May 14, 2024

Meeting Summary: Coosa-North Georgia Council April 23, 2024

To:         Coosa-North Georgia (CNG) Regional Water Planning Council

From:    Christine Voudy, GA EPD

              Paula Feldman, Freese and Nichols

              Andrea Druhot, Freese and Nichols


Subject: Meeting Summary: CNG Regional Water Planning Council Meeting

Date: April 23rd, 2024

Welcome and Introductions

Brooke Anderson, CNG Chairman, welcomed the group and made introductions. Mr. Anderson thanked the City of Rome for hosting the first focus-topic meeting of the interim period between regional plan updates.

 Mr. Anderson presented the agenda topics:

  1. Council Business
  2. Focus Topic Intro
  3. Background on the Lead and Copper Rule, Revisions, and Improvements
  4. Implementation of the LCRR and LCRI
  5. Open Council Discussion
  6. Local Presentation
  7. Fund Options for LCRR and LCRI

Council Business

  1. Council members approved the November 2023 meeting minutes.
  2. Council members approved the April meeting agenda.

Mr. Anderson shared about a seed grant project to understand nutrient trading. EPD recently approved a nutrient trade where a stream bank restoration in Lumpkin County earned phosphorus credit.

EPD approved a new seed grant project to analyze precipitation and extreme variations on a watershed basis for the Coosa Region.

Mr. Anderson reminded the council of the six focus topics for the next 3 years. Today is the first topic: lead and copper rule requirements.

Background on the Lead and Copper Rule, Revisions, and Improvements: How Did We Get Here, Why It Matters: Daniel Asriel & Leann Nguyen, EPA

Mr. Asriel and Ms. Nguyen from the EPA provided background on the Lead and Copper Rule, starting with an overview of acronyms and legislation timeline. The LCRR inventory compliance date is October 16th, 2024. Finalization of the LCRI is expected by October 16th, 2024, as well. The draft LCRI focuses on a 10-year replacement of all lead service lines, compliance tap sampling, and action levels.

Ms. Nguyen reviewed the detailed lead service line inventory requirements. She shared that the inventory must include the pipe material on both sides of the meter, be accessible to the public, and include the location, among other requirements. The inventory is intended to be a living data set.

Ms. Nguyen and Mr. Asriel answered questions.

  • Question from Mr. Anderson – Will pipe replacement stop at the house or premise plumbing?
    • Lisa Golphin of GEFA clarified that GA funding for replacement is currently requiring replacement of the service line to the building and does not include premise plumbing due to homes on slab foundations. This boundary is related to what utility crews can do compared to a licensed plumber.
  • Question from Mr. Berg – Has there been a study on the number of homes with lead piping in GA?
    • Lisa Golphin of GEFA shared that the LSL inventory will help answer this question.
    • Manny Patel of GA EPD shared that lead was prevalent before 1950s, which utilities can use to prioritize lines for the inventory. GA is assuming no lead for pipes or homes built in 1990 or later.
    • Mr. Asriel concurred and gave the example that Denver is assuming lead prior to 1950.
  • Question from Mr. Anderson – Will there be future inventories?
    • Mr. Patel clarified that inventories must be updated every year.
    • Ms. Golphin shared that the annual updates are due July 1st.
  • Question from Mr. Whitley = Is the LCRR website changing?
    • Mr. Patel: The website is getting better, resolving bugs, but the core options will not change.
  • Question from Mr. Anderson: Was the Flint, Michigan crisis a driver for LCRR?
    • Ms. Nguyen shared that Flint was one of the drivers for LCRR.
  • Question from the council about whether the EPA will address brass containing lead.
    • Mr. Patel hypothesized yes, in the future.
    • The group discussed the challenges with the tap sampling and verification process relative to brass fixtures.


Implementation of the LCRR and LCRI: Beyond the Inventories, What Happens After October 2024: Manny Patel, GA EPD

Mr. Patel elaborated on the background and requirements of LCRR and the draft LCRI. The LCRI will be released by Oct 16, 2024, with a compliance date in October 2027. The EPA will manage non-compliance. LCRR requires customer notices after inventory submission within 30 days of the inventory submission.

Mr. Patel encouraged utilities and local leaders to start preparing messaging and training now for the questions that will come from customers once the inventory is submitted. Mr. Patel reminded the council that the service line must be replaced on both sides of the meter to count as a replacement or to receive funding from the SRF. Mr. Patel mentioned lower action levels for corrosion control plans and the importance of informing elected officials of costs and schedule.

Mr. Patel encouraged use of the EPD’s 120 Water Software, a free database to track replacement for the next three years. Utilities can put a link to the database on their websites to potentially reduce calls.

  • Question from Mr. Anderson – Will there be a module to display the data publicly?
    • Mr. Patel clarified that the software shows the last submitted data, not a real time update, and that utilities must opt-in to display data.

Mr. Patel displayed a table comparing requirements for LCRR and LCRI. Utilities should aim to reduce unknowns in the inventory, since those pipes will count as lead and require replacement as part of LCRI. No replacement plan will be needed if there is no lead pipe in the inventory.

Mr. Patel provided an overview of the LCRI requirements to be included in the service line replacement plan, such as public notification, flushing instructions, pertinent laws, etc. He shared that after October 16, 2024, the timeline for action level exceedances will be within 24 hours.

Mr. Patel presented the proposed LCRI compliance sampling rules/details, which would be active Q4 2027, an overview of the distribution system and site assessments requirements, a diagram of action level exceedances, and a chart about school and childcare lead sampling requirements. Mr. Patel concluded with a summary of public communication timelines.

Open Council Discussion

  • Guest Question: Will EPD plan to continue lab work?
    • Mr. Patel: Yes, EPD will be able to do lab work for lead and copper and manage an increase in requests. There will be a per sample price and utilities must have a contract in place.
  • Question about private systems and wells.
    • Mr. Patel: EPA has not yet done anything yet for private wells aside from providing local water quality testing. Private systems are treated the same as public systems for LCRR rules.
  • Question from Mr. Sullivan –When will the submission button be active?
    • Mr. Patel estimates May as they finish working through some bugs.
  • Question from Mr. Sullivan – Who will own the asset after the private service line is replaced?
    • Mr. Patel: The private homeowner has responsibility for the assets between the meter and the home.
  • The council discussed homeowner agreements for property access and transfer of ownership of the replaced line to protect utility liability.
  • Ms. Golphin shared about the “3 strike rule” for property owners who prohibit property access.  Utilities should make 3 attempts to contact the property owner about LSL replacements and document those attempts.
  • Mr. Anderson mentioned an idea discussed earlier about a list of plumbers; homeowner contracts with a plumber on the list directly, while the utility pays the bill for private service line side.


Local Presentation: Rome and the History of its Rivers: Doug Walker, City of Rome


Fund Options for LCRR and LCRI: Lisa Golphin, GEFA

Ms. Golphin presented funding options for LCRR and LCRI. Three financing programs include: Georgia Fund, Clean Water SRF, and the Drinking Water SRF. The Clean Water SRF and Drinking Water SRF open in June; the Georgia Fund closes at the end of the month. Being a WaterFirst Community provides benefits towards funding, like a 1% reduction in interest.

Ms. Golphin shared that GEFA has funding for LSL via the Bipartisan Infrastructure Law. Available funding also includes 49% principal forgivable grants and loans to eligible disadvantaged communities. Ms. Golphin described distributions from GEFA to date. FY2022 grants must have loan/grant agreement by the end of the month or will be reallocated. GEFA is now allowing two loan draws (15th and 30th of the month) and virtual pre-construction webinars to fulfill requirements.

Eligible projects for funding include LSL inventories, LSL replacement, site restoration, permit fees, non-routine sampling and temporary filters, and community engagement and public outreach. Funding cannot cover internal work force labor. Loans are more flexible than grants on eligible equipment; swordfish is not approved due to its disturbance of the scaling on the pipes.

Ms. Golphin reinforced that LSL replacement should stop within 5 ft of the building and does not need to go to the premise plumbing. The website is the best place to apply under GEFA’s request for interest, which is open July 1 through Dec 31, 2024.

Ms. Golphin answered questions.

  • Question from Mr. Berg – What are the requirements of a WaterFirst community?
    • Ms. Golphin summarized that it is a year-long process with an environmental stewardship focus. Applicants are voted by a selection committee consisting of peers, the EPD, and the EPA.
    • Mr. Berg asked for more info (emailed to council members after the meeting).

Ms. Golphin shared that individual loan amounts are dropping so GEFA can help more communities.


Open Council Discussion

The council members shared the status of their LSL inventories. Mr. Whitley mentioned the high cost of bids to identify pipe material. Some utilities have leveraged their meter changeout programs to do field work. Others have used questioner or the county database for building permits to narrow the field work.

The council members discussed the next steps. Mr. Whitley expressed concern for liability behind the meter, which other council members echoed.

Mr. Anderson asked if a utility could be certified as lead-free. The council discussed and agreed that it was not likely. There could be lead in premise plumbing that could show up in sampling.

Mr. Anderson questioned if you could test one year, certify, and not revisit the site again, or certify the building date to avoid repeat sampling. Ms. Golphin hypothesized that yes, if the area were lead-free, that could be a one-time submittal. The Department of Education has a grant for premise plumbing at schools. The inventory still must be updated annually.

The council asked for opportunities to provide feedback to the EPD. Ms. Golphin shared that the 2nd Tuesday of month has Q&A session with GEFA, 120Water, and EPD. It is a virtual open forum. The next date is May 14th at 2 PM. Mr. Anderson encouraged the council to ask questions at these meetings.

Mr. Sullivan asked about utility water rate distribution on those without lead service lines. Mr. Anderson gave an example on why neighbor replacement matters because lead can backflow into the system; utilities must treat LSL as protecting the system instead of the home.

Mr. Asriel shared that a new rule was recently announced for PFAS/PFOA that identifies six specific chains. Some will be regulated individually, while some will be measured as a group with hazard index. GEFA has funding for PFAS.


Closing Remarks

Mr. Anderson thanked all the council members, visitors, planning contractors, and EPD. The next meeting will be in the center or eastern side of the region around November. The council was encouraged to send meeting location ideas to Ms. Feldman.

Comments from Non-Council Members, Visitors, or the General Public

No public comments.

Council Members Present (15):

  1. Brooke Anderson, Chairman
  2. John Bennett
  3. Mike Berg
  4. Eddie Cantrell
  5. Larry Chapman
  6. Jerry Crawford
  7. Kyle Ellis
  8. Robert Goff
  9. Haynes Johnson
  10. Rebecca Mason
  11. Gary McVey
  12. Tom O’Bryant
  13. Alex Sullivan
  14. Allison Watters
  15. Brandon Whitley

Visitors (11)

  1. Kim Goldner, City of Jasper
  2. George Kelley, City of Blue Ridge
  3. Lisa Golphin, GEFA
  4. Manny Patel, GA EPD
  5. Daniel Asriel, EPA
  6. Leann Nguyen, EPA
  7. Connie McVey, Fannin County Water Authority
  8. Julianne Meadows, NWGRC
  9. Sammy Rich, City of Rome
  10. Jeff Petrea, Georgia Power
  11. John Boyde, City of Rome

GA Environmental Protection Division

  1. Christine Voudy, GA EPD Council Liaison
  2. Clete Barton, GA EPD, Regulatory Support Program Manager

Freese and Nichols (Planning Contractors)

  1. Paula Feldman
  2. Andrea Druhot

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