Tennessee American Water briefs Red Bank on EPA lead-service-line inventory and next steps

At a Red Bank work session, Tennessee American Water representatives told the city commission that an updated EPA lead-and-copper rule requires all water providers to inventory the materials in service lines — including the customer-owned portion — and to submit that inventory to the Tennessee Department of Environment and Conservation and the EPA by November 2027.

Daphne Kirksey, external affairs manager for Tennessee American Water, said the utility’s finished water meets current standards and emphasized the inventory’s purpose is to identify where lead is present. "Our water remains in compliance with all standards, including lead," Kirksey said. "So water remains clean and safe." Kirksey also described outreach materials the utility will publish, including an online map and a stakeholder toolkit to help customers self-report service-line material.

Megan Catalina, director of operations at Tennessee American, described how the company digitized decades of historical service-line records and identified two main periods when lead or lead-containing alloys were commonly used in their system. "We started this process many years ago, probably around 2019," Catalina said, noting company records extend back to the late 1800s and that customer-owned portions remain largely undocumented.

Catalina outlined the next regulatory steps: after utilities submit inventories to state and federal regulators, the EPA requires verification sampling — small excavations near meters to confirm material types — using statistically valid sampling plans that must be approved by the EPA and TDEC. Based on the inventory, utilities will also develop a 10-year plan for removing any lead service lines. "Because it's two years away, they're not solidified in the mechanisms to do all the replacements in that 10 years," Catalina said.

Commissioners pressed presenters on who would bear the cost of removing lead lines found on private property. Presenters said the inventory and verification work is the immediate priority and that the replacement mechanisms, cost-recovery options and any utility responsibilities remain subject to forthcoming EPA and state guidance. Tennessee American said it will document customer-submitted material reports as inventory records and provide recommended water-testing resources on its website.

The utility and a representative from Hixson Utility District noted they plan targeted canvassing and customer surveys (including asking residents to submit photos) to reduce the number of "unknown" entries in inventories. Officials urged older-homeowners — generally those built before the late 1980s — to consult the utility’s online resources and consider available testing services.

The commission did not take formal action at the work session on the EPA requirement; the presentation was informational. Officials said they will continue coordination with local water providers, post the utility’s outreach toolkit on the city website if the city chooses, and monitor EPA and TDEC guidance as it is released.