JMT is working with clients in Delaware, Pennsylvania, and Virginia to ensure they comply with the latest reporting requirements defined in the Lead and Copper Rule (LCR) and subsequent revisions. On October 16, 2024, communities across the United States submitted inventories of water service lines containing lead to state health agencies. Representing a true ‘OneJMT’ effort, the Water/Wastewater group, in coordination with Survey/SUE and the Technology Group, ensured that our clients met this significant reporting milestone mandated by the Federal government.

Established in 1991 under the Safe Drinking Water Act (SDWA), the original LCR responded to growing concerns about lead and copper contamination, particularly from aging pipes and infrastructure. It set action levels of 15 parts per billion (ppb) for lead and 1.3 parts per million (ppm) for copper, requiring water systems to monitor these levels and implement corrosion control measures if action levels were exceeded. While this framework marked a crucial step in addressing water quality issues, it lacked specific mandates for replacing lead service lines.

The presence of lead, often leaching from corroded pipes, poses severe risks to the health of vulnerable populations, especially children, whose developing brains are particularly susceptible to its neurotoxic effects. While less hazardous, copper can also cause significant health issues at elevated levels.

Over time, high-profile incidents like the Flint, MI, water crisis highlighted the inadequacies of the original LCR and galvanized public demand for stronger protections. This led to revisions and improvements in the rule, reflecting a deeper understanding of the public health implications of lead and copper exposure. In response, the EPA proposed revisions to the LCR in 2019, culminating in a final rule in January 2021. These revisions strengthened protection against lead contamination by requiring utilities to develop plans to replace lead service lines. The emphasis shifted from monitoring to actively reducing lead exposure, with increased monitoring frequency and enhanced public education requirements. However, while these revisions marked a significant improvement, they did not establish specific deadlines for replacing lead and galvanized service lines.

Building on these revisions, the EPA issued further improvements to the LCR on October 8, 2024.  The Lead and Copper Rule Improvements (LCRI) establish clear mandates for completely replacing all lead service lines (LSLs) and galvanized requirement replacement (GRRs) lines within ten years of the compliance date of October 2027. The 2024 improvements also reinforced the need for more rigorous monitoring protocols, emphasized public engagement, and lowered the action level threshold for lead from 15 parts per billion (ppb) to 10 ppb. 

SERVICE LINE INVENTORY

To ensure that our clients met the mandated reporting deadline, JMT initially conducted desktop analyses of property information, public records, and building permits to ascertain the date of construction of private and commercial buildings in each of our client’s communities. This phase was critical as lead was banned from water distribution systems in the U.S. in 1986 with the passage of the SDWA Amendments. Following this initial phase of work, JMT developed field sampling plans to verify the presence of LSL and GRR at representative locations throughout each community. Survey/SUE teams initially conducted visual inspections to confirm the presence of lead pipes on either side of the curb stop or shut-off valve, typically located near the street and often in front yards. When necessary, additional field sampling was conducted by excavating test pits to access the segment of the service line leading into the shut-off valve maintained by the utility (‘system-owned side) and the segment serving the resident or occupant (‘customer-owned side). The diagram below shows a typical service line configuration. The presence of lead was confirmed by a magnet test followed by a scratch test on the exposed pipe.

Source:  U.S. Environmental Protection Agency

 

TECHNOLOGY SUPPORT

JMT’s Technology Group supports multiple lead service line inventory projects by deploying GIS-centric tools and applications to manage inventory data effectively.  Working in concert with our engineering teams, GIS Analysts initially load available mapping data into ESRI’s Cloud SaaS environment, ArcGIS Online. The ArcGIS Online platform allows JMT personnel and external stakeholders to quickly and securely access critical data over the web. When available, we will load the client’s water distribution system mapping data into the Cloud environment to serve as a reference during inventory activities. GIS Analysts then use billing data provided by our clients to geo-code the location of each customer address. The resulting geo-coded points represent each service line in the system. All data collection and reporting activities are associated with these points throughout the inventory process. 

Using ESRI’s ArcGIS Field Maps, Survey/SUE crews access mapping and customer service line location data on their tablet PCs and record the results of inventory surveys via data input forms (see example). Crews may also upload imagery captured at service line sites from the field to the Cloud. Our teams can eliminate data transcription errors by leveraging tools like Field Maps while increasing efficiency.     

Office staff can access inventory data in near real-time using online data viewers and dashboards available through ArcGIS Online. Easy access to project data enables our teams to address emerging issues quickly.  Dashboards (see example) allow project teams to track the progress of inventory activities and monitor critical metrics. Similar dashboards can be deployed over the web and made available to community stakeholders; in this way, JMT can support our clients’ public outreach efforts. 

Mobile Data Collection Form

Lead Service Line Inventory Progress Dashboard

Regulated water system owners are responsible for continuously refining their asset inventories through follow-up confirmatory testing activities to accurately assess the extent of lead in their systems. Additionally, over the next 10 years, systems are required to develop and execute service line replacement plans that address the entire lifecycle of replacement activities. These plans must include strategies for removing lead service lines that address community-specific factors, such as prioritizing service line replacement in neighborhoods disproportionately impacted by lead.

To mitigate the financial burden associated with replacement activities, the Federal government has made $15 billion available to fund this work directly over the next five years and an additional $11.7 billion contribution to state revolving fund programs. JMT is working with our clients to secure lead service funding through these programs. Our Virginia Beach office recently assisted two communities in Virginia in obtaining over $4 million in funding for lead service line work.  The City of Petersburg and the Town of Wakefield will use this money to fund scheduling, construction, and oversight of lead service line replacement work over the next several years.   Team JMT is prepared to support these efforts in Virginia and across the firm’s footprint.  Moving forward, we are committed to helping our clients “Get the Lead Out” of their systems, ensuring that future generations have access to clean, safe drinking water.

Test pit excavation to determine service line composition