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
EPA promulgated the LCRR on January 15, 2021. The compliance date was extended to October 16, 2021 due to administrative review. After the review, no changes were made to the rule, but EPA hinted at a future rule to simplify and clarify the requirements of the LCRR.
On December 6, 2023 EPA proposed the LCRI. The LCRI will supersede most of the requirements of the LCRR once it is promulgated. There are however some items which will still need to be completed under the LCRR. These items include:
- Complete the Initial Service Line Inventory by October 16, 2024.
- Begin notifying customers which have Lead, Galvanizing Requiring Replacement (GRR), or unknown service line material.
- Reporting requirements
- Requirement for Tier 1 public notification if 90th percentile > lead action level of 0.015 mg/L. Public must be notified within 24 hours.
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
State-Specific Resources
• Utah
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
Lead and Copper Resources
The Update is a monthly newsletter exclusively focused on U.S. water news, encompassing regulatory compliance and political developments.
LCRR – The Update – AE2S
- Proposed Lead and Copper Rule Improvements Published December 5, 2023On the last day of November, the U.S. Environmental Protection Agency (USEPA) announced the much-awaited proposed Lead and Copper Rule Improvements (LCRI). The water industry has been watching and waiting for the proposed changes to be released as water systems simultaneously work towards compliance with the Lead and Copper Rule Revisions (LCRR) deadline of October […]
- Get the Lead Out Initiative to Accelerate Removal of Lead Service Lines Nationwide December 1, 2023The U.S. Environmental Protection Agency (USEPA) announced the new Get the Lead Out (GLO) Initiative to help ensure safer drinking water for communities. Through the GLO initiative, which is funded entirely by the Bipartisan Infrastructure Law and is in partnership with the Department of Labor, USEPA will partner with 200 underserved communities nationwide to provide the technical […]
- Have you started your lead service line inventory? The LCRR deadline is 12 months away! October 11, 2023In mid-2021, when the U.S. Environmental Protection Agency (USEPA) announced the Lead and Copper Rule Revisions deadline, October 16, 2024 seemed a long way away. There are now 12 months left to accomplish the considerable requirements that all water systems must complete. AE2S has been working with water systems to help them with LCRR compliance. […]
- Request to Halt Litigation Over Lead and Copper Rule Revisions January 4, 2023In mid-December, the U.S. Environmental Protection Agency (USEPA) asked the United States Court of Appeals for the District of Columbia Circuit to halt litigation over the Lead and Copper Rule Revisions (LCRR) in the case of Newburgh Clean Water Project v. U.S. EPA. The case was filed in January 2021 and includes the following parties: […]
- USEPA Announces Opportunities for Public Input on Lead and Copper Rule Improvements October 24, 2022The U.S. Environmental Protection Agency (USEPA) will host two virtual public meetings to discuss and solicit input on environmental justice considerations related to the development of the proposed Lead and Copper Rule Improvements (LCRI). These sessions will provide opportunities for USEPA to share information about the upcoming LCRI rulemaking and for individuals to offer input […]
- Three Steps to Begin the LCRR Process September 28, 2022The Lead & Copper Rule Revision (LCRR) is the largest change in drinking water regulation in two decades. Although the first compliance deadline is in two years, on October 16, 2024, there is a lot of work to get done. It is prudent for water systems to start the process as soon as possible to […]
Learn How AE2S Can Help You On The Journey To Compliance
Perspectives and Insights > Lead and Copper Rule Improvements
Helping You Prepare for Compliance
The US Environmental Protection Agency (EPA) proposed the Lead and Copper Rule Improvements (LCRI) on December 6, 2023. Comments on the proposed rule were due on February 5, 2024. The LCRI is being proposed to build on the recently promulgated Lead and Copper Rule Revisions (LCRR).
EPA hopes to promulgate the LCRI by the October 16, 2024 compliance date for the LCRR. This will assure a seamless transition from the LCRR to the LCRI. The LCRI will not change the compliance date for the service line inventory of October 16, 2024.
Play Video about LCRI video poster
Presented by
Nate Weisenburger, PE, P Eng, ENV-SP
The major proposed changes to the LCR and LCRR
1. Reduce the lead action level from 0.015 mg/L to 0.010 mg/L.
- The copper action level will remain unchanged at 1.3 mg/L.
- The lead trigger level of 10 µg/L promulgated under the LCRR will be eliminated.
2. Mandatory full lead service line replacement of all lead service lines (LSL) and galvanized requiring replacement (GRR) under the water systems control.
- Full LSL and GRR must be replaced within 10 years from the compliance date of the LCRI.
- Require an average annual replacement rate of 10 percent, calculated over a 3-yr rolling period.
- States may set a faster replacement rate where feasible.
- Criteria available to take more than 10 years for LSL and GRR replacement:
- High number of LSL and GRR based on total system wide number of service lines.
- Required to replace > 10,000 service lines per year.
- The system’s replacement pool must be calculated and updated annually.
- Replacement pool will include all LSL, GRR, and unknown service lines.
- Provide counts of LSL and GRR service lines replaced each year.
3. Develop Baseline Inventory by the final compliance date of the LCRI
You are required to collect information during normal operations:
- Baseline inventory is similar to the Service line inventory but will include information on connectors.
- Include customer addresses associated with each service line in the inventory.
- Must offer to inspect customer service line within 60 days if the customer believes their service line was incorrectly categorized.
- Must resolve all unknowns within 10 years.
- Lead connectors will not be considered part of the service line.
- Validate a subset of the non-lead service lines in the inventory.
- Validation pool will include those service lines identified as non-lead using non-standard methods such as predictive modeling, water quality sampling, and new and emerging methods.
- Random sample of service lines in the inventory to achieve a 95% confidence level. If less than 1,500 non-lead service connections in validation pool must validate 20%. Greater than 1,500 non-lead service lines in validation pool must validate between 322 and 384 sites.
- Validation will include a visual inspection of two (2) points on the line.
- Must report to the state any non-lead classified lines which are found to be lead or GRR in the inventory.
- Must complete validation by year 7 of the replacement program.
4. Sampling for Lead and Copper
- Systems sampling at lead service line sites must take first- and fifth-liter paired samples for lead.
- Both samples must be analyzed for lead.
- The first draw sample is analyzed for copper.
- The higher of two lead values is used in the 90th percentile calculation.
- Revert back to standard 6-month monitoring
6. Lead Service Line and Galvanized Requiring Replacement Requirements
- Replacement plan due at LCRI compliance date (Est Oct 2027)
- Meet seven (7) plan elements from the LCRR
- Add strategy to inform the public about the plan and replacement program.
- Identify any legal requirements or agreements that affect water system’s access to the service line to conduct full service line replacement.
- Service line replacement plan must be made publicly accessible.
- Create strategy to achieve full replacement at rental properties.
- Will not permit relining of LSL or GRR to be considered as a full replacement.
- Physical disconnection from the watermain for abandoned properties will count as a full replacement as long as the state or system has a law or policy prohibiting reconnection.
- Water systems will not be required to pay for the customer side LSL replacement.
- Partial Service line replacements will not be disallowed for emergency repairs or planned infrastructure work. May not be counted as full service line replacement.
- Require installation of dielectric coupler separating new and existing service line.
- Systems must attempt to engage property owner at least 4 times using 2 different communication methods to replace LSL or GRR.
LCRI Proposed Schedule
Direct Transition from the LCRR to the LCRI
Lead and Copper Resources
The Update is a monthly newsletter exclusively focused on U.S. water news, encompassing regulatory compliance and political developments.
LCRR – The Update – AE2S
- Proposed Lead and Copper Rule Improvements Published December 5, 2023On the last day of November, the U.S. Environmental Protection Agency (USEPA) announced the much-awaited proposed Lead and Copper Rule Improvements (LCRI). The water industry has been watching and waiting for the proposed changes to be released as water systems simultaneously work towards compliance with the Lead and Copper Rule Revisions (LCRR) deadline of October […]
- Get the Lead Out Initiative to Accelerate Removal of Lead Service Lines Nationwide December 1, 2023The U.S. Environmental Protection Agency (USEPA) announced the new Get the Lead Out (GLO) Initiative to help ensure safer drinking water for communities. Through the GLO initiative, which is funded entirely by the Bipartisan Infrastructure Law and is in partnership with the Department of Labor, USEPA will partner with 200 underserved communities nationwide to provide the technical […]
- Have you started your lead service line inventory? The LCRR deadline is 12 months away! October 11, 2023In mid-2021, when the U.S. Environmental Protection Agency (USEPA) announced the Lead and Copper Rule Revisions deadline, October 16, 2024 seemed a long way away. There are now 12 months left to accomplish the considerable requirements that all water systems must complete. AE2S has been working with water systems to help them with LCRR compliance. […]
- Request to Halt Litigation Over Lead and Copper Rule Revisions January 4, 2023In mid-December, the U.S. Environmental Protection Agency (USEPA) asked the United States Court of Appeals for the District of Columbia Circuit to halt litigation over the Lead and Copper Rule Revisions (LCRR) in the case of Newburgh Clean Water Project v. U.S. EPA. The case was filed in January 2021 and includes the following parties: […]
- USEPA Announces Opportunities for Public Input on Lead and Copper Rule Improvements October 24, 2022The U.S. Environmental Protection Agency (USEPA) will host two virtual public meetings to discuss and solicit input on environmental justice considerations related to the development of the proposed Lead and Copper Rule Improvements (LCRI). These sessions will provide opportunities for USEPA to share information about the upcoming LCRI rulemaking and for individuals to offer input […]
- Three Steps to Begin the LCRR Process September 28, 2022The Lead & Copper Rule Revision (LCRR) is the largest change in drinking water regulation in two decades. Although the first compliance deadline is in two years, on October 16, 2024, there is a lot of work to get done. It is prudent for water systems to start the process as soon as possible to […]
Nate Weisenburger, PE, P Eng, ENV-SP
(406) 268-0626