Water utilities are on a tight deadline as the Environmental Protection Agency (EPA) prepares to enforce the Lead and Copper Rule Revisions (LCRR) by October 16, 2024. These revisions are designed to ensure the safety of drinking water and reduce lead exposure in communities across the United States. With six months left, it’s crucial to understand the key requirements and take necessary steps to comply with the rule. The LCRR builds on the original Lead and Copper Rule (LCR), established in 1991 to control the presence of lead and copper in drinking water.
The updated version, released in 2022, introduces significant changes aimed at better protecting communities from lead contamination. These changes were prompted, in part, by the Flint water crisis, where thousands of residents were exposed to lead poisoning from April 2014 to October 2015. The LCRR includes stricter requirements, expanded testing protocols, and mandatory lead service line replacement for many water systems.
Under the LCRR, public water systems must submit a comprehensive inventory of service line materials, identifying lead lines, galvanized lines requiring replacement, and unknown materials by the compliance deadline. This inventory is a critical step toward meeting regulatory requirements and mitigating lead exposure. The guidance provided by the EPA emphasizes the importance of transparency and communication with the public regarding the location and condition of lead service lines.
Additionally, the LCRR introduces new public notification requirements. In the event of a Lead Action Level exceedance, communitywide public notification must occur within 24 hours. This requirement underscores the urgency of addressing lead contamination and maintaining public trust. Stephen Estes-Smargiassi, chair of the American Water Works Association’s (AWWA) Lead and Copper Rule Advisory Committee, advises water utilities to proactively engage with public officials, media, and other stakeholders before starting the sampling process to avoid surprises and ensure clear communication.
The EPA has released several resources to help water systems comply with the LCRR. The Guidance for Developing and Maintaining a Service Line Inventory provides best practices, a template for creating inventories, and case studies to assist water systems in meeting the October 16 deadline. The Small Entity Compliance Guide, released in June 2023, is tailored to support small community and non-transient non-community water systems. Additionally, the EPA has hosted webinars to educate professionals on the revised rule and funding opportunities through programs like the Drinking Water State Revolving Fund (DWSRF) and the Bipartisan Infrastructure Law (BIL).
With six months remaining, water treatment professionals should focus on several key actions to ensure compliance with the LCRR:
1. Develop a Comprehensive Service Line Inventory: This step involves identifying all lead and galvanized lines and creating a plan for replacement. The inventory must be submitted by October 16, 2024.
2. Communicate with Stakeholders: Proactive communication with public officials, health departments, and community members is essential. Ensure that everyone is aware of the new requirements and the steps being taken to comply with the LCRR.
3. Prepare for Public Notification Requirements: Establish a process for communitywide public notification within 24 hours of a Lead Action Level exceedance. This requires coordination with media outlets, public officials, and other stakeholders.
4. Stay Informed and Utilize Available Resources: The EPA provides extensive guidance and resources to support compliance efforts. Take advantage of webinars, templates, and other materials to ensure compliance.
The clock is ticking, so it’s crucial to act now to ensure compliance by October 16, 2024.
Resources:
AWWA
EPA
OpenGov
