Where to Start with the Revisions to the Lead and Copper Rule (LCR) – Part 2

Replacement Plan

Once the Service Line Inventory has been created, the next steps include (1) the creation of a Replacement Plan and (2) an update to the Sampling Plan.

• Any system with a Lead, Galvanized downstream of Lead, or Unknown service line material must assemble a plan for replacement of these lines. Implementation of the replacement plan can be mandated if Lead and Copper samples exceed the new “Action” and/or “Trigger” levels. IDEM is creating the framework for these requirements. Any replacement of a service line must be from the water main to the premise plumbing. Partial replacements are no longer acceptable. If a user voluntarily replaces their portion of the service line, the utility must replace the public-owned side as well. Follow-up sampling and monitoring are required after replacement.
• Each Utility’s Sampling Plan will need to be updated with the creation of the Service Line Inventory. Sampling must now be performed annually at high-risk sites. If you have Lead Service Lines in your system, it is unlikely that this sampling frequency will be reduced until these service lines are removed from the system. The Revised LCR has updated the method of sampling for Lead and Copper as well. In addition to the previously-mentioned sampling sites, schools and daycares must also be identified and sampled.

Commonwealth has performed several service line replacement projects both in combination with other larger utility improvements projects and as independent projects. Several grant funding options exist for these projects. Contact Brady Dryer, Compliance Manager, at bdryer@contactcei.com  or 317.888.1177, for more information.