Newsletter: Lead & Copper Rules Require Action by October 2024

Michigan communities are making progress in removing harmful lead from the drinking water and complying with the requirements of the state’s revised Lead and Copper rules.

The Village of Nashville is one of Michigan’s proactive communities. It recently received $1.1 million from the state’s Drinking Water State Revolving Fund (DWSRF) to replace more than 300 service lines from the main to the building/house. The funding was a big relief.

“I applaud the state’s efforts to help us replace service lines and reduce lead action levels in the drinking water we provide to our customers,” said Scott Decker, Nashville’s Department of Public Works director. “The DWSRF funding relieves a heavy burden on us.”

Like all Michigan communities, Decker and other Nashville officials are still on the clock to prepare and maintain a comprehensive inventory of service line materials by October 16, 2024, and provide verification methodology. The inventories, to be submitted to the Michigan Department of Environment, Great Lakes, and Energy (EGLE), must also be updated every five years.

“We should have no problem completing our distribution system inventory prior to the deadline,” Decker noted. “We have the entire system up to date, thanks to a meter replacement project we recently completed, and we will finalize it once the lead service line replacement project is complete in 2023.”

Nashville is among dozens of Michigan community water suppliers using Fleis & VandenBrink (F&V) to complete the EGLE comprehensive report.

“Compiling a comprehensive distribution system material inventory and verifying the methodology has been time-consuming,” Decker noted. “We could not have done this without F&V’s assistance.”

The new Lead and Copper Rule requirements, set forth by the Environmental Protection Agency (EPA), went into effect nationwide in December 2021. But Michigan’s lead and copper rules are more stringent than US EPA rules when applied to cities with lead pipes.

The new rules:

• Require public water systems to replace all lead service lines.
• Reduce the lead action level from 15 parts per billion (ppb) to 12 ppb by 2025.
• Require a second water sample collection at sites served by lead service lines.

Regardless of tested lead levels, community water suppliers were required to begin replacing at least 5% of the lead service lines in 2021. Elevated lead levels also increase this service replacement timeline by administrative rule.

Annual reports to EGLE on the status of the replacement project is also required. EGLE has also moved up its annual lead pipe inventory deadline from the end of April to March 30, 2023.

The new rules also require increasing public communication and outreach, including notifying residents within 30 days of having known lead service lines connected to their homes.

F&V CAN HELP WITH NEW RULES, EXPECTATIONS
Community water suppliers with systems that have corrosive water, no inventories, and elevated lead and copper levels at homes, may have financial difficulties complying with the new rules.

But funding is available through the DWSRF for lead service line replacement on public and private property and asset management efforts. Low interest loans and principal forgiveness are also available for disadvantaged communities.

A smart approach could be to bundle service line replacements into another project. It would help accelerate community replacement programs.