Preparing Public Utilities for Lead Service Line Requirements

In 1986, federal laws were enacted that prohibited the use of lead in plumbing and fixtures, which can leach into the water supplies and cause serious health problems.

While the laws prevented new lead installations, they did not require removal of historic lead service lines. Utilities have been required to sample for lead in their systems, and many utilities add a corrosion inhibiting additive to the water to limit any possible leaching of metal.

Regulations have been advanced and made more stringent over time, and in the latest round of regulations to combat this highly visible issue, the Environmental Protection Agency (EPA) is requiring public utilities to develop a comprehensive water supply line inventory. The goal is to provide better documentation of what systems are in place, provide more information to the public, and more efficiently plan for replacements where needed.

This means that by October 2024, water utilities must review their entire system and identify all properties where service lines are constructed out of potentially hazardous lead or galvanized steel materials. This includes both the utility-owned portion of service lines, as well as the privately-owned piece. Importantly, any service lines with “unknown” materials will be regulated as if they were lead.  

Developing an inventory is a task that, for most of these water suppliers, is daunting, for several reasons.

First, while records may be detailed and current for assets owned by the agency, the records regarding utilities on private property are often incomplete or non-existent. Second, many utilities have been hard at work since the 1986 amendment to the Safe Clean Drinking Water Act to remove lead fixtures from their systems and take other measures to comply with subsequent amendments.

This new regulation, and the short time frame in which it must be achieved, leaves many utilities feeling like the finish line keeps moving further out, with diminishing returns.

This new regulation enters relatively new and unchartered territory, as there are not many practices and procedures prepared to create inventories of service line materials on private properties.

But there is a path forward, and WSP USA is in a strong position to help these utilities create the roadmap that works for them.

There are some things public utilities can do today that can make this daunting effort more manageable.

1. Digitize the record collecting process. Utilities should begin work now to organize and scan paper records. Make it simple to compile, clear to understand and easy to upload from the site so that when the work is done, the property has been recorded and no further work is necessary. Similarly, utilities should create forms to record information observed by their staff, or customers, whenever work on plumbing in the house or in the yard is performed. Linking it to the GIS will confirm the property location and allow for improved analysis down the road.
2. Create an inventory of properties built after 1986. Rule out all properties that should already be compliant. That includes all properties built after the federal rules prohibiting lead in drinking water were enacted. Some states and local municipalities enacted this regulation even earlier, so it may encompass even more properties in those areas. Identify and eliminate those properties as being at risk.
3. Conduct “Scratch and Sniff” Tests. Public utility service professionals already visit numerous properties every day for a variety of tasks, from meter reads to meter replacement and maintenance. That creates a great opportunity to add one extra step on the trip and conduct a simple but effective “scratch and sniff” test. How does it work? The service professional can examine and test the metallic plumbing near the wall of the premise by scratching it. If it is soft and gray in color, it is likely a lead pipe. If the material is hard and appears orange, then it is copper. Anything else would indicate a material that is most likely safe. Utilities may also want to create a program for customers to self-document their piping using a similar process. All work should be documented with photographs when possible.
4. Apply for funding. The 2021 federal “Infrastructure Investment and Jobs Act” includes $15 billion in funding for lead service line inventory and replacement work. Nationally, it is estimated that completing the work to identify and remove lead service lines could cost up to $60 billion, so it is likely that this funding will go quickly. Most of this funding will be provided through each state’s Drinking Water Revolving Fund program, so utilities should review the process and schedule for applying and submit an application as soon as possible.
5. Find a partner. Even with these approaches to streamline the process, it’s a tall order for public utility employees to handle this massive endeavor on their own and still conduct their essential work. There are firms that have the necessary infrastructure to perform this task efficiently without taking away from those critical responsibilities. It will also be critical to develop an effective communications program for customers who may be concerned and confused about the cost, schedule and health impacts of compliance with the new regulations. An initial investment may lead to significant savings in the long run for a utility.

Even the most efficient process is going to be an expense for all public utilities. Fortunately, as noted above, there will be federal and state funding available to cover a significant amount of these expenses. In my next article, I will explore this aspect of the lead and copper requirements.

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