3Ts for Public Water Utilities
A TRAINING, TESTING, TAKING ACTION Approach
'"l "Mil I III 1*
What are the 3Ts?
The 3Ts toolkit was developed for schools and child care facilities to help them
implement a voluntary program for reducing lead in drinking water. It includes
a training, testing, and taking action approach.
How does it differ from sampling under the Lead and Copper Rule?
Lead and Copper Rule (LCR)
3Ts for Reducing Lead in Drinking Water
Required for: all community and non-transient non-
community water systems.
Voluntary Program: to assist schools with training,
testing, and taking action.
Sampling Protocol: The LCR takes a system-wide
approach. If the 90th percentile lead level concentration
of tap samples exceeds the 15 |ig/L action level, water
systems must take additional actions. The sampling
protocol under the LCR includes a 1-L first draw sample
after a stagnation period of 6 hours.
Sampling Protocol: Only schools and childcare facilities
that own and/or operate a public water system must
meet the requirements of the LCR. Under the 3Ts, EPA
recommends sampling and follow-up actions be taken at
each individual outlet. The 3Ts consists of a 2-step
sampling protocol, which includes two 250-mL samples:
(1) first draw after an 8 to 18 hour stagnation, and (2) a
flush sample after 30 seconds.
Follow-Up Actions: Water systems are required to
undertake treatment actions, depending upon system size
and corrosion control treatment status. These include
corrosion control, public education, water quality
monitoring, and lead service line replacement.
Follow-Up Actions: The initial sample and the follow-up
flush sample will help determine the source of the lead
(e.g., the fixture or behind the wall). Then remediation
measures can be implemented as appropriate to address
that outlet. This includes removing fixtures and
repairing/replacing water coolers, to minimize exposure.
Note: EPA recommends a smaller sample in the 3Ts because it is more effective at identifying the sources of lead at
an outlet because it represents a smaller section of plumbing. A 250-mL sample from a faucet would be less likely to
include portions of the plumbing behind the wall that the faucet is mounted on. There is no known safe level of lead
for children. EPA encourages schools to prioritize remediation efforts based on lead sample results and to use the
steps in the 3Ts to pinpoint potential lead sources to reduce their lead levels to the lowest possible concentrations.
Office of Water
EPA 815-F-18-002
October 2018
v>EPA
OFFICE OF GROUND WATER
AND DRINKING WATER

-------
How Can Water Systems Help?
Public water systems are critical partners in helping schools conduct testing for lead.
Although water systems may not be under a legal obligation to do so, assistance could be
provided through technical guidance, sampling and/or sharing in sampling costs, sample
analysis, assistance developing sampling plans and plumbing profiles, and support in
communicating with the school community.
Provide information that may be helpful: Schools and child care facilities might benefit from
viewing the results of the water system's required monitoring under the Lead and Copper Rule
and from having a copy of the latest consumer confidence report. Public water systems should
be able to tell schools whether lead monitoring is current, the monitoring results are below the
lead action level, and corrosion control treatment is provided.
Assist with determining if lead is present: Lead pipes within the school and lead service lines
can be replaced. Child care facilities in small buildings are at a higher likelihood of being served
by lead lines. Provide schools with information about whether there is a lead service line or
help identify the service line material.
Support the school in developing their sampling plan: Tell school officials whether you have
conducted lead monitoring at the school, and talk with them about factors that may indicate
whether lead could be a problem within building(s).
Collect and analyze samples: School personnel are unlikely to be familiar with sample
collection procedures. You can assist with sample collection or train school staff on how to
collect samples for lead testing. You can also help the school identify a certified laboratory for
sample analysis.
Help interpret results and determine potential lead sources: Solutions to lead problems
typically need to be made on an short-term and on a permanent basis. Schools and child care
facilities are encouraged to work closely with water professionals and the water system when
making repairs to ensure that the chosen remediation options will remove lead from the water
and to understand the benefits and considerations of each option.
Communicate with the school and the public: Some schools may be uncertain about
developing a 3Ts program due to concerns about how to communicate with and engage the
school community as a whole and the general public. You can provide expertise to help schools
develop communication materials and attend public meetings to answer questions, provide
information about lead in drinking water and encourage community partnerships to help
support the school throughout the process.
a
6
Resources:
View the full 3Ts Toolkit:
www.epa.gov/safgewater/3Ts
View Lead and Copper Rule Resources:
www.epa.gov/dwreginfo
Assisting Schools and Child Care Facilities
in Addressing Lead in Drinking Water:
http://www.awwa.0rg/portals/O/files/legreg/
documents/assistingschoolslead2005.pdf

-------