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Lead Service Line Replace­ments

Getting the lead out does not stop with removing the lead service line (LSL). Under the Lead & Copper Rule Revisions (LCRR), you are required to take these additional steps to protect your community's drinking water. 

Service Material Inventory

All systems are required to compile a service line material inventory—including both utility-owned and privately-owned sides of the service line—within 3 years of the LCRR publication date (by January 2024) or demonstrate absence of LSLs.

Any galvanized service lines that are, or were formerly, downstream of an LSL are considered "galvanized requiring replacement," not quite LSLs from a customer perspective, but still required to be included in the overall count of LSLs for eventual replacement. Services with unknown materials that may be lead will be classified as "lead status unknown service lines" and will count towards the total number of LSLs in the system. Unknown materials that are unknown but known not to be lead (for example, installed after the lead ban), can be classified as "non-lead" meaning that their exact material does not need to be known. Update inventory annually or triennially, based on sampling frequency, with any replacements and/or verifications.

All systems must notify customers who have service lines categorized
as lead, galvanized requiring replacement, or lead status unknown
  • Lead service line – Service line made of lead (lead goosenecks only are not considered lead service lines)
  • Galvanized requiring replacement – Galvanized service line currently or formerly downstream of a lead line, lead gooseneck, pigtail or connector.
  • Lead status unknown – Service line of unknown material installed before a lead ban that may be lead
within 30 days of completing the inventory and then on an annual basis. The EPA has specific guidelines in the Rule for what information needs to be included in the notification.

If a system exceeds the lead trigger level, additional notification to customers with LSLs, galvanized requiring replacement or lead status unknown service lines is required within 30 days of the end of the monitoring period in which the exceedance occurred. The notification shall include information about the lead service line replacement program. The notification must also be repeated annually until the system is no longer in exceedance.

Replacement Program Plan

All systems with LSLs must also prepare a Lead Service Line Replacement Program by January 2024. This plan must include:

  • A strategy for determining "lead status unknown" service lines
  • Procedures to conduct full LSL replacements
  • Communication strategies
  • LSL replacement goal rate in the event of a lead trigger level exceedance (for systems over 10,000 persons)
  • Flushing procedures
  • LSL prioritization strategies
  • Funding strategies including ways to accommodate customers that are unable to pay for the replacement of their portion on their own

Conducting a Replacement

Following each lead service line replacement (LSLR), systems must:

  • Provide a pitcher or faucet filter and cartridges to each customer for 6 months after replacement or a disturbance. Filters must be certified to remove lead per NSF 53 and must be provided within 24 hours for full and partial LSLRs. Filters must also be provided for any disturbance to a LSL, such as meter replacements.
  • Provide notification, including flushing procedures, to the customer after a disturbance or replacement of a LSL, galvanized line requiring replacement or lead status unknown service.
  • Collect a lead tap sample at each location where a LSLR occurred within 3 to 6 months after replacement. Results need to be provided to the customer within 30 days. If the tap sample exceeds the lead action level of 15 µg/L, the customer should be notified within 3 days of receiving the results.
  • Inform consumers annually that they are served by an LSL, galvanized requiring replacement or lead status unknown.

Partial Replacements

Only full LSLR (both customer-owned and utility-owned portions) count toward the replacement target. A partial lead service line replacement, such as a utility-owned side replacement where the customer-owned side remaining is lead or galvanized steel, does not count as a replacement.

Partial replacement (utility-side only) are only allowed during main replacements and emergency replacements. In this case, the utility is required to notify the customers 45 days in advance and offer to replace the customer-side in addition to the utility-side. The utility is not required to bear the cost of the customer-owned side replacement.

If the customer is unable or unwilling to have their side replaced, a utility is required to notify the customer and follow risk mitigation procedures in their LSLR plan. Risk mitigation measures should include flushing guidance to remove particulate lead and providing a pitcher or faucet filter certified to remove lead per NSF 53 standards and replacement cartridges for no less than 6 months.

A tap sample must be taken between 3 and 6 months after the partial LSLR. Results need to be provided to the customer within 30 days. If the tap sample exceeds the lead action level of 15 µg/L, the customer should be notified within 3 days of receiving the results.

If a utility is replacing LSLs to meet a goal-based LSLR Program or the 3% per year LSLR Program due to a trigger level or lead action level exceedance, respectively, conducting a partial LSLR does not count towards meeting the goal. In fact, it remains as a "lead service line" since the line still contains lead.

Customer-Triggered Replacements

The public side of the service line must be replaced within 45 days if a consumer notifies a system within 3 months of replacing the private customer-side. A filter and flushing instructions must be provided within 24 hours of receiving notification of the replacement from customer. If the customer notifies the water system after 3 months from the replacement, no replacement or filter are required.

Latest News
https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule
As of March 10, 2021, the EPA is requesting additional public input on the Lead and Copper Rule Revisions and has extended the effective date to at least June 17 and potentially December 16. This may push the compliance date back from January 2024 to September 2024.
Read EPA's Release Opens in new window.

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