Using GIS for Compliance with EPA's Lead and Copper Rule

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girl at water fountain

According to the United States Environmental Protection Agency (EPA) and the Centers for Disease Control and Prevention (CDC) there is no known safe level of lead in a child's blood. Great strides have been made to address lead in the nation's water supply, starting with the Safe Drinking Water Act, which was signed into law in December 1974. The EPA subsequently issued the Lead and Copper Rule (LCR) in 1991, establishing even greater regulation to help remediate the ill health effects of lead in public drinking water. The LCR focused on establishing a Maximum Contaminant Level Goal (MCLG) of zero for lead, requiring optimized corrosion control for those systems having a difficult time controlling lead, educating the public about risks of lead exposure, and replacing lead service lines.

As of 2016, about 7% of households in the U.S. were estimated to have lead service lines, or an estimated 6 to 10 million lead service lines across the country according to the EPA. Because of continued public health concerns and certain water quality events, the EPA is revising the rule. The Lead and Copper Rule Revisions (LCRR) will be effective December 16, 2021. The compliance deadline for water system owners and operators of community and non-transient, non-community water systems will be October 16, 2024. Some of the revisions include the following:

  • Using science-based testing protocols to find more sources of lead in drinking water

  • Establishing a trigger level to jumpstart mitigation earlier and in more communities

  • Completing more lead service line replacements

  • Requiring testing in schools and childcare facilities

  • Requiring water systems to identify and make public the locations of lead service lines.

Supporting the Water Utility Owner

Water utility owners have an opportunity to be proactive and stay ahead of LCRR requirements. Identifying assets throughout your entire system that could result in increased monitoring requirements or compliance issues and acting early on will be key. In addition, you will need to make plans to address lead service lines, including galvanized service lines downstream of a current or prior lead service line and service lines of unknown material installed prior to the lead ban in the U.S. The current 2024 deadline is just three years away. We recommend that you do not wait for the final details of the LCRR to begin planning and collecting inspection and inventory data.

GIS for Visualizing the Data

You will need to identify the potential existence of lead on both the public and private sides of the service line connections for your entire system. The first step in the inspection program is planning: understanding the age of the distribution system and known locations of lead service lines, galvanized service lines requiring replacement, and lead status unknown service lines. This understanding is key to prioritizing and determining the scope and scale of the program.

Some utilities have good records of installations and work orders contained on valve or service cards that could provide critical information about each connection's age or material type. Unfortunately, this information is challenging to assess system-wide unless it is digitized and stored as an attribute of a GIS feature such as a service line or curb stop connection point. Manually entering this information would be a difficult task and can create quality control issues. Advanced technologies, such as machine learning, may be a solution for some utilities.

For several utility clients, GeoDecisions used machine learning to scan valve or service cards for specific pieces of information, perform translations where necessary, and enter the data as attributes to a geographic point in GIS. The quality of the original cards has much to do with the success of the machine learning translation. In one instance, we assisted a water utility in translating almost 7,000 valve cards in just three days. Using machine learning, we converted all the data from the cards into digitally available information, improving the completion time and accuracy of the data. Visualizing the valve or service cards results in GIS allowed this water authority to understand the approach, prioritization, and magnitude of the inventory program.

Machine learning was used to populate water lateral service lines with age and material type attributes as part of a planning initiative for lead and copper inspections. Machine learning saved countless hours of manual data entry.

Machine learning was used to populate water lateral service lines with age and material type attributes as part of a planning initiative for lead and copper inspections. Machine learning saved countless hours of manual data entry.

GIS for Tracking Inspections and Replacements

Developing secure and easy-to-use GIS web map applications to inspect and manage service line replacements can be integrated into an existing enterprise content management (ECM) or computerized maintenance management system (CMMS) programs. A simplified version of the web map or application can also be designed for the public to view the inspection results and understand their options for correcting any issues on the private side of the curb stop or meter. Public notification may also include personalized voice, text, or email prompted by the inspection results and can be configured in GIS. One possible option is GeoDecisions Notify.

Compliance, Design, and Contracting

Once you have identified your assets, particularly the lead service lines and other aging infrastructure, the next step will be to develop a lead service line replacement program. Consider leaning into a consultant that specializes in LCRR monitoring. You should be able to depend on the consultant to provide consulting and compliance services along the way, including LCRR monitoring and reporting program assessments, corrosion control treatment optimization studies and project implementation, public education materials development, water main replacement program design and implementation, and contract development.

The revisions to the LCR are just around the corner. Get ahead of the game and start mapping your lead service line replacement program today.

Contact Dave Gilbert at dgilbert@geodecisions.com to learn more about data capture, planning, inspection, and mitigation applications for your lead and copper program.

For additional insights about the LCRR, regulatory compliance, and keeping the lead out, contact Scott Hughes at rhughes@gfnet.com.