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Lead and Copper Rule Revisions

Vermont's public water systems are regulated under the federal Lead and Copper Rule (LCR) and the Vermont Water Supply Rule which refers to it. Visit the Vermont Lead and Copper Rule page for more information about current requirements, or to access forms and templates. Learn about the health impacts from lead pipes in water infrastructure by visiting the Vermont Department of Health page

Under the Lead and Copper Rule Revisions (LCRR), every community and non-transient non-community (NTNC) water system must complete a service line inventory (SLI) no later than October 16, 2024

  1. Every community and NTNC water system must inventory all service line connections.
    • NTNC and single-building systems must inventory the pipe material connecting the source of water to the building inlet.
  2. Water systems must develop a lead service line replacement (LSLR) plan if they have at least one:
    • Lead service line (LSL);
    • Galvanized line requiring replacement; or
    • Line of unknown material.

Visit the U.S. Environmental Protection Agency's Lead and Copper Rule Implementation Tools | US EPA page for resources to help water systems implement the LCR including the LCRR.

Lead and Copper Rule Improvements (LCRI)

On November 30, 2023, the U.S. Environmental Protection Agency (EPA) announced further proposed changes to the Lead and Copper Rule called the Lead and Copper Rule Improvements (LCRI). Access VT DEC’s guidance document on the proposed LCRI (Last Updated: March 13, 2024) to learn how this may affect Vermont water systems. Visit the EPA's website about the proposed rule for additional details.

On this page:


Service Line (SL) Diagram

"Service line from a water main to premise plumbing in a building."
An example of a service line. The system-owned portion spans from the water main connector to the property boundary or curb stop. The customer-owned portion is the part of the service line that extends from the curb stop to the meter box or isolation valve in the building's premise plumbing.


Funding and Assistance Opportunities

All water systems may develop their SLIs on their own, but there are also assistance opportunities available. 

NTNC Water Systems with 10 or Fewer Buildings

The Drinking Water and Groundwater Protection Division's (DWGPD) staff are providing free SLI development to very small (10 buildings or fewer) NTNC water systems including schools, non-profit organizations, government agencies, and businesses. Staff will individually contact these entities to coordinate this initiative.

Water Systems Serving 1,000 or Fewer Customers

The DWGPD is using 2022 Drinking Water State Revolving Fund (DWSRF) Set-Asides to offer community and NTNC water systems serving 1,000 or fewer people, free SLI development assistance. DEC has contracted with MSK Engineers, Otter Creek Engineering, TruePani, and Weston & Sampson. These contractors are working with water systems to develop SLIs and LSLR Plans. Access this Contracted Assistance Program Frequently Asked Questions (PDF) to find out more about how this program can help your water system complete an SLI or LSLR Plan. Email ANR.SLI@Vermont.gov with inquiries about the program or to confirm your water system's eligibility.

Community Water Systems Serving More than 1,000 Customers or 250 Service Connections

The DWSRF LSL Planning program offers loans for qualified water systems to hire a consultant to develop their SLIs and LSLR Plans or pay for water systems' staff time. Visit the Water Investment Division's Applications and Forms page for SLI loan application forms, templates, and policies. The loan amount awarded depends on the water system's number of service connections. Visit the DEC's Intended Use Plans (IUP) page for more details; access the DWSRF IUP 2022 Amended Draft (PDF), page 49, to review the latest information on SLI loans available to these water systems.

Disbursing Loan Funds to Water Systems (Contractors / Consultants)

  1. The contractor or water system submits via ANR Online the final SLI and the LSLR Plan, if necessary. Then, 90% of funds will be authorized. 

  1. DWGPD staff review the final submission(s), provide comments, and meet with the contractor and/or water system to discuss comments,  

  1. After comments are satisfactorily addressed and the final submission(s) are approved, the remaining 10% will be disbursed.  

Disbursing Loan Funds to Water Systems (Staff Time / Force Account) 

Water systems that have identified the materials for 30%, 60%, and 90% of their service addresses may: 

  1. Send the partially completed draft SLI Excel workbook to ANR.SLI@Vermont.gov

  1. DWGPD staff review the submission, provide comments, and meet with the water system to discuss comments. 

  1. After comments are satisfactorily addressed and the milestone submission is approved, partial disbursement of funds will be authorized. 

Once 100% of the water system's service lines are inventoried: 

  1. The water system submits via ANR Online the final SLI and the LSLR Plan, if necessary. 

  1. DWGPD staff review the final submission(s), provide comments, and meet with the water system to discuss comments. 

  1. After comments are satisfactorily addressed and the final submission(s) are approved, the final disbursement of funds will be authorized. 


SLI Guidance, Templates, and Submissions

SLI Guidance 

Access the following guidance documents to learn more about how to complete an SLI: 

Watch the DEC's SLI Training Video on YouTube to learn how to complete an SLI. Skip to specific sections of the SLI Training Video by accessing the SLI Training Video Time Stamps Document (PDF). You can also download the SLI Training Presentation Slides (PDF). To attend a live training on how to complete an SLI, visit the Vermont Rural Water Association page for current trainings.

SLI Templates

Community and NTNC water systems must complete their SLI using one of the following templates. Every connection served must be on its own row.

  • Multiple Building SLI Template (Excel Workbook). Last Updated: May 10, 2024
    • System serves multiple buildings, such as a fire district or municipality.
  • Single Building SLI Template (Excel Workbook). Last Updated: May 6, 2024
    • System serves a single building with no accessory water use, such as a single-building school or a condominium association all under a single roof.
  • Non-Potable SLI Template (Excel Workbook). Last Updated: May 6, 2024
    • System has service connections for non-potable water, such as fire protection or other non-drinking purposes. The water system must complete the Non-Potable SLI template for those non-potable connections in addition to the Multiple Building or Single Building SLI template.

Note: when a user begins entering an address, the required cells will auto-fill with orange highlighting until every cell is populated. Users must complete the fields marked as 'required' in the SLIs. The DWGPD will not approve SLIs with incomplete information in the 'required' columns.

SLI Submissions

Water systems must complete and submit SLIs electronically through the SLI Submission Form on ANR Online.

Instructions on how to submit or revise the inventory can be found on the SLI Submission Guidance (PDF).

Making the Service Line Inventory (SLI) Publicly Available

Water systems must make the service line inventory (SLI) publicly available. The method of how a water system makes the SLI available to the public is best determined by the water system. This may be as simple as the water system keeping the inventory in its records and providing a copy upon request or as complex as the EPA’s recommendations in Section 7.2 of the Guidance for Developing and Maintaining a Service Line Inventory (Last Updated: June 2023), which may be better suited for larger systems.

In addition to annual notifications to specifically affected customers that are provided drinking water by lead, galvanized requiring replacement, and unknown service lines, community water systems must also notify all customers in the annual Consumer Confidence Report that the SLI is publicly available.


LSLR Plan Guidance, Template, and Submissions

LSLR Plan Guidance

Access the LSLR Plan Guidance (PDF) (Last Updated April 11, 2024) for more information about how to develop your water system's LSLR Plan. Watch the DEC's LSLR Plan Training Video on YouTube for more guidance. Skip to specific sections of the LSLR Plan Training Video by accessing the LSLR Plan Training Video Time Stamps Document (PDF). You can also review the LSLR Plan Training Presentation Slides (PDF).  

LSLR Plan Template

Download the LSLR Plan Template (PDF) (Last Updated: April 19, 2024) to describe your water system's:  

  1. Strategy for determining the composition of lead status unknown service lines.
  2. Procedure for conducting full LSLR.
  3. Strategy for informing customers before a full or partial LSLR.
  4. LSLR goal rate.
  5. Description of a procedure for customers to flush service lines and premise plumbing of particulate lead.
  6. LSLR prioritization strategy.
  7. Funding strategy for conducting LSLRs.

LSLR Plan Submissions

    Water systems must complete and submit LSLR Plans electronically through the LSLR Plan Submission Form on ANR Online.


    Identifying Unknown Service Lines

    During the required records review and initial visual inspections, some service lines in a water system's SLI may be categorized as "unknown material". Water systems must continue to identify the material of these service lines through customer engagement and other strategies designated in the water system's LSLR plan.

    Technical Assistance from DEC

    A Request for Proposals (RFP) is currently in development to hire contractors to assist Vermont water systems with identifying service line materials. Contractors will be tasked with canvassing customers, visual inspections of customer-owned service lines, water quality sampling, and revising water systems' SLIs. DEC expects the first round of assistance to be offered in Summer 2024 and a second round of assistance in early 2025.

    Encountering Leaded Pipes during Infrastructure Work

    When lead service lines, galvanized requiring replacement service lines, and lead connectors (a.k.a. goosenecks and pigtails) are encountered during infrastructure work, access the Leaded Pipes Encountered During Infrastructure Work Guidance Document (PDF). This guidance document includes instructions, notification and certification documents, and an outline of the actions permittees and water systems must follow when leaded pipes are encountered. 


    Notification of Known or Potential SL Containing Lead Guidance

    The federal Lead and Copper Rule (Revisions) (40 CFR 141, Subpart I) requires all water systems with lead, galvanized requiring replacement (GRR), or lead status unknown service lines in their inventory to inform all persons served by the water system at the service connection with a lead, GRR, or lead status unknown service line.

    If a water system’s initial service line inventory includes a lead, GRR, or unknown material service line, then the water system must notify affected customers by November 15, 2024. Water systems must certify to VT DEC no later than July 1, 2025 that they have delivered the initial notification and educational materials to affected customers.

    As new customers connect or start service with the water system, water systems must also provide notice at time-of-service initiation.

    Access Guidance and Instructions for Notification of Known or Potential Service Line Containing Lead (PDF) (Last Updated: June 7, 2024)

    Access Template for Affected User Notification (PDF) (Last Updated: June 7, 2024)

    This form may be submitted by emailing, mailing, or faxing the Service Line Notification Delivery Certification (PDF) (Last Updated: June 7, 2024) and notification documents to VT DEC Drinking Water and Groundwater Protection Division’s Infrastructure Sustainability Section.


    Last Updated on June 7, 2024

     

    Contact the DWGPD for questions about Service Lines

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