Revised Lead and Copper Rule: Start now to develop service line inventories

The clock is ticking toward Oct. 16, 2024 — the deadline for all U.S. water utilities to comply with the multi-faceted Revised Lead and Copper Rule (LCRR) established by the U.S. Environmental Protection Agency (EPA).  

Although EPA plans to revise the LCRR by releasing improvements before October 2024, the agency has stated that service line inventories, a key action item, will remain an unchanged requirement of the rule.

All water community water systems (CWSs), regardless of size, must develop and maintain an inventory of service lines that the public can access (40 CFR 141.84(a)). The inventory must describe both water system-owned and customer-owned segments of the service line. A utility must submit the initial inventory to its primacy agency by Oct. 16, 2024.
 
Systems serving more than 50,000 people must also make the inventory available online. Information about how to access the inventory should be included in future utility Consumer Confidence Reports. 

Service line inventory a foundational step

A utility must identify the materials of each service line in its service territory as 1) lead, 2) non-lead, 3) galvanized requiring replacement (GRR) if it has ever been downstream of a lead or unknown service line, or 4) lead status unknown (LSU). Systems that can demonstrate they only have non-lead service lines must provide an initial inventory and release a publicly accessible statement that details the method used to determine materials but will not need to provide updates in subsequent years.

The LCRR requires water systems to provide households an initial notification of lead, GRR or LSU service lines within 30 days of completion of the service line inventory, and then annually after that. These notices should include educational materials detailing the health effects of lead and actions to reduce risk of exposure. 

“Gathering more information about service line materials allows you to readily collaborate with customers on replacing lead or galvanized lines while also replacing them on the company side,” said Daniel Lawrence, vice president of engineering and real estate with Aquarion Water Company. “This puts the focus of service line replacement where needed and more efficiently eliminates any health risks.”

Developing an inventory can be challenging, particularly when service line materials on customer properties are not well documented. Utilities can use the data at hand and then improve initial inventories annually with available verification methods, making sure to follow state-specific inventory requirements. EPA has provided detailed information and recommendations in its document, Guidance for Developing and Maintaining a Service Line Inventory.

“A system will realize many benefits from having a completed inventory, including the ability to better meet the LCRR requirements, improved planning and budgeting for lead service line replacements, access to more funding opportunities such as those provided through the Infrastructure Investment and Jobs Act, and improved trust and messaging with its customers,” said Sandra Kutzing, vice president and lead and copper strategy leader at CDM Smith.

Communications key to inventory process

Water systems can begin to strengthen trust with their customers and communities by educating them about the health risks of water exposed to lead and the need for service line inventories and lead service line replacements. AWWA’s Lead Communications Guide and Toolkit, a resource developed by the Public Affairs Council, provides information and case studies about how to communicate proactively with customers. The guide includes strategies to help water utilities prepare for the communications challenges posed by LCRR.

“The more time a system spends developing their inventory, the less unknowns they will have by the deadline, and minimizing the number of notifications sent to customers with unknown service lines can help avoid unnecessary concern,” said Kutzing. “These notifications are especially important for customers who actually have lead service lines to understand the health risks and how to protect themselves and their families.”

Lawrence said that Aquarion has used social media, postcards, site visits and phone calls to help customers and communities understand the purpose of the work being done and its importance in protecting public health. 

“Our next step is to connect with communities so they can reach out for funding to help in the replacement of customer side service replacements, where they are eligible,” he said. “Aquarion is developing a method for customers to understand the status of their service line for compliance in October 2024. Being open and transparent with clear and consistent communication is critical to building trust.” 

Other AWWA resources for managing lead and lead communications are available for download. These include an animated video that helps consumers understand how to protect their households from the risk of lead getting into their drinking water through service lines or plumbing fixtures, fittings and solder that contain lead. A Feb. 9, 2023, Connections article reviews LCRR requirements that impact all water utilities.