Lead, a widely recognized toxic pollutant, poses a serious threat to human health by damaging our neurological, cardiovascular, immune, and developmental systems. To protect public health and reduce exposure to lead in drinking water, EPA established the Lead and Copper Rule (LCR) in 1991, and then Lead and Copper Rule Revisions (LCRR) in December 2021.
The LCRR, along with the recently proposed Lead and Copper Rule Improvements (LCRI), involves improving lead sampling and corrosion control, expanding public education and customer outreach, starting lead testing in schools and childcare facilities, building a public inventory of lead service lines (LSLs), as well as replacing these LSLs. A major part of compliance is building an inventory, and while this inventory can be submitted with unknowns, that comes with its own implications.
Reasons to Minimize Unknowns
To Improve Public Perception and Address Health Implications
Building public trust through communication is a key aspect of the LCRR and the proposed LCRI. When numerous unknowns are reported, residents may grow concerned about the uncertainty, which could harm the utility's reputation and lead to higher costs later. Also, these unknown service lines could pose public health risks if they contain lead. The inability to identify these lines may result in inadequate measures to address potential health hazards.
To Address Compliance Concerns
Submitting an inventory of unknown service lines may raise compliance concerns. The LCRI, anticipated to go into effect in 2027, will factor in unknown service lines in a utility’s required replacement rate. This means that a utility may be on the hook for replacing more lines than they feasibly can due to the high number of unknowns in their system.
To Expedite LSL Replacement Plans
Having an inventory with unknown service lines presents significant challenges for water utilities in planning lead pipe replacements. This results in inefficient resource allocation, as utilities are unable to prioritize areas with lead pipes, potentially leaving communities at risk of lead exposure. An accurate inventory is also vital for strategic asset management, which will enable informed decisions about maintenance and replacement schedules to safeguard public health.
Lead-free Status, Zero Unknowns, and LCRR Compliance
A common question is — whether a utility with no lead automatically becomes LCRR compliant after the October 16 deadline. However, part of meeting LCRR compliance involves proving that service lines do not contain lead.
The LCRR assumes service line owners are guilty until proven innocent and requires submittal of a service line inventory (with materials clearly marked) to the EPA by October 16, 2024. So, even utilities with no lead need to submit an inventory this October.
Further, depending on population size, you'll have to do more than just submit an inventory. For municipalities serving 50,000 or more people, the inventory must be publicly accessible and published online too.
Reducing Unknowns: Benefits and Future Post the LCRR Deadline
A successful implementation of LCRR and reduced unknowns in the long term will reduce lead exposure and its health impacts and thus improve overall public health, especially protecting more vulnerable populations (such as children and pregnant women). Plus, reduced unknowns will not only help utilities comply with regulations but also play a larger role in increasing public confidence in drinking water safety.
Meeting or missing the LCRR deadline has its own implications. You can find more about it here.
Effective Communication Sets the Stage for Compliance
Providing a great communication experience keeps ratepayers informed, shapes a utility’s public perception, and helps improve operational efficiency. However, managing all the data related to communication events can be challenging. Creating an auditable database will become even more crucial when the Environmental Protection Agency's (EPA) proposed LCRI takes effect.
With LCRI, utilities will be on the hook for not only conducting outreach events, but also documenting them. Consider lead service line replacements, where the LCRI mandates utilities to reach out to property owners four times, utilizing two distinct methods to notify them about the replacement process.
This is where leadCAST® and leadCAST Predict can help! leadCAST streamlines communication, enhances public engagement, and ensures seamless reporting.
Tools and Resources for LCRR and Beyond
To comply with LCRR/LCRI, EPA has provided various tools and resources, and here’re a few FAQs that can help utilities answer the questions around the compliance requirements.
Case Studies
Trinnex has worked with several water utilities to help them comply with the regulations.
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One of the recent examples is the Middlesex Water Company (MWC), which needed a solution for LCRR compliance. MWC chose leadCAST, a management system for Lead & Copper Rule programs that provides a data management and predictive modeling system.
MWC, using leadCAST, has reduced unknowns, guided targeted field verifications, built an integrated/comprehensive system to track their lead service line data, and created their service line inventory.
Through its implementation, MWC has reduced their unknowns by 40%, saving significant effort and rapidly identifying inventory materials. Click to download the case study.
Another example is the City of Salem, VA, which needed an all-in-one tool to help with service line inventory development and management.
Salem, in collaboration with Trinnex, optimized data management, established a single source of truth, and utilized machine learning to identify the likelihood of lead.
Click here to download the case study.
While it may not be necessary to buy a custom-made solution, it sure can help. You can read more about it in this buyer’s guide.
What’s next: LCRI Compliance, Driven by No Unknowns
The proposed LCRI requires water utilities to replace 100% of the lead service lines within 10 years and identify all unknown service lines in their inventory.
leadCAST is well-positioned to help water utilities execute their LSL replacement plans by:
- Allowing easy movement of properties from the lead inventory into the replacement pool
- Tracking and visualizing LSL replacement progress
- Streamlining right-of-entry (RoE) form collection and management with a public portal
- Providing in-app replacement inspection capabilities accessible on mobile devices along with inspection QA/QC functionality
This is only step one in what utilities can look into post the LCRR deadline. There’s more around sampling, enhancing safety, and replacing LSLs. So, stay tuned in as we work together to protect our water systems for a healthier future.
