Lead and Copper Rule Revisions: What a Water System Needs to Know Elizabeth Grove, MRWA Management Circuit Rider Many of you have heard by now about the new requirements of the recent changes to the Lead & Copper Rule. If you haven’t, you need to get updated as the clock is ticking on meeting the new requirements outlined in this rule! The Lead & Copper Rule Revisions (LCRR) went into effect on December 16, 2021. This new rule included many changes to the current Lead & Copper Rule, but the major item that EPA wants every water system to concentrate on is the Lead Service Line (LSL) Inventory requirements outlined in the new rule. The LSL inventory requirement applies to every public water system in the nation. Basically, every water system must inventory every water service line in their system, from the main to the foundation of the house, and determine what type of material is present. There has been some confusion with water systems regarding the “service line all the way to the house” definition. Most water systems only own and maintain the service lines from the water main to the meter or to just past the meter. The remainder of the water line to the house is the responsibility of the homeowner or occupant. This rule requires that the inventory include the homeowner’s or occupant’s portion of the line in the inventory. It does not mean that the water system is taking over ownership or control of the homeowner’s portion of the service line, only that the inventory must include that portion. The inventory must be completed and turned in to the Missouri Department of Natural Resources (MoDNR) by October 16, 2024. MoDNR will provide an Excel spreadsheet template for systems to use to enter the information on each service line. The template is expected to be available by late June 2022. Information that will be required in the inventory includes, but is not limited to, an address or unique identifier for each service line and type of material (lead, galvanized requiring replacement, non-lead, or unknown). Some systems may think that taking the easy way out would be to categorize all service lines as “unknown”. However, doing this will make things more difficult in the future. While the present emphasis is on completing the inventory, future requirements will include lead service line replacement, and those “unknown” service lines may have to be treated as lead lines and require communication with the property owner and/or service line replacement.
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