The U.S. Environmental Protection Agency (EPA) established new requirements under the Lead and Copper Rule Revisions (LCRR) for those in the drinking water industry. All community water systems (CWSs) and non-transient non-community public water systems (NTNCs), which may include systems that serve potable water at manufacturing sites, port authorities or universities, will need to comply with the LCRR by Oct. 16, 2024.

The latest revisions amend the Lead and Copper Rule (LCR) established in 1991 by the EPA to limit public exposure to lead in drinking water. Under the LCRR, CWSs and NTNCs are required to develop and submit a lead service line (LSL) inventory to their state governing agency. The inventory must include detail of all utility- and customer-owned service lines connected to the public water distribution system:

  • Lead service lines. This refers to a service line or lines made of lead.
  • Galvanized requiring replacement. This references a galvanized service line or lines present downstream of a lead service line or a lead status unknown service line.
  • Non-lead service lines. This means a line that is proven to not be made of lead, instead made of plastic or copper, through an evidence-based record, method or technique.
  • Lead status unknown. The service line has been deemed not known to be constructed of lead, galvanized requiring replacement or a non-lead service line.

The developed LSL inventory should be considered a living dataset, and thus information should be actively updated and continually modified to reflect any adjustments made by the CWSs or NTNCs. Any components that are deemed in need of replacement should be identified as part of the inventory. Developing an LSL inventory is the first step toward establishing a course of action to address deficiencies to see that the water system maintains compliance and provides clean, safe drinking water.

Government funding opportunities are available to help finance activities needed to comply with the LCRR. For the state of Texas, for example, the Texas Water Development Board, the U.S. Department of Agriculture and the Texas Water Infrastructure Coordination Committee all have funding opportunities available for water systems to apply for financial assistance. Systems in other states should look to state agencies to identify opportunities local for that region, as each state has its own application procedure.

Bringing in a knowledgeable environmental services team can help CWSs and NTNCs navigate the latest requirements. A team of professionals can provide support in efficiently developing the inventory documentation and identifying strategic solutions regarding assets in need of replacement.


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Angelika Ortiz is an environmental scientist at Burns & McDonnell, specializing in the Texas Commission on Environmental Quality (TCEQ) permitting process. She is experienced in developing technical reports detailing state and federal drinking water regulations and helps industrial, utility and manufacturing clients work through environmental challenges.