xvEPA

Voluntary School and Child Care Lead
Testing & Reduction Grant Program

Implementation Document
for States and Territories

* " *	. ^ . > . • - .	• 0 j>

Office of Water (4606M)

EPA 815-B-25-001
January 2025


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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 the 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 thqM^^5Hralaif»llwlnj||iB»BilBni!ai«!5P^iHiguidance 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
the EPA. The EPA will award funds with approved applications according to an allocation formula. All public
materials for the grant program are available at

www.epa.gov/safewater/grants

www.epa.aov/safewater/grants

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


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I.	OVERVIEW	3

II.	STATUTORY AUTHORITY	4

III.	ELIGIBLE APPLICANTS	5

IV.	NOTICE OF INTENT	7

V.	ALLOCATION OF FUNDS	7

VI.	APPLICATION PACKAGE AND SUBMISSION INFORMATION	8

VII.	ELIGIBLE USES	8

VIII.	USE OF FUND REQUIREMENTS	14

IX.	AWARD ADMINISTRATION INFORMATION	15

RESOURCES	19

APPENDIX A: SUMMARY OF KEY WORK PLAN ELEMENTS	20

APPENDIX B: DECLINE FUNDING AND ADMINISTRATION TRANSFER	21

APPENDIX C: LEAD REMEDIATION ACTIONS AND ELIGIBILITY	22

APPENDIX D: THE EPA PROGRAM REVIEW ASSESSMENT CHECKLIST 26
APPENDIX E: ADDITIONAL LEAD TESTING OPTIONS TO IDENTIFY SOURCES OF LEAD IN DRINKING
WATER	28



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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 the 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 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).

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I!. 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 (WIIN), 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 the 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 the Bipartisan Infrastructure Law,
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.

i °	o *	"is. ibb* " • ° ft

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Lead remediation efforts include the 3Ts remediation actions (e.g., immediate, short-term, and long-term
measures), 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 apparatuses related to drinking water. See Appendix C for further details
on lead remediation activities and eligibilities.

Measuring the amount of lead in a water sample is the most common lead testing option to identify the
presence of lead sources in drinking water. The grant program expands on additional lead testing options
to identify the presence of lead sources in drinking water plumbing in schools and child care facilities.
See Appendix E for eligibilities of additional lead testing options.

States should fuily describe the planned activities in their application, including lead testing and
remediation options used in funded projects. See section VI Application Package and Submission
Information.

On October 8, 2024, the U.S. EPA issued a final rule requiring drinking water systems across the country
to identify and replace lead pipes within 10 years. The Lead and Copper Rule Improvements (LCRI) also
require more rigorous testing of drinking water and a lower threshold requiring communities to take
action to protect people from lead exposure in water. In addition, the final rule improves
communication within communities so that families are better informed about the risk of lead in
drinking water, the location of lead pipes, and plans for replacing them.

The LCRI retains the requirements from the 2021 Lead and Copper Rule Revisions (LCRR) for Community
Water Systems (CWSs) to conduct sampling and public education in schools and child care facilities but
expands the available waivers to include sampling efforts conducted prior to the rule compliance date,
including sampling conducted under this grant program. The EPA plans to develop guidance and
outreach materials in the coming three years and will update grant program documents where
appropriate. For more details visit, Lead and Copper Rule Improvements.

111. ELIGIBLE APPLICANTS

The 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 the 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 the EPA. Upon receipt, the 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

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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."

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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 NOIP The NOIP can be submitted by email to
WllNDrinkingWaterGrantsffiepa.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: The 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 the 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, the 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. The 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 the 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, the EPA will calculate the final allocations,
and the 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.
The 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 Section 1464(d)(5) of SDWA, 42 U.S.C. §3Q0j-24(d)(5).

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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 the 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: The 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.

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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:

•	The 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 EPA's 3Ts.

Potential Child Care Program Collaboration

The 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

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:

•	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 the 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 the 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(e).

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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

•	The 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.

•	Review Appendix E for additional lead testing options to include in the grant work plan.

If the grant recipient intends to use state regulations or guidance other than the 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
objectives.

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

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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
actions to parents, staff, and the larger
school and child care program
community.

To learn more about these elements, please visit

www.epa.gov/safewater/3Ts.

Lead is particularly dangerous to children
because their growing bodies absorb more
lead than adults and their brains and
nervous systems are more sensitive to the
damaging effects of lead.

To learn more about lead visit:

http://www.epa.gov/ground-water-and~
drinking-water/basic-information-about-
lead-drinking-water

E.	Build 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. On October 25, 2023, the Office of Management
and Budget's (OMB) Made in America Office released its final guidance for implementing the Buy
America, Buy America Act. 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 the 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. 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).

The 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 2014 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.

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G.The EPA Strategic Plan Linkage and Anticipated Outputs/Outcomes

Pursuant to Section 6a of EPA Order 5700.7, "Environmental Results under the EPA Assistance
Agreements/' recipients' work plans must link proposed assistance agreements with the EPA's Strategic
Plan. The 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 the EPA Strategic Plan: 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 the 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 2014 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.

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

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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.

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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. The
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 the 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 the EPA's approval. This policy is implemented in a grant-specific Term
and Condition entitled "Pre-award Costs." All costs incurred before the EPA makes the award are at
the recipient's risk. The 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.

E.	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 will not displace those
resources.

F In-kind Assistance: At the request of a recipient, and if the EPA agrees, an EPA award, may include
in-kind assistance provided by the EPA (including contractor support and purchases or leases of
equipment or purchases of supplies), or the EPA's personnel under Intergovernmental Personnel
Act assignments or Interagency Agreements. In-kind assistance that the 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 the 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

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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
the 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 the 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 the EPA
Order 5700.1. A recipient may request in-kind assistance, or the 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 the EPA
purchases equipment that is delivered to a recipient as the EPA in-kind assistance the
cost for those items would be placed in the equipment category. On the other hand, if
the 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 the 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
the EPA assistance agreements under this program may be viewed at: www.epa.gov/grants/grant-terms-
and-conditions The EPA Headquarters will provide the EPA Regions with a list of terms and conditions
that will also apply to the grant program. The 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 The 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 the EPA funds even if one particular

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component of the state is named in the assistance agreement as the recipient. Transfers of the EPA funds
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 §§200.331-200.333), the National Term and Condition for Subawards, and the
EPA Subaward Policy unless the 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 the 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 the
EPA's Subaward Policy can be found at: https://www.epa.gov/sites/default/files/2016-
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 the 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 the 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 the 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 30th. 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 the EPA's electronic Online Reporting Tool.

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 the EPA's electronic Online Reporting Tool. 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

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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 wiii be accepted via the EPA's electronic Online Reporting Tool.
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 the 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: The 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 the EPA anticipates using as part of the 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

Drinking Water Act 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 the EPA Assistance
Agreements: www.epa.gov/grants/best-practice-guide-procuring-services-supplies-and-equipment-
under-epa-assistance

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

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SUMMARY STATEMENT
SCOPE OF WORK

A.	State Goals and Priorities

B.	Grant Program Implementation and Activities

i.	Activities using either the 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 the EPA's Strategic Plan Linkage

The activities described in this work plan support the grant Programmatic Priorities and the EPA'
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. The 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 the 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 the 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 the
EPA). The state should contact the 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 the 3Ts
remediation actions 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 the 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 identified lead
source presence.

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 Program Remediation Trigger (PRT).

•	States are required to establish the PRT under the grant program. The PRT 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 identified lead sources
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

2014 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 the 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, the EPA will use the Lead

and Copper Rule Improvements definition, which is, "...that is made of lead or where a
portion of the service line is made of lead. A lead-lined galvanized service line is defined as
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 (e.g., galvanized service line that currently is or ever
was downstream of a lead service line; or is currently downstream of a lead status unknown
service 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/water-
research/consumer-tool-identifying-point-use-and-pitcher-filters-certified-reduce-lead

o The 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 PWSwill 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
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

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IV.	Maintenance Plan States are to ensure plans are in place for maintenance and continuation efforts of
lead remediation activities. Per the 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 not related to human consumption 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 not being used for water for human consumption

•	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 and 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 arid
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.

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

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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, the EPA
provides funding to water utilities. More details at https://www.epa.Qov/around-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) and 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, and/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?

The 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/dwcapacitv/voluntarv-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-voluntarv-
school-and-child-care-lead-testing-and-reduction-grant-program

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APPENDIX D: THE EPA PROGRAM REVIEW ASSESSMENT CHECKLIST

The 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: The
EPA Program Review Assessment Checklist below) to evaluate internally whether the state is meeting grant
objectives.

Table 1. The EPA Program Review Assessment Checklist

State Oversight Agency



Contact information



Reviewer information



1.

Objectives/Grant

Reviewer Checks

Findings/

Follow-up



Requirements



Outcomes

Actions

2.

Linkage to the
EPA strategic
plan

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





3.

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 (the 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.



o"* ** ^ H

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

Performance Reports:

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

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





4.

Statutory
requirement: 37s

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

Testing: Verify that lead testing 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.

Lead Testing
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.





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The EPA is providing supplementary information in this appendix regarding additional options for lead testing
that may be used to identify sources of lead in the plumbing that serves drinking water in schools and child
care facilities. These options are in addition to the water sampling and lead testing methods described in prior
publications of the EPA Voluntary School and Child Care Lead Testing and Reduction Grant and 3Ts programs.

Lead remediation, including POU devices, are eligible costs under the EPA Voluntary School and Child Care
Lead Testing and Reduction Grant program. Lead remediation should occur after lead sources are identified
and documented according to the grant project work plan.

If a state decides to use additional lead testing options described in this appendix in lieu of, or in addition to,
drinking water testing, it must specify these methods in its grant work plan. When using these additional
testing options, it is important to include the criteria for prioritizing appropriate remediation action to reduce
lead exposure because these options do not provide a numerical drinking water lead level (e.g., prioritizing
remediation in older buildings based on year built or equipment installed).

States may use the following additional testing options to identify the source of lead in drinking water in
schools and child care facilities:

•	Analysis on lead presence using criteria based on construction and plumbing codes, permits, and
existing records or other documentation which may indicate the presence of lead (e.g., permits,
blueprint records/building schematics, construction records). Key information in these records
include:

o Building age (because buildings built before 2014 may be more likely to contain lead in
solder and/or plumbing components); and

o Plumbing age (because faucets and plumbing installed prior to 2014 may be more likely
to contain lead); and

•	Lead service line identification:

o Accessing the public water system (PWS) initial service line inventory, as required under
the 2021 Lead and Copper Rule Revisions (LCRR), can help to identify lead service lines.
The LCRR required all community water systems and non-transient non-community water
systems provided a publicly accessible inventory of service line materials by October 16,
2024.

o In some inventories, the service line material may be unknown. Smaller child care

facilities operated out of single-family residences could be more likely to be served by an
LSL based on the diameter of the service line. Focus identification activities on locations
where service lines are less than two inches in diameter.

•	Methods to determine potential lead exposure locations include:

o Blood lead level records of children (analysis from school health records, public health
records) combined with records on lead presence in drinking water in the building; and

o Visual inspection and capture of plumbing (e.g., photo of pipes/solder/new fixtures and
fittings) bv a state certified Plumbing Inspector to identify lead sources [See: Protect Your
Tap: A Quick Check for Lead],

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•	Rapid water lead testing kits:

o While rapid water lead testing kits can be useful as an initial screen, the EPA discourages
the use of these kits as a standalone method to identify lead sources. These kits are
prone to false negatives (i.e., Results are typically reflected as present or absent. An
absent result may be false.). They also do not provide a quantifiable lead level, and
generally only measure dissolved lead, not particulate lead. Knowing the numerical water
lead level aids in prioritizing appropriate remediation actions to reduce lead exposure.

o Follow-up water testing (using the EPA 3Ts protocols) or combining these test kits with
other non-water lead testing options should be used to further confirm the identification
of lead presence.

•	Other best practices that can be documented to identify the presence of lead in drinking water
according to project work plan.

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