EPA Lead and Copper Rule Improvements (LCRI)

Author: Stephen Waldvogel
Drinking clean water

At a glance

The EPA's proposed LCRI tackles lead in drinking water with a three-pronged approach: replacing lead service lines, strengthening health protections, and educating the public. With mandatory compliance within just 10 years, GHD Technical Director for Water & Wastewater Treatment, Stephen Waldvogel shares his experience and insights to navigate this complex but crucial modernization.
Learn how to best approach the most important and challenging requirements of the EPA’s Lead and Copper Rule Improvements (LCRI)

Prioritizing and planning your approach to the EPA’s Lead and Copper Rule Improvements (LCRI)

The EPA (Environmental Protection Agency) has released the LCRI, the proposal would reduce lead exposure in drinking water through three focuses: replace lead service lines, increase health protection and boost public information and awareness through education. The rule requires states, water systems, and communities to better identify where lead service lines are, reduce lead action levels, act sooner to control corrosion and inform the community timely and clearly about health hazards due to lead exposure through drinking water. 

This new regulation will be expensive, labor-intensive, and logistically challenging. The reach of this modernization of the water systems across the United States is ambitious and it can be hard for utilities to pick a starting point and create a plan. 

With limited exceptions, it will be mandatory for Community Water Systems (CWS) to comply within 10 years of implementation. Our experience has taught us how to best approach the most important and challenging requirements of the LCRI.

Where to start

  • Inventory LSL’s – Included are new and enhanced inventory and LSL Replacement Plan requirements. In the absence of evidence of the material, it is assumed the service line is made of lead and should therefore be replaced. Through a package of analytical solutions data and document mining, we have developed a way to create a preliminary inventory of known LSL’s and unknown service lines (SL) from across a service area without breaking ground. Using modeling, we can predict not only the likelihood of lead in a specific unknown SL but also the estimated cost of replacement. Providing you with the documentation to verify which materials were used and complete the initial inventory of LSL’s within your system - currently required by the Fall of 2024 to comply.

  • Determine lead action levels – The limit is reduced from 15 parts per billion (ppb) to 10 ppb. To visualize this, imagine 10 ppb as the width of 10 human hairs in a 68-mile radius or 10 seconds out of 32 years. If the lead action level exceeds the new maximum, the utility will have to act and replace the service line.

  • Expand customer outreach and education - Utilities are required to take additional actions to notify their communities not only of the dangers but also how they can reduce their exposure until their lines are replaced. Simple actions such as running the tap water for a few seconds or adding water filters can help diminish exposure to lead in the water.

  • Water quality testing – The LCRI calls for increased water quality and corrosion control by collecting first liter and fifth liter samples at sites with lead service lines and use the higher of the two values when determining compliance with the rule in controlling water quality.

The marathon

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The proposed 10-year time frame to achieve the LCRI’s requirements is an ambitious goal. It will be a marathon not a sprint to get there. We partner with our clients and use cutting-edge tools combined with our team’s extensive knowledge and experience to reduce lead risks and make decisions best suiting their needs and reducing costs. GHD aids in finding funding, planning, identifying and prioritizing projects, design, oversee procurement and construction. It is important not to wait, there is a lot of work to be done, having a partner you can trust and has experience will be key to getting to the finish line.

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