FAQs

Yes. Even if your system has no known lead service lines, you are still required to comply with key components of the EPA’s Lead and Copper Rule Revisions (LCRR) and Lead and Copper Rule Improvements (LCRI). Specifically, you must still:

• • Submit the inventory with material classifications of all water service lines and supporting evidence.
  • Include a statement in your Consumer Confidence Report CCR) confirming the absence of lead, GRR, or unknown service lines
  • Maintain records and be prepared to update the inventory if new information arises.

Baxter & Woodman can assist your municipality in preparing and submitting a compliant inventory, even if your system is lead-free. We also help ensure your CCR and public communications meet EPA standards.

Community Water Systems and Non-Transient Non-Community Water Systems must comply with five key areas:

• Water Service Line Inventory: Identify and document the material of all water service lines served.
• Replacement Planning: Develop a plan to replace lead and galvanized requiring replacement service lines.
• Public Education & Notification: Inform residents about risks associated with lead risks and any actions your system is taking to address.
• Full Lead Service Line Replacements: Replace lead lines completely from the watermain to inside the property.
• Lead Sampling: Conduct regular sampling to monitor lead levels.

Baxter & Woodman can assist with inventory development; replacement planning, design and construction oversight; public education and outreach strategies; and maintaining compliance.

Lead typically enters drinking water through the corrosion of lead-containing plumbing materials (pipes, solder, fixtures). Properties built prior to 1988 are at a higher risk of having lead-containing materials. Lead is rarely found in source water, such as groundwater, rivers, or lakes.

Corrosion control treatment (CCT) reduces water corrosivity by:

• Adjusting the pH and/or alkalinity of the water before it enters the distribution system
• Adding inhibitors, like orthophosphate or silica, which create a protective coating on the inside of lead pipes to prevent lead from leaching (dissolving) into the water

Exceeding the action level (currently 15 ppb) triggers mandatory actions, including:

• Tier 1 Public Notification
• Monitoring water quality parameters, such as pH and alkalinity
• Evaluating corrosion control treatment

Systems should have templates and protocols in place should they need to issue a Tier 1 public notification within 24 hours.

Exceedances require a prompt response. B&W helps water systems navigate these steps efficiently.

Your CCR must include the following information:

• Latest lead sampling results, including the lowest and highest results reported
• The 90^th Percentile Lead Level from the most recent results
• A statement that a water service line inventory and replacement plan (if applicable) have been prepared and instructions on how to access them
• If CCT is used, an explanation in how it reduces lead exposure
• EPA-approved health risks language from lead exposure

B&W helps municipalities craft CCR language that meets EPA standards and is easy for residents to understand.

A galvanized water service line requires replacement if it currently is or ever was downstream of a lead service line; or is currently downstream of a lead status unknown service line.

If you can’t prove otherwise, a galvanized service line must be treated as GRR. B&W assists with documentation and inventory updates.

Most commonly, water systems are requesting funding through State Revolving Fund (SRF) programs, Congressional Directed Spending, or through federal programs, such as the Water Infrastructure Finance and Innovation Act (WIFIA). Water systems are also looking at their water rate structures and considering cost-share programs with impacted property owners.

B&W helps identify and apply for funding opportunities to reduce the financial burden on your community.

State primacy agencies have the ability to apply a Non-Compliance Advisory or a Violation Notice to water systems that are not in compliance with the LCRR/LCRI depending on what portion of the regulations the water system is out of compliance with.

Non-Compliance Advisory – These are violations that are usually resolved using a Public Notice or re-submission. The timelines to complete vary based on the reason for the violation. Usually a Non-Compliance Advisory is issued for a monitoring or reporting violation.

Violation Notice – These violations are an official legal enforcement process that have an initial notice to the system and then subsequent meetings with the Primacy Agency that result in a Compliance Commitment Agreement. A timeline to get back into compliance is agreed upon within the Compliance Commitment Agreement that must be met.

If you are concerned that your community is not in compliance with current lead and copper regulations, Baxter & Woodman can assist you in identifying what you are out of compliance with, coordinating with your Primacy Agency for next best steps and implementing procedures to regain compliance.

No. EPA strongly discourages partial replacements, as they can increase lead levels due to galvanic corrosion and disturbance of lead particles. Under LCRR and LCRI, partial replacements are prohibited except for emergency repairs or when coordinated with other infrastructure work.