​​​​​​​​​​​Lead and Copper Rule

Service Line Inventories

EPA issued the Lead and Copper Rule Improvements (LCRI) on October 8, 2024, which requires all community and nontransient noncommunity water systems to submit a baseline inventory to DEP by November 1, 2027. The baseline inventory submission is in addition to the initial service line inventory required under the Lead and Copper Rule Revisions (LCRR) that was due to DEP on October 16, 2024.

To increase the accuracy of inventories, the federal LCRI clarifies the requirements for verification of non-lead service lines, including establishing important requirements for a validation pool. The baseline inventory under LCRI must also include connectors and a street address associated with each service line and connector. Accordingly, DEP has modified its service line inventory forms (both the Word and Excel versions) to align with the federal LCRI requirements. DEP recorded a video which illustrates the revisions made to the DEP service line inventory spreadsheet. The video is available below:

Water systems will not be able to submit inventory templates with revision dates prior to “09/2024” starting August 27, 2025, all service line inventories will need to be entered into the new DEP Service Line Inventory templates.  If you downloaded either of the DEP Service Line Inventory forms prior to September 2024, please email ra-epsdwlcr@pa.gov  for upgrade instructions.
 

Inventory Template

DEP Service Line Inventory Excel Template: To meet the baseline inventory requirements, DEP is recommending the use of the DEP Service Line Inventory Excel Template. 

• DEP Service Line Inventory Form Excel Template and Instructions 3930-FM-BSDW0119 
  

Water systems that already have an electronic database containing service line inventory information who do not wish to manually enter their information into the service line inventory spreadsheet developed by DEP (document number 3930-FM-BSDW0119) may request to have their data imported into the spreadsheet.

• Format existing data so it is compatible for import. Refer to Formatting Data for Import into the PA SLI spreadsheet 
• Fill out the SLI Import Cover Page 
• Submit the cover page and formatted data to ra-epsdwlcr@pa.gov

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 (document number 3930-FM-BSDW0042) :

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

Inventory Submission

Important things to note when submitting a Service Line Inventory (SLI) through the Drinking Water Electronic Laboratory Reporting system (DWELR):

• DWELR can only be used to submit the SLI if the SLI was created by entering or importing data into the most recent version of 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 HERE  For Detailed instructions about the submission process

You may submit your completed baseline SLI any time between now and November 1, 2027.

Questions? Contact ra-epsdwlcr@pa.gov

DEP developed the following documents pertaining to RMM:

Resources

Filters ANSI/NSF 53 Certified for the Removal of Lead: The following document consists of information regarding availability of filters that are ANSI/NSF 53 certified for the removal of lead from drinking water.  The document contains information for point-of-use devices commonly used in households and information for hydration stations commonly used in schools and businesses.

• Filters ANSI/NSF 53 Certified for the Removal of Lead

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.

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):

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

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 Notice.
• 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.