Lead Service Line Inventory Requirements Under the LCRR

August 2026 · Orevant Compliance Intelligence

The Lead and Copper Rule Revisions (LCRR), effective December 2021, require every public 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 five categories: Lead, Galvanized Requiring Replacement (GRR), Non-lead, Lead status unknown, or Lead connector. Systems must make the inventory publicly available and update it annually.

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

Systems with lead or GRR service lines must replace all lead service lines within 10 years by 2031, at a minimum rate of 3 percent per year. Systems exceeding the lead action level of 10 ppb must accelerate replacement.

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.

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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.

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Orevant provides compliance information tools. Content on this page does not constitute legal advice. Compliance determinations should be verified with your state primacy agency.