The U.S. Environmental Protection Agency (EPA) mandates that all public water systems develop an inventory of their service lines and prepare a lead service line replacement plan by October 2024. Communities must act swiftly to meet this rule, published as the National Primary Drinking Water Regulations: Lead and Copper Rule Revisions (40 CFR Part 141, 40 CFR Part 142). Here, we break down the regulations, responsible parties, compliance, transparency, and funding.

Lead in Drinking Water

Water service lines supply drinking water from the water main to the home. When service lines made of lead corrode, lead can enter the water and contribute to lead exposure in drinking water. Particularly for infants and young children, lead presents serious health concerns that have earned the EPA’s attention since 1991, when the first Lead and Copper Rule (LCR) was published.

Today’s Regulations

Decades later, the EPA continues to strengthen actions to protect public health, requiring lead service line inventories. A catalog of service lines becomes the foundation for a comprehensive approach to identifying lead service lines, replacing them, educating the community, and tackling lead exposure in drinking water.

Public water systems must prepare and maintain an inventory of service line materials or demonstrate the absence of lead service lines by October 16, 2024. A water system must also submit a lead service line replacement plan by October 16, 2024, if it contains one or more of the following:

  • Lead service lines.
  • Galvanized steel service lines requiring replacement (galvanized lines that are or were downstream of a lead service line or cannot be verified otherwise).
  • Service lines whose lead status is unknown (material is unknown).
Source: Lead Service Line Replacement Collaborative. https://www.lslr-collaborative.org/uploads/9/2/0/2/92028126/howtocheckservicelinelead_18.01.23.pdf

Responsible Entities

Those subject to the LCR include the following:

  • Community water systems. Public water systems that serve at least 15 service connections used by year-round residents or regularly serve at least 25 year-round residents (40 CFR §141.2).
  • Non-transient non-community water systems. Public water systems that are not community water systems and regularly serve at least 25 of the same persons over six months per year (40 CFR §141.2).

While there are a variety of ownership agreements for providing water service in the United States, the rules require that service lines owned by customers and the water system are inventoried. Water system providers are responsible for the inventory of all users connected to their system, including out-of-district users.

However, responsibility can be complex. For example, when a village water district provides water to a consecutive town system, such as a system with a master meter at the village limit, the village bills the town in bulk, and the town bills the individual customers. In this arrangement, the consecutive system (the town) is responsible for the town inventory. However, in a customer-based intermunicipal arrangement, when a village bills customers in both the village and the town, the village is responsible for the inventory of all customers served both in the village and in the town.

Inventory Components

The lead service line inventory, to be completed by October 2024, must include the following elements:

Materials classification (lead, galvanized requiring replacement, non-lead, unknown) of portions of each service line connected to the public water distribution system that are owned by the water system and by customers.

Location identifier for any lead or galvanized lines requiring replacement.

Publicly available inventory.

Additional elements are recommended to support asset management, document the existence of lead connections, and streamline future reporting.

Source: U.S. EPA. https://www.epa.gov/system/files/documents/2023-06/EPA-Factsheet-Combined-06072023%20508-final.pdf

Replacement Plans

The lead service line replacement plan, also due October 2024, must include the following:

Strategy for determining materials of service lines with unknown lead status.

Procedure for conducting full replacement of lead service lines.

Strategy for informing customers before a replacement.

Procedures to flush lines.

Replacement-prioritization strategy.

Funding strategy.

The EPA’s Guidance for Developing and Maintaining a Service Line Inventory and Service Line Inventory Template, both released in 2022, outline these requirements and additional recommendations.

Public Transparency

Public health is at the center of the LCR, so lead service line inventories require public transparency. Community water systems and non-transient non-community water systems must make a portion of their inventory publicly available. Where lead lines, galvanized lines requiring replacement, or lines with unknown lead status are identified, water systems must notify the public or users of the involved building(s) through an annual notice to all existing and new customers served. If a water system serves more than 50,000 people, the inventory must be available publicly online.

Funding for Inventories and Replacements

State and federal funding is available to assist municipalities in completing lead service line inventories and replacements. Additional funding and other grant programs that support healthy, thriving communities may become available to reduce costs. (See chart.)

A Final Word

Lead in drinking water is a growing community health concern. Water systems are required to provide more information to consumers on an annual basis, beginning in October 2024. Partnerships between drinking water service providers, engineers, health departments, community organizations, and residents can effectively and efficiently advance the quest for safe drinking water.

About the author

Jennifer Vaughn is a project manager at LaBella Associates who brings 14 years of experience as a civil and environmental engineer as well as a grant specialist. She supports municipal clients in prioritizing projects, securing grant funds, completing studies, and executing community improvement projects. She has served over
50 municipalities, helping them to secure over $75 million in grant funds. She can be reached
at [email protected].

About the company

LaBella Associates is home to over 1,500 multidisciplinary consultants who plan, design, engineer, and manage public and private projects that enrich communities. The firm’s expertise is recognized in infrastructure, building, environmental, and energy projects throughout the eastern United States and Spain.

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