Lead and Copper Rule Revisions

On December 16, 2021, the EPA identified the next steps to be taken over the next few years to reduce lead in drinking water. The Lead and Copper Rule Revisions (LCRR) will go into effect by October 16, 2024. Between now and when the LCRR goes into effect, the EPA is taking steps to develop a new rule, the Lead and Copper Rule Improvements. Additional details and resources can be found on EPA’s LCRR webpage.

We are awaiting guidance from EPA on the majority of changes related to the LCRR, but have confirmed that systems subject to the LCRR (Community and Non-Transient Non-Community water systems) will need to develop service line inventories.

Application for Expedited Approval Funding:

Funding

The Drinking Water Board has approved an expedited approval application process for systems seeking funding at or below $100,000 to develop service line inventories and/or lead service line replacement plans. This application is now open and closes on February 20, 2023.

Disclaimer: Submitting this application is NOT a guarantee that any funding requested will be provided. The Division of Drinking Water will review applications and make final decisions with regard to eligibility and award approval.

Hardship Criteria

Water systems may be eligible for grant funding if they meet the Divisions hardship criteria in all or part of the system’s service area. 

  • The system as a whole, can be eligible for principal forgiveness if it meets either of the following criteria: 
    • The estimated average water bill exceeds 1.75% of the local median adjusted gross income (MAGI) 
    • The system MAGI is at or below 80% of the state MAGI
  • If systems do not qualify for disadvantaged funding above, they may be eligible for grant funding for a portion of the service area. This eligibility is based on the EPA’s demographic index at the census block level. The demographic index is a combination of two socioeconomic factors: income and demographic data. To determine eligibility, use the Division’s web map. Blue areas correspond to census block groups at or above the 80th percentile for the demographic index. Funding allocated on this basis must only be used on work in the specific areas. Water systems can apply for multiple census blocks that meet the criteria in their service areas. Systems may receive a combination of grants and loans. The percentage of the award given as grants will be based on the percentage of connections located within disadvantaged census blocks.
Lead Service Line Inventory Basics

Water systems must prepare and submit an initial service line inventory by Oct. 16, 2024. Service lines need to be placed into one of four categories:

Lead Service lines

Lead Status Unknown Service Lines

Galvanized lines requiring replacement

  • Galvanized service lines that are/were downstream from a lead pipe
  • Lead often attaches to and builds up on galvanized SLs

Non-lead Service lines (copper, plastic, etc.)

  • It is recommended that the actual service line material is included in the inventory, if possible
  • Both the system-owned section and the customer-owned section of all service lines in the distribution system must be included in the inventory.
  • Lead connectors (i.e., goosenecks or pigtails) are not required to be included in the inventory. EPA recommends including lead connectors where records exist. Water systems must replace lead connectors when encountered.
  • Systems are not expected to have identified 100% of their service lines in the initial inventory due on October 16, 2024. Systems with service lines that have an unknown lead status will work to identify the service line material and update the inventory over time.
  • Water systems need to document service line materials that are observed during the course of other projects such as meter or main replacement. It is recommended that water systems develop a standard operating procedure (SOP) that describes how and where staff will document service line material information that is collected.

A service line inventory template can be found in the Resources section.

Completing a Records Review

The first step in developing a service line inventory is completing a records review. It is vital that water systems do a thorough review to reduce the number of Lead Status Unknown lines and to potentially avoid having to rely on more intensive and disruptive identification methods later.

Systems must review certain records under the LCRR. Required records include:

  • All construction and plumbing codes, permits, and existing records which indicate service line materials
  • All water system records, including:
    • Maps of the distribution system
    • Lead and Copper Sample Site Plans
    • Historical records on each service connection
    • Meter installation records
    • Historical capital improvement or master plans
    • Standard operating procedures (SOPs)
  • All inspections & records of the distribution system that indicate service line materials
Resources

Learning Opportunities

Check out DDW’s training calendar to stay on top of learning opportunities.

The Association of State Drinking Water Administrators (ASDWA) is hosting a free, multi-day symposium on Lead Service Line Inventories every Wednesday in February 2022. You can register here. These trainings will be recorded and the recordings will be made available for free. This symposium provides an opportunity to hear lessons learned from other states and water systems that have already undertaken inventory work. DDW staff will also be providing Utah specific guidance on developing service line inventories in the coming months and will be making those resources available online.

Upcoming Resources & Learning Opportunities

The Division will add resources and learning opportunities to this webpage as they become available. Future expected resources and tools include templates for service line inventories, guidance documents that clarify requirements, and a toolbox of resources to assist systems with communicating the new requirements to the public.

Existing Resources

Contact Us

Bridgette Charlebois (brcharlebois@utah.gov)
Distribution Monitoring Specialist
Utah DEQ- Division of Drinking Water
(801) 247-7422

Rebekah Brown (rebekahbrown@utah.gov)
Environmental Program Coordinator
Utah DEQ – Division of Drinking Water
(385) 501-9128