On January 15, 2021, the U.S. Environmental Protection Agency (EPA) issued Lead and Copper Rule Revisions (LCRR) that went into effect on December 16, 2021. Group A Community and nontransient noncommunity (NTNC) water systems are required to follow the LCRR, which is located in 40 CFR 141. At the same time, EPA announced that it was going to begin new rulemaking to update these same requirements, which they identified as the Lead and Copper Rule Improvements (LCRI). The part of the LCRR not expected to change in the LCRI are the requirements relating to the Lead Service Line Inventory or LSLI. All other requirements of the LCRR are subject to change under the LCRI.
What does this mean to Group A water systems? While EPA works on the LCRI, water systems need to develop and submit a Lead Service Line Inventory (LSLI) by October 16, 2024; while continuing to comply with the prior version of the Lead and Copper Rule.
We will update this page regularly, as EPA provides additional guidance.
EPA-Released Guidance and Template for LSL Inventory
On August 4, 2022, EPA released the Guidance for Developing and Maintaining a Service Line Inventory along with along with the Service Line Inventory Template to help guide public water systems in developing and maintaining the LSL inventory.
The key points to know:
- All Community and non-transient non-community (NTNC) water systems must develop an initial inventory of service lines that meets the LCRR requirements, including service line materials classification and information sources, for both the public and private portions of every service line.
- Each service line must be classified as either:
- Galvanized requiring replacement.
- Lead status unknown.
- Non-lead service lines must be determined through evidence-based record, method or technique.
- Water systems must submit their inventories by October 16, 2024.
- Water systems must make their inventories publicly available. Large water systems, populations greater than 50,000 people, must post the inventories on their website.
- Community systems must indicate in their CCR how to access service line inventory information. Non-lead community water systems may include a statement that they have no lead service lines in their CCR.
- Water systems must notify every person served by a lead, galvanized requiring replacement, or lead status unknown within 30 days of completing their LSLI.
- Water systems must use any information on lead and galvanized iron or steel that it has identified per their materials assessment required per 40 CFR 141.42(d), and review any record explicitly identified in the LCRR.
- The inventory will need to be updated regularly. Systems must identify and track information on service line materials as they are encountered in the course of normal operations, so digital versions may be beneficial for updates.
Lead service line inventory-related information and tools:
- EPA’s Guidance for Developing and Maintaining a Service Line Inventory.
- EPA’s Service Line Inventory Template (Excel).
- EPA LSLI webinar, August 10, 2022. Getting the Lead Out: Guidance for Developing Service Line Inventories and Funding Information on The Bipartisan Infrastructure Law.
- Lead Service Line Replacement Collaborative.
- Lead service line identification: A review of strategies and approaches.
- Lead Service Line Inventory Symposium: 2022—ASDWA.
- EPA Site—Funding for Lead Service Line Replacement.
- EPA Office of Water—LSL Identification and Replacement Webinars.
General LCRR information:
- EPA December 2021 announcement of the LCR and the LCRI.
- EPA Basic Information about Lead in Drinking Water.
- AWWA Lead Resource Page.
- Association of State Drinking Water Administrators (ASDWA).
Please email your questions to LCRRassistance@doh.wa.gov.