Lead Service Line Replacement Plans – Does Your Facility Need One?

The United States Environmental Protection Agency (U.S. EPA) published the Lead and Copper Rule (LCR) in 1991 to protect the public from potentially contaminated drinking water coming from water pipes using copper or lead materials. Since the initial rule in 1991, the EPA has modified the rule as needed such as the 2021 Lead and Copper Rule Revisions (LCRR). These ongoing modifications have been catalyzed by President Biden’s Bipartisan Infrastructure Law and are set to make great strides in reducing public exposure to lead and copper in drinking water.

Is the LCRR applicable to your industrial facility?

Of these ongoing rule changes packaged with in the LCRR, one of the most impactful regulations is the “Lead Service Line Inventory and Replacement Reporting Requirements” codified in 40 CFR 141.90(e). This regulation affects community water systems and non-transient, non-community water systems under 40 CFR 141.80(a)(1). Non-transient, non-community water systems (NTNCWS) are defined as a public water system that regularly serves at least 25 of the same persons over 6 months per year. NTNCWS includes industrial facilities, schools, office buildings, or hospitals that supply potable water for employees.

Lead Service Line Replacement Plan

The “Lead Service Line Inventory and Replacement Reporting Requirements” sets the date of October 16, 2024, for facilities to create, and submit to the state, a lead service line inventory as well as a lead service line replacement plan.

The lead service line inventory requires facilities to identify the materials of service lines connected to the water distribution system. The lead service line replacement plan requires facilities with lead, galvanized requiring replacement, or lead status unknown service lines to create a lead service line replacement plan. The plan is required to detail a strategy to determine the presence of lead in service lines as well as replace them if need be.

What’s The Next Step

The lead service line inventory and replacement plan are comprehensive reports that will set up a framework to do away with lead-based piping systems. These reports will require a detailed look at current systems and possible modifications. With only a little over a year left until the compliance deadline there is no time like the present to start building your inventory and plan. If you have questions or want to discuss your compliance strategies, reach out to Evan Mia at emia@all4inc.com.