Urgent, Act Now: October 16, 2024 Deadline for Lead Service Line (LSL) Inventory
TIME IS RUNNING OUT!
Your state’s regulations for addressing lead contamination issues may vary, but this discussion will focus on preparations for the EPA’s Lead and Copper Rule Revisions (LCRR) and the likely direction for the future Lead and Copper Rule Improvements (LCRI).
The Lead and Copper Rule Revision (LCRR) Compliance Date is approaching. By October 16, 2024, all Community Water Systems (CWS) and Non-Transient, Non-Community Water Systems (NTNCWS) must submit an initial inventory of all service lines, using state- or EPA-mandated templates. This includes both system-owned and customer-owned lines, even if identified as non-lead. Systems with lead, galvanized requiring replacement, or unknown service line materials must notify customers of potential lead risks within 30 days of inventory delivery to the regulatory agency. The LCRR specifies the language notification and just last month EPA provided a fact sheet on this process and sample letters. These may be modified further by the state regulatory agencies.
For more information, go to these website to access EPA documents:
- EPA Fact Sheet for Notification of Known or Potential Service Line Containing Lead
- Templates for Notification of Known or Potential Service Line Containing Lead
It is critical to understand that the inventory requirements specify categorization of the entire service line, regardless of ownership.
The LCRR retains the current 15 ppb lead Action Level, and the way a 90th percentile calculation is made. However, the LCRR makes an Action Level (AL) Contravention a Tier 1 Notification requirement. (Public Notification within 24 hours).
The LCRR requires pitcher filter provisions associated with complete or partial LSL replacements, and formalizes policy for replacing lead connectors when encountered,.
Discussions with state public water regulatory agencies and affected Systems indicate that many Systems will have a percentage of their service lines as unknown when submitting their inventory. It is crucial for affected Systems to use this inventory as a framework and formal plan record for ongoing investigations, planning for unknown service lines, lead service line replacement, and pipeline repair/maintenance activities. It may also be of importance in identifying locations for future compliance monitoring which is expected to change following the anticipated final adoption of proposed Lead and Copper Rule Improvements (LCRI)
The proposed Lead and Copper Rule Improvements (LCRI), expected to be approved by October 2024, will mandate additional activities, including:
- Replacing 10% of lead service lines per year, regardless of ownership.
- Eliminating unknown service lines from the inventory within 10 years.
- Lower the compliance lead Action Level from 15 to 10 ppb.
- Impose major changes to the required sampling pool and significant changes to compliance sample collection requirements.
- Impose changes to corrosion control treatment requirements in the event of an AL Contrevention
- School drinking water lead testing program requirements
H2M is ready to assist clients in meeting the Federal LCRR deadline of October 16, 2024, related state deadlines, and preparing for compliance with the pending LCRI requirements.
