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How to Stay on Track with the Revised Lead and Copper Rule (RLCR)

Posted by Tori Morgan on Thursday, October 28, 2021

The Revised Lead and Copper Rule (RLCR) is at our doorstep, with a scheduled effective date of December 16, 2021. RLCR is a federal EPA regulation that will require water systems to conduct a Lead Service Line (LSL) Inventory and prepare a Lead Service Line Replacement (LSLR) Plan with an anticipated deadline of October 16, 2024

That deadline seems quite far away right now, but undoubtedly, it will be upon us before we know it. With the potentially high level of effort needed for compliance, procrastination is not a strategy I would recommend, so here's the immediate, short-term, and long-term information you need to get started.

What you need to know:

Requirements under the new rule include:

Using science-based testing protocols to find more sources of lead in drinking water.
Establishing a lead trigger level to jumpstart mitigation earlier and in more communities.
Requiring more and complete lead service line replacements.
Requiring testing in schools and childcare facilities.
Requiring water systems to identify and make public the locations of lead service lines.

What should you be doing NOW?

LSL Inventory and Replacement Plan –get started, reduce your “Lead Status Unknown’s”. Check out our LSL Inventory & Replacement Plan Blog
Review your current sampling pool and historic 90th percentile results. Understand if you are likely to have a trigger level exceedance and what would be the required action.
If possible, eliminate any individual sites with Action Level (AL) exceedances.
Update public educational materials and notices.
Identify the schools and childcare facilities in your service area.

What should you prepare to do in the future?

Lead Service Line Inventory and subsequent replacement action plan.
Lead Service Line Replacement (LSLR) plan that describes in detail the procedures for replacing the lead service lines.

The RLCR requirements are a federal mandate, and water utilities across the country will be working towards compliance and considering funding opportunities to help offset associated costs. Early planning and preparation for a shovel-ready project will be key to viable funding opportunities.

12/16/21: Update from EPA- The Lead and Copper Rule Improvements (LCRI):

The EPA announced next steps to strengthen the regulatory framework on lead in drinking water, here is where they will be focusing:

Issuing guidance - including best practices, case studies, and templates to help develop lead service line inventories—to assist its partners in implementation of the rule.
Proposing requirements that, along with other actions, would result in the replacement of all lead service lines as quickly as is feasible.
Consider opportunities to strengthen tap sampling requirements and explore options to reduce the complexity and confusion associated with the action level and trigger level, with a focus on reducing health risks in more communities.
Funding – EPA will allocate $2.9 billion in Bipartisan Infrastructure Law funding to states, Tribes, and territories to remove lead service lines. This 2022 allocation is the first of five allotments that will provide $15 billion in dedicated funding for lead serve lines replacements. In addition to the dedicated investment in lead service lines, the Law provides an additional $11.7 billion in general funding through the Drinking Water State Revolving Fund, which can also be utilized for lead removal projects.

EPA intends to maintain the requirements for information to be submitted in the initial lead service line inventory by the current October 16, 2024 compliance date. That being said, water systems should continue with their Lead Service Line Inventory Survey implementation. The agency anticipates finalizing the forthcoming Lead and Copper Rule Improvements (LCRI) prior to October 16, 2024

We will continue to stay informed and share updates as they become available.