MURFREESBORO, TN - In compliance with a requirement from the Environmental Protection Agency (EPA) and the state of Tennessee, Consolidated Utility District (CUD) has verified that all service lines within its distribution network – a total of 70,788 service lines – are free of lead.
The report has been filed with the Tennessee Department of Environment and Conservation and has been accepted in advance of the due date of October 16. Per EPA guidance, CUD will update its list in October 2025 to include the service lines built within the past year. According to the EPA, water utilities are required to verify their service line materials according to the date that went into effect for the lead ban, which was March 18, 1988.
CUD will update the list of service lines every year, though the list will only carry the new service lines for that year. Due to the existing lead ban, all of those would be lead free.
“None of the service lines fell into the category of lead or unknown materials,” said Randy Harrell, CUD Environmental Coordinator.
“In fact, we actually found some that we questioned ourselves, and we did more investigation just to be sure. To perform the testing, we used a detection device that has the ability to note the differences between copper, galvanized, and lead pipe.”
CUD not only managed its own research but also shared information with other utilities about how to establish and implement their own lead line survey programs. CUD provided guidance about methods and detection technology to water utilities in Murfreesboro, Woodbury, Memphis, Spring Hill, Wilson County, and Camden.
“At every step in the process, our Water Quality Team put an emphasis on completing the project ahead of time while also being thorough,” said Roger Goodson, General Manager of CUD.
“We feel privileged that we could help other utilities as they performed their surveys.”
The Environmental Protection Agency (EPA) website notes that the Lead and Copper Rule is the National Primary Drinking Water Regulation as enacted in 1991 and requires actions by public water systems to reduce levels of lead and copper in drinking water.
In January 2021, the EPA developed the Lead and Copper Rule Revisions with a deadline of October 16, 2024 for water systems to comply with the requirements. Lead in water pipes has been linked to slowed growth, learning deficits, and lower IQ in children, problems related to childbirth for pregnant women, and cardiovascular issues and decreased kidney function in adults. Young children, infants, and unborn children are especially vulnerable because the effects of lead occur at lower exposure levels.
The final report submitted by CUD included specific meter numbers, street addresses, descriptions of pipe material, and verification sources. Background sources required for the review included distribution system maps, capital improvement plans, operating procedures and manuals related to pipe materials, meter installation records, and any documents that would indicate the location of lead service lines.
CUD has never used lead pipe in its distribution network. Anecdotal evidence suggests that lead pipe was not used in construction in Southern states as much as in Northern states. This may have been a regional preference at the time as much as a statement regarding which pipe materials were most accessible and easily transported to certain states.
At Consolidated Utility District, we are committed to providing quality water and wastewater service, now and in the future, using the most cost-effective, innovative, and efficient methods and technologies available.
