The Park Rapids City Council received an update on Tuesday about upcoming implementation of a new rule from the U.S. Environmental Protection Agency (EPA).

During a special work session, City Engineer Jon Olson with Apex Engineering told the council that the Lead and Copper Rule (LCR) has been in the works since 1991, but final revisions were fast-tracked following the water crisis in Flint, Michigan. The final rule was published at the end of 2021, with a compliance deadline of Oct. 16, 2024.

Olson said the latest version of the rule includes changes to water-sampling procedures, increasing the concentrations of lead being detected in drinking water and affecting how cities are required to respond.

Also required by the LCR is a lead service line inventory, Olson said. This means the city will have to document every water service line within city limits, from water main to meter, and identify lead and galvanized lines as well as lead solder used in copper fittings prior to the 1990s.

Olson called it a “pretty big undertaking,” and noted that every city in the nation is struggling with the same challenge. He added that the inventory may result in the need for a replacement plan for noncompliant water services.

“The good news is, it sounds like there’s funding available for this,” said Olson, “in the form of a grant, and it’s available to all cities. It doesn’t have the same eligibility requirements that we’re up against on most of our funding sources.”

Olson said the engineering community has learned the inventory does not require cities to excavate all service lines. Nevertheless, he emphasized the size of the undertaking.

“We don’t have really good records (of service line types), even on the city side” he said. “On the private side, we have very little information.

“If we’re unable to identify the pipe type, it will be classified as a lead service pipe. The issue with that is, if you have a bunch of unknowns, then your action plan, the replacement plan, is far more extensive.”

Olson said the city’s water system contains approximately 45 miles of mains with nearly 1,700 service connections and more than five miles of original cast-iron pipe, which likely contain some amount of lead. The presence of lead service lines is likely, he said, particularly in neighborhoods older than 1991.

Olson also noted that despite street and utility projects affecting water lines from the main to the property line, the city has not taken an inventory of service lines from the property line to the water meter.

To start, Olson said, the city can review the records for data about pipe types – such as drawings of work done after 1980, plus meter and service replacement records – then do a field investigation to look at the pipes going into water meters, and find a way to manage the data, such as adding a layer to the city’s geographic information system (GIS).

One approach he suggested involves sending notices to property owners, requesting their help, but noted that they typically respond only 20-30% of the time and their accuracy is questionable.

“The challenge is,” said Olson, “it does require a little bit of knowledge in plumbing and pipe type to really make this effective. Copper and lead look very similar. You do have to scratch them. You might have to put a magnet on it to verify whether or not it’s magnetic.”

Another approach he suggested is going door to door, verifying pipe type at each meter, taking pictures and organizing the data. Olson said this approach is more labor intensive, but also more effective.

Asked what is due by the October 2024 deadline, Olson said at least the inventory, possibly also an action plan. If a replacement plan is triggered, the city would be expected to replace at least 3% of service lines per year, he said.

Olson also mentioned the need to obtain easements to do the replacement work.

Council member Erika Randall suggested starting with the option of asking property owners to help, as well as factoring the project into the city’s budgeting process.

Council members also suggested taking the opportunity of the Fair Avenue project to knock on property owners’ doors and get ahead on the inventory.

Council member Liz Stone urged Olson to communicate clearly with Fair Avenue residents, so they understand that the city is currently replacing utilities only as far as their property line.

Olson also explained that, just because there’s a lead pipe, doesn’t mean it’s dangerous. He said the scale that builds up inside pipes protects drinking water from the lead, unless a change in the water chemistry causes the pipes to descale – which is what happened in Flint.

“At some point in time, whether it’s a part of this analysis,” Olson said, “I see those requirements coming down and down and down, until eventually all of the services are replaced. It’ll be based on the annual water quality, as to whether or not that replacement plan is triggered.”

Olson said funding is available to replace the entire service line, all the way to the house, with the city acting as the sponsor for the grant. He said reimbursement arrangements will have to be made for replacement work done on private property.