copper programs.
The WPCA is required to submit a lead service line inventory and a replacement plan by
October 16, 2024. She added that it is allowable to have unknowns in the inventory and the
WPCA would have a couple of years to "wrap it up". Mr. Jones asked if the legislation was State
or Federal, Ms. Lachmayr answered Federal although each State promulgates the rules
themselves. For example, the Connecticut final date of inclusion is 1989 vs. 1986 for the Federal
date. The State may add its own stricter requirements.
Quick overview of Ledyard system:
1,141 unknown service lines.
A large number of connections will require investigations.
In Ledyard the service lines are partially owned by both the customer and the Utility but
nonetheless it is the WPCA's responsibility to provide information on the inventory regarding
the service line material.
Chairman Lynch expressed concern that in the past some customers refuse to let the Utility
inspector into their homes. Ms. Lachmayr said that what the State will evaluate is a percentage
of the system, not necessarily every single connection. Probabilistic models can be used to
determine the unknown materials in the system. She added that if lead is found and the owner is
refusing replacement, the Utility is required to document three attempts to perform the
replacement.
Ms. Lachmayr offered advice on how to explain to customers why the survey is being conducted.
She said it is important to start out by explaining that the water is high quality drinking water,
and that compliance was maintained with established lead and copper limits within the water
system. Secondly, the lead inventory is being performed as a requirement of the Environmental
Protection Agency and the State of Connecticut. End the explanation by stating that the WPCA
is committed to providing safe drinking water to all residents and works hard to keep that
commitment.
The Department of Health has a template that is required to be completed by October 16, 2024.
An overview of a few of their requirements:
A galvanized service line downstream of a lead gooseneck will require replacement.
Anything with lead will need replacement.
If lead is found, the customer needs to be told within 24 hours.
Once a lead replacement is complete the customer needs to be provided with the required steps
to flush the lines.
Make the inventory public facing. Starting on October 16, 2024, access to the inventory must be
provided. This can be as simple as a spreadsheet but it must be searchable by the customer
address. Often Towns will create a page on their website which will allow access to the
self-reporting forms, show customers how to test their service line, contains frequently asked