Is Your Water System Prepared for the Lead and Copper Rule Revision?
Recent water system problems around the country have heightened awareness about the impacts and concerns of lead in water systems. In fact, new research combined with recent events like in Flint, Michigan, has led to the first proposed major revisions to the Lead and Copper Rule since 1991. The Environmental Protection Agency’s (EPA) primary driver behind these revisions is to identify and correct potential lead exposure issues.
The Lead and Copper Rule maintains the current Maximum Contaminant Level Goal of zero parts per billion (ppb) and the current Action Level of 15 ppb. A major addition in this revision adds a trigger at 10 ppb that prompts new planning efforts in water systems with lead service lines. It also increases response levels when the 15 ppb Action Level is triggered.
These proposed revisions will require water system owners to take action to meet the anticipated requirements. It affects every community using lead service lines.
Six Things You Need to Know
The EPA’s revised proposal focuses on the following six key areas:
1. Identifying Most Impacted Areas
The goal is to identify and quantify lead service lines (LSL) in your system. The EPA will require a lead service public inventory. You will need to identify and mitigate elevated levels of lead in your system. If you don’t have an inventory of how many LSLs are in your system, start collecting that data.
Please note: If you only have galvanized or copper service lines, you are not completely out of the woods. You still need to complete an inventory if the galvanized pipe was downstream of the lead pipe. While the LSL inventory is being conducted, water systems must prepare an LSL replacement plan. These plans will be due within three years of the revised final rule publication date.
2. Strengthening Treatment Requirements
The new lead 10 ppb trigger level will require evaluations for corrosion control. If required, a system will have 18 months to complete the study and inform regulators of the corrosion control treatment it intends to pursue. System operators will have to take a holistic view of their system as phosphate-based corrosion inhibitors often cause issues during the treatment of your wastewater.
EPA Provides Learning Sessions
The EPA hosted several virtual engagements to obtain further public input on the Lead and Copper Rule Revisions particularly from individuals and communities that are most at-risk of exposure to lead in drinking water. The recordings for the sessions for communities, tribal agencies, national stakeholders, and the public listening sessions can be found here.
3. Replacing Lead Service Lines
If you are completing partial LSL replacements now, stop. Start to pursue full LSL replacement (from the water main to the building inlet). Partial LSL replacements will no longer be allowed—except for extreme circumstances, such as emergency breaks. As a system operator, you don’t have to completely pay for the replacement, but there will be triggers in the new rule that you must meet.
4. Increasing Sampling Reliability
The EPA is proposing further clarification on sampling procedures. The revision will also adjust sampling sites to target areas of higher lead levels and require more frequent sampling. You need to prepare for increased staff time and operational costs to meet these requirements.
5. Improving Risk Communication
Communications regarding LSL projects are critical to a successful project and to protect the health and safety of the public. Systems operators will be required to notify customers of lead level exceedances within 24 hours. Linking GIS to notification systems is a way to easily send out communications to potential users.
6. Protecting Children in Schools
Mandatory testing of schools and childcare facilities will be required under the proposed revisions. Children are the most vulnerable group to the impacts of lead poisoning and protecting them is our top priority.
Now is the time to prepare for documenting and developing your plan for lead replacement in your system.
Revisions are coming, and it is best to prepare before it’s too late. The thought of full LSL replacement can be overwhelming to some communities, especially when the utility operator does not own the service line. Developing an LSL replacement plan helps mitigate being overwhelmed.
There are also funding options available to help assist property owners with full LSL replacement. As part of your plan, begin developing communication and public information around LSLs and the importance of getting rid of them.
Guidance & Resources
Utilities may also want to seek guidance from consultants who have a history and experience with lead service line replacement. Morrison-Maierle can help to navigate through the process of developing and executing an LSL replacement strategy.
For more information on the proposed revisions and additional funding options, check these links:
- General information on the proposed revisions for the Lead and Copper Rule
- Summary and key takeaways for the proposed Lead and Copper Rule Revisions
- Additional funding options for lead service line replacements
- EPA Lead and Copper Rule Proposal Roadmap
Technical review of this article provided by Casey Hanson, PE