LCRR Step-by-Step Guide: How to Comply with the EPA’s Lead and Copper Rule Revisions [Updated for 2024]
The Lead and Copper Rule Revisions (LCRR)
LCRR stands for Lead and Copper Rule Revisions. The rule details a series of requirements that all 60,000+ public water systems in the U.S. must meet by October 16, 2024 to prevent drinking water contamination.
[Have you heard? The EPA just announced a new rule that calls for replacing 100% of lead pipes in 10 years —it’s called the Lead and Copper Rule Improvements (LCRI).]
The EPA created both the LCRR and its predecessor, the LCR (Lead and Copper Rule).
- 1991—The EPA establishes the Lead and Copper Rule (LCR) to control the presence of lead and copper in drinking water.
- 2022—The EPA releases an addendum to the LCR called the Lead and Copper Rule Revisions (LCRR), establishing new requirements for protecting people from lead and water contamination.
The release of the LCRR was motivated in part by the lead water contamination disaster in Flint, Michgian, when almost 100,000 residents were exposed to lead poisoning from April, 2014 to October, 2015. (Flint has since been in compliance with the original LCR for six consecutive years.)
Under the LCRR, it’s estimated that about 40% of large water systems may have to conduct line replacements.
“Initial estimates are that on the order of 40% of larger water systems with lead service lines will be required to conduct mandatory lead service line replacement and revise their corrosion control practice.”
Steve Via, Federal Relations Director for the American Water Works Association
This guide contains everything you need to know about the Lead and Copper Rule Revisions, including how to create a lead service line inventory—one of the most difficult parts of LCRR compliance.
Keep reading to learn all about the LCRR, how to create a service line inventory, and more.
When is the LCRR compliance date?
The compliance date for the LCRR is October 16, 2024.
What do the Lead and Copper Rule Revisions (LCRR) require?
Here’s an overview of what the LCRR requires for all public water systems:
- Develop a lead service line (LSL) inventory and make it publicly available.
- Develop an LSL replacement plan.
- Sample schools and childcare facilities for lead and copper.
- Strengthen treatment to comply with the new 10 microgram/liter (μg/L) trigger level.
- Communicate with the public about the LCRR’s requirements and the steps you’re taking to meet them.
The primary motivation for creating the LCRR is to keep people, and especially children, safe from the dangers of drinking water contaminated by lead and copper.
This is why the lead service line inventory requirement is so important. The inventory allows you to know where there is potentially hazardous piping, to take the steps needed to replace it, and to share this information with the public.
To make drinking water safe, the EPA’s goals for the LCRR are to:
- Help water systems identify those areas most impacted by contamination hazards.
- Strengthen requirements for drinking water in communities throughout the U.S.
- Replace lead service lines.
- Improve the reliability of water sampling.
- Improve water systems’ communication of contamination risk to the public.
- Reduce the chances of contamination in schools and daycare centers.
Model LCRR Timeline
Meeting all of the LCRR requirements won’t happen overnight.
Here’s a model timeline to help you start drafting a path toward meeting the October 16, 2024 deadline.
- Month 1—Research inventory requirements with your state agency to make sure you understand everything you need to do. (Your state agency may have requirements that go beyond the EPA’s requirements—here’s a list of agencies to help you get started.)
- Month 2—Review funding program requirements and identify a funding strategy for the inventory and replacement work and other key efforts.
- Month 3—Start preparing funding applications and related documentation
- Month 4—Start conversations with schools and childcare providers in your community about the LCRR and how you’re meeting its requirements.
- Month 6—Review Pb/Cu compliance sample locations and update as needed.
- Month 7—Begin creating your lead service line inventory and being preparing public education materials to communicate the work you’re doing for LCRR compliance.
- Month 12—Complete your inventory.
- Month 13—Verify your inventory.
- Month 14—Release public education materials to communicate the work you’re doing to comply with the LCRR.
- October 16, 2024—Service line inventory and LSL replacement plan due (try to get this in before the actual deadline, of course).
Don’t have 14 months? You can still get your inventory done!
The above timeline is just a framework to help you imagine the work. You can adapt it to be more aggressive if you need, and do several items at the same time, like having conversations with local schools while also starting to create your inventory.
With the right asset management system all of this work can be streamline and accomplished, even in a short period of time.
After the Deadline
- November, 2024 and beyond—Start compliance monitoring at new sample sites.
How do I create a lead service line inventory for the LCRR?
One of the most challenging parts of the LCRR is the requirement to create a lead service line (LSL) inventory.
Smaller cities may have tens of thousands of lines. And larger cities may have hundreds of thousands or even millions of lines, making the prospect of creating an inventory that includes every single one intimidating, to say the least.
[Related read: What Is a Facility Condition Assessment?]
Another challenging aspect of creating a service line inventory is the stipulation that it must be made publicly available. Doing this requires an asset management system that allows water systems to both create a massive inventory and make it easily shareable with anyone who wants to see it.
But don’t worry—we’ve got you covered.
Keep reading for a step-by-step approach to creating and verifying your LSL inventory.
Creating a Water Service Line Inventory: A Step-by-Step Guide
Municipalities across the country are recognizing the importance of maintaining an inventory of water service lines.
These inventories help protect public health, ensure compliance with regulatory requirements, and support effective maintenance and upgrade schedules.
This section of our LCRR guide outlines the step-by-step process you can follow to create your inventory and be compliant with the LCRR.
[Related read: Strategic Asset Management (SAM)—An In-Depth Guide]
Step 1—Establish Your Objectives and Scope
What data will you be collecting about your service lines?
Spend time on this step. If you decide another data point should be added once you’ve already started collecting data, it may take a tremendous amount of time to go back and update your inventory.
Here is information you definitely want to include:
- Location and address for the line (use GIS data for precise location)
- Age of the line
- Line material
- Condition of the line
Here are some additional details you may want to consider including:
- Customer account associated with the line
- Diameter of the line
- Utility side material
- Utility side installation date
- Private installation date/building construction date
- Private material and source (keep in mind that interior/exterior can be different) and source
- Goosenecks in the line
- Private side installation date/building construction date
- Any updates that could indicate replacements, including information on contractors that worked on the line with dates of work and materials used
Here are some starting places for creating the list of information you want to include in your inventory:
- Other data important for your municipality
Ask people you know at other water systems who have already started this work for guidance. What data did they collect? They may have a few items you missed, which could help you save time down the road.
Step 2—Identify Your Inventory Methods
After you identify the type of data you want to collect, the next step is to determine where you’re going to get the data. Most likely, you’ll get your data from multiple sources.
Here are some tips:
- Research records and as-built drawings.
- Research the age of your lines—EPA banned the usage of lead in 1986, so concentrate on older service lines.
- Use GIS and/or mapping-based tools/software.
For remaining service lines made of unknown material, you’ll need to:
- Assume they are LSL until you can determine otherwise.
- Conduct visual inspections of each one in the field to determine whether they are lead.
OpenGov’s Cartegraph Asset Management has been used successfully to create LSL inventories, allowing you to archive GIS, historic, and field data for your lines.
“Cartegraph Asset Management was a key part of how we got our lead service line inventory made. It let us track historical records and repairs, and gave us information that let us go out and see trouble spots and how they correlate with the rest of our system. It’s a game changer.”
Brendon Lockette, Asset Management Coordinator, City of Plano, TX
Step 3—Choose a Tracking Method
Sure, you could use Excel to track all of your service line data. But working with a spreadsheet that has 80,000 tabs can make it hard to get anything done, let alone find a way to share the information with the public.
Platforms like OpenGov’s Cartegraph Asset Management were created to help Public Works Departments manage their assets. With Cartegraph Asset Management, a water system can create customized fields for tracking the specific data they want for their service line inventories.
The system also lets you:
- Share your service line inventory publicly.
- Report on progress toward inventory completion.
- Use mapping enabled by a GIS (Geographic Information System) to visually represent the locations of your water service lines in relation to water mains and meters.
In the City of Plano, TX, Brendon Lockette helped create a water service line inventory that included 88,672 water meters, allowing him to see how far he was toward completion through every step of the process.
A snapshot of Plano, TX’s LSL inventory progress from Cartegraph Asset Management (note: they’re done now)
Step 4—Assemble a Cross-Functional Team
After you’ve determined the data you want to collect, where you’ll get it from, and where you’ll track it, it’s time to get your team together. This is the last step you’ll take before you actually start collecting your inventory data.
Assembling a team of experts from different departments, such as engineering, GIS, and utility management, is crucial.
This team will be responsible for collecting and managing the service line inventory data and making sure that the inventory meets its objectives.
Step 5—Collect the Data
Now it’s time to roll up your sleeves and get the data you need to create your inventory.
LCRR inventory data can be drawn from:
- Historical records
- Visual inspections conducted in the field (these can be conducted in-person or by doing virtual inspections)
- Consulting with utility companies
Make sure you don’t cut corners in your data collection. The end goal is to make sure children and adults in your community don’t get exposed to contamination in their drinking water—and this can only happen if the data you collect is good.
Step 6—Verify Your Inventory
Here are four ways you can verify your inventory data.
1. Ordinance and Regulation Verification
Refer to guidelines set by past laws to verify that the information in your inventory is accurate. For example, the Safe Drinking Water Act requires plumbing to be lead free, so any lines put in after it was enacted in June of 1986 should comply with the LCRR.
Within a system like Cartegraph Asset Management, you can associate each line with its installation date to filter for service lines that comply. Additionally, you can link historical parcel dates to properties where meters are located to get a second set of dates to determine if either the private or city side of the service line was installed after the specified dates.
In the City of Plano, TX, Asset Management Coordinator Brendon Lockette added a verification method in the City’s instance of Cartegraph Asset Management with the label “Texas State lead ban” and the corresponding effective date so he could filter out lines installed after that date as in compliance.
2. As-Built Drawing Verification
Use GIS data to create a comprehensive map that centralizes all of your infrastructure data. The map should include links to scanned as-built drawings, which can be stored in your document management system.
You can then access these as-built drawings through the map. By examining them, you can identity the materials used for each service line with which they’re associated.
To speed up the review, you can use a bulk editing feature to update multiple locations tied to a specific as-built drawing at once.
Note: This verification method requires an asset management system like Cartegraph Asset Management that has an integration with a GIS solution, which allows you to access the precise locations of the water mains, navigate to the corresponding as-built drawings, and ensure accurate verification.
3. Historical Task Verification
If your local government has been tracking service line repairs, this data can be used for its LSL inventory verification.
Historic documentation of repair work, replacements, and materials can all be linked to specific service lines as they’re added to the inventory. Once the data is connected to specific lines in the inventory, it can be reviewed to identify instances of lead or copper piping.
4. Field Verification
In field verification, you go into the field and visually inspect each line to see what it’s made of. Field verification will be required when you don’t have data for a line telling you when it was put in, who put it in, or its materials.
Here are some tips for executing reliable field verification in your LCRR inventory:
- Create training materials for those who will do the field verification to ensure quality data outputs.
- Train your personnel using these materials before anyone is allowed to collect verifying service line data in the field.
- Split your personnel into two groups—one focused on inspection work and one focused on maintenance work for water meters, main breaks, and service lines.
And that’s it. At least as far as creating the inventory goes.
What To Do After Making the Inventory
Here are some follow up steps to take after you’ve created your inventory:
Step 1—Implement Regular Updates and Maintenance
Creating a water service line inventory is not a one-time process.
It’s crucial to establish a regular schedule for updating the inventory as new service lines are added, or existing lines are modified or replaced.
Step 2—Take Required Reporting, Communication, or Other Compliance Steps
Municipalities must ensure that water service line inventory complies with any local, state, or federal regulations. Compliance may include regular reporting to regulatory agencies and taking necessary actions to address any non-compliance issues.
Step 3—Use the Inventory for Decision Making
Now that you have your inventory, use it for informed decision-making.
A good asset management platform will allow you to do scenario building with your inventory, letting you make complicated maintenance decisions, helping you:
- Identify service lines that require maintenance or replacement.
- Plan capital improvement projects.
- Ensure the safety and quality of the water supply.
- Choose what to prioritize in your deferred maintenance.
Do It Yourself or Hire a 3rd party?
Collecting all the service line data you need with your internal team might be challenging, or even impossible.
Many municipalities have opted to do some of the data collection themselves and hire a third party to collect the rest of it.
After meeting with your stakeholders, you may decide that you’ll do all the data collection related to existing data, like historic or ordinance-related data, and you’ll hire a third party to do field data collection and verification.
However you split up the work, it’s good to keep in mind that there are third party service providers out there that focus on helping public water systems be compliant with the LCRR.
Start your search online. Vet the providers you find by seeing if you know anyone they’ve worked for, and you might be able to speed up your journey to LCRR compliance.
What LCRR resources are available?
Want to learn more about the LCRR?
Here are some resources to help you get started:
- The Lead and Copper Rule (official EPA page)
- The Revised Lead and Copper Rule—Lead and Copper Rule Revisions (official EPA page)
- Guidance for Developing and Maintaining a Service Line Inventory (official EPA resource)
- Supporting Materials: Final Revisions to the Lead and Copper Rule (official EPA resource)
- LCRR Fact Sheet (official EPA resource)
- Health and Environmental Agencies of U.S. States and Territories (EPA directory to help you find your stage agency)