Preparing for LCRI Compliance: Key Insights from NRWA

The National Rural Water Association (NRWA) has published an incredibly useful resource to help water systems navigate the upcoming Lead and Copper Rule Improvements (LCRI) compliance requirements. With the November 1, 2027 deadline approaching, this article provides clear guidance on what utilities need to do now to stay ahead. It breaks down the complex requirements into actionable steps, helping to ensure compliance and avoid costly penalties to your utility.

Highlights from the article:

• Regulatory Timeline: Current LCRR requirements remain in effect until 2027, when LCRI submissions are due.
• Service Line Inventory: Systems must update and verify inventories, including connectors and unknown lines.
• Annual Notices: Required for locations with lead service lines, galvanized requiring replacement, or unknown materials.
• Verification Requirements: New rules call for visual validation of non-lead lines and approved methods for confirming materials.
• Compliance Risks: Unknown lines in the 2027 baseline inventory trigger additional obligations like sampling and replacement plans.
• Data Management: Digital tools are strongly recommended to handle the data-intensive nature of LCRI compliance.

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.

Featured Webinar Series: Improving CWA-NPDES Permit Compliance

Have you attended webinars from the Improving CWA-NPDES Permit Compliance series of technical assistance webinars put on by the EPA and the Significant Noncompliance Rate Reduction National Compliance Initiative? (Also known as the SNC NCI).

These webinars are meant for plant operators, municipal leaders, TAPs, and compliance inspectors who are working to improve surface water quality and drinking water impacts by ensuring compliance with Clean Water Act and/or National Pollution Discharge Elimination System permits. Attending live will provide you with a certificate of attendance that may be eligible for CEU credit in your state, depending on your state’s certification authority. The EPA has an archive of webinar recordings dating back to 2019, but watching these recordings does not make you eligible for a certificate of attendance or any CEU credit.

All the same, the recording archive contains information on a wealth of topics under the umbrella of CWA/NPDES permit compliance. We have put together a few recommended highlights below, but be sure to examine the whole archive as you grow your knowledge in pollutant discharge.

Recording Highlights

POTWs – What Does Your Permit Say? (Part 1)
January 22, 2024: This presentation covers how to read and understand a NPDES permit, how permittees can ensure that permit requirements are met, and a discussion of the most common reporting requirements for NPDES permits. Presented by Dan Connally, vice president of ERG Group with 22 years of experience in NPDES permit development.

POTWs – What Does Your Permit Say? (Part 2)
February 28, 2024: Part two of ‘What Does Your Permit Say?’ covers the permit requirements for pretreatment and biosolids, associated federal regulations, and both standard and special conditions for publicly owned treatment works. Presented by Dan Connally, Bob Brobst (Principal Environmental Engineer at PG Environmental), and Chuck Durham (Principal Engineer and Senior Project Manager at PG Environmental).

Fats, Oils, and Grease: What We Know After 23 Years of FOG Work
October 12, 2023: This presentation focuses on managing the impacts of FOGs on collection systems and wastewater treatment plants, as well as fees, public outreach, and enforcement for food service establishments. Presented by Byron Ross of Monitoring & Management Services, with nearly 40 years of experience in wastewater treatment.

Everything You Wanted to Know About PFAS But Were Afraid to Ask
April 12, 2023: This session examines the emerging contaminants PFAS and PFOA and discusses their uses, properties, impacts, and possible treatment methods in wastewater and drinking water. Viewers will also learn to identify the sources of these contaminants. Treatment options explored include activated carbon, ion exchange resin, reverse osmosis/nanofiltration, advanced oxidation, and biosolid removal. Presented by Jamie Hope, wastewater operator and training technician, with four decades of experience in wastewater treatment.

Small POTWs: What to Expect and How to Prepare for your NPDES Permit
June 16, 2022: This webinar explains what a small publicly owned treatment works can expect as they undertake NPDES permitting. It also features a step-by-step overview of obtaining a permit and insights on collaborating with permitting authorities. Presented by Sean Ramach, NPDES Training Coordinator for the EPA Office of Wastewater Management, Water Permits Division.

RCAP's Drop of Knowledge: Article Roundup #4

Drop of Knowledge is a monthly digital article from Rural Community Assistance Partnership (RCAP.) The articles focus on topics like wastewater, drinking water, policy, and infrastructure in rural America. It contains how-to’s, tips, and guidance from more than 300 technical assistance providers (TAPs) across the country. Some featured articles are linked below:

• Resolving Inflow and Infiltration Issues in a Growing Community
• The Beginner’s Guide to Geospatial Asset Management
• How Smoke Testing Can Help Your Small Wastewater Collection System
• Red Cliff Wastewater Treatment Plant Compliant Treatment Process
• Meeting the October 2024 Deadline: A Quick Guide for Water Utilities Struggling to Get Started with Lead Service Line Inventory Compliance
• What is the Most Important Business in Your Community?

Looking for something else? Find more articles and subscribe to A Drop of Knowledge.

Public Notification & Emergency Communication

Public Notification Rule is intended to ensure that consumers will always know if there is a problem with their drinking water. These notices immediately alert consumers if there is a serious problem with their drinking water that may pose a risk to public health. They also notify customers if their water does not meet drinking water standards, the water system fails to test its water, or if the system has been granted a variance (use of less costly technology) or an exemption (more time to comply with a new regulation.) Consumer Confidence reports (CCRs) are an annual report of the status of the drinking water at a facility that are also required. However, CCRs do not necessarily report problems, but a status.

We have 731 resources (and counting) on Public Notification in our Documents Database that provide valuable information on this topic. You can search for documents about how states are responding to health advisories for water systems, ways to prepare for a drought related water shortage, advice for working with news media, boil water advisories during natural disasters, and many other useful guides that will help you to deliver safe and clean water to utility customers. 

To access the wealth of knowledge on Public Notification within our database just select "CATEGORY" in the dropdown then choose "Public Notification." Once you make that selection, a second dropdown will appear where you can choose "HOST," “TYPE,” or “STATE” to narrow the search even further. If you have a specific search term in mind, use the “Keyword Filter” search bar on the right side of the screen.

This is part of our A-Z for Operators series.

Nitrate Levels in Drinking Water

U.S. EPA regulates nitrate in drinking water to protect public health. Nitrate may cause health problems if present in public or private water supplies in amounts greater than the drinking water standard set by U.S. EPA. There is also concern about nitrate in wastewater effluent.

We have 204 resources (and counting) on Nitrate in our Documents Database that provide valuable information on this topic. You can search for documents on how to address the presence of nitrate, analytical methods recommended for drinking water monitoring of secondary contaminants, case studies on controlling nitrification in a distribution system, and many other useful guides that will help you to deliver safe and clean water to utility customers. 

To access the wealth of knowledge on Nitrate within our database just select "CATEGORY" in the dropdown then choose "Nitrate." Once you make that selection, a second dropdown will appear where you can choose "HOST," “TYPE,” or “STATE” to narrow the search even further. If you have a specific search term in mind, use the “Keyword Filter” search bar on the right side of the screen.

This is part of our A-Z for Operators series.

Compliance Monitoring for Water Systems

Regulations can require compliance monitoring at specific locations and at specific times and intervals. This can look like the collection of water samples or recording information about the system from gauges and dials. Often, samples must be shipped very quickly to the laboratory before the sample degrades. It is recommended that systems also complete voluntary monitoring for operations and maintenance purposes to diagnose potential problems.

We have 2,350 resources (and counting) on Monitoring in our Documents Database that provide valuable information on this topic. You can search for documents on sampling protocols for PFAS, comparison of coliform media, algal toxin removal capabilities of common drinking water treatment processes, Consumer Confidence Reporting (CCR) compliance checklist examples, and many other useful guides that will help you to deliver safe and clean water to utility customers. 

To access the wealth of knowledge on Monitoring within our database just select "CATEGORY" in the dropdown then choose "Monitoring." Once you make that selection, a second dropdown will appear where you can choose "HOST," “TYPE,” or “STATE” to narrow the search even further. If you have a specific search term in mind, use the “Keyword Filter” search bar on the right side of the screen.

This is part of our A-Z for Operators series.

Lead and Copper Pipe Replacement

Lead and copper enter drinking water primarily through plumbing materials. Exposure to lead and copper may cause health problems ranging from stomach distress to brain damage. The treatment technique for lead and copper requires systems to monitor drinking water at customer taps. If the action level for lead is exceeded, the system must also inform the public about steps they should take to protect their health and may have to replace lead service lines under their control.

We have 521 resources (and counting) on Lead and Copper in our Documents Database that provide valuable information on this topic. You can search for documents on how to collaborate with organizations to replace lead service lines (LSLs), case studies that analyze LSLs in small community water systems, how to reduce lead in drinking water in schools and childcare facilities, how to address lead in drinking water with the Drinking Water State Revolving Fund (DWSRF), and many other useful guides that will help you to deliver safe and clean water to utility customers. 

To access the wealth of knowledge on Lead and Copper within our database just select "CATEGORY" in the dropdown then choose "Lead and Copper." Once you make that selection, a second dropdown will appear where you can choose "HOST," “TYPE,” or “STATE” to narrow the search even further. If you have a specific search term in mind, use the “Keyword Filter” search bar on the right side of the screen.

This is part of our A-Z for Operators series.

Drinking Water Standards: Rules, Regulations, Compliance

The U.S. Environmental Protection Agency (EPA) sets standards that, when combined with protecting ground water and surface water, are critical to ensuring safe drinking water. U.S. EPA works with its regional offices, states, tribes and its many partners to protect public health through implementing the Safe Drinking Water Act. The standards are the levels of a particular contaminant that are allowed in drinking water and still considered safe.

We have 1482 resources (and counting) on Drinking Water Standards in our Documents Database that provide valuable information on this topic. You can search for resources like an overview of the Safe Drinking Water Act (SDWA), information on how U.S. EPA develops risk-based drinking water regulations, a comprehensive list of potential contaminants in water, and many other useful guides that will help you to deliver safe and clean water to utility customers. 

To access the wealth of knowledge on Drinking Water Standards within our database just select "CATEGORY" in the dropdown then choose "Drinking Water Standards." Once you make that selection, a second dropdown will appear where you can choose "HOST," “TYPE,” or “STATE” to narrow the search even further. If you have a specific search term in mind, use the “Keyword Filter” search bar on the right side of the screen.

This is part of our A-Z for Operators series.

Arsenic in Drinking Water

Arsenic is a heavy metal and a regulated contaminant in drinking water and wastewater effluent. In 2001, under the Arsenic Rule, EPA adopted a lower standard for arsenic in drinking water of 10 parts per billion (ppb) which replaced the previous maximum contaminant level (MCL) of 50 ppb. Arsenic is a semi-metal element in the periodic table. It is odorless and tasteless. It can enter drinking water supplies from natural deposits in the earth or from agricultural and industrial practices. 

We have 180 resources (and counting) on Arsenic in our Documents Database that provide valuable information on this topic. You can search for documents about the arsenic rule, complying with the arsenic maximum contaminant level, the reporting requirements for the annual Consumer Confidence Reports (CCR), and many other useful guides that will help you to deliver safe and clean water to utility customers. 

To access the wealth of Arsenic related knowledge within our database just select "CATEGORY" in the dropdown then choose "Arsenic." Once you make that selection, a second dropdown will appear where you can choose "HOST," “TYPE,” or “STATE” to narrow the search even further. If you have a specific search term in mind, use the “Keyword Filter” search bar on the right side of the screen.

This is part of our A-Z for Operators series.