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Questions or Comments: LCRR@tceq.texas.gov

Lead and Copper Rule Revisions

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. On this page, find information related to the rule including provisions for service line inventories and testing in schools and child care facilities.

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. 

EPA has 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 this additional rulemaking is expected prior to October 16, 2024.

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 Lead Service Line Inventory (LSLI) Guidance and completing the 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

Service Line Inventories

CWSs and NTNCs must submit 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.

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 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.

  • 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: Can a water system use predictive modeling or assume based on a subset of records the age of homes in a neighborhood and by extension the service line materials of the homes therein? What is TCEQ’s stance on the use of Artificial Intelligence (AI) or machine learning (ML) software for lead service line inventory services?
    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: 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: Does the inventory need to include irrigation and fire line pipe?
    Answer: The EPA guidance (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: Our system has irrigation meters that provide water to street green spaces for landscaping solely. They will never be utilized to feed water to structures, water fountains/sinks, used for drinking water, etc. Do these meters need to be included on the inventory?
    Answer: The EPA “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. If the line does not go to a building, it does not need to be included in the inventory.

  • 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.

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 LCRR requirements starting October 16, 2024.

School administrators or child care providers are not required to take action under the rule revisions at this time but can participate in voluntary lead sampling. See TCEQ’s Lead Testing in School and Child Care Program.

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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