March 1, 2021

Lead and Copper Rule: Where Should I Start?

Second in a series about the EPA’s Lead and Copper Rule Revisions. This post has been updated to reflect the EPA’s new compliance deadline.

Though municipalities have three years to prepare for the Lead and Copper Rule Revisions (LCRR), there is a lot to do during that time. Where to start?

Here are two key things to keep in mind:

• Every municipality will have to do something; what that is depends on multiple factors.
• The difficulty of complying will vary based on resources and risk exposure.

The compliance deadline is Oct. 16, 2024. Starting early will give you the best chance to successfully navigate the changes. That early effort should include stakeholder communication, risk assessment, scheduling, budgeting and resourcing.

Stakeholder Communication

• The new rules are extensive and packed with information, so start discussions with your staff early.
• Prepare your City Council and other stakeholders for the possibility of finding higher lead concentrations or having more difficulty complying with requirements. This could happen because of new procedures for sample site selection, prioritization and sampling, even without changes to operations, water source or overall water quality.

Risk Assessment

Check historical lead and copper compliance concentrations and sampling locations, which can help determine (but not guarantee) the risk of not meeting the new 10 µg/l trigger level.

Scheduling

Develop a compliance schedule, which will help with other aspects of compliance planning, including budgeting and identifying necessary resources.

Budgeting

• Include budget in your upcoming capital improvement plan: A typical midsize municipality will likely spend hundreds of thousands of dollars in additional staff time, laboratory costs, consulting and capital improvements for compliance, and a large city could need millions of dollars for extensive lead service line replacement.
• Explore external funding sources: While these sources are available, they are limited in scope and mostly nonspecific to lead service line replacement, and competition may be significant, so identify needs and apply early.

Resourcing

• Check the availability of existing records and historical information: Accurate and easily accessible records will make compliance efforts such as the lead service line inventory easier.
• Make the most of support resources: Regulatory agencies and water industry groups are making information, training and expertise available to assist municipalities. And Freese and Nichols can help answer your questions, provide guidance and more.

To learn more or schedule a brown bag session, contact Clay Herndon, wch@freese.com, 405-252-5934.

See Also:

• Lead and Copper Rule: What Must Water Systems Do?