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Lead and Copper Rule Revisions

The Lead and Copper Rule Revisions (LCRR) represent a major change in drinking water regulations impacting all 60,000+ public water systems in the U.S. All water systems will be required to develop a lead service line (LSL) inventory, strengthen treatment to comply with a new 10 microgram per liter (μg/L) trigger level, sample schools and childcare facilities, and enhance public communications. Furthermore, systems with LSLs will need to develop a replacement program depending on lead compliance sample concentrations. Read on to learn about the changes that will take effect and the systems that will be impacted.

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The LCRR codifies changes in six key focus areas:
  • Identifying the areas most impacted
  • Strengthening drinking water treatment requirements
  • Replacing lead service lines
  • Increasing sampling reliability
  • Improving risk communication
  • Protecting children in schools and childcare facilities
LCRR Timeline
How can utilities prepare for compliance?

Begin preparations as soon as possible

All systems need to provide the following materials by October 16, 2024.

LSL Inventory

Begin compiling records and developing an LSL inventory.

Review your GIS for information to support LSL inventory development and feasibility of linking location identifiers to your electronic documents.

Prepare defensible assumptions. According to the Federal Register, utilities can assume lead
status based on local ordinances / codes stipulating service line material type(s).

LSL Replacement Plan

Develop LSL Replacement Plan, (including galvanized pipes requiring replacement) unless all service lines have been identified as non-lead.

Work on clearing lead-status unknown service lines to reduce burden for LSL replacement.

Childcare Facility and Elementary School Identification

Develop list of childcare facilities and schools and initiate discussions with facility managers on required sampling.

Sampling Plan

Review lead and copper compliance data to determine if your system may be impacted by the 10 μg/L trigger level, or new requirements for individual samples above 15 μg/L. If compliance is anticipated to be a challenge, review corrosion control treatment and optimization strategies.

Communications that meet LCRR requirements

Review new requirements for public notification and begin developing materials and a plan for compliance.

LSL inventories will take time to prepare.

A combination of approaches will likely be needed to develop a defensible inventory.

Research records and historic construction practices

Apply GIS-based tools

Analyze water quality results and profiling

Visually inspect pipe materials/excavating

We are here to help.
Pipe loop testing

Carollo can help you determine how your system will be impacted and work with you to develop and implement a compliance plan.

We can support you in the following ways:

  • Navigating the intricacies of the 115-page rule.
  • Identifying a LCRR Compliance Strategy that is specific to your utility.
  • Digitization of records, integration into GIS, and other digital solutions.
  • Reviewing changes in water quality or treatment that could impact future compliance.
  • Conducting desktop, bench, or pipe loop corrosion control testing to meet compliance requirements and identify treatment to achieve lower lead concentrations.
  • Assisting with compliance with the current LCR.
    • Corrosion control study.
    • Evaluating and addressing the impact of source water or treatment changes.
    • Developing optimized water quality parameters (OWQPs).

Need to conduct a corrosion control study?

Carollo can help you identify the optimal testing approach, conducting either a desktop comparison of an analogous system, coupons tests, recirculating pipe loops, or a flow through pipe rig.

Interested in learning more? Earning PDH credit?

Additional Resources