Lead and Copper Rule Improvements
Town of Bowling Green, VA
June 4, 2026
Town
About TruePani
Engineering, communications, and data management firm specialized in lead in drinking water
Headquartered in Knoxville, TN, with staff nationwide
Lead and copper assistance to over across 18 states including over 800 waterworks in Virginia
Lead and Copper
Technical Assistance
• TruePani is providing technical assistance to small community and non-transient waterworks serving 10,000 people or fewer
• Assistance available for all aspects of the LCRI with an emphasis on the baseline inventory and unknown identification strategies
What is a service line?
Inventory must include the systemand customer-owned portions of all service lines in the system’s distribution system.
”Public side”
“Private side”
Materials include
Non lead like copper or plastic
Lead
Galvanized Requiring Replacement
Unknown
Federal Reserve Bank of Chicago. Getting the Lead Out: New Opportunities and Challenges to Scale Up Lead Service Line Replacement. February 2022
Lead and Copper Rule Improvement: Major Requirements
Initial compliance date of November 1, 2027
Baseline inventory submission
A list of all schools and licensed child care facilities
Service Line Replacement Plan, if required
Begin mandatory lead and GRR service line replacement
Fully known inventory and removal of all lead and GRR service lines under the control of the waterworks by November 1, 2037
Validation of non-lead determinations by December 31, 2034
Town of Bowling Green Council Meeting | TruePani Inc.
WSSC Water, Galvanized Water Service Lines
Customer Notification Requirements
Annual notification to all lead, GRR, and unknown customers by December 31
Notification deadline changes after start of LCRI
LCRI requires notification to customer and all served
Certify the distribution of notifications by July 1 in the following year by either:
Notify residents upon new service initiations at addresses served by lead, GRR, and unknown within 1 business day
Starting after November 2027, customers must be offered lead testing
Town of Bowling Green Council Meeting | TruePani Inc.
Deadline Requirements
▪ Certify the distribution of 2025 service line material customer notifications by July 1
In 2026
November 1, 2027
(LCRI Takes Effect)
▪ 24-hour, Tier 1 notification for lead ALE
▪ Update language in the CCR
▪ Annual notification by end of year
▪ Baseline Inventory
▪ Service Line Replacement Plan, if required
▪ List of all schools and child care facilities
▪ Lead action level reduced from 0.015 mg/l to 0.010 mg/l
▪ Begin replacing lead and GRR service lines
▪ Standard tap monitoring begins for systems with GRR or lead
▪ Updated compliance sampling plan
January 1, 2028
▪ Tap sampling protocol provided to customers
▪ List of water quality parameter sites, if required
January 30, 2035 ▪ Validation pool results
November 1, 2037
▪ Fully known inventory
▪ Removal of all lead and GRR service lines under system control
Town of Bowling Green Inventory Status
Currently compliant, but inventory has GRR and unknowns
Fully known on system side, Unknown and GRR are due to customer materials
VDH developed GRR reclassification guidance
530 unknowns can be IDed through approved statistical methods
TruePani completed statistical proposal which was approved by VDH in February 2026
Required a minimum of 107 customer service line investigations from randomly generated list
Hand digging, meter box inspections, customer surveys, crawl space or basement inspections, etc.
Town of Bowling Green Council Meeting | TruePani Inc.
Advantages of a Fully Known Inventory
Reduce or eliminate annual notification
Required by end of year to all customers served by lead, GRR or unknown line
Certified the following July 1
If fully non-lead, no mandatory replacement or service line replacement plan
Replacement must be complete by 2037
Replacement is independent of ownership and based on control
VDH is expecting all water systems with GRR and/or Lead to replace these lines
If fully non-lead, no return to standard monitoring
Currently collecting 10 samples every 3 years
Standard monitoring is 20 samples every 6 months with complicated sampling procedure for those served by lead lines
If fully non-lead, reduction or elimination of extra lead mitigation requirements like pitcher filters and additional communication
Questions?
Guidance Documents
EPA Lead and Copper Rule Improvements
Inventory and Replacement Fact Sheet (PDF)
Validation Pool Fact Sheet (PDF)
Other EPA LCRI Fact Sheets
VDH Lead and Copper Rule Guidance
Preparing for the Lead and Copper Rule Improvements Guidance Document (PDF)
VDH ODW GEC SWIFT Portal Instructions (PDF)
VDH Protocol to address GRR Lines (PDF)
GEC SWIFT Portal
VDH School and Child Care Sampling Projects
Town of Bowling Green Council Meeting | TruePani Inc.