Beyond the Inventory: Next Steps in the Journey to Lead-Free Water

A feature article from APWA-MN Platinum Sponsor SEH

We’ve officially crossed a major milestone: the October 16, 2024, deadline for Lead Service Line (LSL) inventories has passed.

Water systems nationwide rose to the challenge of mapping their lead infrastructure. Now, it’s time to shift from identification to action. The Final Lead and Copper Rule Improvements (LCRI) isn’t just another regulatory update – it’s a roadmap to cleaner, safer drinking water.

What’s Next?
With the LSL inventories in hand, water systems must now transition from identification to action. Staying ahead of these deadlines will require proactive planning, from updating sampling protocols to ensuring the accuracy of the service line inventories. Here’s what water systems need to know to remain compliant and safeguard their communities:

Compliance by November 1, 2027

By this date, water systems must implement several significant changes:

• Lower Lead Action Level: The action level drops from 15 µg/L to 10 µg/L. Systems that once met standards may now be required to take action – like optimizing corrosion control or replacing lead service lines.
• Updated Sampling Protocols: Utilities must collect both first-liter and fifth-liter samples, using the higher result. This better identifies risk, especially at sites with lead, galvanized lines downstream of lead, or premise plumbing made of lead.
• Inventory Verification: Initial inventories must be updated, verifying all known and unknown service lines.
• Service Line Replacement Plan: Systems must prepare a detailed plan for replacing lead, galvanized requiring replacement (GRR), and unknown lines.
• Outreach to Schools and Childcare Centers: Community water systems (CWSs) must notify elementary schools and licensed childcare facilities about sampling eligibility and share the EPA’s "3Ts" guidance –Training, Testing, and Taking Action.

Beyond Pipes – Protecting People

This next phase isn’t just about the pipes; it’s about people. Communities can expect stronger protections and clearer communication with the addition of the following requirements:

• Certified Filters for Partial Replacements: Certified point-of-use filters must be provided during partial replacements to reduce exposure risks.
• 24-Hour Consumer Notifications: Any disturbance to lead service lines requires notifying customers within 24 hours, along with steps to reduce exposure.
• Improved Consumer Confidence Reports: Reports must include clearer language, service line replacement details, and guidance for reducing lead exposure.
• Education After Exceedances: If a system exceeds the action level, educational materials must be sent to every service address – not just billing customers – with targeted messaging for vulnerable populations.
• Sampling Offers: CWSs must offer water sampling to homes that exceed the action level or are served by lead, GRR, or unknown service lines.

These next steps reflect the EPA’s commitment to its overarching values of public health protection and environmental safety. However, it’s important to note that some states are taking this a step further. For example, Wisconsin recently lowered its blood lead poisoning intervention threshold to 3.5 µg/dL, aligning with the CDC’s updated 2021 guidelines. This stricter standard highlights how states can adapt federal rules to address specific local challenges, creating even stronger safeguards for their communities.

Key Future Deadlines

Several key deadlines are on the horizon as the LCRI moves from planning to long-term implementation:

• January 1, 2028: Water systems with lead or GRR lines must begin six-month monitoring unless they’ve already met LCRI protocols (including the new lower action level).
• January 30, 2029: Annual service line inventory updates begin.
• October 2032: Schools and childcare facilities must complete lead sampling and conduct follow-up testing as needed. Water systems are responsible for providing sampling guidance and ensuring timely results and remediation recommendations.
• December 31, 2034: Systems must verify the accuracy of previously identified non-lead service lines. This can include historical record reviews, inspections, and water sampling. Any unverified or incorrect classifications must be addressed.
• December 31, 2037: All lead and qualifying galvanized service lines must be fully replaced.

Why It Matters
Let’s not forget the stakes here. Lead exposure can impact everything from cognitive development in kids to cardiovascular health in adults. With these improvements, the EPA isn’t just enforcing rules – it’s investing in the health and future of our communities. This next chapter is about more than compliance; it’s about delivering safer water, building trust, and creating healthier futures. Stay tuned, stay hydrated, and stay lead-free. Learn more about the EPA’s Lead and Copper Rule Improvements at Lead and Copper Rule Improvements | US EPA

Kevin Young, PE* *Registered professional engineer in MN and VA
Simon McCormack, PE* *Registered professional engineer in MN