Clean drinking water and lead pipe removal has been top of mind in Michigan since the Flint water crisis. In 2018, the State of Michigan’s Department of Environment, Great Lakes, and Energy (EGLE) amended the state’s Safe Drinking Water Act to require water supplies to develop and maintain a Complete Distribution System Materials Inventory (CDSMI).
Michigan EGLE recently updated the due date and requirements for the CDSMI to more closely align with the EPA’s Revised Lead and Copper Rule requirement for a Lead Service Line Inventory.
Let’s dig into the changes in Michigan.
What is the updated CDSMI deadline?
The CDSMI submission deadline is now October 16, 2024, which is aligned with the EPA deadline. This new deadline is earlier than the previous deadline of January 1, 2025.
Is the CDSMI allowed to include service lines of “unknown” material in October 2024?
Yes, but carefully. Water supplies will have the option to select “unknown” as the service line material in the CDSMI, but Michigan EGLE is encouraging water supplies to avoid this where possible. Additionally, under the LCRR/LCRI rule revisions, all “Lead status unknown” service lines will trigger additional customer communications and replacement/verification requirements.
Is the Michigan CDSMI template the same as the EPA’s Service Line Inventory template?
EGLE will provide a unique inventory template for the CDSMI and is actively working on the template. Water supplies will be notified directly when the CDSMI template is available.
What other requirements have changed?
Where federal regulations are more stringent than the Michigan rule, water supplies must comply with the federal rule. Specifically, this adds a few new requirements for MI water supplies:
- Inventories must be publicly available.
- Inventories must be available online for supplies serving more than 50,000 people.
- Information regarding inventory availability must be included in Consumer Confidence Reports
- Service line material notification requirements expand to include premises served by service lines where lead status is unknown
- Service line material notification must be repeated annually until the service line is known not to contain lead or galvanized-requiring-replacement (also called GPCL or galvanized previously connected to lead)
Is EGLE planning to release further guidance?
Yes, as of mid-February 2024, EGLE is working to finalize the template and release additional guidance as soon as possible. This guidance will build on the Minimum Service Line Verification guidance and Evaluating Minimum Service Line Materials Verification guidance and provide instruction on how to submit to EGLE and how to complete some of the remaining required items for the CDSMI.
