As the U.S. EPA deadline for initial Lead Service Line Inventories and approaches, we share key insights from ongoing lead service line inventories and replacement projects in the U.S.
October 16, 2024 is the deadline set by U.S. EPA for water systems around the nation to submit an initial Lead Service Line (LSL) Inventory to state primacy agencies. This requirement under the Lead and Copper Rule Revisions (LCRR) is the first step in investigating lead in their communities and protecting public health by replacing lead service lines.
For over 20 years, Arcadis’s subject matter experts have been helping various utilities understand and meet LCRR Program Components starting with Corrosion Control Treatment (CCT) services. After helping the City of Flint and other communities improve their water treatment techniques, Arcadis evolved to help utilities conduct inventories, replace LSLs, develop school and childcare sampling programs, test residential drinking water for lead, communicate with internal and external stakeholders about LSL replacement opportunities and needs, and acquire state and federal funding to carry out all these components. In this write-up, we share insights from our ongoing projects around the country and what’s ahead.
Funding Support
Take advantage of the $15 billion that U.S. EPA is releasing to water utilities for LSLR work through the Bipartisan Infrastructure Law (BIL) from 2022-2026 by understanding how to successfully work with your State Revolving Fund.
Develop a funding strategy that accounts for all customers, especially those facing economic hardship.
Effectively communicate your LSLR funding needs and prioritization strategy to gain the support of utility and city leadership.
In New London, CT, nearly $7 million in BIL funding was made available to replace 150 LSLs and complete LSL inventory. We expect U.S. EPA to announce the next round of the Reducing Lead in Drinking Water grant, one of three Water Infrastructure Improvement for the Nation (WIIN) grants and the only one that water utilities can directly apply for. This is a competitive funding opportunity and requires a 20% match. Previous awardees, such as the City of Trenton and Detroit Water & Sewer Department, utilized the grant to replace LSLs while others used the funds to stand up lead sampling programs in schools and childcare facilities.
Service Line Inventory
Inventory submissions are due October 16, 2024. It’s OK to submit with unknowns. Once inventories are submitted, notification letters must be mailed out to all service lines identified as Lead, GRR and Unknown by Nov 16, 2024. Some states require prior approval if you are modifying EPA’s letter template so plan accordingly.
There are many tools available to help reduce the number of unknowns in your inventory in a cost-effective manner. In some states, you can receive loan forgiveness from the BIL to defray the cost of inventory investigations.
Using the right digital tools from the beginning will enable the project team to not only communicate efficiently but also make decisions based on real-time data. The LCRR requires multiple touchpoints with residents and having a tool to track this is equally important as having a reliable inventory.
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Currently, it is anticipated that the Lead and Copper Rule Improvements (LCRI) will provide water utilities with three more years to complete the system inventory. Whether your system has lead or no lead, Arcadis offers many tools and experience working with all types of algorithms (models) to cost-effectively reduce the unknown service line materials in your system.
LSL Replacement Program
Water utilities are responsible to remove and replace all lead service lines even if the water utilities are not the owner.
It is anticipated that the LCRI will require this to be completed in about 10 years. This does not mean the water utility must pay for all the replacements.
For most states, a LSL Replacement Plan is due in three years Oct 2027, which was delayed by LCRI.
Take the opportunity to know what you have in your system to be able to craft the program that will work for you and your rate payers. Arcadis can help you craft the replacement program that fits with your budget and philosophy for your water utility. As an experienced Program Manager for all aspects of service line replacement, we offer many real-time tools that simultaneously update records, produce required notifications, and assist with required sampling as programs progress to save time and money.
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Sampling and Monitoring Program
Carefully consider the impact residential, school, and childcare sampling programs will have on current field and lab staff and ensure your program is sustainable while also providing value to the community.
Pilot your approach to new sampling requirements, especially school/childcare and 1st/5th Liter sampling, before requirements kick in so that you can reduce customer confusion and increase the quality of your results.
Leverage best practices to increase sampling kit returns in post LSLR and school/childcare sampling programs.
LCRI delays all major LCRR sampling requirements, giving utilities an opportunity to focus on developing inventories and more time to prepare to come into compliance with some of the more complex changes such as sampling all elementary and licensed childcare facilities over five years. U.S. EPA has stated that all school and childcare sampling that follows LCRR protocol and is conducted after 2021 will count so we recommend working through all the kinks of your sampling program now.
Public Education and Outreach
Develop clear goals (I.e. increasing LSLR or sampling program participation) so that you can select the right communication strategies and tools.
Break silos in your organization by collaborating with utility and city communication staff who are familiar with what outreach strategies have been most effective in your community.
Take time to educate city officials on what these rule changes may mean for your community and get their buy-in on your approach.
This year, most utilities will be focused on preparing and sending out their first material notification letters to all customers served by service lines classified in the inventory as unknown, lead, or galvanized requiring replacement. Most communities feel U.S. EPA’s template for this letter requires significant tailoring. Arcadis helps systems use this first opportunity to educate customers about the complexity of lead in plumbing and impower them to take action to help identify service line materials and reduce lead in their own homes. Next year, utilities can start to expand the approach started in the inventory to other aspects of the rule such as LSLR or school/childcare sampling outreach.
Corrosion Control Treatment
Continue to monitor the effectiveness of your corrosion control strategy. This is the time to prepare for the reduced action level of 10 ug/L.
If your system has LSLs, consider performing 1st & 5th liter or profile sampling in advance of rule deadlines to improve data and understanding of the effectiveness of your corrosion control strategy.
As utilities prepare to implement strategies to address LCRI and the PFAS MCL, it's important to keep line of sight on corrosion control treatment and simultaneous compliance with all aspects of the Safe Drinking Water Act.
Treatment techniques for PFAS can influence corrosion control treatment and now is a good time to evaluate your treatment strategies and goals. While LCRI removes the trigger level and delays the action level of 10 ug/L, this time is critically important for utilities to review their corrosion control strategy. Arcadis is a leader in chemical optimization and corrosion control and can help utilities prepare for the new action level. We have over 20 years' experience performing desktop and demonstration studies of all sizes.
A legacy for many generations to come
Since the ban on installation of lead pipes in 1986 in the U.S., a multitude of public and private organizations and communities have made a concerted effort to protect public health through optimization of corrosion control treatment and lead service line replacement. To date, the industry has made great strides at reducing exposure to lead and will continue to focus on prioritizing public health through engineering solutions.
