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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 proposed Lead and Copper Rule Improvements (LCRI) on November 30, 2023 and published the proposed LCRI in the Federal Registry on December 6, 2023. On this page, find information related to the rule including provisions for initial service line inventories and testing in schools and child care facilities.

  • 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 using TCEQ form 20943 and submit it to TCEQ by October 16, 2024.

  • 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 spreadsheet? 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: EPA does not require systems to utilize the EPA template for their inventory. However, TCEQ does request that inventories be submitted using TCEQ form 20943 to facilitate standardized data submissions.

  • 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. The TCEQ inventory template (TCEQ form 20943) 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. The attached Materials Identification-Stepwise Approach image illustrates the prioritization of methods used to identify service line material. 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: A utility has galvanized service line material on the customer side but unknown (not proven to be lead/ non-lead yet) on the utility side. Will this be a Tier 3 site or a Tier 5 site?
    Answer: Using Table 1: Classification of Entire Service Line When Ownership is Split from the Classifying SLs worksheet within TCEQ’s Inventory form 20943, the scenario described would be a Galvanized Requiring Replacement (GRR) service line and would therefore be considered a Tier 3 site. The only GRR sites that would not be tier 3 would be non-single family residences. TCEQ’s Inventory form 20943 includes formulas to automatically calculate the tiering. If the pertinent information is filled out, then Column Y should automatically generate the appropriate tier using the new tiering criteria.

  • 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: When filling out TCEQ’s Inventory form 20943, if a water system has a postal address for the service line, then do they also need to fill out the column G (Other Location Identifier) and columns H and I (GPS Coordinates)?
    Answer: The LCRR requires a location identifier for each service line. Based on feedback from stakeholders during the creation of the form, TCEQ determined that most systems would be able to use a standard street address as their location identifier, but included column G (Other Location Identifier) and columns H and I (GPS Coordinates) to provide alternative options for systems who might have unique situations (e.g., multiple service lines at the same address, rural communities where a street address may not accurately reflect the location of a service line, etc.).

  • Question: When systems enter GPS coordinates on TCEQ’s Inventory form 20943, the template automatically adds 2 extra zeros to the end of their entries. Does this have an impact on the data submitted?
    Answer: The extra zeroes are added by Excel as a means of ensuring the format of coordinates is standardized regardless of specificity provided by PWS. All coordinate cells are capped out at 7 decimal places (e.g., 00.0000000). TCEQ WSD is not expecting PWS to report to that decimal degree. A PWS can input latitude and longitude coordinates to the degrees recommended. Regardless of entry, the actual input by the system does not change. For example, a system can put a latitude of “30.01916” and the form will display it as “30.0191600” but the actual data contained in that cell is still “30.01916”; no correction is needed.

  • Question: Our system struggles with technology (access to a computer, email, and/or using Microsoft Excel). 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 and Microsoft software. Additionally, TCEQ’s free Financial, Managerial, and Technical (FMT) program, is available to assist with one-on-one support.

  • Question: What can I do if I’m unable to attend a TCEQ LCRR presentation or FMT workshop?
    Answer: Check out the Lead and Copper Playlist on YouTube for recorded workshops and instructional videos. Link below:

    Lead and Copper Youtube

  • 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.

  • Question: On the PWS Information worksheet of TCEQ’s Inventory form 20943 it asks, “If a CWS, do multi-family residences comprise at least 20% of the structures you serve?” Does this need to be the individual apartment units OR should the count be based on the number of multi-family buildings?
    Answer: The LCRR specifies that when multi-family residences comprise at least 20 percent of structures served by the water system, the system may include these types of structures in their sampling pool (40 CFR 141.86(a)(3)). Therefore, when determining the 20%, it should be the number of buildings or structures and not the number of individual apartment units.

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. According to EPA, finalization of this additional rulemaking is expected prior to October 16, 2024. 

NEWOn November 30, 2023, EPA announced the proposed Lead and Copper Rule Improvements (LCRI) and on December 6, 2023, EPA published the proposed LCRI in the Federal Register . 

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 is being discussed during Drinking Water Advisory Work Group (DWAWG) meetings.

DWAWG webpage - Meeting presentations and information about participating in meetings.

YouTube channel - View presentations and meetings.

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

The EPA held a webinar on March 28th, 2023, giving more information about the initial Lead Service Line Inventory (LSLI) Guidance and completing the initial LSLI: Small Drinking Water Systems Webinar Series | US EPA

Funding Opportunities

There are a variety of different funding opportunities available. 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) all have funding that may apply to small and medium systems. 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.

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

Initial Service Line Inventories

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

TCEQ is developing guidance documents and resources including Service Line Inventories for Public Water Systems (RG-593)  (COMING SOON) a guide for preparing and reporting LCRR service line inventories.

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.

NEW CWSs and NTNCs with service lines (public or private) connected to the public water distribution system must complete a comprehensive spreadsheet inventory using Form Microsoft Excel Document TCEQ-20943 (Rev. Date - 2/3/2023).

NEWFor 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 form and training on LCRR requirements.

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

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. 

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

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.

NEWWater 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.

Contact Information

LCRR@tceq.texas.gov

TCEQ, LCRR Program
P. O. Box 13087, MC-155
Austin, TX 78711-3087
Phone (512) 239-4691

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 form and training on LCRR requirements.

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