Lead and Copper Rule Revisions (LCRR)

On December 16, 2021, the U.S. Environmental Protection Agency (EPA) announced that the Lead and Copper Rule Revisions (LCRR) issued January 15, 2021 will go into effect to support near term actions to reduce lead in drinking water. The LCRR establishes a compliance deadline of October 16, 2024 for water systems to complete their initial service line inventories. In addition, EPA announced that they will begin developing new regulation, Lead and Copper Rule Improvements (LCRI), to strengthen key elements of the LCRR.

On November 30, 2023, the U.S. Environmental Protection Agency (EPA) announced the proposed Lead and Copper Rule Improvements (LCRI).  While the LCRI does not impact the October 16, 2024 deadline for service line inventory submittals, it is important for water systems to be aware of this Proposed Rule for planning purposes. LDH will continue to provide updates on the LCRI rulemaking as it progresses. This includes notifying systems of any future compliance deadlines, training and technical assistance.  

Current key provisions in the proposed LCRI, include:

• Achieving 100% Lead Pipe Replacement within 10 years. When lead service lines are present, they represent the greatest source of lead exposure in drinking water. The proposed LCRI would require the vast majority of water systems to replace lead services lines within 10 years.
• Locating Legacy Lead Pipes. Knowing where lead pipes are is critical to replacing them efficiently and equitably. Water systems are currently required to provide an initial inventory of their lead service lines by October 16, 2024. Under the proposed LCRI, all water systems would be required to regularly update their inventories, create a publicly available service line replacement plan, and identify the materials of all service lines of unknown material.
• Improving Tap Sampling. The proposed LCRI would make key changes to the protocol that water systems must use for tap sampling informed by best practices already being deployed at the local and state level, like in Michigan. Water systems would be required to collect first liter and fifth liter samples at sites with lead service lines and use the higher of the two values when determining compliance with the rule.
• Lowering the Lead Action Level. EPA is proposing to lower the lead action level from 15 parts per billion (ppb) to 10 parts per billion (ppb). When more than 10 percent of a systems routine lead sample results exceed the action level, the system would be required to inform the public within 24 hours and take action to reduce lead exposure while concurrently working to replace lead service lines. For example, the system would install or adjust corrosion control treatment to reduce lead that leaches into drinking water.
• Strengthening Protections to Reduce Exposure. Water systems with multiple lead action level exceedances would be required to conduct additional outreach to consumers. Systems that exceed the lead action level 3 or more times in a 5 year period would be required to make filters certified to reduce lead available to all consumers.
• Lead Sampling in Schools and Childcare Facilities. Under the LCRI, system are required to sample for lead and elementary schools and licensed childcare facilities that they serve and provide recommendations on how to reduce lead exposure from drinking water.
• Including Lead Connectors in Future Inventory Updates. What is a “connector”? Under the LCRI, a connector is defined as a short segment of piping, not exceeding two feet, that can be bent and is used for connections between rigid service piping, typically connecting the service line to the main. They are often referred to as goosenecks or pigtails.

 For more information, including LCRI Fact Sheets, please visit:  https://www.epa.gov/ground-water-and-drinking-water/proposed-lead-and-copper-rule-improvements

What Does This Mean for Public Water Systems?

1. The compliance deadline for water systems to complete their initial Lead Service Line (LSL) Inventories is October 16, 2024. Maintaining this compliance deadline ensures water systems will make continued progress to identify lead service lines, which is integral to lead reduction efforts. By preparing a LSL inventory, water systems will be able to target communication to residents in homes with LSLs about the actions they can take to reduce their lead exposure. In addition, the inventories will allow water systems to better identify sampling locations and begin planning for LSL replacement actions including applying for state and federal grants and loans.
2. The compliance deadline for water systems to submit updated lead and copper sample plans and lead service line replacement (LSLR) plans will be extended beyond October 16, 2024. The current LCRR requires that all water systems submit an updated lead and copper tap sampling plan and a lead service line replacement (LSLR) plan by October 16, 2024. However, since the EPA intends to propose changes to the LSLR and tap sampling requirements in the LCRI, the EPA will delay the October 16, 2024 deadline for submitting LSL replacement plans and tap sampling plans so that systems can incorporate any potential revisions made through LCRI. EPA anticipates publishing a proposed LCRI in late 2023.

To view the LCRR in its entirety in the Code of Federal Regulations, please visit: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-141/subpart-I.

For more information on the LCRI, please visit: https://www.epa.gov/ground-water-and-drinking-water/lead-and-copper-rule-improvements

for Guidance, please visit: https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule

Where can I find additional infromation on the Lead and Copper Rule Revisions?

LDH LSLI Requirements

LDH Service Line Inventory Presentation

LDH LSLI Frequently Asked Questions

Who should we contact if we have questions about the inventory requirements?

If you have questions about the inventory, you can contact any of the following LDH staff: