Lead & Copper Rule Revisions (LCRR)
Self-Assessment Survey How to Identify Materials
Lead and Copper Rule Revisions (LCRR)
The Environmental Protection Agency’s (EPA) Lead and Copper Rule (LCR) is the National Primary Drinking Water Regulation first implemented in 1991, requiring actions by public water systems to reduce levels of lead and copper in drinking water. On January 15, 2021, the EPA updated and issued revisions to the original LCR under the Lead and Copper Rule Revisions (LCRR) and a deadline for water systems to comply with these revised requirements on October 16, 2024. On December 6, 2023, EPA published the proposed Lead and Copper Rule Improvements (LCRI) that, when final, will significantly reduce exposure to lead through drinking water (LCRI proposed compliance date October 2027).
The primary goal in the implementation of the LCRR, and subsequent LCRI, is to ensure that drinking water in communities across the United States remains safe and free from contaminants.
Rule Summary
The proposed LCRI is a major advancement in protecting children and adults from the significant, and irreversible, health effects from being exposed to lead in drinking water. These advancements are based on the science and existing practices utilized by drinking water systems. Key provisions in the proposal include:
• Achieving 100% Lead Pipe Replacement within 10 years. When lead service lines are present, they represent the greatest source of lead exposure in drinking water. The proposed LCRI would require water systems to replace lead service lines within 10 years.
• Locating Legacy Lead Pipes. Knowing where lead pipes are is critical to replacing them efficiently and equitably. Water systems are currently required to provide an initial inventory of their lead service lines by October 16, 2024. Under the proposed LCRI, all water systems would be required to regularly update their inventories, create a publicly available service line replacement plan, and identify the materials of all service lines of unknown material.
• Improving Tap Sampling. The proposed LCRI would make key changes to the protocol that water systems must use for tap sampling informed by best practices already being deployed at the local and state level. Water systems would be required to collect first liter and fifth liter samples at sites with lead service lines and use the higher of the two values when determining compliance with the rule.
• Lowering the Lead Action Level. EPA is proposing to lower the lead action level from 15 µg/L to 10 µg/L. When a water system’s lead sampling exceeds the action level, the system would be required to inform the public and take action to reduce lead exposure while concurrently working to replace all lead pipes. For example, the system would install or adjust corrosion control treatment to reduce lead that leaches into drinking water.
• Strengthening Protections to Reduce Exposure. Water systems with multiple lead action level exceedances would be required to conduct additional outreach to consumers and make filters certified to reduce lead available to all consumers. The filters must be certified to reduce lead.
Taken together, these provisions in the proposed LCRI would strengthen public health protections, reduce complexity, and streamline implementation. EPA anticipates finalizing the LCRI prior to October 16, 2024.
Developing a Lead Service Line Inventory (LSLI)
The City of Hickory has developed an initial service line inventory (SLI) for all water systems owned or operated by the utility. The utility will continue to develop the inventory through identifying the unknown materials over the course of the LCRI compliance period.
The SLI must identify the location and material of all service lines in the water system that connect to homes, buildings and structures. The utility must also make that information available to the public. The SLI must classify the material for customer-owned and system-owned service lines.
The SLI will classify service lines in one of four ways:
- Lead
- Galvanized Requiring Replacement (GRR)
- Non-Lead
- Unknown
A GRR service line is a galvanized pipe that has the potential for mineral deposits, such as lead, to accumulate within the piping over time.
An initial SLI is due to NC DEQ by October 16, 2024.
How is Hickory developing the service line inventory?
The City of Hickory will use several methods to identify service line materials including:
- Existing Records and Data
- Field Inspections
- Customer Self-Assessment and Survey
Existing Records and Data: Staff can use property construction dates from county GIS databases to determine the age of service lines. Buildings constructed after 1988 are highly unlikely to have lead service lines. That's because 1988 was the effective date of the 1986 amendment to the EPA’s Safe Drinking Water Act. The act prohibited the use of lead for drinking water pipe, solder, and flux. In addition to property construction dates, the city utilized existing records of tap cards and as-built plans for determination of utility owned service line material.
Field Inspections: Staff or contractors will conduct inspections at properties across the water systems it owns and operates to verify service line material and minimize the quantity of Unknown service lines. The City will inspect service lines by:
- Excavation
- Mechanical Excavation
- Vacuum Excavation
- AMI Meter Replacement Project
- Identification at the time of meter replacement project.
- Modeling
- Predictive Modeling
- Geostatistical Modeling
- Water Quality Sampling
- Service Line Sampling
- Calculate premise plumbing volume, flush out premise plumbing, then collect and analyze a service line sample.
- Flushed Sampling
- After a set flushing time, collect and analyze a sample.
- Service Line Sampling
- Sequential Sampling
- Collect and analyze a series of consecutive samples from the interior tap to the service line.
Customer Self-Assessment Survey: Customers can contribute to the SLI and report their customer-owned service line material by performing a self-assessment and filling out an online form below.
City of Hickory Service Line Inventory Map
Use the interactive map below to view the material of each service line of our system according to our records. Search an address or pan to your residence.
Public Notices
City of Hickory water customers should expect to receive a flyer and notice letter in the mail about their water service line materials.