Lead Service Line Replace­ments

Service Material Inventory

All systems are required to compile a service line material inventory—including both utility-owned and privately-owned sides of the service line—or demonstrate absence of LSLs by the October 16, 2024 compliance deadline.

Any galvanized service lines that are, or were formerly, downstream of an LSL are considered "galvanized requiring replacement," not quite LSLs from a customer perspective, but still required to be included in the overall count of LSLs for eventual replacement. Services with unknown materials that may be lead will be classified as "lead status unknown service lines" and will count towards the total number of LSLs in the system. Unknown materials that are unknown but known not to be lead (for example, installed after the lead ban), can be classified as "non-lead" meaning that their exact material does not need to be known. Update inventory annually or triennially, based on sampling frequency, with any replace­ments and/or veri­fi­ca­tions.

If a system exceeds the lead trigger level, additional noti­fi­ca­tion to customers with LSLs, galvanized requiring replacement or lead status unknown service lines is required within 30 days of the end of the monitoring period in which the exceedance occurred. The noti­fi­ca­tion shall include information about the lead service line replacement program. The noti­fi­ca­tion must also be repeated annually until the system is no longer in exceedance.

Replacement Program Plan

All systems with LSLs must also prepare a Lead Service Line Replacement Program by the compliance deadline. This plan must include:

• A strategy for determining "lead status unknown" service lines
• Procedures to conduct full LSL replace­ments
• Commu­ni­ca­tion strategies
• LSL replacement goal rate in the event of a lead trigger level exceedance (for systems over 10,000 persons)
• Flushing procedures
• LSL prior­i­ti­za­tion strategies
• Funding strategies including ways to accommodate customers that are unable to pay for the replacement of their portion on their own

The proposed LCRI due out before October 2024 may make further changes to this requirement potentially delaying the federal due date for the plan. However, a similar plan may be required to obtain SRF money for LSL replace­ments.

Conducting a Replacement

Following each lead service line replacement (LSLR), systems must:

• Provide a pitcher or faucet filter and cartridges to each customer for 6 months after replacement or a disturbance. Filters must be certified to remove lead per NSF 53 and must be provided within 24 hours for full and partial LSLRs. Filters must also be provided for any disturbance to a LSL, such as meter replace­ments.
• Provide noti­fi­ca­tion, including flushing procedures, to the customer after a disturbance or replacement of a LSL, galvanized line requiring replacement or lead status unknown service.
• Offer to collect a lead tap sample at each location where a LSLR occurred within 3 to 6 months after replacement. Results need to be provided to the customer within 30 days. If the tap sample exceeds the lead action level of 15 µg/L, the customer should be notified within 3 days of receiving the results.

Partial Replace­ments

Only full LSLR (both customer-owned and utility-owned portions) count toward the replacement target. A partial lead service line replacement, such as a utility-owned side replacement where the customer-owned side remaining is lead or galvanized steel, does not count as a replacement.

Partial replacement (utility-side only) are only allowed during main replace­ments and emergency replace­ments. In this case, the utility is required to notify the customers 45 days in advance and offer to replace the customer-side in addition to the utility-side. The utility is not required to bear the cost of the customer-owned side replacement.

If the customer is unable or unwilling to have their side replaced, a utility is required to notify the customer and follow risk mitigation procedures in their LSLR plan. Risk mitigation measures should include flushing guidance to remove particulate lead and providing a pitcher or faucet filter certified to remove lead per NSF 53 standards and replacement cartridges for no less than 6 months.

A tap sample must be taken between 3 and 6 months after the partial LSLR. Results need to be provided to the customer within 30 days. If the tap sample exceeds the lead action level of 15 µg/L, the customer should be notified within 3 days of receiving the results.

If a utility is replacing LSLs to meet a goal-based LSLR Program or the 3% per year LSLR Program due to a trigger level or lead action level exceedance, respec­tively, conducting a partial LSLR does not count towards meeting the goal. In fact, it remains as a "lead service line" since the line still contains lead.

Customer-Triggered Replace­ments

The public side of the service line must be replaced within 45 days if a consumer notifies a system within 3 months of replacing the private customer-side. A filter and flushing instruc­tions must be provided within 24 hours of receiving noti­fi­ca­tion of the replacement from customer. If the customer notifies the water system after 3 months from the replacement, no replacement or filter are required.