Lead and Copper Rule Revisions: Start Preparing for Upcoming Requirements

Lead has long been recognized as a toxic metal that can be harmful to multiple body systems, even at low exposure levels. Lead is particularly harmful to the developing brain of small children and can result in functional impairment. Lead can enter drinking water through the corrosion of lead-containing plumbing materials such as pipes, faucets, and fixtures. 

On December 16, 2021, EPA finalized the Lead and Copper Rule Revisions (LCRR), which further strengthen the protections against lead in drinking water. The LCRR requires water systems to meet a number of new requirements, including:

• Water systems must develop a system-wide lead service line inventory and lead service line replacement plan by October 16, 2024.
• Compliance with a lead “trigger level” of 10 ppb that triggers additional planning, monitoring, and treatment requirements.
• Lead testing in schools and childcare facilities.
• “Find and Fix” at any individual tap above the 15 ppb lead action level to quickly investigate and potentially remediate the source of the lead.
• Strengthened corrosion control treatment, lead service line replacement, lead sampling, and public education measures. 

The lead service line inventory (LSLI) and lead service line replacement (LSLR) plan are key elements that support the LCRR’s overarching goal of proactive lead service line removal and more equitable public health protection.

What is a Lead Service Line Inventory (LSLI)?

The LCRR requires all water systems to submit a lead service line inventory by October 16, 2024 of every service connection in the distribution system to classify the material, of both customer-owned and utility-owned portions of the service line, as one of the following:

• Lead: All or a portion of the service line is lead.
• Galvanized requiring replacement: Galvanized iron or steel service line that is or was at any time downstream from a lead service line or is unknown to have ever been downstream from a lead service line.
• Non-lead: No portion of the service line consists of lead or galvanized requiring replacement.
• Lead status unknown: Service line is not known to be lead, galvanized requiring replacement, or non-lead.

Water systems must take steps to verify service line materials to ensure a complete and accurate inventory. Systems should verify as many “lead status unknown” service lines as possible since unknown service lines are treated as lead service lines unless proven otherwise. Most suppliers should be able to use a combination of knowledge of prohibitions, such as the federal lead ban in 1986, and local ordinances, records review, physical verification, and/or statistical modeling to determine service line materials without physically verifying each line. Only when there is a lack of records and great inconsistency in identified materials during physical verification would a system need to physically verify a large number of their service lines.

The LCRR aims to expand customer awareness, and as such, water systems must make their lead service line inventory available to the public, and systems serving greater than 50,000 people must also make their inventory available online.

Who needs to complete the LSLI?

All community and non-transient, non-community water systems must complete and submit a LSLI to the department. The department is requiring that water systems submit an inventory summary with the total number of service lines in each material category (e.g. lead, non-lead, lead status unknown). Systems with lead or galvanized requiring replacement service lines must also submit a detailed inventory of each lead or galvanized requiring replacement service line with a location identifier (i.e., address or block) and the material classification.

Resource: Lead service line inventory forms and a requirements/FAQ document are available on our website.

What is a Lead Service Line Replacement (LSLR) plan? Do all systems need to complete a LSLR plan?

Water systems with lead, galvanized requiring replacement, or lead status unknown service lines must submit a lead service line replacement (LSLR) plan to the department by October 16, 2024. Completing the LSLR plan will help systems prepare to remove sources of drinking water lead exposure and for identifying the material of unknown service lines. The LSLR plan must be sufficiently detailed to ensure the system is able to comply with the lead service line replacement requirements in the LCRR.

Water systems that have verified that their distribution system contains only non-lead service lines are not required to complete a LSLR plan.

Resources: A lead service line replacement plan template and requirements/FAQ document are available on our website .

The department encourages water systems to begin working on the LSLI and LSLR plan as soon as possible as these will require substantial resources to complete. Stay tuned for additional information on forms and guidance as well as upcoming public meeting opportunities.

➽ Haley Orahood, Regulatory Development and Implementation Specialist

➽ Bryan Pilson, Technical, Regulatory Implementation, and Coordination Unit Manager