By Cheryl Green, PE, CSI  |   June 29th, 2016
Ohio EPA is currently developing new rules for community and nontransient noncommunity public water systems relative to lead and copper sampling, testing, reporting and notifications.  Ohio House Bill 512, signed by Governor Kasich on June 9, 2016, requires the Director of Ohio EPA to adopt new rules for lead and copper monitoring and related actions within 120 days after the effective date of the bill.  The Ohio EPA Early Stakeholder Outreach period for comments is in progress to solicit input prior to the issuance of Draft Rule(s).
The major provisions under H.B. 512 include the following requirements:
  • Establishes a new definition for lead-free piping, plumbing, fittings, fixtures, solder and flux.
  • Establishes new requirements for monitoring, reporting and public notification of lead and copper levels in drinking water for community and nontransient noncommunity public water supply systems.
  • Requires public water system operators to be trained in the identification of lead in drinking water, lead and copper sampling and testing, corrosion treatment, and lead.
  • Requires the Director of Ohio EPA to adopt rules within 120 days for the following:
    • Lead and copper monitoring schedules
    • Rapid reporting of lead concentrations to owners and users of individual taps
    • Notification requirements to all public water supply customers
    • Mapping of potential lead sources in distribution systems and buildings
    • Requirements for new or updated corrosion control plans
    • Establishment of a lead threshold for individual taps
    • Establishment of administrative penalties for failure of reporting and notifications.
  • Provides for financial assistance from the Drinking Water Assistance Fund to fulfill mapping and corrosion control requirements.
  • Provides for information on other funding sources for lead service line and school water-service fixture replacements.
Due to the potential health effects of lead and copper in drinking water, the increased sampling, stricter reporting schedules, and corrosion studies are a step in the right direction.  Because of the potentially labor-intensive task of mapping and identifying the potential system areas and buildings that may contain lead components, PWSs may find it necessary to seek professional assistance to meet proposed deadlines.  Hull has the water system expertise, sampling experience, and GIS mapping capabilities to provide timely assistance.  Our scientists and engineers are experienced in sampling, testing, and recommending treatment adjustments for desired water quality objectives, and can apply their skills to optimize corrosion control aspects of PWS finished water. 
Hull can also assist with compliance with the proposed reporting and notifications requirements. The development of a public notification protocol and procedures for communication with the regulatory agencies is highly encouraged in advance of an actual need for this process. A well-established communication protocol is imperative to ensure that, in the case of an exceedance, the public is well informed and understands the ramifications of the situation, while maintaining continued confidence in their PWS.  Hull has many years of experience in preparing and presenting public communications related to challenging public water issues, from participating in western Lake Erie harmful algal bloom communications to assisting with public meetings in eastern Ohio related to shale oil and gas water sourcing needs.
Hull will be following the rulemaking process and participating in the Ohio EPA Early Stakeholder Outreach, and will forward updates as appropriate.   
Cheryl Green, PE, CSI, Senior Project Manager
Cheryl has over 35 years of experience in civil and environmental engineering for public and private sector clients. Her environmental experience includes planning, design, and permitting of municipal sanitary sewers and wastewater treatment systems; collection and treatment facilities for industrial process wastewater and contaminated storm water; and various environmental facilities. Cheryl has designed many pumping and pressurized piping systems throughout her career, including sanitary lift stations and forcemains. Her civil site engineering experience includes industrial plant facilities design such as fire protection storage tanks and pumping systems, plant rail spurs, roadways and truck docks.
She holds a Bachelor in Civil Engineering from Ohio Northern University.
Your current rule requires us to check the plumbing in 20% of our user's houses, not just the supply water. We are a tiny water supply and this is costing us a lot of money for nothing. Your new rules are hurting us.
- Terry Capuano, PE
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