February 3, 2021

Lead and Copper Rule: What Must Water Systems Do?

First 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.

The U.S. Environmental Protection Agency released long-awaited Lead and Copper Rule Revisions on Jan. 15, 2021, setting new standards aimed at removing harmful levels of lead from drinking water. This will require cities, utilities, homeowners and other water customers to take different levels of action.

The compliance deadline is Oct. 16, 2024, but it’s time to start your process now. You need to determine the extent of your community’s lead problems, what remediations are required and how you will pay for them — and you will have to document your plans.

Key requirements you need to know

✓ Develop an inventory of all service line material

A publicly accessible catalogue of all your service line material must be created. Both the utility and the customer side of the meter are to be identified. If you don’t have lead service lines (LSLs), this must be demonstrated.

✓ Develop a lead service line replacement plan

You’ll need to document a plan for replacing lead service lines and a strategy to pay for the work, including details on how to assist customers who can’t afford their share of LSL replacement costs.

✓ Update your compliance sampling plan and protocol

New sampling procedures are expected to increase some utilities’ measured concentration levels. Utilities now must prioritize sample locations based on risk, starting at homes with known LSLs, and base measurements on a 5th liter sample.

✓ Sample for lead and communicate with all elementary schools and childcare facilities

Sample drinking water for lead at all public/private schools and licensed child care centers you serve, covering at least 20% each year. The goal is to sample every one of these facilities over a five-year period.

✓ Understand and comply with a new 10 µg/L lead Trigger Level

A new 10 µg/L lead Trigger Level mandates a response at concentrations lower than the original 15 µg/L Action Level.

✓ “Find and Fix” lead sources within homes experiencing high lead concentrations

The utility must find and replace lead-contributing sources within any individual home with a concentration above 15 µg/L.  Replacement on both sides of the meters is required.

✓ Optimize your corrosion control

­Most systems will have to install corrosion control treatment if lead levels exceed 15 µg/L. If your system already uses corrosion control treatment, it must be re-optimized if lead levels are higher than 10 µg/L.

✓ Incorporate new public communication and education procedures

­Utilities should prepare to execute multiple new forms of outreach, including educational material, publicly available inventories, communication with schools, and rapid communication within 24-hours in certain situations.

How can Freese and Nichols help?

With a staff of almost 1,000 dedicated professionals, we have performed services for water system programs totaling 2 billion gallons per day.

Our experience includes:

• Current support for clients on lead and copper compliance
• National and international expertise in corrosion control and water treatment
• Training on the revised Lead and Copper Rule through the EPA and American Water Works Association
• Program management and asset management experience that includes inventories, condition assessments and capital improvement planning
• Funding assistance success in helping clients secure almost $3 billion in loans and grants for projects

To learn how we can assist you, please contact David Munn, David.Munn@freese.com; Xi Zhao, Xi.Zhao@freese.com; or your Freese and Nichols client representative.