The What, the Why and the How for Lead Service Line Inventories
By Mark Lannaman and Stacey Isaac Berahzer
Figure 1
An inventory to identify the service lines in water systems across the country has a deadline of October 2024, as set by the U.S. EPA’s Lead and Copper Rule Revisions (LCRR). Most water utilities, aside from Transient Non-Community Water Systems, must provide service line inventory information by the October deadline, which will eventually be used in efforts towards a correction to our water infrastructure nationwide: replacing the lead service lines of the past. Water providers now have a directive towards a water-infrastructure future without lead. But, how long has lead been associated with water pipes?
Lead use for water infrastructure dates back to ancient Roman times, when the material was selected for corrosive resistance and malleability. For these same reasons, generally speaking, along with availability and economics, lead was widely used to build out the U.S. water pipe infrastructure. Indeed, the very word "plumbing" comes from the Latin word for lead, plumbum. The lead pipes that were vital arteries of ancient Rome were forged by smithies whose patron saint, Vulcan, exhibited several of the symptoms of advanced lead poisoning: lameness, pallor, and a wizened expression.
Now that there is an abundance of literature and studies that show the dangers of even low lead exposure, especially for early childhood development, the federal government has laid the groundwork for the huge undertaking of replacing all lead service lines.
But, first, we need to identify which service lines have lead. Figure 1. Demonstrates a typical Georgia household’s service lines. To fund this inventory of service lines (and the eventual replacement of lead ones), water utilities can access different state and federal funds. Some examples of funding sources were provided in this earlier post. For example, the State Revolving Funds (SRFs) act as a critical funding source from the federal government, overseen by the Environmental Protection Agency and managed by each state. In Georgia, the SRFs are managed by the Georgia Environmental Finance Authority (GEFA). GEFA is heavily involved in funding for lead service lines (LSL) work.
While the main looming deadline is the inventory, to obtain SRF money for replacement, the entire service line must be replaced — both the utility-owned side and customer-owned side. This is an important distinction to make. According to the EPA, projects seeking only to replace the utility-owned side of LSL will not be eligible for SRF funding.
All water providers, even smaller ones, must complete this LSL inventory. The way Georgia’s Environmental Protection Division puts it: “The [Lead and Copper Rules Revisions of 2021] establish requirements for all Community Water Systems (CWSs) and Non-Transient Non-Community Water Systems (NTNCWSs) to develop and maintain a complete Service Line Inventory (SLI)”.
So, what are CWSs and NTNCWSs?
We should first look at what EPA considers a “Public Water System” or PWS: “A PWS provides water for human consumption through pipes or other constructed conveyances to at least 15 service connections or serves an average of at least 25 people for at least 60 days a year. A public water system may be publicly or privately owned.”
Fifteen service connections or 25 people is very small! This is why there are over 148,000 PWSs in the U.S.. EPA classifies these water systems according to the number of people they serve, the source of their water, and whether they serve the same customers year-round or on an occasional basis.
There are 3 types of PWSs:
Community Water System (CWS): A public water system that supplies water to the same population year-round.
Non-Transient Non-Community Water System (NTNCWS): A public water system that regularly supplies water to at least 25 of the same people at least six months per year. Some examples are schools, factories, office buildings, and hospitals which have their own water systems.
Transient Non-Community Water System (TNCWS): A public water system that provides water in a place such as a gas station or campground where people do not remain for long periods of time.
Numbers 1 and 2 are in bold above because these systems need to complete the service line inventory by October 16th 2024. These can include mobile home parks, subdivision, churches, schools, and the list goes on and on.
This is a mammoth exercise for the state because there are about 2,000 water systems to which this applies. Georgia has about 1,700 CWSs and roughly 170 NTNCWSs. (By the way, now you know the answer to this poll.) Since many of these systems are very small, and the EPA recognizes that smaller water utilities have fewer resources, the agency has outlined a Small Entity Compliance Guide and Fact Sheet to support such utilities in their efforts.
Fortunately, the state of Georgia has procured an inventory software, 120Water’s PWS Portal for these systems to use. The water systems are responsible for accessing their account and uploading their data. Water system staff need to start by registering here, where they can also sign up for one of the upcoming Q&A sessions.
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