Lead and Copper Rule
The lead and copper rule (LCR) establishes criteria for monitoring and treatment of public drinking water systems to protect public health. This rule establishes a treatment technique to address lead and copper levels. Instead of a maximum contaminant level, an action level is established which if exceeded requires a public water system to take actions to reduce the corrosivity of water and reduce the leaching of metals from plumbing into the water. The most common water treatments involve adjusting pH and alkalinity to reduce solubility and affect calcium deposition on pipes or the addition of phosphate products to provide a physical barrier between pipes and the water.
The LCR requires community and non-transient, non-community water systems to collect samples from consumer taps that are most likely to have plumbing materials containing lead. If 10 percent or more of the samples exceed the lead action level of 15 parts per billion, then water systems are required to take additional actions, including:
- Taking further steps optimize their corrosion control treatment (for water systems serving 50,000 people that have not fully optimized their corrosion control).
- Educating the public about the health effects of lead exposure and actions consumers can take to reduce their exposure to lead.
- Replacing the portions of lead service lines (lines that connect distribution mains to customers) under the water system's control.
Service lines are the pipes that carry water from the water main to the customer's meter (owned by the utility) and lines that carry water from the meter to the customers home (owned by the customer). The use of lead service lines and lead containing plumbing occurred well into the 1950’s and is typically found in older homes and historic residential areas. Homes built after July 1988 are subject to the TN Lead Ban and should not have any lead materials in the service lines.
Public water systems have some general knowledge of where lead service lines have been used, but the exact number and location of lines is not usually known. The Federal and State's LCR, under most circumstances, requires adjustment of water chemistry and monitoring to reduce the corrosion of metals and also requires replacement of lead material.
To obtain information on lead levels found in your drinking water, contact TDEC or your local drinking water provider. Follow the web links below to obtain additional information regarding lead service line identification, lead in drinking water, and steps you can take to reduce lead exposure from all sources.
Lead and Copper Rule Revisions
On December 16, 2021, EPA announced the next steps to strengthen the regulatory framework on lead in drinking water. During the next two years, TDEC will be incorporating new rules regulating lead and copper.
The first compliance milestone with the revisions is the Lead Service Line Inventory (LSLI). Due to the complexity and time involved for the LSLI, we have created a dedicated section below with answers to frequently asked questions. TDEC will continue to update this section as we implement changes.
Lead Service Line Inventory
The Lead Service Line Inventory (LSLI) is a means of establishing an inventory to Identify the materials of service lines connected to the public water distribution system with the purpose of identifying areas with the greatest potential for lead contamination of drinking water and most in need of remediation. The EPA and the State of Tennessee require LSLI information to be submitted by October 16, 2024.
Quick facts about LSLI:
- The LSLI must contain material details for all service connections on the distribution system, regardless of size and the type of usage of the water.
- Public records review, physical inspections, statistical analysis, and investigative sampling are all great ways to get a start on developing an inventory.
- The state will be offering loans and grants for Lead Service Line Replacement activities, including the identification of lead service lines.
Next Step for Water Systems
The next step for water systems is to begin an inventory by determining ownership of the service lines and finding their installation dates. Service lines installed after July 1988 were subject to the lead ban and therefore have evidence-based non-lead classifications. It is highly encouraged for water systems to reach out early to procure funding for the LSLI.
A copy of the LSLI Fillable Excel Data Sheet is found in the "Additional Information" section below. The information required in this excel spreadsheet are the minimum data elements required by LCRR. While completing your inventory, please reference the FAQ drop-down menu below. We will continually add to this as we receive questions. Water systems are still required to continue lead and copper sampling for their respective sampling frequencies and quantities.
A full list of all connections and descriptions of service line materials on both the water system side and customer side: Location, WS side material, customer side material.
Obtaining historical information from several sources will help in the identification of service line ownership and line materials.
- (page 166-209)
- EPA Reference Guide for Public Water Systems Lead and Copper Rule Comparison
- TDEC FAQ for Lead Service Line Inventories
- Lead Service Line Inventory Data Sheet
- EPA Memo: Implementation of the Clean Water and Drinking Water State Revolving Fund Provisions of the Bipartisan Infrastructure Law
- EPA - Funding and Technical Resources for Lead Service Line Replacement in Small and Disadvantaged Communities
- Consumer Plumbing Survey (template for water systems to use with their customers)
Division of Water Resources Drinking Water Compliance