EPA Releases Revised 3Ts Manual

On October 1st, EPA released its revised “3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities” – a significant revision since the October 2006 version. This revised manual is linked to EPA’s new grant program for lead testing in schools and child care centers. This grant program was announced by EPA on September 21st, and the revised 3Ts will likely be a key component to states and school districts that are evaluating whether to submit a letter of notice of intent to participate in this grant program – noting that the deadline for submitting these letters to EPA is January 11, 2019.

For starters, EPA is now recommending a 2-step sampling protocol, with Step 1 being a 250-mL first-draw sample to identify potential lead in the fixture, and Step 2 (if the lead concentration from Step 1 is high) being a 250-mL flush sample (after a 30-second flush) to identify lead in the plumbing behind the fixture. Both samples should be taken after an 8 to 18-hour stagnation period.

The previous 20 ppb Action Level is not included in this version. From page 36 of the manual, “EPA encourages schools to prioritize remediation efforts based on lead sample results, and to use the steps in the toolkit to pinpoint lead sources to reduce their lead levels to the lowest possible concentrations.” There are likely some additional significant revisions that weren’t readily apparent from my quick scan.

EPA has a scheduled a webinar on the revised 3Ts for Thursday, October 25th, from 2:00-3:30 EDT. EPA is planning on hosting the webinar more than once for some flexibility in scheduling for those that are interested.