Tackle LSL Materials Inventory and Corrosion Control Treatment with a Phased Approach

The EPA’s Lead and Copper Rules Revisions (LCRR) went into effect on December 16, 2021. The LCRR mandates that water providers should have a service line materials inventory ready by October 16, 2024.

The developing Lead and Copper Rules Improve­ments (LCRI) aims to reevaluate and expand on the LCRR. Most likely, the LCRI will seek to eventually replace 100% of all LSLs as well as make other changes to the LCRR. LSL inventory require­ments, however, will not be affected by the forthcoming changes envisioned by LCRI.

Under the LCRR, water systems will be required to identify materials for all service lines including the locations of lead service lines and make that information publicly available. Building and managing a service line materials inventory will be a substantial effort. Inventory development is required regardless of whether the system has LSLs or not. Some states are providing templates indicating all the information that must be in the materials inventory. All systems must include information for both utility-owned and privately-owned service lines without exclusion. The inventory information must be made publicly available. For large systems serving over 50,000, this information must also be published online on the utility’s website.

Although not required to identify the materials of every service line ahead of October 2024, water utilities will want to reduce the number of unknowns as much as possible. Water utilities will be required to send an annual noti­fi­ca­tion to any properties with remaining unknown service line materials, along with any identified lead service lines, about the dangers of lead in drinking water. Annual updates of the inventory are required starting in October 2024 until there are no unknowns or lead service lines remaining.

To stay on track and develop a complete inventory by October 2024, here is the three-phased approach to getting that inventory up and running:

• Phase 1
  • Compile your initial data and determine unknowns to create the baseline for your service line materials inventory.
  • Develop a data management solution to unify all your data platforms and ensure that everyone is moving in the same direction and all updates are being captured.
  • Evaluate veri­fi­ca­tion strategies that will work best for your utility and customers.
• Phase 2
  • Implement selected material veri­fi­ca­tion strategies.
  • Begin material predictions with a machine learning model.
  • Collect additional information and validate or update the assumptions and predictions.
• Phase 3
  • Develop a public website and host inventory online.
  • Continue to update inventory with new information.
  • Submit inventory by October 16, 2024.

The LCRR will be more challenging to meet the lead action level and the new trigger level, especially for utilities with LSLs who will have to sample the 5^th liter. It is recommended that utilities, especially those with LSLs, evaluate their current lead levels and corrosion control treatment to see if they need to make a change in order to optimize prior to the new sampling and levels taking effect in 2025. It is imperative to begin the process as soon as possible:

• Phase 1
  
  • For all utilities, review previous studies including water quality, historical tap sample data, and studies and confirm if those studies comply with the new LCRR.
  • Sample the 5^th Liter at homes with known LSLs.
• Phase 2
  
  • Review 5^th L sampling data.
  • Consider pipe scale analysis if you have any LSLs.
  • Perform desktop solubility model.
  • Prepare a CCT baseline review memo with findings and recom­men­da­tions.
• Phase 3
  
  • Perform a CCT study to reoptimize treatment and implement revisions if needed.
• After October 2024
  
  • Maintain optimized CCT and update as needed.

Always stay up to date with LCRR and the potential changes that may arise. Our Journey to LCRR Compliance webinar provides more in-depth information regarding some of the additional require­ments you need to prepare for before October 2024 rolls around.