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****This newsletter is being resent because the previous version had an error to the PFAS article. We apologize for duplicate emails***

In This Month's Newsletter

Lead Copper Rule: Lead Service Line Inventory Continuous Improvements

The PFAS National Primary Drinking Water Regulation: Questions and Answers

Incorporating Supply Chain Resilience in Risk and Resilience Assessments and Emergency Response Plans Webinar

EPA’s Chemical and Products Database (CPDat) 4.0: New and Expanded Chemical Use Data for Support of Exposure Assessment Webinar

EPA to open public docket and host listening sessions on Clean Water Act Section 401 implementation challenges

Public Water System Facility and Contact Changes

EPA Region 8 Drinking Water Contacts

Lead Copper Rule: Lead Service Line Inventory Continuous Improvements

Initial Lead Service Line Inventories were required to be developed and submitted to EPA by Oct. 16, 2024. Inventory updates are not required to be submitted to EPA in 2025 or 2026. Those systems that submitted inventories with many unknowns, may elect to voluntarily work on improving their inventory during this time by identifying the materials of the unknowns. This will put your inventory in the best starting place before inventory updates and service line replacements are required to start. EPA Region 8 suggests using an inventory continuous improvement approach to identify materials of service lines in their inventory prior to the next update deadline. This can be done using low cost, non-invasive methods by revisiting the historical records review, gathering information during normal operations, and considering a customer engagement plan to collect more information on service line materials.

GATHER RECORDS AND BUILD: Revisit the Historical Records Review

Any Information from a Previous Materials Evaluation:

• Under the 1991 Lead and Copper Rule (LCR), systems were required to conduct a materials evaluation. 
• Initial number of LSLs under LCR. 
• Any documents related to special monitoring for corrosivity characteristics.

Construction and Plumbing Codes

Distribution System Inspections

• All inspections and records of the distribution system that indicate material composition of the service connections

Types of inspection records could include:

• Responses to customer complaints
• Inspections to locate leaks
• Inspections to investigate meter issues
• Cross connection inspections

INVESTIGATE: Create New Records of Service Line Materials During Course of Normal Field Operations

• Create inspection records of service line materials during normal operations
• Identifying service line material should be built into normal operations such as:
• Water meter reading, repair, or replacement;
• Service line repair or replacement;
• Water main repair or replacement; and
• Backflow prevention inspections.
• Consider adding standard operating procedures (SOPs) to document how the information will be collected and used.

What records can be used to identify non-lead service lines?

“Non-lead” where the service line is determined through an evidence-based record, method, or technique not to be lead or galvanized requiring replacement.

Evidence Based Records Example: Service line installed after lead ban

EPA Region 8's Wyoming Structures Build Date Map – 2023 Lead Service Line Prioritization Study

• Online GIS map shows dates structures were constructed, and the likelihood of lead based on that time range.
• Assumptions/Constraints: EPA makes no claim regarding the accuracy or precision of the data shown herein. 
• This is not a predictive model; actual service line materials have not been verified.
• Web Application Map- View Only
• Arc GIS Online Feature Layer- Access to the Feature Layer URL to add to your own map or app.
• ArcGIS Online Web Map– Access the Web Map in ArcGIS Online.

EPA WaterTA - EPA's FREE Water Technical Assistance

• Including the Get the Lead Out Initiative (GLO), helps communities:
• LSL Inventories 
• Community Engagement Plans 
• Lead Service Line Replacement Plans 
• State Revolving Fund (SRF) Applications
• Request assistance by completing the WaterTA request form: https://www.epa.gov/water-infrastructure/water-technicalassistance-waterta

Additional Resources:

• For information on the Lead Service Line Inventory regulatory requirements from the Initial Service Line Inventory portion of the 2021 LCRR, visit: https://www.epa.gov/ground-water-and-drinking-water/lead-service-lines.
• Visit the EPA Region 8 Lead Service Line Inventory webpage for additional information and resources for water systems in Wyoming, including: reporting forms, LSL technical assistance partners, instructions on how to submit your inventory to EPA Region 8, and more: https://www.epa.gov/region8-waterops/lead-service-line-inventories-wyoming-and-tribal-lands-epa-region-8.
• If you have questions regarding the information contained in this report, you may contact Erica Wenzel at EPA Region 8. email: wenzel.erica@epa.gov, or call: (303) 312-6411

The PFAS National Primary Drinking Water Regulation: Questions and Answers

The EPA finalized a National Primary Drinking Water Regulation (NPDWR) for six per- and polyfluoroalkyl substances (PFAS) on April 26, 2024:

perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorohexane sulfonic acid (PFHxS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-    DA, commonly known as GenX Chemicals), perfluorobutane sulfonic acid (PFBS).

Exposure to PFAS in drinking water over a long time can cause negative health effects including thyroid disruption, certain cancers, elevated cholesterol, and immune disfunction. Sensitive subpopulations include pregnant women and developing babies. This rule will prevent thousands of deaths and reduce tens of thousands of serious PFAS-attributable illnesses.

Who is affected by this rule?

All community water systems and non-transient non-community water systems.

What are the deadlines?

The EPA will assign initial monitoring to your water system in 2026 so you can meet the April 26, 2027, deadline. Your February 2026 Monitoring and Reporting Requirements Report will communicate your monitoring schedule.

Compliance monitoring is required to begin April 26, 2027, and the monitoring frequency will depend on your initial monitoring results.

Compliance with the MCLs is due by April 26, 2029. The EPA announced in May 2025 it is looking into ways to provide more time for MCL compliance (see link to the announcement at the end of this article).

What are the MCLs?

The April 2024 rule establishes individual maximum contaminant levels (MCLs) for five chemicals, and a Hazard Index MCL for protection from mixtures for two or more of four chemicals when they occur together in drinking water (i.e. co-occur). EPA announced in May 2025 that it plans to retain the MCLs for PFOA and PFOS (see link to the announcement at the end of this article).

* EPA has announced its intent to rescind the regulations and reconsider the regulatory determinations for PFHxS, PFNA, HFPO-DA (commonly known as GenX Chemicals), and the Hazard Index mixture of these three plus PFBS to ensure that the determinations and any resulting drinking water regulation follow the legal process laid out in the Safe Drinking Water Act. For more details, see the link to the announcement from May 2025 at the end of this article.

Where do I sample?

Sampling is required at all entry points to the distribution system (finished water). Each entry point may have a different monitoring schedule based on the source water type. System interconnections between a seller and purchaser are not required to be sampled.

What are the initial monitoring requirements?

Semiannual sampling is required by groundwater systems serving 10,000 or fewer persons. The two samples will be required five to seven months apart.

Quarterly samples collected two to four months apart are required for surface water systems, groundwater under the direct influence of surface water systems, groundwater systems serving more than 10,000 persons, and any entry point that blends surface water and groundwater.

What EPA analytical methods and laboratories are required?

For initial monitoring, the EPA has determined the following labs can be used. These labs must use EPA method 533, EPA method 537.1 version 1, or EPA method 537.1 version 2.

1. Laboratories EPA approved for the Fifth Unregulated Contaminant Monitoring Rule (UCMR5)
2. Laboratories certified by a state laboratory certification program
3. National Environmental Laboratory Accreditation Program (NELAP) state accreditation programs that use the TNI standard – search for NELAP/TNI labs by method (533 or 537.1)

For compliance monitoring, laboratories must be certified by the EPA or the state and use EPA method 533 or EPA method 537.1 version 2.

Can previously acquired PFAS samples count towards the initial monitoring requirements?

Yes! Previously acquired PFAS sample results can partially or completely satisfy your initial monitoring requirements if certain conditions are met:

• Samples were collected in accordance with the Fifth Unregulated Contaminant Monitoring Rule (UCMR5)
• Samples were or are collected by other sample monitoring campaigns, like the Wyoming Department of Environmental Quality’s (DEQ) PFAS in Drinking Water Monitoring Assistance Program, or the EPA Region 8’s Tribal Emerging Contaminants Sampling Project
• Samples were collected using approved methods
• Samples were collected on or after January 1, 2019
• Sample collection meets the timing requirements for initial monitoring
• Most recent data from multiple years must be used
• EPA recommends that labs use one-third of the practical quantitation level (PQL) as the lower bound of their reporting systems.*

* A PQL is the lowest level at which a contaminant can be reliably quantified within specific limits of precision and accuracy during routine laboratory operating conditions using the approved methods. Note that samples collected prior to June 25, 2024, that were only analyzed down to the level of the MCLs are acceptable but would not qualify a system for reduced monitoring. To potentially qualify for reduced monitoring, samples must be analyzed down to half the MCLs or lower.

What are the best available technologies for treatment?

EPA does not specify or require how water systems must comply with the regulation, but the following technologies were identified as those that are capable of meeting the MCLs: granular activated carbon, anion exchange, and reverse osmosis/nanofiltration.

The EPA identifies feasible best available technologies based on factors such as high removal efficiency, reasonable cost, service life, and ability to achieve compliance.

How can I prepare for this rule?

During 2025, prepare for logistics and establish a budget. Each sample set is approximately $309. Become familiar with the rule by reviewing available fact sheets on the regulation website and quick reference guides on the implementation website. Begin planning for possible treatment upgrades, as needed.

What is the PFAS OUT initiative?  

In May 2025, EPA announced planning for the new PFAS OUTreach initiative (PFAS OUT). Through PFAS OUT, the agency will initiate enhanced outreach to water systems known to need capital improvements to address PFAS, including those EPA has identified as having PFOA and PFOS levels above EPA’s MCL. EPA will share resources, tools, funding, and technical assistance opportunities to help utilities address PFAS. PFAS OUT will ensure that no community is left behind as we work to protect public health and bring utilities into compliance with federal drinking water standards.

What technical and financial assistance resources are available?

WaterTA supports communities to identify water challenges, develop plans, build capacity (technical, managerial, and financial), and develop application materials to access water infrastructure funding. Complete the form to request technical assistance.

The Wyoming State Revolving Funds Program (SRF) provides funds to assist public entities with water infrastructure improvement projects. The Wyoming DEQ assists public water systems with the loan application process.

Additional programs and resources are available to local municipalities, Tribes, and communities, and additional financial resources are available. Please contact Karen Ward at ward.karen@epa.gov if you have questions about these assistance resources.

What if I have questions about the regulatory requirements or PFAS sample results I have already taken?

Contact Kendra Morrison at morrison.kendra@epa.gov or (303) 312-6145.

What is the link to EPA’s May 2025 announcement about changes the agency intends to make to the PFAS NPDWR?

See “EPA Announces It Will Keep Maximum Contaminant Levels for PFOA, PFOS”

Please note that the information provided in this article is for technical assistance only and does not supersede the rule requirements in 40 CFR 141 Subpart Z.

Incorporating Supply Chain Resilience in RRAs and ERPs Webinar

Safe Drinking Water Act (SDWA) section 1433 was revised by America's Water Infrastructure Act (AWIA) section 2013 and requires community water systems (CWS) serving more than 3,300 people to prepare (or revise) and certify risk and resilience assessments (RRAs) and emergency response plans (ERPs) to the U.S. Environmental Protection Agency (EPA) by specified deadlines every five years. Recertification deadlines are upon us, with deadlines occurring throughout 2025 and 2026. 

Natural hazards and malevolent acts have the potential to disrupt supply chains for a CWS’s treatment chemicals, potentially impacting treatment and operations. In this webinar, EPA will provide examples of how CWSs can address supply chain considerations in their RRAs and ERPs to build resilience to supply disruptions.

Webinar Details:

• Date: Wednesday, July 23, 2025
• Time: 12:00 p.m. - 1:00 p.m. MST

EPA’s Chemical and Products Database (CPDat) 4.0: New and Expanded Chemical Use Data for Support of Exposure Assessment Webinar

This webinar will discuss the basics of CPDat and the updates provided in the most current version, CPDat v4.0 released earlier this year. This update 1) more robustly links each chemical data record to its original data source, and 2) expands the quantity and quality of chemical and product data made publicly available. CPDat v4.0 also utilizes new controlled vocabularies, designed for exposure and chemical assessments, that form the basis of data search capabilities in a new public application for exploring CPDat data, called Chemical Exposure Knowledgebase (ChemExpo).

Webinar Details:

• Date: Thursday, July 24, 2025
• Time: 9:00 a.m. - 10:00 a.m. MST

EPA to open public docket and host listening sessions on Clean Water Act Section 401 implementation challenges

The U.S. Environmental Protection Agency (EPA) invites public input on implementation challenges associated with Clean Water Act (CWA) Section 401. The agency will use input received to determine next steps to address identified areas of regulatory uncertainty or implementation challenges regarding the scope of certification. 

“Central to the Powering the Great American Comeback is rejecting the false, binary choice between environmental protection and economic and energy development. It is critical that EPA meets its statutory requirements without weaponizing them against beneficial infrastructure projects,” said Senior Advisor for Water Jessica Kramer. “It is our responsibility to guarantee Clean Water Act Section 401 is only being used for its statutory purpose – to ensure permitted projects protect water quality while delivering real prosperity for all Americans.” 

Once the notice is published in the Federal Register, the public will have 30 days to provide input on implementation challenges and regulatory uncertainty related to the 2023 rule. EPA will host two virtual listening sessions for the public. Information on the Federal Register notice, listening session dates, times, and registration instructions, and how to provide written input will be made available at a later date on EPA’s CWA-401 website.