Lead Outreach Verification Effort (LOVE)
Background
In response to the events in Flint, Michigan, the Department of Public Health and Environment established the lead outreach and verification effort (LOVE) to improve implementation of the lead and copper rule in Colorado. The rule requires water suppliers to maintain a sampling pool of high-risk sites based on a tier schedule and materials evaluations that identify lead, copper, and galvanized steel within their distribution system. LOVE, which began in 2016, was designed to ensure compliance with these requirements.
The department set LOVE in motion with a letter in July 2016 to all community and non-transient non-community water systems required to comply with the rule. The department explained the events in Flint and the rationale for undertaking the LOVE process, ultimately requesting that water suppliers review and update their sampling pool based on the information compiled during completion of the materials evaluation form. The letter also included forms that described the tier schedule for sample sites and their corresponding characteristics, including construction date, interior plumbing materials, and service line composition.
Considerations
In the summer of 2018, the department began reviewing all lead and copper sample pools to determine if water suppliers were sampling at appropriate high-risk sites. Those reviews were based on whether or not water suppliers submitted a sufficient materials evaluation, verified their sample site materials, maintained the appropriate number of sites in their sampling pool, and actually sampled at the sites specified in their sample pool.
As water suppliers began reporting their materials evaluation forms and sample pool information, the department found that many water suppliers did not retain construction material records over the years and lacked a true understanding of the rule’s tier-level criteria for identifying high-risk sample sites. The department also found that many public water systems submitted inadequate materials evaluations or no materials evaluations at all, had not verified the plumbing materials at their sample sites, did not have enough sampling sites to satisfy monitoring requirements, or had sampled from sites that were not listed in their sampling pool. Throughout this time, we helped numerous public drinking water systems address these issues and better comply with the lead and copper rule via compliance assistance. We used the Lead and Copper Materials Evaluation & Sample Pools Fact Sheet to help us explain terminology and concepts.
Findings and Progress
Through the LOVE process, the department reviewed all 956 water systems in Colorado that are subject to the rule and offered assistance to those that had not met all requirements. Beginning in July 2019 (three years after LOVE launched), the department issued 146 violations for systems that remained out of compliance with the rule. To date, 75 of those open violations have been resolved and 71 remain outstanding. The department continues to work with those 71 systems to bring them into compliance with the rule. Systems that have already complied with the lead and copper rule requirements must make an ongoing effort to ensure that their sample pool always includes the highest risk sample sites within their distribution system and to sample from those highest risk locations. Doing so is critical to ensuring safe drinking water for the citizens of Colorado.➽ Jamie Duvall, B.S., and Alex Hawley, M.P.H., drinking water compliance assurance
