Lead and Copper Rule Compliance
The Lead and Copper Rule Improvements (LCRI) was published on October 30, 2024, and together with the Lead and Copper Rule Revisions (LCRR), represents a major change in drinking water regulations impacting all 60,000+ public water systems in the U.S. All water systems are required to update their lead service line (LSL) inventories to include information on connectors and verify unknown service lines. In addition to the LSL inventory updates, the LCRI establishes a new 10 microgram per liter (µg/L) action level, revised sampling tiers, sampling at schools and childcare facilities, enhanced public communication, and an LSL replacement plan program. Systems are required to complete full service line replacements of lead and galvanized requiring replacement (GRR) service lines within 10 years of the LCRI compliance date.
Due November 1, 2027
-
- Baseline LSL Inventory, including materials for service connectors (pigtails, goosenecks, etc.).
- Service Line Replacement Plans for lead or GRR service lines.
- List of schools and childcare facilities within the service area.
Starting November 1, 2027
-
- Sampling at schools and childcare facilities.
- Updated lead health effect language for public notification and/or public education materials and in Consumer Confidence Reports (CCR).
Due November 1, 2034
-
- Verification of non-lead service lines not installed after the applicable Federal, State, or local lead ban, visually inspected at a minimum of two points on the pipe exterior, or previously replaced.
Due November 1, 2037
-
- Complete replacement of all lead and GRR service lines.
Begin preparation as soon as possible
Preparing for compliance will require assembling the following necessary materials by the November 1, 2027 deadline:
LSL Inventory
Track updates to service lines including material replacements or new service lines.
Document service line connectors including pigtails, goosenecks, etc.
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 new 10 μg/L action level. 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 replacement is a complex, long-term project
To meet the 10-year LSL replacement requirement under the 2027 LCRI compliance date, utilities will likely need to take a multifaceted approach that includes:
Investigate unknown service lines and develop an LSL replacement plan
Secure funding and labor for service line replacement
Manage and execute the LSL replacement program
Update service line inventory to reflect replacements
Carollo can help assess your system’s impact and then develop and implement a compliance plan
We can support you in the following ways:
- Navigating the intricacies of the 250-page rule.
- Identifying an LCRI Compliance Strategy that is specific to your utility.
- Digitization of records, integration into GIS, and other digital solutions.
- Identifying funding opportunities for lead service line replacement.
- Developing and managing a lead service line replacement program.
- 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 treatments for lower lead concentrations.
- Assisting with compliance with the current LCR and LCRR.
- 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 by conducting a desktop comparison of an analogous system, coupons tests, recirculating pipe loops, or flow through pipe rigs.
