The Lead and Copper Rule Revisions (LCRR), effective December 2021, require every community and non-transient non-community water system in the United States to develop and submit a complete lead service line inventory to its state primacy agency. For many small systems, building this inventory is the most labor-intensive compliance task they face in 2024 to 2026.
What the Inventory Must Include
The LCRR requires systems to classify every service line into one of four categories: Lead, Galvanized Requiring Replacement (GRR), Non-lead, or Lead status unknown. (Connector materials are a separate element the LCRI adds to the baseline inventory due November 1, 2027.) Systems must make the inventory publicly available and update it annually.
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Initial Submission Deadline: October 16, 2024
Systems were required to submit an initial inventory to their primacy agency by October 16, 2024. Systems that missed this deadline are already in violation. Annual updates are required thereafter.
Replacement Schedule
Under the LCRI, systems with lead or GRR service lines must replace them within 10 years of the November 1, 2027 compliance date (by 2037 for most systems), at an annual average of at least 10 percent measured as a rolling three-year average. The lead action level is 15 ppb today and drops to 10 ppb on the LCRI compliance date.
Unknown Service Lines
Unknown lines must be treated as lead for compliance purposes until confirmed otherwise. Physical inspection, water sampling, and record research are valid methods for resolving unknowns. States may require a specific investigation rate per year.
How Orevant Tracks LCRR Obligations
Orevant maps your LCRR obligations including inventory submission status, replacement schedule requirements, and action level exceedance history with deadlines attached.
Check My LCRR Status — Free at orevant.com
FAQ
We submitted our inventory on time. Are we done?
No. Annual updates are required. Systems with lead lines must also submit annual replacement progress reports.
What if we genuinely do not know the material of our service lines?
Unknown lines must be classified as lead for compliance purposes and investigated over time. Your state may specify a minimum investigation rate.
What is the penalty for missing the inventory deadline?
Failing to submit the inventory is a violation of the LCRR. It triggers public notification requirements and a compliance schedule. The violation becomes part of your system SDWIS record.