Your Lead Service Line Inventory is foundational to Lead and Copper Rule Compliance–and while it may be tempting to put off this project until further legislative steps are taken, systems should begin the process now to keep up with compliance deadlines. 

Inventory deadline: 2024

LCR will go into effect in 2024, and we believe it will only get more complex. 

The Biden administration has placed a freeze on the legislation for review, however, the primary content of the revised Rule is likely to remain largely the same, with any updates making it more strict than its current form. Legislation will go into effect in October 2024. 

At that time, systems will need to submit the first draft of their inventories–inventories that not only show where lead can be found in your communities, but have been validated to confirm its presence. The validation process is essential to verify your current data set and fill in gaps. For tips on what validation techniques make sense for your system, check out our Inventory Validation Guide. 

Understanding the requirements of the Revisions, progress toward compliance should begin now to allow ample time.

A Validated Inventory Leads to LCR Compliance 

Knowing where the lead is–and having that location verified–will be the basis for the majority of the LCR compliance requirements. For a full list of requirements and due dates as they stand, view our LCR Pipeline. The revisions introduce numerous new mandates that will be based around this validated inventory–without it, your system could use up valuable resources trying to make up for lost time.

Your inventory will be the basis of the LSL Replacement plan required by the revisions, providing the foundation for the next several years of work as lead pipes are removed. You’ll also need to notify all customers served by LSLs or unknown materials in 2024, a significant communication challenge that won’t happen without accurate inventory data.

The inventory will also dictate your Tier Site Monitoring, where utilities will soon be required to provide 1st and 5th liter sampling at any home with a known LSL. Accurate Tier Lists can only come from an accurate inventory. 

A project of unprecedented scale

The scope of the LSL inventory project will require years of planning and collaboration. 

Inventory is a massive project, and utilities need time to unravel all the moving pieces. In what is essentially a large-scale data puzzle, gathering and validating the numerous relevant parts will be a big undertaking. According to polls conducted during 120Water webinar sessions, 82.7% percent of utilities are missing complete data on private-side line materials. Tools such as 120Water’s Inventory Management Solution can expedite this process, but performing an audit of the current data in your utility will help to build a realistic timeline. 

In addition to data complications, you’ll need to bring together multiple departments to collaborate on this project, including contractors and third party services to empower your team. Building the inventory, validating materials, and completing replacement efforts is potentially a decades-long process, and postponing the process is one more day your community has to live with the possibility of lead in their drinking water. 

Take advantage of federal funding

Make yourself eligible for funding opportunities with a “shovel-ready” inventory. Numerous funding sources have been made available to systems for infrastructure, including water quality and LSL-related projects. Utilities should focus efforts on LSL inventorying if they hope to capture a piece of this funding pie. 

Many of the sources will prioritize “shovel-ready” projects, which implies at the very least an estimation of lines, and most likely a complete inventory. Replacing service lines will be a costly endeavor, and you’ll likely need to utilize funding that’s been made available–waiting to begin your inventory will not put your system in a position to capitalize on those opportunities. 

Save time & money 

The Lead and Copper Rule Revisions are certainly the most important legislative changes in the world of drinking water in decades, however, regulations will continue to evolve as we learn more and as public pressure to remove all lead from the ground mounts. We recommend operating under a future-proof definition of what constitutes a lead service line, collecting public and private information on the following up front:

• Lead Pipes
• Lead Fittings
• Copper with Lead Solder
• Galvanized Lines
• Unknown Materials

This is a project large enough you don’t want to have to do it twice. Approaching it with a broader mentality of what may constitute a replaceable service line will save your utility valuable time and money down the road as regulations evolve. 

Where to begin

Systems are juggling a lot of priorities right now, and it can be easy to assume that with no immediate deadlines, this project can wait until next year. We hope you’ll consider the reasons it’s important to start now so your system is set up for success in the future.

If you’re wondering exactly how to get started, schedule a call with our team and we’ll walk alongside you to assess the best next steps for your system.

Kelly Smith

×

Kelly Smith