LCRI: Next Steps for Water Systems

The recent Lead and Copper Rule Improvements (LCRI) introduced by the EPA mark a significant step towards ensuring safer drinking water across the United States. These improvements require water systems to take several important actions to comply with the new regulations. Below is a guide to help water systems navigate these changes effectively and efficiently.

Develop a Baseline Service Line Inventory: Water systems must create a detailed inventory of all service lines, identifying those made of lead or galvanized steel. This inventory is crucial for planning and prioritizing replacements. The initial inventory was due by October 16, 2024, and must be updated regularly.

Replace Lead Service Lines: One of the core requirements of the LCRI is the replacement of all lead service lines within 10 years. Water systems need to develop a comprehensive replacement plan, secure funding, and begin the replacement process promptly.

Enhanced Testing and Monitoring: The LCRI mandates more rigorous testing protocols to detect lead in drinking water. Water systems must implement these protocols, which include testing at schools and childcare facilities for the first time. Regular monitoring and reporting are essential to ensure compliance and protect public health.

Public Notification and Communication: Transparency is key under the LCRI. Water systems must notify the public about the presence of lead service lines and any exceedances of lead action levels. Effective communication strategies should be developed to keep communities informed about the risks and the steps being taken to mitigate them.

Secure Funding and Resources: Compliance with the LCRI will require significant financial resources. Water systems should explore funding opportunities such as the Drinking Water State Revolving Fund (DWSRF) and grants available under the Bipartisan Infrastructure Law. Developing a robust financial plan is essential to support the replacement and testing initiatives.

Funding can be accessed through several federal programs:

• Bipartisan Infrastructure Law: This law provides $15 billion specifically for lead service line replacement and an additional $11.7 billion for general Drinking Water State Revolving Funds (DWSRF), which can also be used for lead service line replacement.
• Water Infrastructure Improvements for the Nation Act (WIIN) Grants: These grants for small, underserved, disadvantaged communities offer competitive funding opportunities that can help small systems reduce lead in drinking water.
• Water Infrastructure Finance and Innovation Act (WIFIA) Loans: This program provides low-interest loans for water infrastructure projects, including those focused on lead service line replacement.
• EPA Technical Assistance Programs: The EPA offers technical assistance through initiatives like the Get the Lead Out (GLO) Initiative, which helps communities identify lead service lines, develop replacement plans, and apply for funding.

Staff Training and Capacity Building: Ensuring that staff are well-trained and knowledgeable about the new requirements is crucial. Water systems should invest in training programs and capacity-building initiatives to equip their teams with the necessary skills to implement the LCRI effectively.

Engage with the Community: Community engagement is vital for the successful implementation of the LCRI. Water systems should hold public meetings, provide educational materials, and work closely with community leaders to build trust and support for the lead service line replacement efforts.

The Lead and Copper Rule Improvements represent a significant advancement in protecting public health from the dangers of lead in drinking water. By following these steps, and reading EPA's Fact Sheet for further guidance, water systems can ensure compliance with the LCRI and contribute to a safer, healthier future for all communities.

Proposal to Strengthen Lead and Copper Rule

On November 30, 2023, U.S. EPA announced the proposed Lead and Copper Rule Improvements (LCRI). The proposed LCRI is a major advancement in protection from the significant, and irreversible, health effects that can occur after being exposed to lead in drinking water.
  
Key provisions in the proposal include:

• Achieving 100% Lead Pipe Replacement within 10 years. The proposed LCRI would require the vast majority of water systems to replace lead services lines within 10 years.
• Locating Legacy Lead Pipes. Under the proposed LCRI, all water systems would be required to regularly update their inventories, create a publicly available service line replacement plan, and identify the materials of all service lines of unknown material.
• Improving Tap Sampling. The proposed LCRI would require water systems to collect first liter and fifth liter samples at sites with lead service lines and use the higher of the two values when determining compliance with the rule.
• Lowering the Lead Action Level. EPA is proposing to lower the lead action level from 15 µg/L to 10 µg/L. When a water system’s lead sampling exceeds the action level, the system would be required to inform the public and take action to reduce lead exposure while concurrently working to replace all lead pipes.
• Strengthening Protections to Reduce Exposure. Water systems with multiple lead action level exceedances would be required to conduct additional outreach to consumers and make filters certified to reduce lead available to all consumers.

Taken together, these provisions in the proposed LCRI would strengthen public health protections, reduce complexity, and streamline implementation. EPA anticipates finalizing the LCRI prior to October 16, 2024.

Further Resources & News... 

• Press Release
• Q&A Page
• General Fact Sheet
• Proposed LCRI: Pre-Publication Federal Register Notice (pdf)
• Lead Pipe and Paint Action Plan
• Are there lead pipes in my area? Map shows state public water rankings | Fast Company
• EPA proposes requiring lead water pipes to be replaced in 10 years | The Hill
• EPA Proposes Lead and Copper Rule Improvements (LCRI) | ASDWA
• City seeks contractors as lead pipe replacement initiative ramps up | CBS Detroit

5 Strategies for a Lead-Free Rural Water System

The Environmental Protection Agency (EPA) continues to focus efforts around reducing lead exposure from all sources, particularly for children.

The agency is proposing tighter rules for exposure to lead in older residential buildings and childcare facilities that have completed lead abatement. The draft rule would lower the lead dust hazard level to any level greater than zero — meaning any amount of lead paint found remaining in a building would be considered a hazard.

EPA Deputy Administrator Janet McCabe said in a statement: “This proposal to safely remove lead paint along with our other efforts to deliver clean drinking water and replace lead pipes will go a long way toward protecting the health of our next generation of leaders.”

The proposal complements expected exposure reductions from the replacement of lead-based service lines at public water systems. This article from Water Online (excerpted below) outlines the following suggestions for water utilities in rural areas:

Identify how broad-based the problem is.
It’s hard to make any progress without knowing just how big the problem of lead service lines is in any given community. As other communities have done, utilities can create maps of their service line networks. These maps can help identify concentrations of lead pipelines.

Inform customers about potential lead pipeline contamination.
The average customer doesn’t think about lead contamination when turning on the tap. Customers need to be educated about what their pipes are constructed of and how those materials can affect their water quality. The more they know, the more likely they’ll want their utilities or cooperatives to help them solve the problem.

See how other communities have replaced their lead pipes effectively.
Some communities, utilities, and cooperatives have been very successful in upgrading their water systems. Consequently, other communities should take notice. Building a playbook based on a city or town that has already undertaken the effort can be simpler than starting from scratch.

Look for funding sources.
Any kind of pipe replacement is costly. That’s why it’s important to stay on the leading edge of any funding streams available to cooperatives, utilities, towns, etc. For instance, the EPA has some excellent resources and links to various types of water project grants and loans, such as the Drinking Water State Revolving Loan Fund.

Build a framework for replacing all the lead service lines.
With the right information and well-educated customers, utilities and cooperatives can begin building timelines to replace all the lead service lines. In time, the overarching goal can be a lead-free water system. Though some customers might not like absorbing minimal costs along the way, most will appreciate not having to worry about the quality of the water they and their families are drinking.

Further Resources:  

• Lead Home Page | U.S. EPA
• Lead Regulations | U.S. EPA
• Lead Service Line Replacement | U.S. EPA
• Funding and Technical Resources for Lead Service Line Replacement in Small and Disadvantaged Communities