HomeMy WebLinkAboutMemo - Mail Packet - 1/25/2022 - Memorandum From Jill Oropeza Re: Fort Collins Utilities Activities Related To The New 2021 Lead And Copper Rule Revisions Requirements
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Utilities
Water Quality Services
4316 W. Laporte Ave.
Fort Collins, CO 80521
970-416-2529
V/TDD 711
utilities@fcgov.com
fcgov.com/utilities
M E M O R A N D U M
DATE: January 14, 2022
TO: Mayor Arndt and Councilmembers
FROM: Jill Oropeza, Director, Utilities Water Quality Services
THROUGH: Kelly DiMartino, Interim City Manager
Theresa Connor, Interim Utilities Executive Director
RE: Fort Collins Utilities Actions related to new 2021 EPA Lead and Copper Rule
Revisions requirements
Bottom Line
The Environmental Protection Agency (EPA) recently released an update to the Lead and
Copper Rule, known as the Lead and Copper Rule Revisions (LCRR).
Since the 1980s, Fort Collins Utilities (Utilities) has a longstanding practice of taking a
proactive approach to managing lead in drinking water supplies through water treatment,
testing and distribution system maintenance practices that provide customers a high level
of protection against lead.
The purpose of this memo is to outline the major new requirements and how Utilities will
attain compliance. There is no required action from Council; this memo is informational
only. Staff has been proactive in anticipation of the new requirements and received funding
for programs through the budgeting process. A memo on status of the Safe Water Action
Program (SWAP) will be provided in Q1 of 2022.
Background
Utilities staff have been proactively reviewing draft proposed revisions since 2020 and outlining
the necessary steps to maintain full compliance. On December 16, 2021, the EPA announced a
path forward on the implementation of the Lead and Copper Rule Revisions (LCRR) that was
adopted in January 2021 while also announcing the possibility for additional information or
requirements over the next three years. This, among other actions, shows strong
commitment to reducing exposure to lead. The remainder of this memo summarizes the six focus
areas in the LCRR and the actions that Utilities is undertaking to meet these new requirements as
they stand now.
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1. Complete an inventory of service lines
For water systems with lead water service lines, an inventory of all service lines and the materials
they are made of must be completed. For systems without lead service lines, an inventory statement
must be developed that supports the determination that there are no lead service lines.
Next Steps: Develop an inventory statement since we do not have full lead service lines. However,
as a data-driven organization, we will also be working on building an inventory of service line
materials.
2. Strengthen Drinking Water Treatment Requirements
The LCRR requires water systems with elevated lead levels in their residential tap samples (the
annual monitoring program) to reevaluate their existing approaches to keep metals like lead and
copper from corroding out of plumbing materials into drinking water. All Utilities compliance
s well
as the new proposed trigger level of 10 ppt, demonstrating the effectiveness of long-
standing existing corrosion control program. This information is reported to customers annually
through the Utilities Drinking Water Consumer Confidence Report.
Next Steps: No action. As long as lead levels in the Utilities annual monitoring program remain
below the level, Utilities will not be required to make changes in treatment process or
conduct a corrosion control treatment study.
3. Removing Lead
The LCRR requires water systems to develop a replacement plan for all lead service lines with the
rate of replacement being informed by residential lead testing levels.
Next Steps: No action. Utilities does not have any known lead service lines in the distribution
system and therefore a replacement plan is not required.
The LCRR also requires replacement of lead goosenecks when discovered during routine
maintenance.
Next Steps: Continue and accelerate. This requirement is consistent with decades-long
management practice. The removal of lead goosenecks will be accelerated through the Utilities
Safe Water Action Program (SWAP), which targets the replacement of galvanized service lines
and the removal of any associated lead goosenecks that are found in the process.
4. Increasing Sampling Reliability
The LCRR requires water systems to target residential tap sampling locations based on what is
expected to be the highest risk for possible lead. To-date, Utilities has been required to conduct
residential tap sampling at homes constructed between 1983 1986, due to the higher potential
presence of lead-tin solder in the premise plumbing of homes constructed during this time.
Next Steps: No action. These homes are still considered the highest priority for Utilities under the
new LCRR.
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5. Improving Risk Communication
The LCRR requires water systems to notify customers of an action level exceedance within 24
hours, a change from the old rule, under which water systems only had to provide tap sampling
results within 30 days, regardless of lead levels.
Next Steps: Utilities will immediately adopt the new practice of notifying customers within 24
hours of receiving residential lead test results greater than the EPA action level of 15 ppt. Utilities
will also continue the practice of working with homeowners to identify and fix any causes of
elevated lead in their tap water.
Under the LCRR, EPA is also requiring that systems make the lead service line inventory publicly
available and conduct regular outreach to homeowners with lead service lines.
Next Steps: service line inventory, and the inventory statement (Item 1 above), will be
made publicly available Because there are no known lead service lines in
our distribution system, direct homeowner outreach is not anticipated to be needed; however,
information about lead in drinking water and ways to reduc is provided on the
SWAP webpage.
6. Protecting Children in Schools
The LCRR includes a new requirement for water systems to sample drinking water at all schools
and childcare facilities served by the system starting in 2024. The water system is also required to
provide the lead test results and information about the actions the school or childcare facility can
take to reduce lead in the drinking water.
Next Steps: An inventory of schools and childcare facilities that are served by Utilities was
developed in 2021, and outreach and coordination efforts have begun with Poudre School District.
Utilities staff will intensify efforts in 2022 to collaboratively develop the testing program and
supporting educational materials to meet the new LCRR requirements.
CC: Liesel Hans, Utilities Interim Deputy Director, Water Resources and Treatment
Mark Kempton, Utilities Interim Deputy Director, Water Resources and Treatment