The most pressing requirement for water systems that will affect work over the next three years is the mandated creation of an LSL inventory. In 2024, systems will need to submit their first LSL or prove they have none, in addition to beginning sampling at Tier Sites, communicating results to homes over 15ppb, and sampling 20% of elementary schools and childcare facilities. 

For a full list of year-by-year requirements and recommended year-by-year actions, view our Compliance Pipeline.

We recommend that water systems prepare for the upcoming deadlines by developing an LCRR Action Plan, identifying the internal team and external partners that will execute that plan, and developing the data management strategy to support the requirement. Most importantly, the process for developing a preliminary Lead Service Line inventory needs to start now, with actions to gather existing data and begin verifying service line materials.

For a full list of year-by-year requirements and recommended year-by-year actions, view our Compliance Pipeline.

Community Water Systems and Non-Transient Non-Community water systems of any size need to conduct an LSLI or prove they do not have LSLs sometime in 2024.  All Community Water Systems must sample Elementary schools (public and private) and regulated childcare facilities within 5 years of the final compliance date (sometime in 2024). This requirement does not apply to NTNCWS of any size. 

EPA provides water systems serving < 10,000 people with some flexible options for compliance if standard LCR monitoring results in a 90th percentile exceedance. Those four options are: 

• Full LSLR replacement 

• Installation and maintenance of Optimal Corrosion Control Techniques 

• Installation and maintenance of POU devices

• NTNCWS Only: Replacement of all lead bearing plumbing components where taps are used for human consumption (premise plumbing) 

There are several options for funding LCRR related projects, especially the LSL Inventory. They include one-time funds from the Federal Government as well as grants and low interests loans, includinng Drinking Water State Revolving Funds, Water Infrastructure Finance and Innovaction Act Grants, Water Infrastructure Improvements for the Nation Act Grants, and more.

For a full list of funding opportunities and relevant links,  view our Budget Resources Hub. 

The current EPA definition lacks complete clarity–we recommend utilities operate under our suggested “future-proof” definition to ensure they’re on the leading edge of LSL management.

Current EPA Definition:

“Lead service line means a service line made of lead, which connects the water main to the buying inlet. A lead service line may be owned by the water system, owned by the property owner, or both. For the purpose of this subpart, a galvanized service line is considered a lead service line if it ever was or is currently downstream of any lead service line or service line of unknown material.”

Future-proof definition:

We recommend that inventories detail the following public and private information for a service line inventory, which will stand the test of time and protect public health:

• Lead Pipes
• Lead Fittings (e.g. Goosenecks, pigtails)
• Copper with Lead solder (immediately useful for Tier site management) 
• All Galvanized lines (useful for asset management and LCRR requirements)
• Unknown materials

All water systems must conduct  a “location-based” inventory of publicly-owned and privately-owned LSL material information.  At present, EPA gives utilities flexibility and allows them to piece together an inventory with various records such as:  

• “All construction and plumbing codes, permits, and existing records or other documentation which indicates the service line materials used to connect structures to the distribution system.” 
• “All water system records, including distribution system maps and drawings, historical records on each service connection, meter installation records, historical capital improvement or master plans, and standard operating procedures.”
• “ All inspections and records of the distribution system that indicate the material composition of the service connections that connect a structure to the distribution system.”
• “Any resource, information, or identification method provided or required by the State to assess service line materials.”

Utilities can acquire this data from a variety of sources including:

• Work order systems
• Billing systems
• LCR sites
• GIS
• As-builts
• Tap cards
• Contractor records

Customer Engagement campaigns and surveys can be useful to support physical identification of the customer’s side of the line. Two specific strategies for private identification are Lead Check swabs and Water Samples. 

In profile sampling, consecutive samples (typically 10-15 1L bottles) are collected from a customer’s faucet and then analyzed for lead. The resulting concentrations are then used to identify lead sources along the line. 

Lead Swabs are typically used to identify leaded paint but can be useful in identifying lead pipes, leaded solder and leaded brass. These tools can be employed by utility staff or residents.

At present, utilities need only replace lines under LCRR in three scenarios: 

1. If the customer replaces their side of the line and asks the utility to replace the public side
2. If the 90th percentile Tier Site monitoring results are greater than 10 ppb. Under this scenario, the utility must conduct active outreach with customer on known LSLs and unknown lines and must attempt to replace lines at the rate they select with their state regulator in the require Lead Service Line Replacement Plan*
3. If 90th percentile Tier Site monitoring results are greater than 15 ppb, the utility must replace 3% of all known LSLs, Galvanized requiring replacements and unknown service lines annually for two years. 

The rule requires two “good faith attempts” to reach the customers that either resulted in a signed or verbal refusal, or non-response. This provision allows a water system to maintain compliance with the rule in the expected cases when customers do not cooperate enough with systems to meet the minimum LSLR requirements in the rule. However, this provision does not allow refusal of an individual customer to count as a replaced LSL.

*All water systems with LSLs or lead status unknown service lines in their initial inventory must create and submit an LSLR plan to their state by the rule’s compliance date. The LSLR plan must include a description of: (1) A strategy for determining the composition of lead status unknown service lines in its inventory, (2) procedures to conduct full LSLR, (3) a strategy for informing customers before a full or partial LSLR, (4) for systems that serve more than 10,000 persons, a recommended LSLR goal rate in the event of a lead trigger level exceedance, (5) a procedure for customers to flush service lines and premise plumbing of particulate lead, (6) a LSLR prioritization strategy based on factors including but not limited to the targeting of known LSLs, LSLR for disadvantaged consumers and populations most sensitive to the effects of lead, and (7) a funding strategy for conducting LSLRs which considers ways to accommodate customers that are unable to pay to replace the portion they own.

Partial LSL replacements are known to have negative effects on public health as particulate lead can be released in higher amounts. EPA does not ban this practice in the current LCRR but it does not allow water systems to count partial replacements toward the mandatory 3% rate which is triggered by a 90th percentile action level of > 15 ppb. 

Unknown lines do not need to be replaced, but they should be identified. They do come into effect in mandatory replacement as systems will be forced to correctly ID them in the process of achieving the 3% replacement rate. Waiting until this happens to complete the inventory will cause inefficiencies and may erode public trust.

Timing depends on 4 factors: 

1. The condition of the utility’s infrastructure records
2. The size of the utility 
3. The number and complexity of existing data sources
4. Internal resources (people and funds) available 

We recommend that all utilities begin creating their inventory today (if they haven’t already) to be prepared to meet the requirements.

The 120Water Services team supports utilities in a holistic review of these factors and assists in pulling together all relevant evidence for inventories. At the end of this process the 120Water platform becomes the database of record for an inventory that can evolve over time.

There are 2 primary ways to replace LSLs: 

1. Traditional Replacement of an LSL 
   • Open trench replacement
   • Creating different routes for new service lines and disconnecting the LSL
   • Pipe Splitting/Pulling/trenchless
2.  Lining & Coating the inside of the LSL 
   • PET Lining
   • Epoxy Coating 
   • Polyurea/polyurethane Coating

The rule does not expliciting say that predictive modeling can be submitted for reporting purposes but most models are based on the kinds of records that EPA suggests it will accept. Predictive modeling can be useful in two specific ways for LCRR compliance: 

1. To help utilities determine where to focus they inventory verification efforts
2. To help utilities determine where to focus replacement efforts if they encounter compliance issues 

Predictive modeling may be incredibly useful for cities looking to find and replace LSLs in advance of the rule. Simply inspecting a service connection can cost between $400-1500 per line. Modeling directs those effects more efficiently to home with the highest risk of having LSLs.

No, currently only galvanized pipes downstream of a lead service line (e.g. lead segment on the customer side) count as “Galvanized pipe requiring replacement”. This definition may evolve as EPA concludes its review of the rule. 

The rule does not explicitly state the required reporting format (e.g. shape file, csv, ect.) just the data targets themselves. LCRR requires the publicly accessible inventory to provide a “location identifier” for LSLs. A location identifier could be a general location such as a street, block, intersection, or landmark, or other geographic marker associated with the service line. An inventory created and maintained by water systems to track service line materials should use the specific address of each service line in order for the water system to provide the required notifications, but EPA does not require that the system make the exact street addresses publicly available. Instead, the final rule gives the water system flexibility to determine which identifier best meets the needs of its own community. CWS serving more than 50,000 people must publish the inventory online. Utilities should select tools that allow them to easily modify and share the inventory over time on a by-location basis. 

No incentives are explicitly stated in the rule but best practices for experiences in the state of Michigan abound! Education and thoughtful communication are the key. 

These samples are explicitly collected at residences served by an LSL. The 2-4 liters can be discarded. Only the 1st (for copper only) and 5th (for lead only) Liters are analyzed for compliance. 

Sites with lead status unknown service lines must not be used as Tier 1 sampling sites or Tier 2 sites.

Yes. 

This would likely come into effect immediately following the compliance date (sometime in 2024). Any system conducting the standard tier site monitoring after that date should be prepared to carry out Find-and-Fix unless EPA grants an extension on monitoring timelines. 

EPA allows water systems in this position to apply for a waiver from the state by the compliance date. 

All school and childcare facilities in the water system’s service area built before January 1, 2014, need to be sampled. This included private schools and licensed childcare facilities.

5 fixtures for each school and 2 fixtures for each childcare facility must be sampled.

Immediately following the compliance date (2024, TBD)

These facilities still need to be sampled. Waivers can be granted in states with existing testing requirements or in states where EPA WIIN funding is being used for voluntary testing during the compliance period. 

First identify how many facilities you have in your service area and then develop a plan for communicating and conducting testing at these facilities. 

No. EPA suggests this information will be useful in helping water systems understand CCT effectiveness in large buildings. 

Identify what tools you can use to reach customers in 24 hours to prepare for an action level exceedance. Consider how you will communicate with customers about LSLs and school/childcare sampling. 

1. 1. Make the complicated simple. The public knows about Flint, MI but may not yet understand what a lead service line truly is or why sampling in schools and childcare facilities is needed. 
   2. Engage customers in the process. The public can help you fill data gaps in your inventory but thoughtful messaging is critical.  
   3. Talk about other sources of lead. We know lead in drinking water is not the only concern. Educate customers about other lead risks simultaneously (e.g. paint, soil, dust, toys, ceramics). This is not to diminish the very real threat of lead in drinking water, but to help your community see the whole picture — which includes the fact that they likely have other sources of lead in their premise plumbing and elsewhere. Taking this approach will help you build trust and create a leave-behind for customers.