In early 2023, the Biden Administration announced a bold national plan to remove all lead piping in the U.S water and sewer infrastructure within 10 years [Get The Lead Out - GTLO]. They followed up with specifics, and nearly $6 billion in funding to ensure “Clean Drinking Water and Wastewater Infrastructure” as part of Investing in America.
“Today’s announcement delivers funding to every single state and territory in the country to expand access to clean drinking water, replace lead pipes, improve wastewater and sanitation infrastructure, and remove PFAS contamination in water.”
In step with the administration’s initiative, in November of 2023, the U.S. Environmental Protection Agency (EPA), proposed new regulations with the Lead and Copper Rule Improvements (LCRI) to strengthen the initial Lead and Copper Rule (LCR), adopted in 1991, and revised in 2021 as the Lead and Copper Rule Revisions (LCRR).
The LCRR was proposed to help municipal and business leaders develop and maintain a service line inventory – essentially to map current existing conditions of water systems, including the material of each service line – and to require those inventories by October 16, 2024. The EPA has provided both written and video materials to guide municipal managers, corporate facility managers, and small businesses on creating water service line inventories, including:
- Provides best practices for inventory development and communicating information to the public.
- Includes a template for water systems, states, and Tribes to use or adapt to create their own inventory.
- Contains case studies on developing, reviewing, and communicating about inventories.
- Highlights the importance of prioritizing inventory development in disadvantaged communities and where children live and play.
Further, the LCRR guidance states that “The EPA does not expect to propose changes to the requirements for information to be submitted in the initial service line inventory. However, the rulemaking could include changes to the requirements for inventory updates.”
What Does This Initiative & Regulation Mean for Stakeholders, General Contractors, Engineers, and Water Managers?
The main focus of LCRI is to remove a greater portion of lead in the nation’s drinking water supply and improve upon LCRR’s enforcement, which included public disclosure of the number of lead service lines (LSLs) in public water systems, clarification of the sampling requirements, and made changes to how water managers are required to report their test results.
The LCRI has three main initiatives:
- Replacing ALL lead service lines in an equitable fashion
- Improving public health protections & reducing complexities
- Making public information and reporting more transparent
Of course, the marquee goal of LCRI is the same as GTLO: the complete removal of all LSLs – and all galvanized pipes laying downstream of lead pipes – plus removing any pipes whose material is unknown/unclassified.
Presently, the EPA estimates 9.2 million LSLs exist in the U.S.
LSLs as defined above applies to all lines, regardless of whether their lead action levels have caused human health exposure/impact. There is one very limited exception, mainly that the lines must be “under the control” of the water system operator.
Operators will also be required to inventory and tag all lead connectors and replace them. Municipal operators are required to make their service replacement plan available to the public. If the water system has in excess of 50,000 connections (users), the replacement plan must be made available online as well.
Other public notifications in the new regulations include delivering testing results within three days. Where those results exceed the allowable limit (0.010 mg/L), notification must occur within 24 hours, and the operator/municipality has to conduct a public education program within 60 days, repeated in another 60 days after each sampling period wherein the safe level is exceeded.
The cost to replace an LSL is estimated at $4,700, so the base cost to replace all lead drinking water lines with safer materials will have a price tag of about $43.3 billion.
$26.7 billion has been earmarked to replace lead water lines across the country
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So far, the LCRI is aided by $26.7 billion in funds from the Bipartisan Infrastructure Law – $15 billion to replace LSLs and $11.7 billion as part of Drinking Water State Revolving Funds, which can also be used for LSL replacement.
But, Not on Private Property!
It is important to note that LCRI does not provide for the cost of LSL replacement on private property, and it does not mandate states to cover the cost of line replacement for homeowners.
So, if you’re a developer or contractor, you may need to build the cost of LSL replacement into your design-build budget, and to identify any existing LSLs on your project.
Several states have already approved grant programs to assist consumer LSL replacement on private property, and more are expected to join them as the GTLO initiative moves forward.
Creating an Asset Management Plan for Your Community’s Service Lines
One area that GPRS’ Michael Wheeler, Market Segment Leader for Water & Wastewater wants municipalities to pay particular attention to what they need to do with their service line inventory once they have it. And that is to create an asset management plan.
“Take a rural community and Ohio or in Georgia that has one engineer on staff. They don't have the technical expertise to create an asset management plan. You're [the federal government] giving them money and then hoping that they just do their best with it. The idea is to give that rural community the money and give them a plan of how to attack.
Building an asset management plan, and giving rural communities a resource, like GPRS, who can be the consultant for you in building out your asset management plan… who can accurately locate your water and sewer system… to give you a condition assessment of your infrastructure.”
Where Do PFAS Fit In?
PFAS refers to per and polyfluoroalkyl substances – of which some 9,000 chemicals have thus far been identified. Usually, these man-made toxins come from manufacturing & industrial plants, and they are popping up throughout the U.S., with a higher concentration of PFAS polluting communities near industrial sites and military installations.
The EPA has proposed new National Primary Drinking Water Regulations regarding PFAS for six specific PFAS with proposed enforceable levels, monitoring rules, public notices, and processes to reduce PFAS in drinking water. The agency also prevented manufacture or use of 329 PFAS that are no longer used without a completed EPA review and risk assessment.
How GPRS Can Help With Lead Service Line Removal
The first step to removing an LSL is knowing it exists, and that means accurately mapping your water system infrastructure. Both pressurized drinking water lines and sewer lines [sanitary and storm sewer] must be located and mapped prior to daylighting potential lead lines and eventual excavation and replacement.
GPRS maintains a 99.8%+ accuracy rate in utility line location and mapping – the best record in the industry. Add our state-of-the-art, NASSCO-certified video pipe inspection (VPI) services to a standard utility locate to accurately map all storm and sanitary sewer lines, laterals, and to find cross bores caused by trenchless technology (directional drilling), and you can have a comprehensive map of your entire drinking and wastewater systems to make finding and replacing LSLs much faster and easier.
Further, every GPRS customer receives access to the company’s new SiteMap® infrastructure visualization software, that provides you with layered, interactive utility maps, and NASSCO WinCan reports in a secure, cloud-based platform, so you can control the quality of your water infrastructure information and who has access to it. SiteMap® allows you to put the right information into the right hands, at exactly the right time, and in the case of water infrastructure updates and LSL replacement, that time is undoubtedly NOW.
Frequently Asked Questions
How can I tell if my building has lead pipes that need to be replaced?
If you have access to the original record drawings that include MEP (mechanical electrical & plumbing) specifications, you may be able to determine the material of the original pipes. However, most record drawings are inaccurate and do not include renovations and updates. The conscientious process to assess and remove LSLs is to hire an expert utility locating company near you to locate your pipes so you can limit potholing to determine their material.