs: Develop a “Frequently Asked Questions” section and designate a point of contact to handle inquiries.
Simplify kit distribution: Make it easy for homeowners to access sampling kits.
Share results timely: Commit to sharing sampling results promptly. Share results directly if needed to ensure transparency, coordinating with schools and childcare centers as appropriate.
Handle exceedances carefully: Prepare to address cases where results exceed Action Levels. Collaborate with customer service and advisory committees to tailor exceedance notification templates for your community.
Build community connections: Partner with agencies that oversee childcare facilities to create contact lists and identify various childcare environments (for e.g., nurseries, drop-in centers, and shelters).
Work with schools: Identify and engage with public and private schools you serve, establishing relationships with school districts, PTAs/PTOs, and after-school programs. You can also integrate lead-related information into existing school channels, events, and tools.
Respect cultural needs: Tailor communication to meet the cultural priorities and languages of your community, especially in schools and childcare settings. Partner with English Language Learners (ELL) advocates, interpreters, and translators to review materials and make them accessible.

These guidelines, if implemented, can certainly help utilities foster trust, support community health, and enhance LCRI compliance.

How Trinnex’s leadCAST Supports Compliance

leadCAST simplifies tap sampling to meet the EPA’s Lead and Copper Rule Revisions (LCRR) and Lead and Copper Rule Improvements (LCRI). Through a partnership with SimpleLab, leadCAST can handle sampling logistics end to end, making compliance easier for utilities and customers alike.

leadCAST and Sampling

leadCAST provides drop-ship sampling kits via SimpleLab, which manages all logistics for environmental lab testing. Here’s how it works:

Utility orders or a resident requests a kit, which is approved.
SimpleLab ships the material. The sampling kit includes the instructions, chain of custody form, LCRR compliant wide mouth bottle or bottles (for 5th liter testing), and shipping labels.
The resident collects the sample and completes a digital form documenting the collection method.
The kit is shipped to a certified lab and held for up-to 14 calendar days prior to analysis. The utility has the opportunity to review the collection method and cancel the test.
- If cancelled, SimpleLab notifies the lab not to process the sample. If no action is taken, the lab processes the sample after the 14-day hold and uploads the results into SimpleLab’s cloud-based portal.
The results are sent to leadCAST, which then notifies the resident via customized email from the utility. If an exceedance is detected, the utility and resident are alerted right away.

Flexibility for Different Sampling Scenarios

Customer-requested Sampling: leadCAST can allow customers to request kits if lead-related materials are identified on their property.
Post-replacement Sampling: For post-lead service line replacements, leadCAST can make sampling kits available to residents within the 3- to 6-month window, so that utilities do not need to manually track the time since replacement.

In the journey toward clean and safe drinking water, LCRI-approved sampling methods are transforming how we detect and address lead contamination. By improving sampling accuracy, increasing transparency, and engaging communities through clear communication, utilities can effectively tackle lead-related challenges. With methods such as the 5th-liter sampling coupled with streamlined sampling processes and advanced digital tools, utilities can certainly expedite compliance with the EPA regulations, protect public health, and build community trust, marking a significant step forward in ensuring safer water for all communities.

Wondering how to improve communications to comply with sampling requirements? Here’s your next read: Journey to Clean Water: Embracing Safety, Alerting the Community. To understand how you can secure solutions to unknowns LSLs, click here.