If you are someone who works in the water industry or are a homeowner, by now you’ve probably heard of the lead and copper rule revision (LCRR). But what does it mean, and how will it impact your home, your municipality, and your regulations? What do you need to do about it? There’s a lot to unpack here, so let’s start with what LCRR is. Essentially, it boils down (no pun intended) to the fact that there are major changes to drinking water regulations, which will impact more than 60,000 community water systems (CWS) and non-transient non-community (NTNC) water systems. The Environmental Protection Agency (EPA) requires action items be submitted to your state by October 16, 2024. These action items include:

1. Initial lead service line (LSL) inventory
2. LSL replacement plan
3. Revised compliance sample plans
4. Plans for sampling childcare facilities and elementary schools
5. Customer education

Let’s take a look at what these five action items entail.

Initial LSL Inventory (due 10.16.2024)

This item includes water lines owned by water systems, customer-owned portions, and lines beyond the meter. Each service line must be categorized as lead, galvanized requiring replacement (GRR), lead status unknown, or non-lead. In addition to submitting the inventory to the regulatory agencies, if the system serves more than 50,000 people, the inventory must be made publicly available online. Because water systems must identify and track LSL materials as they are encountered during normal operations, it will be important to be prepared for continuous tracking.

Although the development of an inventory may seem overwhelming, the EPA supports the use of predictive models for the development of the inventory, for prioritizing areas where field investigations may be needed, and to aid in line replacement plans.

LCRR boils down to the fact that there are major changes to drinking water regulations, which will impact more than 60,000 community water systems and non-transient non-community water systems. The Environmental Protection Agency requires action items be submitted to your state by October 16, 2024.” Lisa Kelley and Rishi Immanni

LSLR Plan (due 10.16.2024)

Once the LSL inventory is complete, the utility must develop a plan to replace lead service lines. A minimum of 7% of the initial number of lines must be replaced annually and the replacement plan will be updated each year. When planning for replacements, communication with customers will be paramount with public notices and filters/point-of-use devices provided to customers until the required replacements are complete.

Revised Lead and Copper Sample Plans

Requirements call for sample sites to be identified from the results of the LSL inventory and based on newly defined tiers. Additionally, sampling protocols must be updated. For LSL sampling locations, testing will be done on the fifth liter of water collected. This does not modify the existing lead action level at 15 μg/L, however, it does establish a new trigger level of 10 μg/L and requires action be taken to decrease lead levels. For copper pipes, testing will continue to take place on the first liter of water collected.

Updated Customer Education

The EPA requires that within 30 days of completing the initial inventory, systems must notify persons served by lead, GRR, or lead status unknown lines. Early development of a communication plan, including associated education materials, will provide a path for a successful, and compliant, public notice.

What’s Next?

Not sure what to do from here? If you are starting from scratch, it’s best to develop a compliance strategy, which can better equip you to work towards these actions. It will be helpful to think through planning, predictive modeling, asset management, funding and grant assistance, and public outreach.