Where to Start with the Revisions to the Lead and Copper Rule (LCR) – Part 1
Service Line Inventory
The Revised Final Lead and Copper Rule (LCR) became effective on December 16, 2021. The new compliance date is September 16, 2024, meaning preliminary actions should be started soon to meet this short compliance deadline.
The changes in this rule that affect every public water utility include:
- Requirement of the Creation and Publication of a Service Line Inventory
- Updated Requirements for Service Line Replacements
- Updated Sampling Requirements
- New Trigger and Action Levels
- New Outreach and Education Information
- Increased School and Childcare Testing
The first step in tackling these changes is establishing a Service Line Inventory to identify and prioritize those in need of action.
The Service Line Inventory must list all service lines in the utility and indicate their respective known or estimated materials (i.e., Lead, Galvanized, Unknown, Other). The material must be documented on both the public and private sides of the service line. This inventory must be made publicly available online (required for large systems) or through other means (for small systems). The inventory is required to be updated annually or triennially based on the sampling frequency, and is recommended to be updated as projects are completed, and more information is discovered.
The inventory must be based on the “best available knowledge” such as plumbing codes, permits, records on file, and records of projects or inspections. Some utilities may choose this as an opportunity to create or fully utilize a GIS-based system.
With the new LCR, service lines of “Unknown” materials are treated as potential lead lines, and any user with a Lead, Galvanized downstream of Lead, or Unknown service line material must be notified. These users will also be prioritized for sampling with the new sampling procedures.
Commonwealth is actively incorporating the documenting of discovered service lines in all new construction projects to assist with the LCR Inventory requirements. Additionally, Commonwealth has successfully applied the AWWA C810 procedure to prioritize locations at risk and likely require remediation of lead lines. This approach has been approved by the SRF-IFA with resultant grant funding for said replacements and provides an appropriate process for replacing these assets.
We would be happy to discuss these options and other ways we can help in creating your System’s Service Line Inventory. Contact Brady Dryer, Compliance Manager, 317.888.1177, for more information.
