Lead and Copper Rule Revision: Service Line Inventory-ARE YOU READY?

Since the United States Environmental Protection Agency (U.S. EPA) created the Lead and Copper Rule (LCR) in 1991, there have been many changes and updates to the rule. The most recent change is the 2021 Lead and Copper Revisions (LCRR). These changes were originally set to be enacted on January 16, 2024, but were delayed, allowing time for U.S. EPA to review the rule in line with Presidential directives issued on January 20, 2021, to allow the heads of other Federal agencies to review regulations and to conduct consultations.

Service Line Inventory

The new compliance date of October 16, 2024, for the LCRR is just around the corner. This marks the compliance date for all community water systems and non-transient, non-community water systems (NTNCWS) under 40 CFR 141.80 (a)(1) to create a service line inventory. The purpose of the service line inventory is for facilities to identify the material of service lines connected to their distribution system. The inventory must be created in accordance with 40 CFR 141.84(a).

Does this include me?

If you answer yes to the following questions, then YOU NEED AN INVENTORY.

• Does your facility produce potable (drinking) water?

AND

• Does your water system serve at least 25 of the same people over six months per year?

AND/OR

• Do you have at least 15 service connections or do you serve at least 25 residents?

NTNCWS locations include schools, office buildings, industrial facilities, and hospitals that supply potable water for employees.

The service line inventory is integral in eliminating lead service lines and communicating with employees the material of the pipes that is used to transport their drinking water. These inventories will require a very comprehensive look at current systems and how to improve them in the future.

What actions should be taken?

It is important to start early because in our experience a good inventory involves months of research, historical documentation, water sampling, and in-depth investigations. U.S. EPA encourages water systems to partner with plumbers and other third parties to obtain information on service line materials. With just one year left, it is critical to start planning and implementing your inventory now. All4 can assist you in all things LCRR related, such as service line inventories, sampling plans, and service line replacement plans. If you have questions or want to discuss your drinking water compliance needs, reach out to Tia Sova at tsova@all4inc.com