How Can You Get Started on the Path to Compliance?
Step 1: Get On The Funding List
Estimate your potential cost to create the inventory including:
Personnel Time
Equipment Costs
Consulting Fees
Communication Costs
Lead and Copper Rule Revisions
Perspectives and Insights > Lead and Copper Rule Revisions
Helping You Prepare for Compliance
The Lead and Copper Rule Revisions (LCRR) will affect water systems throughout the nation, and we’re committed to help communities prepare.
Service Line Inventory Deadline: October 16, 2024
Step 2: Create a List of Every Service Line
- Make sure you know the location of every single line in your system
- Compare your billing database
- Create a spreadsheet with one row for each service line
- And/Or update your GIS to include a node for each
- Identify which lines have private components and which do not
Step 3: Create a Method For Collecting Field Information
You are required to collect information during normal operations:
- Normal repair and replacement actions on mains, service lines, and meters
- Backflow inspections
- Meter reads
- Customer call outs
- Sampling stops
- Valve box inspections
Need to develop a way to capture this information; cannot rely on anecdotal description.
Paper Form
GIS Field App
Pictures
Step 4: Collect and Review Historical Records
You cannot rely on memory and interviews, you need to document.
Examples of Historical Records:
- Distribution Maps and Record Drawings
- Historical Construction and Plumbing Codes
- Maintenance Records
- Historical Documentation – Tap Cards
- Capital Improvements and Master Plans
- Meter Installation Records
- Standard Operating Procedures
- O & M Manuals
- Inspection Records
- Permit Files
Step 5: Determine the Construction Date of Lines
- Does not have to be exact
- Can use development records
- County records
- Tax records
Step 6: Collect Private Line Information
Ask for help – survey your residents.
What to consider:
- How will you start the conversation?
- What will you ask them to do?
- Where will they put the information?
- Why should they do it?
You can perform a scratch test. Lead is dull, very soft, and will turn a shiny silver color when scratched.
You can also perform a magnet test. Magnets will ONLY stick to steel. They will not stick to lead or copper.
Step 7: Evaluate Gaps For Investigation
Determine What Information You’re Missing
If the Gaps are Greater Than What You Can Accomplish, Take a Targeted Approach
- Likelihood – Disadvantage areas and areas with children are more likely need to be addressed.
- Environmental Justice – Pay attention to environmental justice requirements.
Predictive Modeling Can Help With Large Systems
Step 8: Validate and Investigate
Validate Customer Responses. Validate Historical Records.
Methods:
- Visual inspection during normal operations
- Water quality samples cannot rule out, only confirm lead
- Potholing requires vac-truck
- Excavation most disruptive
Resources
AE2S Articles on LCRR
- Request to Halt Litigation Over Lead and Copper Rule Revisions – January 4, 2023
- USEPA Announces Opportunities for Public Input on Lead and Copper Rule Improvements – October 24, 2022
- Three Steps to Begin the LCRR Process – September 28, 2022
- Guidance for Locating Lead Pipes to Develop Serviceline Inventories – August 29, 2022
- Input from Small Businesses, Towns, and Organizations to be Utilized to Develop Lead and Copper Rule Improvements Proposal – June 2, 2022
- 7 Ways the Lead and Copper Rule Revisions Will Impact Your System – March 29, 2022
- USEPA Announces Intent to Strengthen Lead & Copper Regulations – February 3, 2022
- LCRR Delayed – June 30, 2021