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Questions or Comments: LCRR@tceq.texas.gov

Lead and Copper Rule Revisions and Lead and Copper Rule Improvements

The Lead and Copper Rule Revisions (LCRR) amend the Lead and Copper Rule. All community and non-transient non-community public water systems are required to comply with the LCRR starting October 16, 2024. The U.S. Environmental Protection Agency (EPA) announced the final Lead and Copper Rule Improvements (LCRI) on October 8th, 2024. On this page, find information related to the LCRR and LCRI.

The Environmental Protection Agency (EPA) announced final revisions to the National Primary Drinking Water Regulations for lead and copper under the authority of the Safe Drinking Water Act on December 16, 2021. More information from EPA on the LCRR can be found on EPA’s Review of the National Primary Drinking Water Regulation: Lead and Copper Rule Revisions (LCRR) webpage. 

EPA also announced an additional update to lead and copper rules called Lead and Copper Rule Improvements, to strengthen key elements of LCRR. On October 8, 2024, EPA announced the final Lead and Copper Rule Improvements (LCRI) .

Lead and Copper Rule Revisions Requirements

Beginning 10/16/2024, three provisions of the LCRR listed below go into effect in addition to current lead and copper rule requirements. 

    1. Initial Service Line Inventory Submission:
    2. Customer Notifications
    3. Action Level Exceedance Notification

Information for Public Water Systems

The LCRR is in effect with a compliance date of October 16, 2024. The rule revisions will apply to all community water systems (CWS) and non-transient non-community water systems (NTNC). These PWSs should continue to implement the current LCR sampling, compliance, and reporting requirements as in Title 30, Texas Administrative Code, Section 290.117 and on TCEQ’s Lead and Copper webpage.

Implementation of the LCRR is discussed during Drinking Water Advisory Work Group (DWAWG) meetings. For more information about participating in meetings, visit the DWAWG webpage. You can also view past presentations and meetings on our YouTube channel.

TCEQ continues to use the work group to engage regularly with the public drinking water community on this topic.

Initial Service Line Inventories

CWSs and NTNCs must submit initial service line inventories to TCEQ no later than October 16, 2024.

Initial inventories must include the following:

  • All service lines (public and private) connected to the public water distribution system.
  • Categorization of each service line, or portion of the service line where ownership is split.

The four categories for service lines in the initial Inventory are:

  • “Lead” where the service line is made of lead.
  • “Galvanized Requiring Replacement” where a galvanized service line is or was at any time downstream of a lead service line or is currently downstream of a “Lead Status Unknown” service line. If the water system is unable to demonstrate that the galvanized service line was never downstream of a lead service line, it must presume there was an upstream lead service line.
  • “Non-lead” where the service line is determined through an evidence-based record, method, or technique not to be lead or galvanized requiring replacement. The water system may classify the actual material of the service line (i.e., plastic or copper) as an alternative to classifying it as “Non-lead.”
  • “Lead Status Unknown” where the service line material is not known to be lead, galvanized requiring replacement, or a non-lead service line, such as where there is no documented evidence supporting material classification.

  • Question: Who needs to create a Service Line Inventory?
    Answer: All community water systems and all non-transient non community water systems must create a service line inventory.

  • Question: Our water system does not have lead/copper service lines. All material used is PVC or a similar material. Would we still be required to complete a service line inventory? Also, are we going to be required to take inventory of the piping material from the meter to the place of residency?
    Answer: Yes, all community water systems and all non-transient non community water systems are required to submit a service line inventory to TCEQ by October 16, 2024. The Lead and Copper Rule Revisions (LCRR) further outlines that this inventory must include all service lines connected to the distribution system regardless of ownership status. So, where service line ownership is shared, the inventory would need to include both the portion of the service line owned by the water system and the customer-owned portion of the service line. TCEQ understands that this is no small task, so keep in mind that of the four service line material categories, “unknown” is an allowed option under the rule.

  • Question: Can a PWS utilize their own LSLI template instead of the EPA or TCEQ template?
    Answer: TCEQ requires inventories be submitted using the SWIFT submittal process.

  • Question: Do lead connectors, goosenecks, and pigtails count toward the definition of a lead service line?
    Answer: According to the Lead and Copper Rule Revision (LCRR), if the only lead piping serving the home is a lead gooseneck, pigtail, or connector, and it is not a galvanized service line that is considered a lead service line, the service line is not a lead service line (40 CFR §141.2).

  • Question: What is the significance of the “After 2014” date?
    Answer: In 2014, there was an amendment to the 1986 Lead ban that reduced the definition of “lead free” for piping and pipe fittings to 0.25% (weighted average with respect to wetted surfaces).

  • Question: Can a water system assume anything built after the Texas lead ban date – July 1, 1988 – is non-lead?
    Answer: The Texas lead ban went into effect on July 1, 1988. For the service line inventory, a public water system must review all required records, but the lead ban date can be used to support a conclusion of a non-lead classification.

  • Question: What if a water system doesn’t have any historical records?
    Answer: Systems are required by rule to review all records listed in 40 CFR 141.84(a)(3) to the best of their ability. TCEQ inventory submittal process will ask the system to indicate whether each required record was reviewed and certify that the information within the inventory is true, accurate, and complete. However, TCEQ understands that the inventory is a living document and during the course of normal operation and maintenance the system may need to update the inventory as new information is discovered or received.

  • Question: If a water system has done the background work of going through data and has determined that they do not know the lead status of a significant number of their service lines what should they do?
    Answer: If a water system has reviewed all records required by the LCRR (40 CFR 141.84(a)(3)) and is still unable to determine the material of their service lines, they have a few options.
    They can report the service line material as “lead status unknown.” It is understood that completing the service line inventory will be an on-going project for water systems. Therefore, reporting the service line material as “unknown”, especially for the initial inventory, is acceptable.
    The inventory is intended to be a living document that is continuously improved over time. Unknowns should naturally decrease over time as the system goes through normal operations and continues to gather information.
    Alternatively, if a water system chooses to begin working on verifying unknowns, Chapter 5 of the EPA “Guidance for Developing and Maintaining a Service Line Inventory” outlines some methods for service line investigations. These methods are not required under the LCRR, but are examples of tools that can be used to verify historical records and gather information when the service line material is unknown. Record review is the first and highest priority and physical excavation is the last and lowest priority. Note, if a water system chooses an investigation method not specified by the state under 40 CFR 141.84(a)(3)(iv), state approval is required.

  • Question: Is performing investigative methods [i.e., no historical record review] sufficient to complete the service line inventory?
    Answer: The LCRR requires a review of historical records (40 CFR 141.84(a)(3)) in order to complete the service line inventory; record review cannot be “skipped”- it is a rule minimum. If the system feels they need to assess the accuracy of their historical records or gather additional information when a line is classified as “unknown”, then service line investigations may be needed. The EPA “Guidance for Developing and Maintaining a Service Line Inventory” expands on how to conduct service line investigations. Every water system is different. Each PWS should document their process and procedures for service line inspections and determinations in a system-specific Standard Operating Procedure (SOP).

  • Question: Is a line that was installed 1980, with copper lines and 50/50 solder (usually 50% lead, 50% tin) considered a lead service line under the LCRR?
    Answer: Through verification with EPA, TCEQ can confirm that a copper service line (despite the percentage of lead in the solder) is still considered “non-lead” for the purposes of the service line inventory.

  • Question: Can a water system use meter pit investigations to verify unknown service lines?
    Answer: Per EPA guidance (Section 6.1.2), “remember that no matter the approach, systems must review all historical records as listed in the LCRR”. This information is further outlined in Chapter 4. After required record review, meter pit investigations with scratch and magnet tests are acceptable field investigation techniques according to EPA guidance (See Chapter 5 of guidance, specifically section 5.1 and 5.1.1). Each PWS should document their process and procedures for service line inspections and determinations in a system-specific Standard Operating Procedure (SOP).

  • Question: Can a water system assume a service line with a diameter greater than 2 inches is non-lead?
    Answer: No. Although it is unlikely that a service line greater than 2 inches is non-lead, water systems must review all records required by the Lead and Copper Rule Revision (LCRR). Combined with the installation date of the line and other records, the line size could support a material classification of non-lead.

  • Question: How can water systems afford to complete the inventory?
    Answer: TCEQ provides free financial, managerial, and technical (FMT) assistance to help systems comply with regulations and can provide on-site or virtual assistance with the inventory. The FMT program can be reached at FMT@tceq.texas.gov and additional information about the program can be found on the this website and at our Financial, Managerial, and Technical Assistance Program webpage.
    Significant funds have been made available to assist public water systems with Service Line Inventories through the Bipartisan Infrastructure Law (BIL)/Infrastructure Investment and Jobs Act (IIJA). The Texas Water Development Board (TWDB) has funding for water systems desiring to work on service line inventories and replacement.
    Additionally, EPA published a webinar on August 10, 2022 that addresses guidance for developing service line inventories and finding information.

  • Question: My understanding is that any service line of unknown material (i.e., Lead Status Unknown) are considered lead under LCRR. Is that true?
    Answer:Unknown service lines should NOT be reported as Lead. While it’s true that reporting service lines as “Lead Status Unknown” does come with additional steps (such as public notice), Lead Status Unknown is its own category within the service line inventory. Public notice is required because when systems have “Lead Status Unknown” service lines, they cannot guarantee that the service line as “non-lead”.

  • Question: I don’t have lead service lines; therefore, I don’t need to do a service line inventory, right?
    Answer: False. All community and non transient non community water systems must submit a service line inventory to the TCEQ by October 16, 2024, even if all of the system’s service lines are made of non-lead material.

  • Question: Can systems use interviews with senior staff as a form of record?
    Answer: Yes. Documented interviews and affidavits from senior personal with historic knowledge of the water system are an example of “other records” within the records required to be reviewed under the LCRR.

  • Question: Is it true that water systems MUST excavate service lines to determine if they are lead?
    Answer: No! Per EPA guidance (Section 6.1.2), “remember that no matter the approach, systems must review all historical records as listed in the LCRR”. This information is further outlined in Chapter 4. After required record review, visual inspections with scratch and magnet tests or excavations are acceptable field investigation techniques according to EPA guidance (See Chapter 5 of guidance, specifically section 5.1 and 5.3). Each PWS should document their process and procedures for service line inspections and determinations in a system-specific Standard Operating Procedure (SOP).

  • Question: Does the inventory need to include irrigation and fire line pipes?
    Answer: EPA’s “Guidance for Developing and Maintaining a Service Line Inventory” emphasizes that a service line is defined as “the pipe connecting the water main to the interior plumbing in a building.” Therefore, all lines that go from a main to a building must be included in the inventory. However, section 2.2.1 notes that if the service line could be repurposed in the future for a potable or non-emergency use, then these lines should be included in the system’s service line inventory.

  • Question: Utility A reads the meters and bills for utility B’s customers; however, the service lines are maintained by utility B. Which of the two utilities will be responsible for inventorying the service lines?
    Answer: The service line connections are designated to a single PWS. Whichever PWS ID the connection belongs to is who should inventory the service lines.

  • Question: Our system struggles with technology (access to a computer or email). How will we be able to successfully submit the service line inventory?
    Answer: If a water system struggles with access to technology they may want to reach out to their local library to see if they provide free access to computers. Additionally, TCEQ’s free Financial, Managerial, and Technical Assistance (FMT) program, is available to assist with one-on-one support.

  • Question: Is sampling a method you can use to rule out if a line is lead or not? For example, if a system were to do sequential sampling and came back with no detects of lead, can they use that documentation to prove no lead in the system?
    Answer: At this time, EPA does not indicate that water quality sampling (targeted sampling, flushed sampling, or sequential sampling) can be used for service line material determination. Per Section 5.2 of the EPA’s “Guidance for Developing and Maintaining a Service Line Inventory,” water quality sampling is more appropriately used as a screening tool, since low and non-detect lead levels may not reliably detect the absence of lead service lines. The LCRR requires documentation review; if record review indicates material of construction based on code, ordinance, tap records, etc. This should be noted in the inventory.

  • Question: What is TCEQ’s stance on the use of Predictive Modeling, Artificial Intelligence (AI), Statistical Modeling, or machine learning (ML) software to complete the service line inventory?
    Answer: EPA does not indicate that predictive models can be used for determination. Per Section 5.5 of the EPA’s “Guidance for Developing and Maintaining a Service Line Inventory,” predictive modeling can be used for prioritizing areas for service line investigations and expediting lead service line replacement. Modeling can be used to make inferences about areas of unknown condition. TCEQ recognizes that predictive modeling is a tool to prioritize the investigations of unknown sites, but it cannot be used to prove a negative. The LCRR requires documentation review; if record review indicates material of construction based on code, ordinance, tap records, etc. this should be noted in the inventory.

  • Question: What is TCEQ’s stance on the use of Emerging Technologies (e.g., metal detectors, SWORDFISH, etc.) to complete the service line inventory?
    Answer: At this time, EPA does not indicate that emerging can be used for service line material determination. Per Section 5.6 of the EPA’s “Guidance for Developing and Maintaining a Service Line Inventory,” emerging methods have “technical basis but limited research or field implementation to demonstrate their effectiveness.” The LCRR requires documentation review; if record review indicates material of construction based on code, ordinance, tap records, etc. this should be noted in the inventory.

For more information on how to conduct an LSLI investigation click on: LSLI Investigations Example Standard Operating Procedure

Visit our Financial, Managerial, and Technical Assistance Program webpage or email FMT@tceq.texas.gov for information or help preparing or submitting your Service Line Inventory.

EPA has released their Guidance for Developing and Maintaining a Service Line Inventory and it is available at the EPA LCRR webpage . 

EPA's Small Drinking Water Systems Webinar Series | US EPA provides information and guidance on the initial Lead Service Line Inventory (LSLI). See their Past Webinar Recordings on February 27th, 2024, and March 28th, 2023.

Additionally, EPA published a webinar on August 10, 2022, that addresses guidance for developing service line inventories and finding information.

The Association of Safe Drinking Water Administrators (ASDWA) has a free webinar series on LCRR and service line inventories, with monthly presentations as well as past recordings. 

Service Line Disturbance Guidance

According to EPA's Guidance for Developing and Maintaining a Service Line Inventory , EPA recommends "alerting the customer that such disturbance can potentially cause temporarily elevated lead levels in drinking water and providing them with information about how to reduce lead levels, such as flushing".

To assist PWSs that wish to voluntarily notify their customers of a service line disturbance, TCEQ is providing example language for a service line disturbance event. Notice of service line disturbance is not required by the LCRR and does not need certification of delivery to the TCEQ. 

Water line disturbances can occur during normal operations, emergency repairs, and/or planned service line investigations. The information below may be used when communicating with customers where a disturbance of a lead service line, galvanized requiring replacement service line, or service line of unknown materials occurs. This information can be modified to fit the purpose of the PWS.

Lead is a common metal found in the environment. Drinking water is one possible source of lead exposure. We are focused on protecting the health of every household in our community; however, lead from service lines and lead plumbing and fixtures can dissolve or break off into water and end up at the faucet during infrastructure work.


Health Effects of Lead

There is no safe level of lead in drinking water. Exposure to lead in drinking water can cause serious health effects in all age groups. Infants and children can have decreases in IQ and attention span. Lead exposure can lead to new learning and behavior problems or exacerbate existing learning and behavior problems. The children of women who are exposed to lead before or during pregnancy can have increased risk of these adverse health effects. Adults can have increased risks of heart disease, high blood pressure, and kidney or nervous system problems.


Steps You Can Take to Reduce Your Exposure to Lead in Your Water

Below are recommended actions that you as a customer may take, separately or in combination, if you are concerned about lead in your drinking water. This list also includes where you may find more information and is not intended to be a complete list or to imply that all actions equally reduce lead from drinking water.

      • Obtain an NSF 42 and 53 certified home water filter. If you use a filter, it should be certified to remove lead and particulate reduction. Read any directions provided with the filter to learn how to properly install, maintain, and use your cartridge and when to replace it. Do not run hot water through the filter. For more information on facts and advice on home water filtration systems, visit EPA’s website at: How to ID Filters Certified to Reduce Lead in Drinking Water
      • Clean your sink aerators. Regularly remove and clean your faucet’s screen (also known as an aerator). Sediment, debris, and lead particles can collect in your aerator. If lead particles are caught in the aerator, lead can get into your water.
      • Use cold water for drinking, cooking, and preparing baby formula. Lead is dissolved more easily into hot water. Boiling water does not remove lead.
      • Run your water before use. The more time water has been sitting in your home’s pipes, the more lead it may contain. Before drinking, flush your home’s pipes by running the tap, taking a shower, doing laundry, or doing a load of dishes.
      • Identify and replace plumbing fixtures that may contain lead or copper pipes with lead solder.
      • Have your water tested. Contact us to have your water tested and to learn more about the lead levels in your drinking water.
      • Get Your Child Tested to Determine Lead Levels in His or Her Blood. A family doctor or pediatrician can perform a blood test for lead and provide information about the health effects of lead. State, city, or county departments of health can also provide information about how you can have your child's blood tested for lead. The Centers for Disease Control and Prevention (CDC) recommends that public health actions be initiated when the level of lead in a child’s blood is 3.5 micrograms per deciliter (µg/dL) or more.


Resources


Funding Opportunities

There are many funding options Public Water Systems (PWS’s) can apply for to fund LCRR related inventory development and line replacement, regardless of size or population. These include but are not limited to funds from the U.S. Department of Housing and Urban Development (HUD), the U.S. Department of Agriculture (USDA), the Texas Water Infrastructure Coordination Committee (TWICC), and the Texas Water Development Board (TWDB). EPA has more funding information found here: Funding for Lead Service Line Replacement | US EPA . You may also contact the TWDB at (512) 463-0991, or email at Financial_Assistance@twdb.texas.gov.

Do you need assistance applying for funding? Complete the technical assistance request form and an EPA representative will contact you: Water Technical Assistance Request Form | US EPA

NEW TWDB has now released the Drinking Water State Revolving Fund (DWSRF) Lead Service Line Replacement (LSLR) funding solicitation: DWSRF - Lead Service Line Replacement (LSLR) Program | Texas Water Development Board

Financial Managerial and Technical Assistance

Visit our Financial, Managerial, and Technical Assistance Program webpage or email FMT@tceq.texas.gov for information or help preparing or submitting your Service Line Inventory and training on LCRR requirements.

Schools and Child Care Programs

Community water systems that supply drinking water to schools or child care facilities will be required to comply with new LCRI requirements.

NEW Water systems can start to create a list of schools and child care facilities they serve within their system. TCEQ has created a resources guide and template to assist water systems in building their list. To view this resource, click on: Creating a School and Child Care List.

School administrators or child care providers are not required to take action under the rule revisions at this time. TCEQ is offering a FREE statewide program to help eligible participants conduct voluntary sampling and analysis for lead in drinking water at their schools and child care facilities. See TCEQ’s Lead Testing in School and Child Care Program for more information and to enroll today.

Related Links

Contact Information

LCRR@tceq.texas.gov