​​​​​​​​​​​Lead and Copper Rule

Service Line Inventories

EPA published the Lead and Copper Rule Revisions (LCRR) in January 2021, which requires all community and nontransient noncommunity water systems to submit a service line inventory to DEP by October 16, 2024.

IMPORTANT INVENTORY INFORMATION: (New 7/22/2024)
The Department and EPA Region III have received an increased number of inquiries surrounding record requirements for categorizing each service line. In response, the Department has engaged in additional conversations with EPA on this topic and determined it is very important to provide this information which we encourage public water systems to carefully review and consider. CLICK HERE for information to assist public water systems in finalizing and submitting their service line inventory.

Questions? Please contact the Bureau of Safe Drinking Water – Operations Section at RA-EPSDWOpsSection@pa.gov.

Inventory Submission:​

​(New 8/16/2024) The PA DEP is now ready to accept on-line Service Line Inventory (SLI) submissions through the Drinking Water Electronic Laboratory Reporting system (DWELR).
Important things to note:

• DWELR can only be used to submit if the SLI was created by entering or importing data into the PA SLI spreadsheet.
  
• You must have an active DWELR user account to submit your SLI.
  
• • If you do not have a DWELR user account, first register for a Greenport account: PA.GOV | Department of Environmental Protection
    
  • Fill out and submit form 3900-FM-BSDW00021: DEP eLibrary DWELR Registration Form
    
  • Allow at least one week for a new DWELR account to be created. 
    
  • SLIs may be submitted using either a PWS or Laboratory DWELR account (P or L).
    
•     CLICK H​​ERE for Detailed instructions about the submission process
  

Inventory Template:

DEP Service Line Inventory Excel Template: To meet the inventory requirements, DEP is recommending the use of the DEP Excel Inventory Template. Note: If you downloaded the DEP template prior to April 2023, please email ra-padwis@pa.gov for upgrade instructions.

• DEP Service Line Inventory Form Excel Template 3930-FM-BSDW0042A
• DEP Service Line Inventory Excel Template - Instructions
  
  Water systems that already have an electronic database containing service line inventory information and who do not wish to re-enter their information into the service line inventory spreadsheet developed by the Department (document number 3930-FM-BSDW0042a) may e-mail ra-padwis@pa.gov to request an alternate template for use and upload.

Very Small System Service Line Inventory Word Template: For systems with no more than 5 service connections (e.g., a nontransient system), a Microsoft Word form is available:

• Service Line Inventory Word Version Instructions, Cover Page, and Form

Inventory Resources:

Material Verifications Training Aid: Please click on the link below to access a 16-page document which uses visual aids to thoroughly explain DEP’s expectations for water systems to demonstrate adequate evidence to categorize a service line as non-lead. The document includes thirteen detailed examples of hypothetical situations that outline various evidence water systems would have available to them along with their options for additional evidence to review. This Training Aid clearly differentiates each example by “system side” and “customer side”.

• Non-Lead Verifications Training Aid with Examples Updated: 09/19/2023

Historical Record Review Checklist: As part of conducting the inventory, water systems must review all records available to identify service line materials. The following table is meant to guide water systems through completing a thorough records review of all information which may be available to help identify service line material. It is best to review this checklist as an initial step in preparing to complete a thorough inventory. This checklist is an optional training aid, water systems are not required to complete or submit this checklist.

• Historical Record Review Checklist

Service Line Inventory FAQ: The following document consists of frequently asked service line inventory questions and DEP’s answers.

• Q&A for Service Line Inventories Updated: 6/5/2024

Service Line Inventory Training Course Workbook: DEP held classroom service line inventory training in 2022 and 2023 across the state. The following is the course workbook (see below under Inventory Training for more training information):

• DEP Service Line Inventory Training Course Workbook

Community Engagement Plan Template
It is important to inform and involve water system customers in the service line inventory process. The more customers understand, the more likely they are to cooperate with and provide accurate information to their public water supplier; thereby increasing the water system’s ability to complete a more accurate inventory in a timely manner. To this end, DEP is making available a Service Line Inventory Community Engagement Plan template for public water suppliers. Please note:

• Areas of the template highlighted in yellow are intended to be updated by the water system.
• Areas of the template highlighted in green provide additional notes for the water system.
• Various examples are listed within the template, which can be removed or modified to reflect the needs of the community or water system.

Link: Community Engagement Plan Template(this will open doc in new window)

Community Engagement Message from EPA: EPA produced a short video intended to support water supplier efforts to obtain critical service line inventory information from Public Water Supply customers. EPA Region 3 Administrator Adam Ortiz delivers his support in this video:

• English: Identifying Service Lines for Customers (1 min 26 sec)

Another version of this video with the same message of support, this time from EPA Region 3 staffer Ruby Stanmyer to Spanish-speaking customers is also available:

• Spanish: Identifying Service Lines for Customers (1 min 40 sec)

Inventory Training:

Tutorials: The following are video tutorials on the DEP service line inventory template and how to collect sufficient evidence for the non-lead designation of a service line:

• Video Tutorial: DEP Service Line Inventory Template (22 mins)
• Video Tutorial: DEP Evidence for Non-Lead Designation (12 mins)

Service Line Inventory Training Course Workbook: DEP held classroom service line inventory training in 2022 and 2023 across the state. The following is the course handout materials that provide valuable information:

• DEP Service Line Inventory Training Course Workbook

Recorded Service Line Inventory Training: The following is a recording of the DEP classroom course on service line inventories (4 parts):

• Lesson 1: Inventory Requirements (37 min)
• Lesson 2: Records Review (23 mins)
• Lesson 3: Methods of Identification (13 mins)
• Lesson 4: Inventory Form (38 mins)

The associated course workbook is available here:

• DEP Service Line Inventory Training Course Workbook

Web-based Service Line Inventory Training: This self-paced course is worth 3.5 contact hours for certified drinking water operators and is available on DEP’s Earthwise Academy:

• LCRR Service Line Inventory Web-based Course

Service Line Replacement - RMM:

The Environmental Protection Agency (EPA) has stated that lead service line replacements (LSLR) are associated with short-term elevated drinking water lead levels for some period of time after replacement. To combat these elevated lead levels and ensure that LSLR are completed properly, risk reduction measures (RMM) have been developed for water systems to implement. The measures are outlined in the Risk Mitigation Measures for Water Systems Conducting Lead Service Line Replacement fact sheet.

DEP held a webinar on RMM for water systems in July 2023: RMM Webinar Recording: July 13, 2023

DEP developed the following documents pertaining to RMM:

• Certification form for water suppliers to document that all risk mitigation measures were completed: Risk Mitigation Measures (RMMs) Certification Form 3930-FM-BSDW0066
  
• Public notice template to provide the required notice to owners of affected service lines: Lead Service Line Replacement Customer Notification 3930-FM-BSDW0089
  
• Sample result consumer notice for water suppliers that must accompany the sample results provided to the applicable resident: Lead Service Line Replacement Sample Results Information 3930-FM-BSDW0067

Overview of the Lead and Copper Rule (LCR)

Publication and Revision Dates

Subchapter K in Chapter 109 published December 24, 1994, revised with minor revisions on August 10, 2002 and with short-term revisions on December 18, 2010.

Chapter 109 Sections

• §109.1101 Scope
• §109.1102 Action levels and treatment technique requirements
• §109.1103 Monitoring requirements
• §109.1104 Public education and notification
• §109.1105 Permit requirements
• §109.1106 Design standards
• §109.1107 System management responsibilities
• §109.1108 Fees

Purpose

Protect public health by minimizing lead (Pb) and copper (Cu) levels in drinking water, primarily by reducing water corrosivity. Pb and Cu enter drinking water mainly from corrosion of Pb and Cu containing plumbing materials.

General Description

Establishes an action level (AL) of 0.015 mg/L for lead and 1.3 mg/L for copper based on the 90th percentile level of tap water samples. An AL exceedance is not a violation but can trigger other requirements that include water quality parameter (WQP) monitoring, corrosion control treatment (CCT), source water monitoring/treatment, public education (PE) and lead service line replacement (LSLR).

Applicability

All community water systems (CWSs) and nontransient noncommunity water systems (NTNCWSs) are subject to the LCR requirements.

LCR Reference Guide

This Lead and Copper Rule Quick Reference Guide (PDF) is a general reference guide to the major provisions of the Lead and Copper Rule.

LCR Sample Site Location Plan

This Instruction Packet for Lead and Copper Tap Sample Site Location Plan (3900-FM-BSDW0549) provides the regulatory requirements and template forms to complete a sample site location plan.

LCR Monitoring

Lead and Copper Tap Homeowner Sampling Procedures (PDF)
Homeowners should leave faucet aerators in place prior to sampling.

Clarification of Requirements for Collecting Samples and Calculating Compliance (PDF)
Where samples need to be collected, whether customer requested samples are counted in the 90^th percentile compliance value, and how the 90^th percentile compliance value is calculated.

Instructions and Template for Consumer Tap Notice for Lead Results
Chapter §109.1104(b) requires water systems to deliver a consumer tap notice of lead tap water monitoring results to persons served by the water at sites that are sampled. This document provides instructions and a template for this consumer tap notice. DEP has also created a fill-in-the-blank template for a NTNCWS Consumer Tap Notice. Additionally, the water supplier shall submit to DEP within three months of the end of the monitoring period in which lead tap monitoring was conducted a sample copy of the consumer notice of lead tap monitoring results along with a certification form (3900-FM-BSDW0205) that the notices were distributed by mail or by another method approved by DEP.

Treatment Technique Requirements

Corrosion Control Treatment (CCT) Applicability

• All large systems
• Small and medium systems that exceed either action level (AL); may stop CCT steps if both ALs are met during 2 consecutive 6-month monitoring periods prior to approval to construct CCT facilities; but, must resume CCT if subsequently exceed either AL.

CCT Compliance Schedule

All activities begin from the end of the monitoring period in which the AL was exceeded:

• Submit a CCT feasibility study (PDF) within 18 months.
• Submit a permit application within 30 months.
• Initiate construction or modification of CCT facilities within 48 months.
• Complete construction or modification of CCT within 60 months.

CCT Requirements for Optimal CCT for Large Water Systems (PDF)
Large water systems that change water sources are still obligated to maintain Optimal CCT.

2016 EPA OCCT Manual

The Optimal Corrosion Control Treatment Evaluation Technical Recommendations document provides technical recommendations that water systems can use to comply with Lead and Copper Rule corrosion control treatment requirements and effective evaluation and designation of optimal corrosion control treatment (OCCT). Additionally, this document also provides Excel-based OCCT Evaluation templates that can be used to organize data and document decisions.

Lead Public Education (PE)

Community water systems and nontransient noncommunity water systems that exceed the lead action level in their 90th percentile value are required to deliver lead PE materials.

PE Material Content

• Must meet EPA requirements established under 40 CFR 141.85(a)(1) and (2). EPA has developed numerous documents and PE material templates that are located at this site: LCR Compliance Help. DEP has created a fill-in-the-blank template for a CWS lead PE pamphlet.
• NTNCWSs and CWSs that receive DEP approval to follow the NTNCWs delivery methods may use the "Instructions & template for NTNCWSs Lead PE Poster and Pamphlet" (3930-FM-BSDW0137)

Delivery Method

• System must submit copes of PE materials to DEP prior to delivery.
• CWSs: deliver materials to bill-paying customers and post lead information on water bills, work in concert with local health agencies to reach "at-risk" populations (children, pregnant women), deliver to other organizations serving "at-risk" populations, provide press releases, include new outreach activities from §109.1104(a)(2)(i)(H), and post PE materials to website if system serves > 100,000 people.
• NTNCWSs: Posting and distribution to all customers (can be electronic).

Timing

• Within 60 days after the end of the monitoring period in which Pb AL was exceeded if not already delivering PE.
• Repeat annual except: quarterly water bill inserts, press releases twice a year and continuous web posting.
• Discontinue whenever Pb AL is met; but, must resume PE program if subsequent Pb AL is exceeded.

Simultaneous Compliance

AWWA "Managing Change and Unintended Consequences: Lead and Copper Rule Corrosion Control Treatment" Copyright 2005
This document provides valuable resources and detailed explanations on how water quality changes may impact lead corrosion. NOTE: Systems are required to notify DEP prior to treatment changes or source water changes. This document is under revision to incorporate that notification requirement.

Microbial and Disinfection Byproduct Rules Simultaneous Compliance Guidance Manual (PDF)
This manual describes many of the potential conflicts that may arise as systems comply with the rules currently being developed by the U.S. Environmental Protection Agency (EPA), known collectively as the Microbial and Disinfection Byproduct (M-DBP) cluster of rules.

Chapter 4 "SIMULTANEOUS COMPLIANCE ISSUES BETWEEN THE STAGE 1 DBPR, THE IESWTR, AND LEAD AND COPPER RULE" within this manual identifies conflicts between the Stage 1 DBPR, IESWTR, and the LCR can occur when the chemical stability of drinking water is affected. Lead and copper are released into drinking water by corrosion, specific chemical measures such as pH and alkalinity adjustment and the addition of corrosion inhibitors are employed. Certain actions that may be necessary for PWSs to comply with the Stage 1 DBPR, such as enhanced coagulation, can upset the established operating chemistry in a system by lowering the pH. Similarly, certain actions that may be necessary for PWSs to comply with the IESWTR, such as removing additional turbidity, can be affected by the addition of chemicals that inhibit corrosion.

This chapter briefly discusses the LCR and presents several potential conflicts between the Stage 1 DBPR, the IESWTR, and the LCR. It includes discussion of the following topics:

• pH impacts
• Turbidity issues
• Microbial re-growth issues
• Enhanced coagulation issues
• Disinfection strategy issues

Regulations and Guidance

Subchapter K of Chapter 109

• This subchapter establishes treatment technique requirements that include requirements for corrosion control treatment, lead service line replacement and public education. These requirements are triggered, in some cases, by samples collected at consumers' taps which exceed a lead or copper action level.
• This subchapter applies to community water systems and nontransient noncommunity water systems. For purposes of this subchapter, the systems are classified as either large, medium or small, based on the population served by the system. A large water system serves more than 50,000 persons. A medium water system serves more than 3,300 and fewer than or equal to 50,000 persons. A small water system serves 3,300 or fewer persons.
• A community or nontransient noncommunity water system which is a consecutive water system shall comply with this subchapter regardless of the compliance status of any public water system from which finished water is obtained. Each interconnection with a public water system from which finished water is obtained is considered source water for the receiving public water system and is subject to the monitoring, corrosion control treatment and source water treatment requirements under this subchapter.

DEP has created a Lead and Copper Rule Short-term Revisions (LCRSTR) (PDF) summary document that describes each revision and includes the Chapter 109 page number of the online Chapter 109 version (PDF). These revisions were published in the PA Bulletin on December 18, 2010 and are now incorporated into Chapter 109.

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