October LCRR deadline: Be proactive, not reactive

The Oct. 16, 2024, deadline to comply with certain requirements in the U.S. Environmental Protection Agency’s (EPA) Lead and Copper Rule Revisions (LCRR) is looming. Is your water system ready?

Since announcing in December 2021 that the LCRR was final, EPA has proposed further changes in its pending Lead and Copper Rule Improvements (LCRI). These were sent to the Office of Management and Budget (OMB) on Aug. 2 for review.

Although some provisions in the LCRI may supersede requirements in the LCRR, EPA has emphasized that all community water systems and non-transient non-community water systems should be prepared to meet certain LCRR provisions on Oct. 16 that will not change once the LCRI is finalized. These include:

• Preparation such that the system can meet Tier 1 public notice requirements in the event of a system lead action level exceedance (e.g., communitywide notice within 24 hours of becoming aware of the exceedance). 

• Submission of a service line inventory by Oct. 16 that identifies all service lines in a system’s service area as either lead, galvanized requiring replacement (GRR), non-lead, or lead status unknown. This includes making the inventory publicly available. EPA has provided guidance and individual state primacy agencies have specified instructions for inventory development and submittal.

• Notification of customers whose service line is lead, GRR or lead status unknown. With inventories due by Oct. 16, initial notification within 30 days of official inventory submittal is no later than Nov. 15.

“Regardless of whether lead has been a topic of interest locally, your water system needs to be prepared and tell your story to your community,” said Jeff Swertfeger, superintendent of water quality and treatment with Greater Cincinnati Water Works and chair of the Water Utility Council’s Regulatory Committee.

“Your customers, local elected leaders and the media will be interested in the status of your service line inventory and your ongoing work to identify and replace lead and galvanized requiring replacement service lines,” Swertfeger added. “Communicating your efforts now and for the foreseeable future is critical to helping your community to understand what you are doing to prevent lead exposure through drinking water.”

How-to guidance on lead regulations

For the other initial LCRR requirements, EPA describes the LCRI as resetting initial compliance dates to three years after when the rule is finalized. More information is available on EPA’s April 2024 fact sheet about LCRR implementation. 

Both the LCRR and proposed LCRI include new requirements for water utilities of all sizes to expand consumer awareness about lead, develop service line inventories, communicate about public health, and test at schools and childcare facilities. 

EPA recently released a fact sheet and templates on the service line material notification. These resources and EPA’s other LCRR guidance contain both required and suggested elements. Water systems may adapt their own public-facing materials to communicate more clearly to their local communities as long as they include required elements.  

AWWA and its sections offer educational programming and information to encourage exchange of successful practices, including a lead communications resource page and a Lead Communications Guide and Toolkit.