Voluntary School and Child Care Lead Testing and Reduction Grant Program, Implementation Document for States and Territories


xvEPA

Voluntary School and Child Care Lead
Testing & Reduction Grant Program

Implementation Document
for States and Territories

Office of Water (4606M)
EPA 815-B-23-009
July 2023

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SUMMARY

The Environmental Protection Agency (EPA) is providing funding to eligible states and territories for participation
in the Voluntary School and Child Care Lead Testing and Reduction Grant Program. States, territories, and tribes
will use this funding to assist local educational agencies in testing and reducing lead in drinking water at schools
and child care facilities.

This document contains the state Voluntary School and Child Care Lead Testing and Reduction Grant Program
implementation information for both internal and external stakeholders, including updates per the enactment of
the	also known as the Bipartisan

Infrastructure Law (BIL), to reduce lead exposure in drinking water at school and child care facilities through
remediation. This document aligns with the historic effort of thafl!Sl»laf!IH«f»lgnirK^	provide

resources to local, state and federal entities to accelerate reducing lead exposure to children while focusing on
low-income and often overlooked communities. It follows through on EPA's on-going commitment to protect
children's health and reduce children's exposure to lead in drinking water as described in the EPA's

It expands upon guidance and outreach to the

federal and non-federal signatories of

Reduce Lead Exposures and Disparities in U.S. Communities-

Memorandum Of Understanding
Drinking Water in Schools and Child Care Facilities

Strategy to
g Lead Levels in

Participating states shall ensure that each local educational agency that receives grant funds shall use the funds in
accordance with !a^5^irawliB?Bwl«3BBT51iilim>iBliiil^nii^uidance or applicable state regulations that are
not less stringent than the 3Ts guidance. Participants will make the lead test results publicly available and notify
parent, teacher, and employee organizations of the availability of the results.

Interested states and territories submit their notification of intent to participate (NOIP) in the grant program to
EPA. EPA will award funds with approved applications according to an allocation formula. All public materials for
the grant program are available

A separate document will be provided for tribal funding and is also located at
The entity "state(s)" used throughout this document implies states and U.S. territories

www.epa.aov/safewater/grants

------- TABLE OF CONTENTS 1. OVERVIEW 3 11. STATUTORY AUTHORITY 4 III, ELIGIBLE APPLICANTS 5 IV. NOTICE OF INTENT 6 V. ALLOCATION OF FUNDS 6 VI. APPLICATION PACKAGE AND SUBMISSION INFORMATION 7 VII. ELIGIBLE USES 7 VIII. USE OF FUND REQUIREMENTS 13 IX. AWARD ADMINISTRATION INFORMATION 14 RESOURCES 18 APPENDIX A: SUMMARY OF KEY WORK PLAN ELEMENTS 19 APPENDIX B: DECLINE FUNDING AND ADMINISTRATION TRANSFER 20 APPENDIX C: LEAD REMEDIATION ACTIONS AND ELIGIBILITY 21 APPENDIX D: EPA PROGRAM REVIEW ASSESSMENT CHECKLIST 25 V - *•' i, - « J" o « " *\

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I. OVERVIEW

This document describes the programmatic requirements applicable to ail grants to states, the District
of Columbia (DC), and U.S. territories awarded through this grant program1. Under the grant program,
"states" is defined by the Safe Drinking Water Act (SDWA). Consistent with this definition, within this
document, the term "state" will be used to describe the 50 states and the District of Columbia, the
Commonwealth of Puerto Rico, Guam, the U.S. Virgin Islands, American Samoa, and the Commonwealth
of the Northern Mariana Islands.

Requirements for tribal grants are detailed in a separate guidance memo available at:

https://www.epa.gov/tribaldrinkingwater/wiin-act-section-2107-lead-testing-school-and-child-care-
program-drinking-water. All projects funded with Voluntary School and Child Care Lead Testing and
Reduction Grant Program funds must meet all eligibility and funding requirements outlined in this
document. Grant recipients must also comply with 2 CFR Part 200, terms and conditions under the
grant, and any other federal laws.

This document provides information on how EPA intends to implement and manage the state Voluntary
School and Child Care Lead Testing and Reduction Grant Program (the grant program). Designed to
support reducing lead exposure to children, who are the most vulnerable population, the objective of
the grant program is to support lead testing and reduction activities in drinking water at schools and
child care facilities. This document provides eligible recipients an explanation of the implementation
process and provides eligible recipients with direction on the process for applying for grant funding, in
addition to program requirements and restrictions. Grantees shall follow the framework for grants
management, requirements, and reporting using the Uniform Grants Guidance (UGG) under 2 CFR Part
200. Grantees are encouraged to communicate and collaborate with the Agency regularly to discuss any
challenges or questions that may transpire as they develop their respective work plans, budget
narratives, and/or implementation processes.

Some of the statutory provisions described in this document contain legally binding requirements.
However, this document does not substitute for those provisions, regulations, or the binding terms and
conditions of a grant.

1 For purposes of this program, the term "State" includes, in addition to the several states, only the District of Columbia, the
Commonwealth of Puerto Rico, Guam, the U.S. Virgin Islands, American Samoa, and the Commonwealth of the Northern Mariana Islands.
42 U.S.C. §300f (13)(A)

SDWA section 1464(d) - Implementation Document for States and Territories

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II. STATUTORY AUTHORITY

Are private and charter schools eligible
beneficiaries of the grant?

Section 1464(d) of the Safe Drinking Water Act
(SDWA), as amended by section 2107 of the 2016
Water Infrastructure Improvements for the Nation
Act (WHIM), section 2006 of the 2018 America's Water
Infrastructure Act (AWIA), and by section 50110 of
the 2021 Infrastructure Investment and Job Act (IIJA),
authorizes EPA to award grants to states to assist
local educational agencies to test and remediate lead
in drinking water at schools or local educational
agencies and child care programs. SDWA section
1464(d)(1) defines child care programs and local
educational agencies as:

(A)	Child Care Program- The term 'child care program'
has the meaning given the term 'early childhood
education program' in section 103(8) of the
Higher Education Act of 1965 (20 U.S.C. 1003(8)).

(B)	Local Educational Agency- The term 'local
educational agency' means:

(i)	a local educational agency (as defined in
section 8101 of Elementary and Secondary
Education Act of 1965 (20 U.S.C. 7801));

(ii)	a tribal education agency (as defined in
section 3 of the National Environmental
Education Act (20 U.S.C. 5502)); and

(Hi) a person that owns or operates a child care
program facility.

The term "local educational agency" (LEA) as
defined in section 8101 of Elementary and
Secondary Education Act of 1965 (20 U.S.C. 7801)
means a "public board of education or other public
authority legally constituted within a state to
...[administer]... a service for, public elementary
schools or secondary schools in a city, county,
township, school district, or other political
subdivision of a State, or...recognized in a state as
an administrative agency for its public elementary
schools or secondary schools." For example, this
would include public school districts, Educational
Service Agencies, such as Boards of Cooperative
Educational Services (BOCES), Intermediate
Educational Units, and those charter schools that
operate as LEAs under state law.

States can use grant funding to test and remediate
lead in drinking water at public and/or at private
child care facilities which serve low-income
communities; however, the emphasis remains on
public institutions.

Section 50110 of the IIJA, P.L.117-58, November 15, 2021, also known as BIL, amended SDWA section
1464(d) to expand the eligible activities and the eligible applicants under this grant program. The IIJA
amendments to SDWA section 1464(d), now authorize funds in the Voluntary Schools and Child Care Lead
Testing Grant Program to be used for voluntary lead testing, or compliance monitoring, and for lead
remediation as described below:

[T]he administrator shall. . .make grants available to—(i) "States to assist local educational agencies,
public water systems that serve schools and child care programs under the jurisdiction of those local
educational agencies, and qualified non-profit organizations in voluntary testing or compliance
monitoring for and remediation of lead contamination in drinking water at schools and child care
programs under the jurisdiction of those local educational agencies;"

In other words, states are now authorized to use grant program funds to include not only voluntary lead
testing, but also compliance monitoring and remediation efforts. States should develop a comprehensive
plan on the use of the funding. States are encouraged to align grant supported voluntary lead sampling,
compliance monitoring, and remediation efforts in accordance with state program(s) to improve
collaborations and to enhance program implementation efforts.

SDWA section 1464(d) - Implementation Document for States and Territories

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States should fully describe the planned activities in their application. See section VI Application Package
and Submission Information,

Lead remediation efforts may include but are not limited to the removal, installation, and replacement of
internal plumbing, faucets, water fountains, water filler stations, Point-of-Use (POU) devices, lead service
lines or lead connectors, and other lead-free apparatus related to drinking water. See Appendix C for
further details on lead remediation activities and eligibilities.

. ELIGIBLE APPLICANTS

EPA has chosen, under the authority provided in SDWA section 1464(d), to provide funds
noncompetitively under the grant program to "states" as defined by the Safe Drinking Water Act. This
includes the 50 states, the District of Columbia, the Commonwealth of Puerto Rico, the U.S. Virgin
Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands.

Written correspondence from the state governor or designee to the Administrator of EPA is required to
certify a state agency as the recipient of funds who has the legal and administrative authority to enter
into a grant or cooperative agreement with EPA. Upon receipt, EPA will consider the state agency
designated by the governor, the lead agency for the state for the purposes of this grant program.

"The Administrator may make a grant for the voluntary testing or compliance monitoring for or
remediation of lead contamination described in subparagraph (A) directly available to— (i) any local
educational agency described in clause (i) or (Hi) of paragraph (1)(B) located in a State that does not
participate in the voluntary grant program established under subparagraph (A); or (ii) any local
educational agency described in clause (ii) of paragraph (1)(B); (Hi) any public water system that is
located in a State that does not participate in the voluntary grant program established under
subparagraph (A) that—

(I)	assists schools or child care programs in lead testing;

(II)	assists schools or child care programs with compliance monitoring;

(III)	assists schools with carrying out projects to remediate lead contamination in drinking
water; or

(IV)	provides technical assistance to schools or child care programs in carrying out lead
testing; or

(iv) a qualified non-profit organization, as determined by the Administrator "

SDWA section 1464(d) - Implementation Document for States and Territories

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IV. NOTICE OF INTENT

States that want to receive Voluntary School and Child Care Lead Testing and Reduction Grant Program
funding must submit a Notice of intent to Participate (NOIP) indicating the lead agency charged with the
state's oversight and responsibility for receipt and actions pertaining to the grant program.

A. Notice of Intent to Participate States and territories must submit a NOIP to initiate
participation in the grant program.

B. Submission of the NOIF The NOIP can be submitted by email to
WIINDrinkingWaterGrants(5)epa.gov. The NOIP must be from an official within the governor's
office, the director of the designated agency, or other authorized officials.

C. Review of the NOIP: EPA will forward the NOIPs to the appropriate EPA Regional Office for
review. Regions will work with the states as necessary to resolve any identified issues.

States that submitted a NOIP for the initial funding request must still confirm participation in the grant
program. This is subject to funding availability and to the extent EPA chooses to administer the program.
See Appendix B for further details if a state decides to decline funding or transfer administration.

V. ALLOCATION OF FUNDS

A. Allocation Formula Under the Voluntary School and Child Care Lead Testing and Reduction
Grant Program, EPA plans to allocate funds to eligible states and territories based on an
algorithmic formula that includes factors for population, low-income, and lead exposure risk.
No more than 4 percent of grant funds accepted by an eligible entity may be used to pay the
administrative costs of carrying out the grant2. EPA has allocated approximately 6.44 percent of
the appropriation for this grant program to aid tribal educational agencies. In the initial notice
of allocations EPA assumes that all 50 states, the District of Columbia, and the five qualifying
territories will participate in the grant program. If fewer than all states submit a NOIP, the
formula will be applied to any remaining funds, and these funds will be reallocated to all eligible
participants. States that decline to participate will not be eligible to receive any reallocated
funds for that year. There is no match requirement for this program.

B. Allocation Notification After receiving ail NOIP's, EPA will calculate the final allocations, and
EPA Regions will notify state and territory contacts via e-mail. Each state and territory must
then submit a work plan and budget narrative to their EPA Regional contact for review. EPA will
review the work plan and budget narrative and provide comments so that the state or territory
can correct any issues before submitting their complete application through Grants.gov.

2 Sec. 300j-24, subsec, C, part 5. Limitation on use of funds.

SDWA section 1464(d) - Implementation Document for States and Territories

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VI. APPLICATION PACKAGE AND SUBMISSION INFORMATION

A.	Content of Application Package The application package will include all the following materials:

a.	Standard Form (SF) 424 Application for Federal Assistance

b.	Standard Form (SF) 424A Budget Information

1. Applicants are to characterize costs for construction contractors as "Construction" and
costs for architectural and engineering services as "Contractual

c.	Key Contacts Form

d.	EPA Form 4700-4, Pre-award Compliance Review

e.	Project Narrative Attachment Form, An optional sample is available at
www.epa.gov/safewater/grants to prepare the Work Plan and Budget Narrative.

B.	Grants.gov Application Instructions

a.	Your organization's authorized official representative (AOR) must submit your complete
application package electronically to EPA through Grants.gov.

b.	Follow the instructions available on Grants.gov to submit an application package
through Grants.gov. The application package contains the required forms listed above.

1.	Go to Grants.gov

2.	Search by Funding Opportunity Number: EPA-CEP-02

3.	From the list of Opportunity Package(s) currently available, click on the "Apply" link
corresponding with Assistance Listing #: 66.444

VII. ELIGIBLE USES

SDWA section 1464(d), as amended by section 50110 of
IIJA, allows states to use grant funds provided under the
Voluntary School and Child Care Lead Testing and
Reduction Grant Program to assist local educational
agencies (LEAs), public water systems (PWSs), and
qualified non-profit organizations, in voluntary lead
testing or compliance monitoring, and lead remediation
in drinking water at schools and child care facilities. The
state's work plan must describe how the state will
ensure that projects selected for funding support the
programmatic priorities listed below.

The funds are subject to the following:

A. Project and Budget Period: EPA anticipates that funds
awarded under this grant program will have a two-year
project period. The project period starts once funds are
awarded to the state.

SDWA section 1464(d) - Implementation Document for States and Territories

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B. Project Eligibility Activities for lead testing and remediation in drinking water in schools and child care
facilities should be done in accordance with the following:

•	EPA's 37s for Reducing Lead in Drinking Water guidance or

•	Applicable state regulations or guidance regarding reducing lead in drinking water in schools and
child care facilities that are not less stringent than EPA's 3Ts.

C. Notification: SDWA section 1464(d)(6) requires
that any recipient3 of grant funds must publicly
make available test results and notify parents,
teachers, and employee organizations of the
availability of the results. Specifically, grant
recipients must:

Potential Child Care Program Collaboration

EPA encourages states to engage with the
following state child care organizations as a
resource in reaching out to and prioritizing child
care facilities for testing, compliance monitoring,
and lead remediation:

Child Care Licensing Agencies
Child Care Resource Referral Agency
Child Care Development Fund
Administration

•	Make available a copy of the results of any
testing for lead in drinking water carried
out using grant funds, as soon as
practicable but no later than 30 days after
receiving the results, if applicable, in the
school and child care program
administration offices and, to the extent
practicable, on the internet website of the

local educational agency for inspection by the public; and

•	Notify parent, teacher, and employee organizations of the availability of the results no later than 30
days after receiving the results.

•	All results should be made publicly available and communicated to the impacted communities as
soon as practical but no later than 30 days after receiving the results. Methods of communication
may include publication in local newspaper(s), posting in public places, or mail or other direct
delivery to the impacted communities (e.g., email to facility employees, parents, students). A
record of these items may be requested by EPA during the term of the grant and project.

•	If hardcopy results are made available for disclosure to the community impacted by testing, said
copy of notification should be documented by the recipient of the grant funding (e.g., the state
agency) - including information regarding the date and location in which the information was
disclosed publicly - if it is not made readily available digitally via URL link or website address. See
communication templates in Module 1 of the 3Ts Toolkit.

D. SDWA section 1464(d) Programmatic Objectives: The principal objective of the assistance to be
awarded under this program is to provide grants to states to help LEAs to perform voluntary lead testing
and remediation in drinking water, utilizing EPA's 3Tsfor Reducing Lead in Drinking Water guidance or
applicable state regulations or guidance regarding reducing lead in drinking water in schools and child care
facilities that are not less stringent.

3 The recipient is the state agency which is responsible for meeting all the requirements in this section. Subrecipients may be subject to
the same federal requirements as the state recipient, but the state recipient is ultimately responsible for monitoring the activities of the
subrecipient, as necessary, to ensure compliance with program requirements and terms and conditions. See 2 CFR 200.332(d).

SDWA section 1464(d) - Implementation Document for States and Territories

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The objective of the grant program is to:

(1)	Reduce children's exposure to lead in drinking water;

(2)	Help states target funding toward schools and child care programs unable to pay for testing;

(3)	Utilize the 3Ts model (or another state guidance no less stringent) to establish best practices for
a lead in drinking water prevention program;

(4)	Foster sustainable partnerships at the state and local level to allow for more efficient use of
existing resources and exchange of information among experts in various educational and health
sectors; and

(5)	Enhance community, parent, and teacher cooperation and trust.

Project work plans should detail how the state will expend grant funds in accordance with

•	EPA's 3Ts for Reducing Lead in Drinking Water guidance; or

•	Applicable state regulations or guidance regarding reducing lead in drinking water in schools and
child care facilities that are not less stringent than the 3Ts guidance.

If the grant recipient intends to use state regulations or guidance other than EPA's 3Ts document, the
grantee must demonstrate that the state program or regulation is no less stringent than the following
elements outlined in the 3Ts manual. This should be described in the grant recipient's work plan:

1.	Communication - must be integrated throughout the development and implementation of
lead testing in drinking water in schools and child care facilities. Communication should
establish key partnerships to support the program and keep the public informed. Recipient
work plans should include a timeframe pertaining to public notification of testing results. Make
available a copy of the results of any lead testing in drinking water carried out using grant funds,
as soon as practicable but within 30 days of receiving the results. Notify impacted communities
of the availability of results no later than 30 days after receiving the results. If hardcopy results
are made available for disclosure to the communities impacted by testing, said copy of
notification should be provided to the recipient of the grant funding - including information
regarding the date and location in which the information was disclosed publicly - if it is not
made readily available digitally via URL link or website address.

2.	Training - for school and child care program officials to raise awareness of the potential
occurrences, causes, and health effects of lead in drinking water. The program should utilize
partnerships to develop program plans and assign responsibilities that provide the framework
for an effective program. Training may include partnering (or developing a new technical
assistance team) with experienced networks to provide technical assistance that achieves the
3Ts testing objectives. It may indicate what the process is to train and build a capable workforce
that can execute the testing and the various steps in the 3T's process to move towards the
testing objectives.

3.	Testing - of drinking water in schools and child care facilities to identify potential lead
problems. Sampling protocols should utilize existing state guidelines for testing or, when state
guidelines are not established, the 3Ts guidance.

SDWA section 1464(d) - Implementation Document for States and Territories

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Children six years and younger are most
susceptible to the effects of lead

4. Taking Action-by developing and
implementing a plan to reduce lead in
drinking water, including plans to support
schools in remediation actions, including
maintaining any installed POU devices,
and by communicating remediation Lead is particularly dangerous to children

actions to parents, staff, and the larger because their growing bodies absorb more

school and child care program lead than adults and their brains and nervous

community systems are more sensitive to the damaging

effects of lead.

To learn more about these elements, please visit

www.epa.gov/safewater/3Ts.

To learn more about lead visit:

http://www.epa.gov/ground-water-and-

, . r drinking-water/basic-information-about-lead-

E, Butid America, Buy America Act (BABA) As part of —:——=

the IIJA, BABA was enacted, which includes
domestic preference requirements for Federal

financial assistance programs for infrastructure, as defined by BABA. See Sections 70914 and 70912 of
IIJA, P.L. 117-58. Recipients should be aware that to the extent SDWA section 1464(d) projects or
activities require the construction of infrastructure, these domestic sourcing requirements for American
made iron, steel, and manufactured goods will apply. OMB has issued initial guidance on BABA at

https://www.whitehouse.gov/wp-content/uploads/2022/04/M-22-ll.pdf and is expected to issue
additional guidance as well. On November 3, 2022, the Office of Water (OW) released a memo on
Implementation Procedures with a collection of frequently asked questions and answers on
implementation procedures. For more information and resources, visit EPA's BABA landing page.

F. Project Funding Prioritization States must prioritize assistance with lead testing and remediation in
drinking water at schools and child care facilities that are in low-income areas pursuant to SDWA section
1464(d)(4). This may include public schools as well as child care facilities that are serving these
communities. This prioritization aligns with the statutory requirement under SDWA section 1464(d)(4),
as amended by section 2107 of the 2016 WIIN Act and section 2006 of the 2018 AWIA and section 50110
of the 2021 IIJA. It further aligns with the objectives of the Biden-Harris Lead Pipe and Paint Action Plan
as well. States must prioritize funding to target:

• Schools and child care programs in low-income areas (e.g., schools with at least 50% of the
children receiving free and reduced lunch, Head Start facilities, Early Head Start facilities,
or other appropriate criteria).

EPA recommends states also prioritize lead remediation activities, as outlined in Appendix C, including at
facilities such as:

• Elementary and child care programs that primarily care for children 6 years and under;

• Older facilities more likely to contain lead plumbing; schools and child care facilities built
before 1988 are more likely to have lead pipes, fixtures, and solder; and

• Sustainable, historical buildings that may be used as child program facilities in the future.

If resources are available to a state or LEA from any other federal funds, agency, a state, or a private
foundation for lead testing or remediating lead in drinking water, the state or LEA must demonstrate
that the funds provided from SDWA section 1464(d) grant will not displace those resources. Grant
funding can be used to create a lead testing and remediation project or supplement and enhance
existing state funding or other resources.

SDWA section 1464(d) - Implementation Document for States and Territories

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G. EPA Strategic Plan Linkage and Anticipated Outputs/Outcomes

Pursuant to Section 6a of EPA Order 5700.7, "Environmental Results under EPA Assistance Agreements,"
recipients' work plans must link proposed assistance agreements with EPA's Strategic Plan. EPA also
requires that grant applicants adequately describe environmental outputs and outcomes to be achieved
under assistance agreements (see EPA Order 5700.7, Environmental Results under Assistance
Agreements, for additional information, visit: www.epa.gov/sites/production/files/2015-
03/documents/epa order 5700 7al.pdf)

Linkage to EPA Strategic Plar The activities to be funded under this announcement support the EPA's
FY 2022-2026 Strategic Plan. Awards made under this announcement will support Goal 5: Ensure Clean
and Safe Water for All Communities, Objective 5.1: Ensure Safe Drinking Water and Reliable Water
Infrastructure: protect public health from the risk of exposure to regulated and emerging contaminants
in drinking and source waters by improving the reliability, accessibility, and resilience of the nation's
water infrastructure to reduce the impacts of climate change, structural deterioration, and cyber
threats. Applicants must explain in their work plan how their project will further this goal and objective.

Applicants must include specific statements in the work plan describing the environmental results of the
proposed project in terms of well-defined outputs and, to the maximum extent practicable, well-
defined outcomes that will demonstrate how the project will contribute to the priorities described
above. Specifically, the proposed activities must assist schools and child care programs to test and
remediate lead in drinking water, in accordance with EPA's 3Ts for Reducing Lead in Drinking Water
guidance or applicable state regulations or guidance regarding reducing lead in drinking water in schools
and child care facilities that are not less stringent.

Outputs: The term "output" means an environmental activity, effort, and/or associated work product
related to an environmental goal and objective that will be produced or provided over a period of time
or by a specified date. Outputs may be quantitative or qualitative but must be measurable during an
assistance agreement funding period.

Expected outputs from the projects to be funded under this announcement include, but are not limited

to:

•	Development of LEA and state lead testing and remediation plans for drinking water in
schools and child care facilities, and development of a management strategy that supports a
robust training, testing, monitoring, communication, remediation, and maintenance plan
protecting children from lead exposure now and in the future.

•	Widespread use of the EPA's 3Ts for Reducing Lead in Drinking Water as guidance in
establishing implementation of the state program and/or to use to align procedures in pre-
existing state programs.

•	Plans to prioritize lead testing and remediation to target vulnerable communities and
populations. This includes schools and child care programs in low-income areas (e.g., schools
with at least 50% of the children receiving free and reduced lunch, Head Start and Early Head
Start facilities); elementary and child care programs that primarily care for children 6 years and
under; and older facilities that are more likely to contain lead plumbing. Schools and child care
facilities built before 1988 are more likely to have lead pipes, fixtures, and solder.

•	Public availability of results of any lead testing conducted in school and child care facility
carried out using grant funds within 30 days of receiving results, if applicable, in the school or
child care facility administration offices and, to the extent practicable, on the internet website
for inspection by the public; and notify parent, teacher, and employee organizations of the
availability of the results.

SDWA section 1464(d) - Implementation Document for States and Territories

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• Reduction of lead sources (e.g., fixtures and iead plumbing) in drinking water in school and
child care facilities.

• Establish a memorandum of understanding/memorandum of agreement (MOU/MOA), or
partnership, and letters of support with state and local agencies and nongovernmental
organizations that support schools and child care programs (e.g., an MOU between the state
education, health and environment agencies, state Child Care Licensing Agency, Child Care
Resource Referral Agency, and Child Care Development Fund Administrators). Partnership
agreements to encourage collaboration and efficient use of resources, as well as coordination
of technical assistance, training, and mitigation solutions.

Outcomes: The term "outcome" means the result, effect, or consequence that will occur from carrying
out an environmental program or activity that is related to an environmental or programmatic goal or
objective. Outcomes may be qualitative and environmental, behavioral, health-related, or
programmatic in nature, but must also be quantitative. They may not necessarily be achievable within
an assistance agreement funding period.

Expected outcomes from the projects to be funded under this announcement include, but are not
limited to:

• Schools or child care programs, previously unable to pay for testing or remediation, implement
a testing program and/or mitigate lead exposure by utilizing the 3Ts toolkit to determine the
best action to take for remediation.

• Reduce children's exposure to lead in drinking water.

• Improve knowledge of school and child care program staff about lead in drinking water and other
environmental harms.

• Develop a regular lead testing and remediation program at schools and child care facilities.

• Improve water quality at schools and child care facilities.

• Establish routine best practices at schools and child care facilities such as those outlined in the
3Ts toolkit.

• Reduce the number of lead sources in drinking water at schools and child care facilities.

Other potential outcomes may include, but are not limited to:

• Foster sustainable partnerships at the state and local level to exchange information among
experts in various areas of the school, child care, utility, and health sectors to reduce lead
exposure.

• Enhance community, parent, and teacher trust.

• Improve public knowledge on the health effects of lead in drinking water.

• Enhance school and child care facility building functions and sustainability.

SDWA section 1464(d) - Implementation Document for States and Territories

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VIII. USE OF FUND REQUIREMENTS

The budget narrative must detail funding expenditures that demonstrate adherence to the following:

A.	Federal Matching Funds No funds awarded under the grant program shall be used for matching
funds for other federal grants unless expressly authorized by statute.

B.	Administrative Costs Expense Cap No more than 4 percent of the state's total award may be used
to cover administrative type costs (e.g., record keeping, reporting, personnel, benefits, travel, and
office supplies).

C.	Expenses Incurred Prior to the Project Period: The allowability of pre-award costs are governed by
2 CFR §200.458 and 2 CFR §1500.9. Pre-award costs are those incurred prior to the effective date of
the Federal award directly pursuant to the negotiation and in anticipation of the Federal award
where such costs are necessary for efficient and timely performance of the scope of work. Such
costs are allowable only to the extent that they would have been allowable if incurred after the
date of the Federal award and only with the written approval of the Federal awarding agency. EPA
defines pre-award costs as costs incurred prior to the award date, but on or after the start date of
the project/budget period. Under EPA's interpretation of 2 CFR 200.309, all eligible costs must be
incurred during the budget/project period as defined by the start and end date shown on the grant
award to receive EPA approval. This policy is implemented in a grant-specific Term and Condition
entitled "Pre-award Costs." All costs incurred before EPA makes the award are at the recipient's
risk. EPA is under no obligation to reimburse such costs if for any reason the recipient does not
receive a federal award or if the Federal award is less than anticipated and inadequate to cover
such costs.

D.	Reimbursements: No funds awarded under this grant shall be used for reimbursement of previous
testing/remediation efforts prior to the implementation of the grant program.

I Cannot Displace Existing Funds: SDWA section 1464(d) requires that if resources are available to a
state or local educational agency from any other federal agency, state, or private foundation for
lead testing and/or remediation in drinking water, the state, or local educational agency must
demonstrate that the funds provided from SDWA section 1464(d) grant wiii not displace those
resources.

F In-kind Assistance: At the request of a recipient, and if EPA agrees, an EPA award, may include in-
kind assistance provided by EPA (including contractor support and purchases or leases of
equipment or purchases of supplies), or EPA personnel under Intergovernmental Personnel Act
assignments or Interagency Agreements. In-kind assistance that EPA provides is different than in-
kind contributions an applicant contributes or obtains from third parties for the purposes of
meeting a cost-share requirement.

•	Any cost sharing requirements apply to the amount of the EPA in-kind assistance in
addition to the EPA funds. Also, applicants may not count the amount of EPA in-kind
assistance towards their cost-share.

•	An applicant must acknowledge the amount and purpose of the in-kind assistance it
anticipates including as towards meeting a cost-share requirement must be necessary
and reasonable, allowable, allocable, and eligible as discussed earlier (as outlined in the
Uniform Grant Guidance (UGG)). Costs included in an EPA agreement may not be
charged to any other EPA agreement, financial assistance agreement with another

SDWA section 1464(d) - Implementation Document for States and Territories

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Federal agency, or included in your indirect cost rate to qualify as cost-share.

• An EPA award, at the Agency's discretion, may include in-kind assistance provided by
EPA contracts (including purchases or leases of equipment or purchases of supplies),
personnel under Intergovernmental Personnel Act assignments or Interagency
Agreements.

• In-kind assistance that EPA provides is different than in-kind contributions a recipient
obtains from third parties for the purposes of meeting a cost-share requirement.

• Agency policies for providing in-kind assistance instead of funds are set forth in EPA
Order 5700.1. A recipient may request in-kind assistance or EPA may decide to offer that
assistance in lieu of direct financial assistance.

• These costs must be assigned to the appropriate cost category. For example, if EPA
purchases equipment that is delivered to a recipient as EPA in-kind assistance the cost
for those items would be placed in the equipment category. On the other hand, if EPA
provides in-kind technical services through an EPA contractor, then costs would be
placed in the contractual category. Only authorized EPA personnel may assign tasks to
EPA contractors.

• Project officers (POs) must provide an appropriate justification demonstrating the cost-
effectiveness and/or expediency for the federal government to procure the requested
support. POs may request that recipients provide information to support this
determination.

IX. AWARD ADMINISTRATION INFORMATION

A. 2 CFR Part 200 and 2 CFR Part 1500: The requirements of 2 CFR Part 200 (OMB Uniform Grant Guidance)
and 2 CFR Part 1500 (EPA Uniform Administrative Requirements, Cost Principles, and Audit Requirements
for Federal Awards) apply to this grant funding.

B. Terms and Conditions: General administrative and programmatic terms and conditions applicable to
EPA assistance agreements under this program may be viewed at: www.epa.gov/grants/grant-terms-
and-conditions EPA Headquarters will provide EPA Regions with a list of terms and conditions that wili
also apply to the grant program. EPA Regional teams will ensure that ali applicable terms and conditions
are included.

C. Quality Assurance Project Plan (QAPP): Awards funded under this program will include the collection of
environmental data and will require the development of a QAPP- The structure of the QAPP is intended to
step through the thought process of planning a project, as well as to provide a framework for documenting
the plan. A QAPP is prepared as part of the project planning process and should be completed and
approved before data collection is started. For more information, visit: www.epa.gov/qualitv/qualitv-
assurance-proiect-plan-development-tool. The QAPP can and should be updated with changes on the
project plan or personnel that come up during the project period.

D. Funding to Other State Agencies EPA's general policy, based on the definitions of the terms "Non-
federal entity" (2 CFR §200.1), "Pass-through entity (2 CFR §200.1) "Recipient" (2 CFR §200.1) and "State"
(2 CFR §200.1), is that the state itself is the legal entity that receives EPA funds even if one particular
component of the state is named in the assistance agreement as the recipient. Transfers of EPA funds

SDWA section 1464(d) - Implementation Document for States and Territories

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between state agencies to perform a particular financial assistance agreement would, therefore, be
governed by state law. Additionally, 2 CFR §200.417 "Interagency Services" contemplates situations in
which one agency provides services to another agency within the same unit of government as a direct cost
of performing the EPA assistance agreement.

If using interagency service agreements between state agencies under 2 CFR §200.417, the expenditures
the state agency makes to carry out the Interagency Service Agreement should be shown in the
corresponding direct cost categories (Personnel, Travel, Contractual, etc.). If state law characterizes
agreements under which one state agency provides services to another state agency as a procurement
contract, then the costs would be placed in the contractual category. In interagency service situations, 2
CFR §200.417 provides the state may charge a pro-rated share of indirect costs for the service, or 10% of
the ". . .direct salary and wage cost of providing the service (excluding overtime, shift premiums, and fringe
benefits) may be used in lieu of determining the actual indirect costs of the service." Centralized services
included in central service cost allocation plans subject to Appendix V of 2 CFR Part 200 are accounted for
separately.

There may be situations in which state law provides that state agencies or instrumentalities are legally
separate for the purposes of financial transactions between them or when state financial management
policies for Federal assistance agreements require separate instruments for accounting purposes (e.g., due
to differences in indirect cost rates). In those situations, a state may characterize appropriate funding
transfers as subawards. Note, however, that if one state agency provides a subaward to another state
agency, the state agency acting as the pass-through entity must comply with applicable provisions of 2 CFR
Part 200 (including 2 CFR §200.331), the National Term and Condition for Subawards, and the EPA
Subaward Policy unless EPA provides an exception. Also, should a state choose to provide subawards, the
state can only provide subawards to LEAs as identified in SDWA section 1464(d)(1) and the awards must be
made consistent with 2 CFR Part 200 and EPA's subaward policy. The aggregate cost estimates for
subawards to other state agencies or instrumentalities should be included as line items in the "Other"
budget category. The link to the Subaward policy is www.epa.gov/grants/grants-policv-issuance-gpi-16-01-
epa-subaward- policv-epa-assistance-agreement-recipients.

More information about the Agency's National Term and Condition for Subawards under the UGG and EPA's
Subaward Policy can be found at: https://www.epa.gov/sites/default/files/2Q16-
02/documents/gmc subaward policy appendix b national t and c.pdf

E.	Procurements When procuring property and services under a Federal award, a state must follow the
same policies and procedures it uses for procurements from its non-Federal funds. The state will comply
with §200.323 Procurement of Recovered Materials and ensure that every purchase order or other contract
includes any clauses required by section §200.327 Contract Provisions. All other non-Federal entities,
including subrecipients of a state (other than another state agency), will follow §200.317 General
Procurement Standards through §200.327 Contract Provisions.

F.	Performance Partnership Grants: Funds awarded under this program are not eligible for inclusion
with the state's Performance Partnership Grants.

G.	Pubiic Notification: Not later than 60 days after the date of the award of a subaward by a state, the
state shali publish the following on the website of the state:

• For subawards provided to local educational agencies, the total number and dollar amount of
subawards.

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H.	Testing Results Notification Requirements: Eligible entities receiving grant funding will adhere to
the statutory requirements as noted in SDWA section 1464(d):

• "(B)(i) make available, if applicable, in the administrative offices and, to the extent practicable,
on the Internet website of the local educational agency for inspection by the public (including
teachers, other school personnel, and parents) a copy of the results of any voluntary testing for
lead contamination in school and child care program drinking water carried out using grant
funds under this subsection; and (ii) notify parent, teacher, and employee organizations of the
availability of the results..."

The grant requires using EPA's 3Ts for Reducing Lead in Drinking Water in Schools and Child Care
Facilities, or a process no less stringent. The 3Ts guidance provides for flexible and effective preparation
and coordination to deliver information swiftly, professionally, and consistently, which includes
reporting and recordkeeping. The process and the degree to which information is presented or
maintained, however, is at the discretion of the state (but no later than 30 days after receipt of test
results as outlined in the grant Terms and Conditions) and as approved by EPA via the award process.

I.	Reporting Elements:

Performance Reports - Content: In accordance with 2 CFR 200.329, the recipient agrees to submit
performance reports that include brief information on each of the following areas: 1) A comparison of
actual accomplishments to the outputs/outcomes established in the assistance agreement work plan for
the period; 2) The reasons why established outputs/outcomes were not met; and 3) Additional pertinent
information, including, when appropriate, analysis and explanation of cost overruns or high-unit costs.
Additionally, the recipient agrees to inform EPA as soon as problems, delays, or adverse conditions
which will materially impair the ability to meet the outputs/outcomes specified in the assistance
agreement work plan are known.

Performance Reports - Frequency: States agree to submit quarterly and annual performance reports
electronically to the EPA Project Officer. Quarterly reports are due within 30 days after the reporting
period and the annual reports are due each October 31st. The quarterly reporting periods are October -
December (Quarter 1), January - March (Quarter 2), April - June (Quarter 3), and July - September
(Quarter 4). Annual reporting periods are from October through September of each year. Recipients'
progress report submissions will be accepted via EPA's electronic Online Reporting Tool available at:
https://owsrf.epa.gov/ords/wiin2107/f?p=WIIN-2107.

Quarterly Reports: The quarterly report will reflect information pertaining to the state, the work
performed to meet the objectives of the program, and the grant activity during the period of
performance. Reporting must provide a comprehensive review of the amount of testing and
remediation activities performed; the total number of planned schools and/or child care facilities
included in the testing and remediation program; the number of schools and/or child care facilities that
completed lead testing and remediations; and the breakdown of financial and direct grant assistance
which subsidized the testing during the reporting cycle.

Participating states should coordinate with the EPA Regional Offices on reporting elements after
applications have been approved for awards. Recipients' progress report submissions will be accepted
via EPA's electronic Online Reporting Tool available at: https://owsrf.epa.gov/ords/wiin2107/f?p=WIIN-
2107. In accordance with 2 CFR 200.329, the recipient agrees to submit performance reports that include
brief information on each of the following areas: 1) A comparison of actual accomplishments to the
outputs/outcomes established in the assistance agreement work plan for the period; 2) The reasons why

SDWA section 1464(d) - Implementation Document for States and Territories

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established outputs/outcomes were not met; and 3) Additional pertinent information, including, when
appropriate, analysis and explanation of cost overruns or high-unit costs.

Annual Reports: The annual report will reflect the participating entity's comprehensive efforts toward
lead testing and remediation in schools and/or child care facilities over the course of the calendar year.
Recipients' progress report submissions will be accepted via EPA's electronic Online Reporting Tool
available at: https://owsrf.epa.gov/ords/wiin2107/f?p=WIIN-2107. In accordance with 2 CFR 200.329,
the recipient agrees to submit performance reports that include brief information on each of the
following areas: 1) A comparison of actual accomplishments to the outputs/outcomes established in the
assistance agreement work plan for the period; 2) The reasons why established outputs/outcomes were
not met; and 3) Additional pertinent information, including, when appropriate, analysis and explanation
of cost overruns or high-unit costs.

Final Reports: The state is required to submit a final report that includes the following: summary of the
project or activity, testing, and remediation benefits and other outputs and outcomes achieved, and
costs of the project or activity. The final report shall be submitted to EPA within 120 calendar days of
the project/budget period end date. An example guide of the details on reporting information is
available from the EPA. In accordance with 2 CFR 200.329, the recipient agrees to submit performance
reports that include brief information on each of the following areas: 1) A comparison of actual
accomplishments to the outputs/outcomes established in the assistance agreement work plan for the
period; 2) The reasons why established outputs/outcomes were not met; and 3) Additional pertinent
information, including, when appropriate, analysis and explanation of cost overruns or high-unit costs.

Annual Program Review: EPA oversees the financial and programmatic implementation of the Voluntary
School and Child Care Lead Testing and Reduction Grant Program. As part of its oversight role, the
Agency will review projects' goals and activities annually to evaluate efficiency, effectiveness, and
administration of the grant program and procedures in compliance with obligations under SDWA section
1464(d) and the Uniform Grant Guidance (2 CFR 200). Appendix D shows the Program Review
Assessment checklist that EPA anticipates using as part of the annual oversight review.

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SDWA section 1464(d) Voluntary School and Child Care Lead Testing and Reduction Grant Program FAQs
and Resources: https://www,epa.gov/dwcapacitv/wiin-grant-voluntarv-school-and-child-care-lead-
testing-and-reduction-grant-program

WIIN Grant Program Resources: www.epa.gov/safewater/grants

3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities:

www.epa.gov/safewater/3Ts

Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance Agreements:

www.epa.gov/grants/best-practice-guide-procuring-services-supplies-and-equipment-under-epa-
assistance

EPA Subaward Policy with attachments: www.epa.gov/grants/grants-policv-issuance-gpi-16-01-epa-
subaward-policv-epa-assistance-agreement-recipients

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APPENDIX A: SUMMARY OF KEY WORK PLAN ELEMENTS

SUMMARY STATEMENT
SCOPE OF WORK

A.	State Goals and Priorities

B.	Grant Program Implementation and Activities

i.	Activities using either EPA 3Ts or another protocol that is no less stringent

ii.	Communication

iii.	Training

iv.	Testing

v.	Taking Action

C.	Roles and Responsibilities

D.	Timeline and Milestones

E.	SDWA Grant Programmatic Priorities and EPA's Strategic Plan Linkage

The activities described in this work plan support the grant Programmatic Priorities and EPA's FY
2022-2026 Strategic Plan. Goal 5: Ensure Clean and Safe Water for All Communities, Objective
5.1: Ensure Safe Drinking Water and Reliable Water Infrastructure.

F.	Outputs and Outcomes

i.	Outputs: An environmental activity or effort> and/or associated work products that are
produced or provided over a specific period of time. Outputs may be quantitative or
qualitative but must be measurable during an assistance agreement funding period.

ii.	Outcomes: The result, effect, or consequence that will occur from carrying out an
environmental program or activity that is related to an environmental or programmatic
goal or objective. Outcomes may be environmentalbehavioral, health-related, or
programmatic in nature, must be quantitative, and may not necessarily be achievable
within an assistance agreement funding period. EPA encourages recipients to identify
outcomes wherever possible because they lead to environmental and/or public health
improvement more clearly than outputs.

G.	Budget Narrative

H.	APPENDIX: COLLABORATORS AND ASSOCIATES UNDER THIS PROGRAM (OPTIONAL)

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APPENDIX B: DECLINE FUNDING AND ADMINISTRATION TRANSFER

Once a new year's funding becomes available, states will have 120 days (from the date of the latest
allotment memo) to decline funding prior to releasing funds to participating entities. See the following for
guidance to decline funding.

I. Decline Funding Notifications The governor's office has been notified and chooses to decline funding.
A notice to decline funding needs to be sent to the EPA from the governor's administration office.

The governor's administration office sends out a notice to decline funding to the EPA Regional Office, which
will be used to notify EPA Headquarters, detailing:

1. Amount being declined

2. Reason for the decline

3. If applicable, how the state will apply for sequential funding

4. If applicable, the process if another state agency will take over grant implementation

II. Grant Program Administration Continuation After Decline

Respective states will continue the process of implementation through the respective state agency until
completion of program objectives; until all funds have been drawn. The state will coordinate and
communicate with EPA all of the implementation processes and actions that may impact the grant.

In the case where a state chooses to decline all subsequent funding and cannot continue to carry out and
implement the grant, if applicable, all agencies listed in the Notice of Intent to Participate (NOIP) need to be
notified. When applicable, all agencies listed in the NOIP will need to confirm the decline to carry out and
implement the grant program.

III. Administration Transfer: State agency transfer decisions are at the discretion of the state (not EPA).
The state should contact EPA for further details.

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APPENDIX C: LEAD REMEDIATION ACTIONS AND FUNDING ELIGIBILITY

This appendix outlines the lead remediation actions and potential activities for funding of the grant. Lead
remediation is the reduction of lead sources in drinking water through the removal, replacement, or new
installations of plumbing and associated services that affect human consumption. This includes but is not
limited to activities related to internal plumbing, faucets, water fountains, water filler stations, Point-of-
Use (POU) devices, lead service lines, and other lead-free apparatus related to drinking water.

I. Statutory Authority Section 50110 of IIJA, amended SDWA section 1464(d) to authorize the use of
funds in the Voluntary School and Child Care Lead Testing and Reduction Grant Program for lead
remediation and compliance monitoring in schools and child care facilities in addition to lead testing:

"States to assist local educational agencies, public water systems that serve schools and child care
programs under the jurisdiction of those local educational agencies, and qualified non-profit organizations
in voluntary testing or compliance monitoring for and remediation of lead contamination in drinking
water at schools and child care programs under the jurisdiction of those local educational agencies

Projects funded under this grant are required to be performed in accordance with EPA's 3Ts (Training,
Testing, and Taking Action) program approach or one as stringent for lead reduction and remediation in
drinking water in schools and child care facilities. Specific to funding remediation projects, the 3Ts
program recommends the following:

•	States should fund lead remediation efforts on each drinking water fixture with a detected lead
level.

•	States should assist local educational agencies and public water systems (PWSs) that serve
schools, child care programs, and qualified non-profit organizations participating in the grant
program to prioritize lead remediation efforts on elevated lead levels as defined by the testing
Program Remediation Trigger (PRT).

•	States are required to establish the PRT lead level in parts per billion under the grant program.
The PRT level is used to prioritize remediation activities in schools, child care facilities, and PWSs
under the jurisdiction of the LEAs that serve these facilities.

•	States should assist local educational agencies and PWSs as well as non-profit organizations
participating in the grant program to prioritize low-income areas with detected lead levels that
may fall below the PRT due to the many underlying factors that make these communities more
vulnerable.

o Contact the state programs at https://www.epa.gov/dwcapacity/wiin-2107-lead-testing-
school-and-child-care-program-drinking-water-state-grant-program.

States should also prioritize funding remediation activities at the following locations:

•	Elementary and child care programs that primarily care for children 6 years and under;

•	Older facilities more likely to contain lead plumbing; schools and child care facilities built before

1988 that are more likely to have lead pipes, fixtures, and solder; and

•	Sustainable, historical buildings that may be used as child care program facilities in the future.

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li. Lead Remediation Funding Eligibility: States may include eligible lead remediation activities in the
work plan and budget approved by EPA. Lead remediation activities included in the work plan need to
describe activities according to the 3Ts (or another program no less stringent) including the lead
remediation actions as well as the budget and maintenance plans for the activities. The breakdown on
funding usage is at the discretion of the state. If resources for lead testing and/or remediation are
available to a state or LEA from any other federal agency, a state, or a private foundation for testing
and/or lead remediation in drinking water, the state or local educational agency must demonstrate that
the funds provided from SDWA section 1464(d) grant will not replace those resources. Grant funding can
be used to create a new program or supplement and enhance existing state resources.

III. Eligible Uses: IDA was enacted on November 15, 2021; hence, expenditures for compliance and lead
remediation activities are eligible post November 15, 2021. All lead remediation actions eligible for
funding are to proceed after the presence of lead sources are identified and documented as according to
the grant project work plan. Potential lead remediation activities states may include in the work plan,
budget, and maintenance plans can include but are not limited to the installation of or removal and
replacement of the following:

•	Fixtures such as faucets and related components

•	Water fountains and related plumbing (e.g., fountain valve, bubbler, cooler tank)

•	Plumbing re-configuration (e.g., adding a bypass from the lead source)

•	Pipes/valves joint with lead solder

•	Removal and replacement of full lead service lines (LSL) including lead connector (e.g., lead
goosenecks, pigtails, etc.)

o To define a "lead service line" for the purpose of this document, EPA will use the Lead

and Copper Rule Revisions definition, which is, "...a service line made of lead, which
connects the water main to the building inlet. A lead service line may be owned by the
water system, owned by the property owner, or both. For the purposes of this subpart, a
galvanized service line is considered a lead service line if it ever was or is currently
downstream of any LSL or service line of unknown material. If the only lead piping serving
the home or building is a lead gooseneck, pigtail, or connector, and it is not a galvanized
service line that is considered an LSL the service line is not a lead service line."

o Lead goosenecks, pigtails, and connectors are eligible expenses under this grant, whether
standalone or connected to a lead service line.

•	Galvanized piping downstream of lead line

•	Filler stations with POU devices certified to remove lead

•	POU devices certified to remove lead

o Follow guidance for consumer selection of POU devices:

https://www.epa.gov/sites/default/files/2018-

12/documents/consumer tool for identifying drinking water filters certified to redu
ce lead.pdf

o EPA is not interpreting POU devices as "treatment facilities." If a facility meets the

definition of a "public water system" under SDWA section 1401 and meets all the criteria
for exclusion from the National Primary Drinking Water Regulations (NPDWRs) under
SDWA section 1411, the installation of POU devices at individual taps does not make the
facility a "treatment facility" under SDWA section 1411(1) and the facility is still excluded
from the requirements of the NPDWRs. Therefore, a school or child care facility that is
currently not a regulated PWS will not become regulated by installing POU devices if that
is the only change made by the school or child care facility. Section 1411 of SDWA says

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NPDWRs will not apply to an entity "which consists only of distribution and storage
facilities (and does not have any collection and treatment facilities)."

•	Other removal, replacements, and reduction of lead source activities in drinking water as
according to work plan

IV.	Maintenance Plan States are to ensure plans are in place for maintenance and continuation efforts of
lead remediation activities. Per EPA's 3Ts for Reducing Lead in Drinking Water, schools and child care
facilities should establish routine practices to reduce exposure to elevated lead levels and other
environmental hazards (e.g., bacteria).

If POU devices are to be installed in a school or child care facility, states are to ensure proper
maintenance plans are developed. The recipient should propose maintenance plans to replace filters
based on their projected use. The plan could include, for example, the manufacturer's usage instructions
for POU (and filter) operation and replacement. Maintenance plans should include but are not limited to
the following:

•	Maintenance personnel and replacement schedules (e.g., start and end periods of use)

•	Locations and time use periods (e.g., POU filters being installed for a fixed short time or long
extended periods)

V.	Ineligible Uses: Lead testing and/or remediation actions related to non-drinking water fixtures are not
eligible for funding. This could include lead testing, removal, installation, and/or replacement of fixtures
and plumbing immediately connected to the non-drinking water fixtures, which can include the following:

•	Utility faucets

•	Hose bibs

•	Sprinkler system

•	Lawn and utility hoses

•	Other water fixtures that are not used for human consumption

o Under SDWA, human consumption means drinking, bathing, showering, hand washing,
teeth brushing, food preparation, dishwashing, and maintaining oral hygiene

VI.	Field Scenarios on Eligible Use of Funds: The following are examples of field scenarios to illustrate
eligible projects that may receive funding for lead remediation activities.

Field Scenario 1 There is an internal lead pipe behind a building wall. To access the lead pipes, the
wall and surrounding area needs to be tested for lead paint and asbestos, in addition to removing the
wall. What activities under this scenario are eligible for Voluntary School and Child Care Lead Testing
and Reduction Grant Program funding?

The grant may cover the cost to test for asbestos and lead paint on the wall arid surrounding area
impacted which blocks access to remove the lead pipe. In addition, the funding may cover the lead
pipe replacement and the associated costs to reach the lead pipe, including the removal of walls and
removal of the asbestos.

Field Scenario 2 The school or child care facility has tested and demonstrated that several fixtures
and multiple internal plumbing components have elevated levels of lead. The school or child care
facility was unable to locate and shut off the water by the water valve. The school or child care
facility contracted a specialty plumber who was able to locate and shut off the water valve associated
with the plumbing and fixture. Is this service covered under the grant program?

Grant funds may cover the cost of plumbing services associated with locating and shutting off the
water valve.

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Field Scenario 3: The school or child care facility has tested and determined the source of lead is the
LSL leading from the main water line to the facility. Will the grant program cover the cost of replacing
the LSL?

Full LSL replacement is an eligible expense for the program grant funds including replacing the public
and private portions and any lead connectors such as goosenecks, pigtails, etc. Coordinate with your
state and local water utility to replace the entire LSL. To further support LSL replacement, EPA
provides funding to water utilities. More details at https://www.epa.aov/Qround-water-and-drinking-
water/lead-service-line-replacement.

Field Scenario 4: The school or child care facility would like to work with a contractor to create a
process to transfer results and create a database for the lead testing results and remediation actions.
Is this covered under the grant program?

Creating a database to manage lead testing results and remediation actions can be covered with
grant program funding.

Field Scenario 5: I understand that POU devices are an eligible expense under the expanded
remediation criteria for this grant program. Do they need to be owned and maintained by the school
or the PWS?

POU devices are an eligible expense under the Voluntary School and Child Care Lead Testing and
Reduction Grant Program. Funds are authorized to be used for voluntary lead testing or compliance
monitoring for and lead remediation. Lead remediation efforts may include but not be limited to the
removal and replacement of internal plumbing, faucets, water fountains, water filler stations, POU
devices, lead service lines or lead connectors, and other lead-free apparatus related to drinking water.

The responsibility for installing and maintaining the POU may vary depending on the agreement
between the grant recipient (e.g., state) arid the school or facility receiving the eligible projects or
activities related to the removal and replacement of internal plumbing, faucets, water fountains, lead
service lines or lead connectors, the installation of water filler stations, arid/or other lead-free
apparatus related to drinking water under the grant program.

Field Scenario 6: My school district has a lead issue and is interested in applying for the grant
funding. How can we apply?

EPA sends grant funding to designated state agencies to implement the Voluntary School and Child
Care Lead Testing and Reduction Grant Program. Contact your state agency to find out if the school
district is eligible by visiting: https://www.epa.gov/dwcapacity/voluntary-school-and-child-care-lead-
testing-and-reduction-state-grant-program-contacts.

For additional information regarding the Voluntary School and Child Care Lead Testing and Reduction
Grant Program, view FAQs and resources: https://www.epa.gov/dwcapacitv/wiin-grant-voluntary-
school-and-child-care-lead-testing-and-reduction-grant-program

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EPA will use the Program Review Assessment Checklist listed in Table 1 below to determine whether its grant
program is operating as intended. This assessment review is focused on the implementation of the program
and procedures in compliance with statutory and grant obligations, such as meeting grant objectives, project
deliverables, proper grant administration, and program statutory requirements.

States may consider developing a similar customized state program review assessment tool (i.e., Table 1: EPA
Program Review Assessment Checklist below) to evaluate internally whether the state is meeting grant
objectives.

Table 1. EPA Program Review Assessment Checklist

State Oversight Agency

Contact information

Reviewer information

Objectives/Grant

Reviewer Checks

Findings/

Follow-up

Requirements

Outcomes

Actions

Linkage to EPA
strategic plan

Determine if program fits within EPA's
Strategic Plan and produce appropriate
outputs and outcomes consistent with EPA
Order 5700.7 Al, Environmental Results under
EPA Assistance Agreements.

2 CFR Part 200
and 2 CFR Part

1500

requirements

Verify if program is meeting requirements of 2
CFR Part 200 (OMB Uniform Grant Guidance)
and 2 CFR Part 1500 (EPA Uniform
Administrative Requirements, Cost Principles,
and Audit Requirements for Federal Awards)
that apply to this grant funding.

Funding prioritization: Verify program

prioritization to low-income areas.

Is part or all of the program funding toward:

Schools and child care programs in low-

income areas (e.g., Schools with at least 50%

of the children receiving free and reduced

lunch, Head Start and Early Head Start

facilities); or Elementary and child care

programs that primarily care for children 6

years and under?

Verify if program is meeting grant specific

SDWA section 1464(d) programmatic Terms

and Conditions.

SDWA section 1464(d) - Implementation Document for States and Territories

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Verify program progress reports are being
submitted onto EPA's online reporting system
in a timely manner.

Performance Reports:

•	Quarterly: Reporting period end dates:
December 31st, March 31st, June 30th, &
September 30"; Deadlines for reporting
to EPA: 30 days after reporting period
ends,

•	Annual: Reporting period end date:
September 30th: Deadline for reporting
to EPA: October 31st.





4.

Statutory
requirement: 37s

for Reducina
Lead in Drinkina
Water guidance
(or another state
guidance not less
stringent)

Testing: Verify that sampling protocols
(QAPP/QMP) are consistent for schools and/or
child care facilities participating in the
program.

Verify the state has established a program
remediation trigger (PRT) for actionable
measures following lead testing.





Training: Verify that trainings are in place on
the risk of lead in drinking water, lead testing
and reduction education to facility personnel
as well as the impacting communities.





Taking Action: (1) Verify pre and post testing
activities, communication to parents, staff,
and the larger school and/or child care
program community; (2) Verify remediation
activities are in place, including activities to
reduce lead in drinking water appropriately in
terms of immediate, short, and/or long-term
actions.





5.

Sample Results
and Remediation
Activities, Public
Notifications

Verify the state ensures lead test results and
remediation activities are being
communicated to the impacting communities
(e.g., facility employees, parents/guardians,
and/or school and child care associated
communities).





Verify if communications to the public of
results are timely, within 30 days of receiving
results.





Verify the state has a website (or other
methods of delivery for public awareness of
test results such as emails or direct mails)
available to present the grant program's lead
testing results and remediation activities.





SDWA section 1464(d) - Implementation Document for States and Territories

26

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