Microbial/Disinfection Byproducts (M/DBP) Federal Rule Update

Note: this article is part 2 of a series to read part one, please visit the Aqua Talk article posted on March 9, 2022

In 2020 EPA began stakeholder engagement as part of its review of Microbial/Disinfection Byproducts (M/DBP) Rules. The M/DBP rules are an important suite of drinking water rules designed to protect the public from the acute risks associated with waterborne disease outbreaks by requiring strong treatment and disinfection. However, the rules also try to balance the chronic health risk associated with cancer from certain disinfection byproducts. The Safe Drinking Water Program (program) engaged in this process and shared some of our thoughts and experiences with these rules.

In a prior Aqua Talk Article we briefly shared our overall input to EPA on a variety of topics including evaluating sources of drinking water that could be Groundwater Under the Direct Influence (GWUDI) of surface water and disinfection treatment evaluations, risks associated with storage tanks and our approach to requiring disinfection residual throughout distributions systems in Colorado. EPA asked us to provide more detailed information regarding our experience with preventing microbial contamination with focus on disinfection, storage tanks and cross connections. In this article we summarize the input provided. 

The Alamosa waterborne disease outbreak in 2008 catalyzed our efforts to reduce exposure to pathogens in tap water. Alamosa had deep wells and no disinfection in place while serving 8,900 people. One thousand three hundred (1,300) people were estimated to have been sick during the outbreak. Twenty people were hospitalized and one person died. Twenty six (26) percent of those that were ill reported symptoms lasting a year and a half later. It was also estimated that 40 percent of the infants in town got sick. In addition, the outbreak caused severe impacts to the economy, and numerous businesses closed. While the cause of the outbreak was most likely animal waste entering cracks or holes in a storage tank, calculations showed that it likely took very little waste to contaminate the entire water system. Thankfully Alamosa has since made improvements to their water system and now provides adequately disinfected drinking water and continues to work to ensure the safety and health of consumers. However, with our goal to minimize waterborne disease risks statewide, we tackled disinfection and backflow prevention in addition to storage tanks.

Beginning in 2014, the program worked with stakeholders to address these issues in our Colorado Primary Drinking Water Regulations (Regulation 11). Key changes to regulations involved:

• Modified disinfection rules drastically reducing waivered systems
• Implemented minimum disinfectant residual of 0.2 mg/L
• Developed special rules for hand-pumped systems and water haulers
• Developed a special rule requiring routine and comprehensive storage tank inspections
• Updated and improved cross connection control rules

We shared with EPA some of the key results we have seen because of these changes, and will share some of that here.

Regarding disinfection waivers, the program has been regularly and thoroughly reviewing disinfection waivers and withdrawing waivers where needed, especially in response to positive total coliform or E. coli results in finished water. The chart below shows the number of public drinking water systems waivers has declined since 2007. By the end of 2022, we expect that there will only be two active disinfection waivers in Colorado. Overall, we believe that this decline in disinfection waivers better protects public health as the added pathogen contamination barrier of continuous disinfection is in place.

For the storage tank rule, we have about 1,400 storage tanks in the state subject to this rule. From April 2016 to August 2020, we issued about 300 violations of the storage tank rule and identified about 400 significant deficiencies involving storage tanks. Some of the specific items observed have included dead rodents in tanks as well as live snakes, and bullet holes. The most common concerns involve issues with hatches and vents. The good news is that well over 90% of these issues have been resolved. We believe this represents a significant improvement in risk reduction associated with storage tanks in Colorado as a result of implementing this rule.

We updated and/or developed handbooks related to water haulers and public water systems that operate primarily hand-pumped wells to include disinfection and operational practices. We also require that disinfectant residual in distribution systems be monitored and reported to the division. If values fall below 0.2 mg/L, then a treatment technique violation requiring tier two public notice can result. We also strengthened our ability to oversee the cross connection control rule and required that distribution systems be specifically surveyed for cross connections. Since 2016, hundreds of cross connection deficiencies and violations have been identified and corrected.

We believe that the overall risk reduction resulting from these efforts has been substantial. We have not had a waterborne disease outbreak at an active public drinking water system in Colorado since 2008. But waterborne disease outbreaks are tricky to confirm, so we also look at the number of E. coli violations. We think that looking over the course of decades is best to observe trends. Below are two charts showing both waterborne disease outbreaks and E. coli violations over the last few decades. As you can see, these trends show very positive results! 

This information was shared with EPA in 2021. We do not know exactly how EPA will use this information or the ultimate direction they will take with updating the M/DBP rules. We will keep you informed, and obviously you will have the opportunity to engage with EPA in this process as well. It will be the mid-2020s before EPA fully updates the M/DBP rules, but these are highly impactful rules and we encourage water systems to be aware of and engaged in the process. Thank you.

➽ Ron Falco, P.E. Safe Drinking Water Program Manager

Drinking Water Contamination Following Wildfires

In recent years we’ve seen an increase in frequency of wildfires occurring along wildland-urban interfaces across the western United States. Because of the increased incidence of wildfire causing large-scale loss of structures, more efforts by universities, water districts, and state regulators have been made to study the effects on drinking water infrastructure and the resulting water quality. When large-scale structure loss occurs, the type of chemical contamination that results is found primarily in the distribution system. Traditionally, most wildfire water quality concerns relate to source water contamination, especially when the wildfire primarily affects the watershed. However in recent years, contamination in distribution systems has also been observed. The distribution system chemical contamination being detected in some cases is made up of primarily volatile organic compounds (VOCs) such as benzene. Short term exposure to high concentrations of such chemicals is a public health concern.

By observing trends from the recent fires in California, Oregon, and Colorado, we have been able to determine factors that appear to lead to higher levels of VOC contamination. These factors include:

• A loss of pressure combined with burned structures and service connections
• Entry of smoke into broken or damaged water lines
• Plastic piping or other distribution system materials that have been exposed to high temperatures

In addition to observing factors that lead to contamination, there have also been important lessons learned that can help prevent or minimize contamination:

• Isolating damaged portions of the distribution system and service connections as soon as safely possible can prevent the spread of contamination
• Use unidirectional flushing when bringing damaged areas back on line and avoid flushing contaminated water through uncontaminated areas
• Contamination appears to be more severe in areas that experienced depressurization as well as damage. So extra caution should be taken when bringing these areas back on line. For example, issuing a drinking water advisory and completing additional sampling should be considered. 

In areas where depressurization occurs typical follow up sampling (coliform bacteria and disinfectant residual) should take place, as well as additional testing for VOCs. Water systems should work with CDPHE and their local public health agency to create a sampling plan that  identifies target contaminants, sample collection protocols, sampling locations (in the distribution system and surviving buildings), and data quality and management. 

In recent fires we have observed that contamination tends to absorb into distribution system piping and can leach out over time. Because of this, it is important to let the water stagnate, with no movement or flow in the line before sampling. Ideally, the stagnation period should be 72 hours but if that is not feasible shorter times are acceptable. 

Remediating VOC contamination can be a long term process. Flushing is the primary method of removal but at times, infrastructure replacement may be necessary. 

Don’t hesitate to reach out to us if you have any questions, would like more information on this topic, or would like any input on activities such as emergency planning and tabletop exercises. For additional information see the EPA’s guidance on Addressing Contamination of Drinking Water Distribution Systems from Volatile Organic Compounds (VOCs) After Wildfires

➽ Chelsea Cotton, P.E. Source Water and Emerging Contaminants Engineer

Lessons learned from boil advisories: Do you really want to sample a home for compliance? Total coliform special sample stations

In the Aqua Talk post on April 6 about the total coliform rule and potential for boil advisories, we discussed that we will publish additional articles about these large-scale boil advisories and the specific challenges and lessons learned. As a reminder, the four part series is covering the following topics:

1. Total coliform perfect storm - incidents that could lead to a boil advisory - April 6, 2022
2. Public notice to thousands - Special steps for large scale advisories - April 20, 2022 
3. What language do your customers communicate in? - Accomplishing public notification considering your community - May 11, 2022
4. Do you really want to sample a home for compliance?  - Total coliform special sample stations (today)

Both the Englewood boil advisory event in August, 2021 and the Marshall Fire that started on December 30, 2021 led to boil advisories affecting more than 25,000 people. To read more about the Marshall Fire boil advisories, see our April 13, 2022 article.  

Today, we want to explore proper total coliform sampling locations. Generally, suppliers of water (regulatory speak for public water system operators and employees) collect total coliform samples from three types of sample taps:

• Indoor taps, 
• Outdoor taps, spigots, or hose bibs, and 
• Dedicated sample stations.

The regulations require that sample locations are previously identified in the supplier sample siting plan (sampling plan) and that the identified sampling sites and sample collection schedule are representative of water throughout the distribution system. Outside taps, spigots, and hose bibs are open to the atmosphere, dust, and animals. Such taps may be subject to higher levels of contamination than inside sampling taps or dedicated sample stations. Outside bacteria sampling sites are not generally recommended due to the risk of contamination, but are allowed. 

Occasionally, suppliers may not have access to a previously identified sample location. If a supplier chooses to sample an outdoor sample location that is not identified in their sampling plan, the supplier must update its total coliform sample siting plan and make sure that the new site is representative of distribution system water quality. Suppliers can easily add their total coliform sample sites using the drinking water portal. If you have any questions, please contact your drinking water compliance specialist. Please be advised that the department will not invalidate positive total coliform or E. coli results just because the samples were collected at outdoor locations.

If a system chooses to collect total coliform samples from outside locations, the department recommends that the supplier take the necessary precautions to ensure that the sample tap is properly cleaned and disinfected with bleach or alcohol before the sample is collected. 

Similarly, indoor sampling sites may be poor sampling sites. Any time water flows through internal building plumbing or pipes not under the control of the water system, the sample is susceptible to contamination. If a system chooses to collect total coliform samples from indoor locations, please be sure to always sample cold water, allow the water to flow for at least five minutes before sampling and remove any attachments on the faucet. The department recommends that the supplier take the necessary precautions to ensure that the sample tap is properly cleaned and disinfected with bleach or alcohol before the sample is collected. Avoid:

• thread taps, swing sprouts, leaky faucets, faucets connected to cisterns, softeners, pumps, pressure tanks
• hot water heaters and tempered water faucets that combine hot and cold water. 

Please be advised that the department will not invalidate positive total coliform or E. coli results just because the samples were collected at indoor locations.

When considering where to take representative bacteriological sampling in your distribution system, it is important to consider that neither location discussed above, outdoor spigots or indoor private building taps best represent water in your distribution system. Despite the possibility that these sites may not be the most representative of water in the distribution system, they are allowed in the rule due to practicality of sampling throughout the service area.

An alternative to sampling at the locations indicated above is installing dedicated sampling stations. Regulation 11 and the Revised Total Coliform Rule allow for representative sampling from sample stations. Specifically, the rule states: 

“monitoring locations may include a customer’s premises, dedicated sampling station, or other designated compliance sampling site.” 

Sample stations could reduce the risk to suppliers of detecting site-specific contamination as mentioned above, due to issues with sample locations at outdoor spigots or indoor plumbing. Suppliers that install and sample from dedicated sample stations generally will have more control of the sampling tap by preventing its use by unauthorized persons and allowing no routine use of the tap except for sampling. A dedicated sample tap is also less susceptible to contamination and generally will be able to provide the most representative sample of a supplier's distribution system. The dedicated sample stations are installed on or near a water main therefore the quality of the water in the service mains is not impacted by service lines or a premise plumbing system. Sample stations could also allow suppliers more flexibility when identifying their system's most representative sample locations since they are not limited by owners or building occupants who may restrict access or not be available. Another benefit to these sample stations is that they can be used by the supplier to sample for other water quality parameters (i.e. chlorine residual, pH, turbidity).

Since several entities in Colorado already have experience with installing sampling stations and their proper upkeep, we recommend that utilities work with peers to properly budget, plan, and install sampling stations should you choose to pursue this specific option. The department is happy to provide contact information of utilities that have success with dedicated sampling stations.

➽ Jorge Delgado, P.E. CDPHE - WQCD

2023 State Revolving Fund Eligibility Survey Open June 1 - June 30, 2022

This survey is conducted on an annual basis by the Colorado Department of Public Health and Environment’s Water Quality Control Division. The survey is used to identify water and sewer infrastructure improvements, as well as stormwater and non-point source needs, that are eligible for funding through the Drinking Water Revolving Fund (DWRF) and Water Pollution Control Revolving Fund (WPCRF) grants and loans programs. All municipalities, counties, districts, public water systems, not-for-profit water systems and other special districts that own or operate public water, sewer, or stormwater systems in the State of Colorado are encouraged to participate.

The survey will remain open from June 1st through the submittal deadline of June 30th.

Resources: 

• The Division’s SRF website: DWRF and WPCRF program details, survey instructions and other useful information regarding the annual survey.
• After reviewing the division website create a profile on the Colorado Environmental Online Services (CEOS) portal and begin your SRF Eligibility Survey 
• Opt into the division’s notification service to receive timely information about SRF and other funding opportunities available through both State and Federal sources.
• If you have questions or require any assistance with the CEOS portal or the eligibility surveys, contact the Grants and Loans Unit at CDPHE_grantsandloans@state.co.us or Erick Worker at erick.worker@state.co.us.

Important:

• Entities must submit an eligibility survey and be on the Eligibility List to be eligible for funding. 
• Entities currently identified on the existing 2022 DWRF and WPCRF Appendix A - Project Eligibility Lists, are eligible to receive BIL funding in 2022 for the water and sewer infrastructure needs listed. See below for more information regarding BIL funding.
• Entities not on the current project eligibility lists will need to complete and submit the eligibility survey through the CEOS portal no later than June 30, 2022, to be added to the 2023 project eligibility lists for BIL funding.
• The surveys have been updated to include sections regarding lead service line replacement needs and emerging contaminants treatment needs. Please remember to complete those sections if you have a funding need for those projects.

Eligible projects can secure competitive, low interest loans with repayment terms of up to 30 years. Completion of a survey is the first simple step towards obtaining funding. It is not an application and it does not obligate an entity to apply for financial assistance; however, identifying capital improvement needs through the Eligibility Survey is a required prerequisite of securing funding offered through the DWRF and WPCRF programs. Loans and grants cannot be extended to applicants who have not responded to this important survey.

The Bipartisan Infrastructure Law (BIL), previously referred to as the Infrastructure Investment and Jobs Act (IIJA), was signed into law on November 15, 2021. The BIL invests more than $50 billion nationally over the next five years in EPA water infrastructure programs including the SRF. Colorado’s first year allotment for the DWRF and WPCRF programs totals approximately $121 million. 

BIL funding will be issued as both loans and additional subsidization in the form of principal forgiveness. Entities seeking BIL funding must be eligible under the existing DWRF and WPCRF programs. Additional subsidization is available to eligible entities that meet the BIL Principal Forgiveness Eligibility Criteria described in the proposed addendum to the 2022 Intended Use Plan. BIL also offers dedicated funding to replace lead service lines and emerging contaminants such as PFAS (per- and polyfluoroalkyl substances).

➽ Erick Worker, Project Manager, Water Quality Control Division, Grants and Loans Unit

Highlights of the CCWP and Operator Certification Board websites

The Colorado Certified Water Professionals (CCWP) website contains a wealth of information to answer frequently asked questions about the operator certification program. From the home page, you can move to two other main sections: one dealing with the CCWP Portal and the other concerning certification and other operator issues. The home page also includes links to:

• Contact information for the CCWP office
• Search engine for looking up certified operators 
• Course catalog for training opportunities approved for continuing education credit
• List of jobs boards that post certified operator positions

The CCWP Portal page provides links to:

• The CCWP Portal Log In
• Free, online courses approved to meet the mandatory regulatory training requirement
• Video tutorials to help operators and course providers navigate the portal and enter data 

The CCWP Program section answers the most common certification and operator questions. It links to pages that: 

• Provide step-by-step instructions for becoming certified in Colorado, including information about:
• Submitting applications through the CCWP Portal
• Fees
• Scheduling exams
• Remote testing option
• Exam preparation
• PSI test center guidance for exam candidates
• Explain the certification options and process for operators coming to Colorado from other states to seek reciprocity 
• Detail the requirements for upgrading certificates
• Explain the criteria and process for certificate renewals
• Provide information about accommodations for military and veterans, including how credit is calculated for military training and experience

The CCWP Program section links to a page for operators in responsible charge. From this page, ORCs can find information to help with the development of written delegation plans for subordinate operators, as well as information about the required written agreement between ORCs and facility owners. There is also a link to ORC contact update forms.

From the CCWP Program page, you can open a link to a listing of contract operators who provide services in Colorado. Finally, the CCWP Program page includes information and a form for operator misconduct complaints.

The Water and Wastewater Facility Operators Certification Board maintains its own website. In addition to meeting and hearing information, the board’s website posts the following documents you may be interested in:

• Current version of Regulation 100 
• Colorado Certified Water Professionals Code of Conduct
• WWFOCB board’s formal policies, guidance and procedures

➽ Nancy Horan, Facility and Operator Outreach and Certification Board Liaison

Coaches Classroom: How to use your monitoring schedule and COC to avoid compliance issues

When we discuss creating a culture of public health among drinking water professionals, a key aspect of this culture is clear communication. This article discusses two tools used to communicate: 

1. Monitoring Schedule. The Drinking Water Compliance Assurance section uses this document to communicate your systems specific monitoring requirements based on Regulation 11. 
2. Chain of Custody. Drinking water systems use this to communicate which chemical or bacteriological analysis they would like performed on their samples, the turnaround time for the results, the location at which the samples were taken, and the order and manner in which the samples have been handled.

These two tools are crucial to ensuring that you are sampling at the correct time, for the correct analyte, and at the correct location, while correctly reporting the information to the division. 

Why is it important to sample? 

As drinking water professionals our main goal is to protect human health by providing safe drinking water to the public. We do this through establishing, maintaining, and monitoring the barriers to waterborne disease outbreaks, lowering levels of lead exposure and mitigating chronic health impacts from chemical and radionuclide contaminants:

• Source water protection
• Treatment
• Monitoring potential contaminants
• Storage
• Distribution
• Public Notification

Compliance sampling generates the data that confirms that the hard work to maintain the multi-barrier approach is working. We all use compliance data to drive our actions.

Monitoring Schedules 

Last year our coaches described the monitoring schedule in detail. To summarize, your monitoring schedule can be used to: 

• Identify where to sample, when to sample, and for what analyte,
• Plan your system’s sampling schedule for the calendar year,
• Verify that your sample results are being received by the division,
• Identify which analytes are required sampling for your system, and
• Help you fill out your chain of custody (COC) for your lab.

The monitoring schedule can also be used to help you budget for your system’s annual monitoring cost. The most up-to-date monitoring schedules can be found by visiting the division’s monitoring schedule website and searching for your system’s PWSID (COXXXXXXX) or name. If you cannot access the internet to find your monitoring schedule please contact the Compliance Assurance Unit’s public assistance line at 303-692-3556. 

Your monitoring schedule will be updated on the division’s website every Thursday to reflect up-to-date schedule and sample results received information. It may take a few weeks for submitted samples to be reflected in the schedule due to lab turnaround and reporting time. 

If you notice something in your schedule that is incorrect such as outdated contact information, incorrect facilities, and sample sites, please submit sections of your monitoring plan that need to be updated. 

Resources: 

• Division’s monitoring schedule website 
• Example monitoring schedule
• Further sampling specifics information

Chain of Custody

The above snap shot is from the most up-to-date CDPHE drinking water COC. 

The best way to ensure that your samples are processed appropriately is to follow these rules: 

1. Contact your lab prior to sampling. We suggest you send them a copy of your monitoring schedule so they can help you fill out your chain of custody accordingly. 
2. Follow hold times and temperature: every analyte has its own specific hold time and temperature. If the samples deviate from the appropriate ranges the lab can no longer use them for compliance analysis as they are no longer valid. Discussing these hold temperatures and times prior to sampling will help you set up your process to return the samples to the lab. 
3. Sample early in the monitoring period. Remember it can take days to weeks for the lab to analyze the samples. Sampling early will ensure you do not miss your compliance sampling and reporting deadlines. 
4. Order extra sampling kits/bottles. This way if you have any issues during the sampling event, you don’t have to wait for new bottles to sample. 
5. Label your sample bottles and fill out your COC prior to sampling.
6. Ensure sample results are submitted in a timely manner – even if they are not due yet!

In some cases, reporting sample results long after they’ve been analyzed can result in violations. For example, if a sample result is high enough to trigger increased monitoring, the supplier will be accountable for all monitoring periods in which they should have been on increased monitoring. Monitoring violations would be issued for all missed monitoring periods and compliance with the maximum contaminant level would be evaluated with the data received over the applicable monitoring periods – even if those quarters did not have data! 

Routinely check your monitoring schedule. You will know that the division has received the sample results because they will be crossed out on your schedule. 

Most labs report data directly to the division through the drinking water portal. Please check with your lab to make sure they will do this for you. This will help ensure that your data is processed in a timely manner and avoid duplication in the data processing.  You must provide the following required information to the lab on the chain of custody if they are reporting the data on your behalf:

• PWS ID - if you do not know you PWSID it is listed on your monitoring schedule
• Facility ID - exactly as listed on your monitoring schedule
• Sample Point ID - exactly as listed on your monitoring schedule
• Collection Date.
• For total coliform bacteria samples:
• Free Chlorine in mg/L.
• Total Chlorine in mg/L (only needed for systems with chloramines).

How to correct errors made in data submission?

Sample reporting errors with facility ID, sample point ID, chlorine residual type, or incorrect measurements can be corrected by resubmitting a revised CSV, creating and submitting a Sample Correction Form, or submitting a copy of sample results with corrected information clearly indicated, via the Drinking Water Portal, fax, or mail or by having your lab resubmit corrected results. Any corrections must be received by the applicable reporting deadline. The collection date, lab name or ID, lab sample ID, analyte, facility ID, sample point ID, and residual must be submitted correctly or the requested correction will not be processed, resulting in a monitoring and reporting violation. Updated CSVs with the same Lab ID, Lab Sample ID, and Analyte are considered revisions, and the most recent submission is used.

If a deletion is needed, please send a PDF through the drinking water portal, using the “Requests and Other Certifications” category or a fax, or mail. The request must include the unique lab sample ID, collection date, analyzing lab, analyte, and the reason for the requested sample to be deleted.

➽ Kyra Gregory Drinking Water Training Specialist

Lead and Copper Rule Revisions: Start Preparing for Upcoming Requirements

Lead has long been recognized as a toxic metal that can be harmful to multiple body systems, even at low exposure levels. Lead is particularly harmful to the developing brain of small children and can result in functional impairment. Lead can enter drinking water through the corrosion of lead-containing plumbing materials such as pipes, faucets, and fixtures. 

On December 16, 2021, EPA finalized the Lead and Copper Rule Revisions (LCRR), which further strengthen the protections against lead in drinking water. The LCRR requires water systems to meet a number of new requirements, including:

• Water systems must develop a system-wide lead service line inventory and lead service line replacement plan by October 16, 2024.
• Compliance with a lead “trigger level” of 10 ppb that triggers additional planning, monitoring, and treatment requirements.
• Lead testing in schools and childcare facilities.
• “Find and Fix” at any individual tap above the 15 ppb lead action level to quickly investigate and potentially remediate the source of the lead.
• Strengthened corrosion control treatment, lead service line replacement, lead sampling, and public education measures. 

The lead service line inventory (LSLI) and lead service line replacement (LSLR) plan are key elements that support the LCRR’s overarching goal of proactive lead service line removal and more equitable public health protection.

What is a Lead Service Line Inventory (LSLI)?

The LCRR requires all water systems to submit a lead service line inventory by October 16, 2024 of every service connection in the distribution system to classify the material, of both customer-owned and utility-owned portions of the service line, as one of the following:

• Lead: All or a portion of the service line is lead.
• Galvanized requiring replacement: Galvanized iron or steel service line that is or was at any time downstream from a lead service line or is unknown to have ever been downstream from a lead service line.
• Non-lead: No portion of the service line consists of lead or galvanized requiring replacement.
• Lead status unknown: Service line is not known to be lead, galvanized requiring replacement, or non-lead.

Water systems must take steps to verify service line materials to ensure a complete and accurate inventory. Systems should verify as many “lead status unknown” service lines as possible since unknown service lines are treated as lead service lines unless proven otherwise. Most suppliers should be able to use a combination of knowledge of prohibitions, such as the federal lead ban in 1986, and local ordinances, records review, physical verification, and/or statistical modeling to determine service line materials without physically verifying each line. Only when there is a lack of records and great inconsistency in identified materials during physical verification would a system need to physically verify a large number of their service lines.

The LCRR aims to expand customer awareness, and as such, water systems must make their lead service line inventory available to the public, and systems serving greater than 50,000 people must also make their inventory available online.

Who needs to complete the LSLI?

All community and non-transient, non-community water systems must complete and submit a LSLI to the department. The department is requiring that water systems submit an inventory summary with the total number of service lines in each material category (e.g. lead, non-lead, lead status unknown). Systems with lead or galvanized requiring replacement service lines must also submit a detailed inventory of each lead or galvanized requiring replacement service line with a location identifier (i.e., address or block) and the material classification.

Resource: Lead service line inventory forms and a requirements/FAQ document are available on our website.

What is a Lead Service Line Replacement (LSLR) plan? Do all systems need to complete a LSLR plan?

Water systems with lead, galvanized requiring replacement, or lead status unknown service lines must submit a lead service line replacement (LSLR) plan to the department by October 16, 2024. Completing the LSLR plan will help systems prepare to remove sources of drinking water lead exposure and for identifying the material of unknown service lines. The LSLR plan must be sufficiently detailed to ensure the system is able to comply with the lead service line replacement requirements in the LCRR.

Water systems that have verified that their distribution system contains only non-lead service lines are not required to complete a LSLR plan.

Resources: A lead service line replacement plan template and requirements/FAQ document are available on our website .

The department encourages water systems to begin working on the LSLI and LSLR plan as soon as possible as these will require substantial resources to complete. Stay tuned for additional information on forms and guidance as well as upcoming public meeting opportunities.

➽ Haley Orahood, Regulatory Development and Implementation Specialist

➽ Bryan Pilson, Technical, Regulatory Implementation, and Coordination Unit Manager