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Lead, a well-known highly toxic pollutant, can severely damage human health, negatively impacting our neurological, cardiovascular, immunological, and developmental systems. The worse news? No safe level of lead exposure has been identified. To protect public health and reduce exposure to lead in drinking water, EPA established the Lead and Copper Rule (LCR) in 1991. Its Implementation over the past twenty-five years has significantly improved public health. The EPA then planned to further strengthen LCR by announcing the Lead and Copper Rule Revisions (LCRR) in December 2021 and the proposed Lead and Copper Rule Improvements (LCRI) in November 2023.
LCRR/LCRI aims to get the lead out of millions of homes by identifying the most at-risk communities and ensuring that water utilities have plans in place to swiftly respond to reduce elevated levels of lead in drinking water. The LCRR/LCRI strengthens the Lead and Copper Rule (LCR) by:
- Improving lead sampling and corrosion control
- Expanding public education and customer outreach
- Starting lead testing in schools and childcare facilities
- Requiring a public inventory of lead service lines
- Initiating more lead service line replacements
However, the rules have prompted many questions. So, to help you resolve a few, we are creating this library of the most frequently asked questions, or FAQs, regarding LCRR/LCRI.
Read on to learn more about the regulations. You can also visit Trinnex LinkedIn and X (Twitter) accounts to catch the latest news around the regulations.
LCRR/LCRI commonly asked questions
- What's the typical success rate utilities can expect to see with self-reporting of service lines for LCRR?
- What falls under the "unknown - not lead" LCRR category?
- When it comes to LCRR reporting, does city responsibility end outside the house, meaning interior plumbing is excluded?
- If we don't have lead, do we automatically meet LCRR compliance?
- Is there a benefit to using Artificial Intelligence in the LCRR compliance process?
- When is the optimal time to start a service line inventory?
- Our GIS does not have service laterals or customer points. What’s the best way to even start assembling an inventory?
- How do you determine the level of effort to achieve Lead & Copper Rule compliance if there’s limited access to clean data?
- Which cities or states have the highest amount of lead pipes?
- Is there a set number of field verifications necessary to make a machine learning model accurate?
- How can machine learning become an acceptable method for service line inventory development?
- How can small utilities reduce the amount of time and resources spent on their inventory development?
- Has the EPA released any guidance on service line inventory development?
- To comply with LCRR, what should the service line inventory include?
- Building your own service line inventory vs. buying one — what is more beneficial?
- How does one tackle cybersecurity implications when managing lead service line inventory?
- When does the obligation to provide images and offer tap sampling after replacements commence?
- Will stub services be required to report on the inventory?
- If galvanized is on the customer side and the city side has no lead, is the city required to replace the galvanized?
- Does the school and daycare sampling paperwork need approval of state or health departments?
- How do utilities offer their public portal in other languages? Do we use a translation service for that?
- How is distribution system sampling different from tap sampling?
- Does the rule require replacement of service line from meter to home?
- How will unknown connectors affect overall service line category?
- School and daycare sampling delayed until 2028. Is a list still required by October 2024?
- Which states have agreed to accept predictive modeling?
- How should I word everything regarding galvanized to the public without being too confusing?
- Is leadCASTTM a web-based subscription software service?
- Does unknown not lead trigger replacements as well?
- Is the service line limited to residential properties, or is it also necessary to include commercial properties?
- Do lead joints trigger galvanized requiring replacement?
Question 1: What's the typical success rate utilities can expect to see with self-reporting of service lines for LCRR?
Answer: Based on projects similar to the Newark Lead Service Line Replacement Program, utilities can expect 5 to 10% customers to self-report. Customers who do submit a response are typically 95% accurate in reporting copper or plastic. We don’t have enough data on lead and galvanized pipes yet to calculate the typical accuracy rate with its self-reporting. DC water has a great website helping customers on how to identify lines.
Self-reporting provides a low-cost way of getting information. You can put the form on your website, mail out postcards, or use door hangers with the QR code that will take customers to the form. There will be some back and forth — some homeowners may take a picture of their gas line rather than their water line. But some inventory data collection systems have built-in workflows to address such common issues, with the ability to notify homeowners when a new photo is needed. While it's not as accurate as physically checking the pipe itself, self-reporting is considerably cheaper and time-saving method, which ultimately contributes to the material identification process and makes your community feel involved.
Question 2: What falls under the "unknown - not lead" LCRR category?
Answer: Under the LCRR, an unknown material is considered guilty until proven innocent. However, service lines installed/updated after the 1990s are safe to be filed under the "unknown - not lead" category. This holds true as long as records exist that justify that lead was not used, and that other material, such as copper or PVC, was instead used for the lines in question.
The best practice is to identify materials of as many service lines as you can, especially before the LCRR 2024 deadline. With this, you will stay on path with maintaining LCRR compliance, and can take advantage of potential funding opportunities to help remove lead service lines.
Before opting for more invasive and expensive investigation techniques to find service line material, water utilities have a few options for obtaining data that will help them identify materials and develop a service line inventory. These top information sources include paper records, historic municipal building codes, and other options as mentioned here.
Question 3: When it comes to LCRR reporting, does city responsibility end outside the house, meaning interior plumbing is excluded?
Yes, in most cases, city responsibility for reporting ends with the customer side up to the foundation. But with self-reporting, we're talking about where the pipe enters at the foundation before the meter. Depending on the region (such as in the South), you might not have access to the pipe coming in through the foundation to be able to identify and verify its material type but once it hits the foundation, you don't have to report on it. It is important to check with your state primacy agency on internal plumbing, some states and municipalities are requiring that information.
Question 4: If we don't have lead, do we automatically meet LCRR compliance?
Part of meeting LCRR compliance involves showing proof that service lines do not contain lead. The LCRR assumes service line owners are guilty until proven innocent and requires submittal of a service line inventory (with materials clearly marked) to the Environmental Protection Agency (EPA) by October 2024. Some states have earlier deadlines. Information sources such as a GIS database, historical records, or physical inspections can help identify material types.
Depending on population size, you'll have to do more than just submit an inventory. For municipalities serving 50,000 or more people, the inventory must be publicly accessible and published online.
Question 5: Is there a benefit to using Artificial Intelligence in the LCRR compliance process?
Yes, Artificial Intelligence (AI) can help identify and verify service line material and thus streamline the LCRR compliance process. AI models can help predict the probability of lead on a small to large scale — from individual homes to an entire neighborhood block — and pinpoint the places to undertake physical inspections, which will bring in significant savings.
You can read our blog post that discusses the cost saving advantages through business intelligence and AI tools. To comply with LCRR, by predicting service line material, utilities can use an AI model and save up to 10% of total inspections needed.
Question 6: When is the optimal time to start a service line inventory?
The countdown to October 2024 has already begun and it is crucial to start building the service line inventory as soon as possible. Water service providers should have a plan in place to collect the necessary information on material types now to develop the inventory. A full inventory can be extremely time intensive and getting started now will save you time and effort in generating communications to ratepayers who have lead or unidentified material types on either the municipal or private side of the lateral.
Question 7: Our GIS does not have service laterals or customer points. What’s the best way to even start assembling an inventory?
Several sources can serve as a good starting point to gather data needed to assemble a service line inventory. For example, billing system data, meter data, and parcels can provide some direction to conducting a desktop study. Other top information sources include service cards, historical building records, CMMS data, or service cards. Integrating your GIS with all the data collected from inventory development efforts will make it easier to update and maintain for regulatory compliance and stakeholder communications.
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Question 8: How do you determine the level of effort to achieve Lead & Copper Rule compliance if there’s limited access to clean data?
When little clean data is available, many utilities have considered machine learning to help streamline material identification and verification. When used for pipe prediction, machine learning helps reduce end-user costs for verifications, can be updated to EPA/state criteria, and provides highly accurate predictions.
For example, Sandy Kutzing, project manager at CDM Smith, suggests that machine learning is smart enough to deduce the likelihood of lead based on the work of a contractor. For example, if a past contractor has used (or has never used) lead pipe material, machine learning can connect the dots — such as spotting locations where the contractor has completed work— and deduce the likelihood for lead in these areas.
Question 9: Which cities or states have the highest amount of lead pipes?
According to the Natural Resources Defense Council (NRDC), the following eight cities have the highest amount of lead in tap water: Baltimore, Chicago, Detroit, Milwaukee, Newark, New York, Pittsburgh, and Washington, D.C. However, many of these cities are already on their way to getting the lead out, including Newark. The NRDC also states that the true amount of lead pipes might be underestimated across the United States.
Question 10: Is there a set number of field verifications necessary to make a machine learning model accurate?
No magic number of field verifications exists to properly stabilize a machine learning model and make it more accurate. The accuracy depends on several factors such as how your water system was built out (whether it was built in the same way), and if the same materials were used in certain areas and time periods. Some models might require as little as 200 verifications to stabilize the model and prove that more verifications won't provide additional benefits. Others might require a lot more.
Question 11: How can machine learning become an acceptable method for service line inventory development?
Machine learning has been questioned as an acceptable method for service line inventory. The EPA allows machine learning to collect verifications, but no guidelines yet exist on accuracy criteria or the number of verifications needed. Some states, such as Michigan, have adopted their own machine learning guidelines, which provide details about field verification data collection.
For instance, if less than 1,500 unknowns exist, at least 20% of those locations will require physical verification. If more than 1,500 unknowns exist, you will have to physically verify that enough of those lines reach 95% confidence.
Learn more about using machine learning to develop an LCRR inventory.
Question 12: How can small utilities reduce the amount of time and resources spent on their inventory development?
Small utilities can reduce time and resources spent on developing an inventory by expanding data collection efforts through self-reporting. Self-reporting minimizes the burden by using homeowners to help collect enough data to indicate where lead material might be and which areas to prioritize for verification.
When combined with a data management system or dynamic central repository, you have the advantage of having a tracking mechanism in place as data starts flowing in. Some tools have self-reporting forms that feed right into the database for live data collection.
Question 13 (Updated): Has the EPA released any guidance on service line inventory development?
The EPA released new guidance materials on August 4, 2022. The EPA originally submitted documents for review by the Office of Management and Budget (OMB) on June 7th, 2022. The OMB typically doesn't review compliance documents but the goal is this guidance will help utilities as they implement Lead and Copper Rule Revisions inventory requirements. The Association of State Drinking Water Administrators or ASDWA had originally reported the initial update.
The OMB typically assists the President in evaluating the effectiveness of agency problems, policies, and procedures.
Question 14: To comply with LCRR, what should the service line inventory include?
The inventory must include details of all service lines — public and private side — regardless of if they are active, going to an abandoned home, irrigation lines, fire lines, and so on. The details include specifics such as plumbing components, interior plumbing, lead status, solder, type of building, material diameter, installation date, material source, verification method, and so on.
The inventory must also specify material classification into four categories (lead, galvanized requiring replacement, non-lead, or lead status unknown), details about all service lines and ownership (e.g., location), along with information to identify the service line material or verify its classification. Learn more about this build vs. buy inventory blog post.
Utilities must also make the inventory available to the public, especially if their population is over 50,000.
You can learn more about LCRR in this webinar we conducted.
Question 15: Building your own service line inventory vs. buying one — what is more beneficial?
To comply with LCRR, there are four different ways you can go about regarding the inventory systems—you can build a GIS-based inventory, an Excel-based inventory, a combined GIS and Excel inventory, with add-ons, or buy an all-in-one unified solution with all the required components. Deciding on what to choose will vastly depend upon your requirements and preference. The timeframes required to implement and launch these options are different too. We know it’s not easy deciding on your inventory system. That’s why we put together this Buyer’s Guide to help you wade through all your options. Here’re more details about building vs. buying a service line inventory.
Click to learn more about building your own inventory, vs. buying a ready-made purpose-built solution.
Question 16: How does one tackle cybersecurity implications when managing lead service line inventory?
The Trinnex cybersecurity team has identified the following topics that should be of highest priority for your utility:
- Leveraging tools for security testing: There is no single tool or approach that can guarantee complete security of an application, it requires a multi-faceted approach. Some common tools that are used are static application security testing (SAST), Dynamic application security testing (DAST). Container security tools, Software composition analysis tools.
- Code development process: Your secure code development process should include at least peer review, testing, scanning, and use processes that highlight security as a priority. Not utilizing these principles can lead to unsecured code getting pushed into a development and production environment.
- Continuous cyber training: Continuous cybersecurity training and resources must be available to everyone. Complete 360-degree protection requires team effort.
- Human resources: Have a dedicated staff focused on security to continuously monitor traffic, coordinate remediations, conduct risk assessments, and respond to incidents, minimizing the risk of loss of data and downtime of your systems and IT infrastructure.
Click to learn more about cybersecurity implications for managing lead service line inventory.
Question 17: When does the obligation to provide images and offer tap sampling after replacements commence?
The commencement of replacement programs is slated for 2027; however, we strongly advise initiating the process earlier.
Question 18: Will stub services be required to report on the inventory?
If you're constructing a home in an area where a stub service hasn't been linked yet, and you lack any association with the property, there's no requirement to report those instances. However, it's important to report stub services that have the potential to be connected and brought back online.
Question 19: If galvanized is on the customer side and the city side has no lead, is the city required to replace the galvanized?
Galvanized requiring replacement refers to galvanized pipes on the customer side that are linked to either a current or previously lead line. Therefore, if your line was previously lead on the utility side, it falls under the category of galvanized requiring replacement.
If you are 100% confident that that line was never lead, then that does not count as a galvanized requiring replacement.
Question 20: Does the school and daycare sampling paperwork need approval of state or health departments?
If you commenced your activities after January 2021, it is necessary to consult your state primacy agency to ascertain the specific requirements related to this matter.
Question 21: How do utilities offer their public portal in other languages? Do we use a translation service for that?
Within leadCAST, we utilize Google's translation service for translating content. However, the right of entry section on the platform can be defined in multiple languages. This is because it contains a significant amount of legal language, and thus, it's a user input field. We prefer not to rely solely on a translation service for this purpose.
Question 22: How is distribution system sampling different from tap sampling?
Distribution sampling occurs in the system at a connection point, like a hydrant. Tap sampling occurs within the property at home. Tap sampling would primarily draw off the interior plumbing unless you do fifth liter and that'll go out to the service line.
Question 23: Does the rule require replacement of the service line from the meter to the home?
Yes, it does, on the private or customer side.
If there are only a few lead lines but many unknowns, you can label the unknowns as either not lead or needing replacement. This reduces the number of unknowns. It's best to do this before 2027 because that's when you must start replacing or submit a plan for replacement
Question 24: How will unknown connectors affect overall service line category?
The EPA has defined a connector as less than two feet. So, if it's more than two feet, it’s going to be a lead service line.
Connectors don't really count in the overall service line categorization. However, if they are lead, they do need to be replaced as you come across them
Question 25: School and daycare sampling delayed until 2028. Is a list still required by October 2024?
No. School and daycare sampling is entirely delayed until 2028. But it is recommend to track those schools right now because the requirements are similar and eventually you will need to submit your plan in 2028 and start that replacement process.
Question 26: Which states have agreed to accept predictive modeling?
Click to view the list of states that have accepted predictive modeling
Question 27: How should I word everything regarding galvanized to the public without being too confusing?
It is recommended to reach out to a communications professional for that.
Question 28: Is leadCAST a web-based subscription software service?
Yes, it is. And you can get more information about it by visiting our website. You can also request more information and someone from the team will get in touch with you.
Question 29: Does unknown not lead trigger replacements as well?
It does not. Unknown not lead is an acceptable category, that is, you do not know what the actual material is, but you know that it's non lead.
For instance, if the diameter exceeds 2 1/2 or three inches, or if the property was constructed after 1986 or the date of your local lead ban, there's no requirement to report the materials used. You can categorize them as unknown not lead or other not lead.
Question 30: Is the service line limited to residential properties, or is it also necessary to include commercial properties?
Commercial is to be included as well. In addition, fire lines are required to be included too. So, anything that someone could connect to, tap to or point of use, that's going to count.
Question 31: Do lead joints trigger galvanized requiring replacement?
No, lead joints do not count as a lead service line.
Looking for more LCRR/LCRI guidance?
We've collected several resources related to LCRR compliance.
Understanding LCRR compliance
The LCRR will become effective in October 2024, with many water utilities seeking resources to help understand the regulatory requirements. A common misconception is that not all water utilities will have to comply with the 2024 regulation. Here are a few resources on meeting compliance.
- Checklist: LCRR Compliance Readiness
- Article: What Are the Major Requirements of the EPA’s Lead and Copper Rule Revisions?
Understanding LCRI compliance
To further eliminate lead from drinking water, EPA released the proposed LCRI, which requires water utilities to replace lead service lines within 10 years, and thus help secure safe drinking water for communities across the country. Here's more information about the proposed rule.
Service line inventory development
All water utilities must provide a materials inventory of their service lines, regardless if they have lead or not. The new rule has sparked some confusion as the definition of a lead service line varies from state to state and the identification process can be costly. Some communities have tossed around machine learning/artificial intelligence methods to help predict the probability of lead. The following resources cover this topic more in depth.
- Webinar Recording: Digital-first Strategies to Manage your Service Line Inventory
- Article: 5 Steps to Build Your LCRR-Required Service Line Inventory
- Blog Post: FAQS on using Artificial Intelligence to Determine Service Line Material
Lead service line replacement and progress tracking
Part of the LCRR 2024 regulation includes keeping a publicly accessible inventory. Communities who have identified lead service lines will also have to create a lead service line replacement plan to meet the LCRR 2024 compliance deadline. Homeowners with confirmed lead service lines will be notified and kept abreast of replacement plan progress. Click the following links to learn more about developing a lead service line inventory, the already implemented lead service line projects, and much more.
