Lead and Copper Rule Revisions

New as of 9/29/2022: Inventory Templates and Guidance Released!

Vermont public water systems are regulated under the federal Lead and Copper Rule (LCR) and the Vermont Water Supply Rule that refers to it. See the main Vermont Lead and Copper Rule page for general information, current requirements, and forms and templates. This page was last revised on 9/29/2022.

Click here for the December 2021 update from the EPA about the next steps with the Lead and Copper Rule Revisions. 

Federal LCRR requirements and implementation timeline

The Federal Lead and Copper Rule has been revised. The Lead and Copper Rule Revisions (LCRR) are only partially going into effect in 2024, with many remaining parts expected to be changed.  We know two things that will be required under the LCRR: 1) Every Community and NTNC system is going to need to have a complete inventory of all service connections served; and 2) systems with at least one lead service line, one galvanized line requiring replacement, or any unknown material lines must generate a service line replacement plan.  These are due no later than October 16, 2024.  The Division will update this page and have many more resources as they become available. Everything else about the LCRR is unknown and will likely be updated by the forthcoming Lead and Copper Rule Improvements.

Service line material inventories

An accurate service line inventory is required of all Community and NTNC systems. Systems may have started this process years ago, but many material inventories have not been revisited since the start of the LCR in the early 1990s.

Inventory Templates

The Division has finalized the service line inventory templates which each system is required to complete. They are available below:

            Multi-building inventory template 

            Single-building inventory template 

            Non-potable inventory template

There are 3 different templates. Systems that serve multiple buildings, such as a fire district or municipality use the multi-building template. Those systems that serve a single building with no accessory water use, such as a single-building school or a condominium association all under a single roof, use the single-building inventory template.  Any water system that has service connections for non-potable water, such as fire protection or other non-drinking purposes ALSO need to complete the non-potable inventory template for those non-potable connections and submit BOTH completed inventories to the Division.

 Please review the templates, instructions, and guidance carefully. Not every column is required to have an approvable inventory. The columns necessary to have an approvable inventory are identified as “required” in the instructions portion of the inventory template, the column headings have red text, and when you start entering an address, the required cells have orange highlighting until the cell is filled in. Inventories with incomplete information in the “required” columns will not be approved.

Guidance Documents

The Division has created guidance on how to complete the service line inventory documents.

          Multi-building guidance 

          Single-building guidance 

Inventory Training Presentation Slides

Click here or on the image below:

Thumbnail of the first slide from the Inventory Training Presentation

Service line parts

A service line is comprised of several parts between the distribution main and premise plumbing, and these parts may be made of different materials:

  • Connector from a distribution main. This may be or include a lead gooseneck/pigtail. and is less than 2 feet in length.
  • System-owned portion of the line (in blue below).
  • Curb stop / shutoff valve.
  • Customer-owned segment of the line (in green below)
  • Connector into the building. This can include a lead pipe segment.
  • Water meter.

Example of typical service line configuration.

The LCRR requires every connection served by a community or NTNC water system to be inventoried.  Every connection served needs to be its own row of the inventory document.  The diagram above from EPA shows a typical example of the parts of a service line, often for a community water system.  For NTNC systems or single-building systems, this means the material of the pipe connecting the source of water to the building inlet needs to be inventoried. For many NTNCs the inventory will only be comprised of one row with this information provided.  

Funding to Create the Inventory

Funding Options:

All Water Systems are welcome to develop their Service Line Inventories on their own, but below are some funding opportunities that will be available. 

For Schools:  The DWGPD is hiring two staff members to help provide FREE Service Line Inventory development to the NTNC Schools develop their Service Line Inventories.  The Division will reach out to NTNC Schools individually to coordinate this effort.  Stay tuned. 

For Water Systems serving a population of 1000 or less:  The DWGPD plans to utilize 2022 DWSRF Set-Asides to offer FREE service line inventory development to NTNC and Community water systems serving 1000 or fewer people. The Division will contract with a consultant(s) to work with systems to develop their Service Line Inventories and Lead Service Line (LSL) Replacement Plans.  Solicitations will go out to Water Systems after October 1, 2022.  Anyone not interested in utilizing this program is welcome to apply for a DWSRF LSL Planning Loan to hire their own consultant. See 2022 Draft IUP for details.

For Community Water Systems serving a population over 1000 or 250 service connections: The DWSRF Loan program has subsidized LSL Planning Loans available for qualified water systems to hire a consultant to develop their Service Line Inventories and Lead Service Line Replacement Plans.  See the 2022 Draft IUP for details.

Training on how to complete an inventory

Through the existing partnership with the Vermont Rural Water Association, the Division has set up several training dates for the rest of 2022, with more dates to be scheduled for early 2023 to provide information about how to complete an inventory.  Remember, that the compliance date is October 16, 2024, so the clock is ticking.  See the Vermont Rural Water Association page for current training offerings: https://vtruralwater.org/training/schedule/

Other information about the Inventories

Service line inventories will need to be completed and submitted electronically. They will need to be submitted via ANR online. (Link to be added).  Additional resources will be coming with instructions on how to enroll and use ANR online.

Service line replacement plans:

Systems containing at least one lead service line, one galvanized line requiring replacement, or one line of unknown material. The systems are required to address the following:

  1. Strategy for identifying lead status unknown lines
  2. Procedure for conducting full lead line replacement
  3. Strategy for informing customers before LSL replacement (full or partial)
  4. Systems serving over 10,000 in population, LSL goal rate; recommended % replaced annually
  5. Procedure for customers to flush service lines and premise plumbing of particulate lead
  6. LSL prioritization strategy based on factors inc. - targeting known LSL, LSLR for disadvantaged consumers, and sensitive populations
  7. Funding strategy for conducting replacement to accommodate customers that are unable to pay to replace the private portion by the system in the event of a lead trigger level exceedance

 

A template for completion will be available soon.

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