EPA Releases Templates for the Notification of Known or Potential Service Lines Containing Lead

On Monday, July 29, EPA released a Word document with three templates, along with the required regulatory language for customer notifications of a confirmed lead service line (LSL), a confirmed galvanized service line (that was known or likely to be downstream of a lead service line) requiring replacement (GRR), or an unkown service line material on either the public or private side. As context, the Lead and Copper Rule Revisions (LCRR) were finalized in 2021, with a deadline of October 16, 2024, for the initial service line inventories and a requirement for notification within 30 days to customers with LSLs, GRRs, or unknowns. Given that most systems have very limited materials information on the private side, millions of these customer notifications will be sent out in late October and early November. Given that the October 16th deadlines is less than 90 days from today (July 31), many primacy agencies have already developed their own templates that meet the regulatory requirements that water systems should use for these notifications. For those that want additional information on the appropriate regulatory requirements for water systems regarding the 30-day customer notification of known or potential service lines containing lead, those requirements are outlined in 40 CFR § 141.85(e).

EPA is planning on releasing the final Lead and Copper Rule Improvements (LCRI) prior to October 16, 2024, even as the timeline for the final review by the Office of Management and Budget (OMB) tightens up.