LCRR Compliance
Implement LCRR Requirements with Confidence
Sunbelt Consulting, LLC assists Georgia’s small and medium water systems in the implementation of the new LCRR
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In managing communities and utilities, there is nothing more critical than protecting public health. The EPA’s updated Lead and Copper Rule Revision (LCRR) aims to remove potentially harmful metals from public water systems. Neglecting these requirements can result in enforcement actions against the utility, diminish public trust, and potentially reduce public health outcomes for the community’s most vulnerable.
The Lead and Copper Rule Revision (LCRR) became effective in 2021 and includes several major initiatives that must be completed by October 16, 2024. The primary components of the LCRR include the elements listed below. Click on each item for details on requirements and applicable deadlines and timetables.
The Georgia EPD has finalized the State requirements for the inventory that can be found here. Additional guidance on reporting and submittal, corrosion control, and service line replacement requirements is expected in the near future.
The U.S. EPA is currently making additional revisions to the Lead & Copper Rule that are expected to be released in the fall of 2023. These revisions are not expected to make any changes to the service line inventory requirement. However, additional requirements can be expected for the service line replacement plan, public education/notification requirements, testing requirements, and service line replacement activities.
All public water systems (including those that are privately owned) are required to develop a location-based, material inventory of all water service lines connected to the public water system, including utility-owned and customer-owned portions of the service lines. The inventory can be developed utilizing the utility’s installation records (construction plans, tap cards, historic system maps), field verification and other approved sources of information.
The EPA requires that the draft inventory be completed by October 16, 2024.
Per Georgia EPD’s Service Line Inventory (SLI) Guidance Manual, service lines shall be categorized as lead, galvanized requiring replacement, galvanized not requiring replacement, lead status unknown, and non-lead. Note that unknown services are treated as lead services.
The inventory must be made publicly available.
To prepare for development of an inventory, water systems should gather all available historic data related to the water system. These include construction plans, dated system maps, tap cards/tap installation records, inspection and repair records, meter and location data, unmetered services data. In the quest to complete an accurate inventory while minimizing field verification, remember that Old is Gold.
Sunbelt Consulting can assist in developing your system’s LSLI with GIS (location based) software, and will assist in reporting to the EPD.
All water systems with lead, galvanized requiring replacement or lead status unknown service lines must develop a Service Line Replacement Plan (SLRP) including strategies for determining the materials of unknown service lines, full lead service line replacement, customer notification prior to line replacement, prioritization, and funding.
Currently, the SLRP must be completed by October 16, 2024. However, this deadline is expected to change with the EPA’s revisions that are expected to be released in the Fall of 2023.
Service line replacement may be required if the trigger or action level (determined based on tap water samples) is exceeded.
Sunbelt Consulting can assist in developing your SLRP. We will work with your community leaders and utility staff, and if desired, we will work with your Engineer, in development of the plan to ensure all stakeholders have input in a customized plan to meet your community’s needs and goals.
The EPA has updated requirements for determining lead and copper tap sampling sites, sampling frequency, number of sampling sites, and determination of trigger and action levels based on 90th percentile concentration calculation from tap sample results.
Sampling includes the 1st liter and 5th liter from a tap that has been unused for at least 6 hours.
Tap samples must be collected from all schools and childcare facilities within the distribution system.
Sunbelt Consulting can assist your utility in identification of tier sampling sites, calculation of 90th percentile concentration, and obtaining sampling kits. We can develop a Standard Operating Procedure for your utility staff to ensure all sampling and monitoring requirements are achieved.
EPD-approved Corrosion Control Treatment of source water may be required if tap sampling exceeds the trigger level for lead or copper.
Sunbelt Consulting can work with your Engineer to assist the community with corrosion control studies, permitting and system installation.
Water systems must notify customers if their service line is determined to be lead, galvanized requiring replacement or lead status unknown and must provide monitoring results to persons served at tested sites. These notifications must be sent within a certain timeframe of submitting the utility’s inventory to the EPD and after receiving results from lead testing.
If the lead trigger or action level (determined based on tap water samples) is exceeded, public notifications must be provided.
Notification must be given to those served by a service line prior to replacement.
Sunbelt Consulting can assist your community in preparation and dissemination of all required notifications and educational materials.
Certified filter devices (pitcher filters or tap filters) may be provided if the lead action level is exceeded and must be provided when lead service lines are replaced.
Sunbelt Consulting can assist your utility with procurement and dissemination of point of use filter devices.