The proposed Lead and Copper Rule Improve­ments have arrived. What does it mean for utilities?

Insight
The proposed Lead and Copper Rule Improve­ments have arrived. What does it mean for utilities?
The long-awaited regulations were recently released, and we are reviewing the proposed changes and updating resources accordingly.

U.S. EPA released the proposed Lead and Copper Rule Improve­ments (LCRI) on November 30, 2023. Here's what water utilities need to know to prepare for compliance.

The LCRI proposal focuses on the following elements. See the proposed rule here. 

Inventory

  • Initial inventory still due Oct 2024 and required noti­fi­ca­tions to LSLs, GRRs & unknown
  • Baseline inventory with connectors due Oct 2027*
  • New non-lead validation step
  • Identify all by 2037*

Service Line Replace­ments

  • Replace all LSLs and GRRs by 2037* (regardless of 90th percentile)
  • 10%/year 
  • Partials prohibited during LSLR programs

Distur­bances

  • Flushing instruc­tions, filter, sampling for replace­ments
  • No post-sampling for major distur­bances
  •  Disturbance require­ments may start before 2027*

Water Quality & Sampling

  • Action Level reduced to 10 ppb
  • 1st and 5th liter for LSLs - count the highest
  • Tier changes delayed to 2028*
  • Offer free water sampling to LSLs, GRRs, unknowns
  • Distri­b­u­tion System and Site Assessment follow-up for individual samples over 10 ppb

School Sampling

  •  Mandatory sampling delayed to 2028*
  •  Can use school sampling results back to Jan 1, 2021 (request waivers)

Corrosion Control

  •  If exceed Action Level (AL), can delay CCT opti­miza­tion if replace all LSLs in 5 years
  •  3 exceedances in 5 years -> offer filters to all
  •  Reoptimize CCT only once if meeting Optimal Water Quality Parameters

Public Outreach

  •  Tier 1 Public Notice within 24-hrs after AL exceedance
  •  3 days sample results to customers
  •  Additional public outreach require­ments

*Date estimated based on LCRI effective date, estimated to be October 2024

Sandy Kutzing Sandy Kutzing
Have questions?
Contact our lead in drinking water leader, Sandy Kutzing.
Lead and Copper Rule Improve­ments (LCRI)
https://www.cdmsmith.com/en/Campaigns/LCRI-Timeline
On November 30, 2023, the EPA announced the proposed LCRI. Our materials will be updated once the LCRI is finalized which is anticipated in October 2024. In the meantime, please see this anticipated timeline based on the proposed regulations.
Get LCRI Timeline
LCRI Timeline LCRI Timeline
Webinar: How the Proposed LCRI Impacts Your Current Operations
Our experts cover proposed changes to inventory, replacements, disturbances, water quality, corrosion control, sampling, and outreach. Watch it and earn a PDH.