​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​


Lead and Copper in Drinking Water

**ALERT** (January 17, 2024) regarding MDE LCRR Service Line Inventory Spreadsheet​ -- Click HERE​ to see more.


The Lead and Copper Rule​​​

water pipesThe federal Lead and Copper Rule (LCR)​, effective in Maryland starting in the early 1990s, requires public water systems (both Community Water Systems (CWS) and Non-Transient Non-Community Water Systems (NTNCWS)) to test for lead and copper in drinking water at customers' taps at high risk sites (Tier 1 sites) located throughout their water distribution system.  If testing reveals that lead and/or copper levels exceed the Action Levels established by the US Environmental Protection Agency (EPA) in 10 percent of samples collected during a particular monitoring period, water systems are required to perform certain actions, such as optimizing corrosion control treatment, notifying the public (if the lead Action Level is exceeded), and replacing Lead Service Lines (if present) to reduce exposure to lead and copper at customers' taps. ​


Contents

Background​​​
Minor Revisions of 2000​
Short Term Revisions​
Lead and Copper Rule Revisions​

Service Line Inventories​

MDE Tra​inings​​​​

MDE Service Line Inventory Spreadsheet and Guidance Documents​

​​Inventory Spreadsheet​​​
Guidance
Inventory Spreadsheet​'s Appen​dices A - G​
Other Documents/Forms​​

​​Service Line Inventory Guidance from the US Environmental Protection Agency​
Association of State Drinking Water Administrators (ASDWA)
Funding and Technical Assistance for Service Line Inventories and Lead Service Line Replacements​​
Lead and Copper Rule Improvements​
How do I know if my tap water is lead free?
Lead and Copper Rule Te​sting Forms​
​For More Information​​​


Background


In 1991, the United States Environmental Protection Agency (EPA) published the ​Lead and Copper Rule (LCR) to minimize lead and copper in drinking water. The Rule replaced the previous Maximum Contaminant Level (MCL) standard of 50 ppb, measured at the entry point to the distribution system, with an Action Level (AL) of 0.015 mg/L for lead and 1.3 mg/L for copper based on 90th percentile level of required compliance monitoring values. The Lead and Copper Rule differs from other Safe Drinking Water Act regulations in that it replaced compliance determination based on an MCL with a three-pronged approach to reducing lead and copper levels:

  1. Treatment technique requirements, including corrosion control and source water treatment;​
  2. Lead service line replacement program;
  3. Public Education for lead.

Lead and copper enter drinking water primarily through plumbing materials. Exposure to lead and copper may cause health problems ranging from stomach distress to brain damage. The Rule established a Maximum Contaminant Level Goal (MCLG) of zero (0) for lead in drinking water and a treatment technique to reduce corrosion of lead and copper within the water distribution system. The treatment technique for the Rule requires water systems to monitor drinking water at customer taps. If lead or copper concentrations exceed the AL in more than 10% of customer taps sampled, the system must undertake a number of additional actions to control corrosion. If the AL for lead is exceeded, the system must inform the public about steps they should take to protect their health including running the water to flush out the lead, using cold water for cooking and preparing baby formula, and identifying if their home plumbing fixtures contain lead. Exceeding the AL is not considered a violation. The LCR applies to all Community Water Systems (CWS) and Non-Transient Non-Community Water Systems (NTNCWS).​

Since 1991, the LCR has undergone various revisions.​

[back to top ↑]​​​

Minor Revisions of 2000


On January 12, 2000, EPA published minor revisions to the 1991 Rule making a number of substantial changes including: 

  • Requirements that when systems replace lead service lines they are to:
    • Replace the portion of the lead service line that they own.
    • Notify residents of the potential for temporary increases in lead levels and measures they can take to reduce lead levels if the system replaces only that part of a lead service line that it owns.
  • Authority for states to invalidate tap samples under certain circumstances.
  • Requirements that systems on reduced monitoring report to the state primacy agency any changes in treatment or the addition of a new water source.

Short Term Revisions


In ​​2007, EPA revised the Lead and Copper Rule to enhance implementation in the areas of monitoring,

  • Required educational statement about lead in drinking water be included in all Consumer Confidence Reports.
  • Changed notification of state primacy agency of anticipated changes in treatment or source water that could increase corrosion of lead from simply notification to prior notice and approval.
  • Changed definition of monitoring and compliance periods to require all compliance samples be taken within the same calendar year.
  • Required water systems above the lead action level to return to standard monitoring if they are on a reduced monitoring schedule.
  • Added flexibility and improved the readability of required public education language.
  • Expanded public education material delivery strategies to better reach consumers and disseminate information to at-risk populations.

New! Lead and Copper Rule Revisions


Service Line Inventories

EPA published the Lead and Copper Rule Revisions (LCRR) in January 2021, which requires all Community Water Systems (CWS) and Non-Transient Non-Community Water Systems (NTNCWS) to submit an initial service line inventory to the Primacy Agency by October 16, 2024. Water systems must develop an inventory to identify the material(s) of service lines connected to the public water distribution system and categorize the service line materials as “Lead”, “Galvanized Requiring Replacement (GRR)”, “Non-lead”, or “Lead Status Unknown” (see link to MDE guidance below). Additionally, there are certain requirements for the water systems to make their information publicly accessible and to notify all persons served by the water system at the service connection with a lead, GRR, or lead status unknown service line​​.

To comply with the service line inventory requirements of the LCRR, Maryland’s public water systems are required to use the inventory spreadsheet provided by MDE to document and report their service line inventory.  Water systems must submit their initial inventory and inventory updates to MDE using this inventory spreadsheet.

Fall 2023
During the Fall of 2023, MDE hosted the first round of virtual trainings for community water systems on how to complete the ​MDE LCRR Service Line Inventory Spreadsheet, which must be used by Maryland's water systems to document, track, and organize their service line inventory and report to MDE.​ The Fall 2023 training concluded on December 15, 2023, and focused on community water systems (both privately owned and publicly owned, including mobile home parks, towns, and cities).

Training for “special" community water systems* (e.g., retirement facilities, nursing homes, correctional facilities, etc.) and non-transient non-community water systems (e.g., schools and businesses), which typically have a small number of service lines and own the entire length of the service line, will be held in early 2024.

*Note: "Special" community water systems are facilities with live-in residents (such as nursing homes, correctional facilities, rehabilitaion centers, retirement homes, hospital with live-in patients, etc.) that have their own water sources (such as wells, springs, etc.).

​Water systems should use an appropriate MDE LCRR Service Line Inventory Spreadsheet that corresponds with the water systems' number of service connections as shown in the table below.

IMPORTANT ANNOUNCEMENT: Due to new information related to service lines​ that has recently come to WSP's attention​, the April 2023 version of the MDE LC​RR Service Line Inventory Spreadsheet has been replaced by the new December 2023 version. The April 2023 version of the inventory spreadsheet is now obsolete and should not be used for reporting service line inventory information to MDE.

Water systems that have already begun using the April 2023 version of the inventory spreadsheet will need to transfer/replicate data properly (i.e., copy-paste data as values -- see Appendix F​) to the new version of the inventory spreadsheet. If your water system would like additional assistance on how to transfer/replicate data properly, please reach out to MDE's Water Supply Program via email at​​ <Reporting.LeadCopperRule@maryland.gov​>.​


**ALERT** (January 17, 2024)

​​An error on the MDE LCRR Service Line Inventory Spreadsheet has been discovered, specifically some critical drop-down options were missing from the December 2023 version of the spreadsheet.  Water systems should stop using the December 2023 spreadsheet and/or sharing the December 2023 spreadsheet with others.  Downloading the December 2023 spreadsheet has been restricted until the corrected version becomes available (expected within the next few weeks).  We apologize for this error.  MDE will work with water systems that have started populating data on the December 2023 version of the spreadsheet to transfer/replicate dat​a properly to the corrected version when it becomes available.​


Number of Service​​ Connections
MDE LC​RR Service Line Inventory Spreadsheet**
(December 2023)
500 or fewer
MDE LCRR Service Line Inve​ntory Spreadsheet_50​​0 rows​​​
Between​ 501 and 5,000
MDE LCRR Service Line Inve​ntory Spreadsheet_50​​00 rows​​
Between​ 5,001 and 10,000
MDE LCRR Service Line Inventory Spreadsheet_100​​00 rows
Between​ 10,001 and 20,000​
MDE LCRR Service Line Inventory Spreadsheet_2​00​​00 rows​​​​
​Between​ 20,001 and 30,000​
MDE LCRR Service Line Inventory Spreadsheet_300​​00 rows​​​​​​
Between​ 30,001 and 45,000​
MDE LCRR Service Line Inventory Spreadsheet_450​​00 rows​​​​
Between​ 65,001​ and 85,000
​​​MDE LCRR Service Line Inventory Spreadsheet_850​​00 rows
Between​ 85,001 and 100,000
MDE​ LCRR Service Line Inventory Spreadsheet_1000​​00 rows
More than 100,000
***​Instructions will be forthcoming***​​​
​​**Note: Inventory spreadsheets with higher number of rows​ are larger (in size) and may take several seconds to a few minutes to open and edit (after downloaded).​​​

After downloading the Excel spreadsheet from MDE's website, you may need to enable editing of the spreadsheet as well as unblock and enable macros.  Follow the steps in Ena​ble Editing, Unblock and Enable Macros Instructions​ to enable editing and unblock and enable macros.​​

Microsoft Excel has a useful feature (called "Freeze Panes") that can help water systems view a large spreadsheet by keeping an area of a particular worksheet visible while you scroll to another area of the same worksheet.  Follow the steps in Freeze/Unfreeze Rows and Columns in a Worksheet Instructions​​ to apply "Freeze Panes" or "Unfreeze Panes" features to your spreadsheet.  Note that the spreadsheet you downloaded may already have Freeze Panes applied.
​Guidance

Inventory Spreadsheet's Appendices A - G:

Coming Soon…
  • MDE LCRR Service Line Inventory Spreadsheet (With Examples) -- for reference ​only
  • LCRR “New” Water Systems Inventory Form
  • LCRR Customer LSL Notification Template 
  • LCRR Customer LSL Notification Certification Form
  • LCRR Template for PWS Written Statement Demonstrating No LSLs

Service Line Inventory ​Guidance from the US Environmental Protection Agency

In August 2022, EPA released Guidance for Developing and Maintaining a Service Line Inventory to support water systems. The guidance (Guidance for Developing and Maintaining a Service Line Inventory) includes best practices and case studies for inventory development. 

In June 2023, EPA released the Small Entity Compliance Guide to support water systems, particularly small water systems, in complying with the LCRR initial inventory requirements.  The guidance ​(Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide) explains the inventory-related actions small community and non-transient non-community water systems are required to take under the LCRR.

​Visit EPA's website​ for more information on EPA's service line inventory guidance.​

Association of State Drinking Water Administrators(ASDWA)

ASDWA has many resources that may be helpful to water systems:

Funding and Technical Assistance for Service Line Inventories and Lead Service Line Replacements​

  • MDE’s Water Infrastructure Financing Administration has opportunities for funding related to service line inventories and lead service line replacements. More information may be found on MDE’s Water Infrastructure Financing Administration webpage.

  • On November 4, 2022, EPA announced a selection of Environmental Finance Centers (EFCs) that will help communities across the country access federal funding for infrastructure projects that improve public health and environmental protection, including service line inventories and lead service line replacements. The current regional and national EFCs that provide assistance for water infrastructure projects include University of Mary​land, Rural Community Assistance Program (RCAP), Environmental Policy Innovation Center (EPIC), U.S. Water Alliance​, and Moonshot Missions​. The selected EFCs will help underserved communities that have historically struggled to access federal funding receive the support they need to access resources for water infrastructure improvements.  For more information on EFCs, visit EPA’s Environmental Finance Centers webpage.
    • ​In addition, the University of Maryland EFC is providing direct support to municipalities, tribes, and water utilities in Maryland to help them access federal and state funding to address water infrastructure needs across drinking water, wastewater, stormwater, and source water. This assistance will be delivered through March 2028 at no cost to recipients through an award from EPA. Available services include assistance identifying water challenges; developing plans; building technical, financial, and managerial capacity; and completing funding application materials. Assistance is available on a need basis, with priority given to historically underserved and disadvantaged communities. To request assistance, contact Michelle Kokolis​ at mkokolis@umd.edu.​
  • The Maryland Rural Water Association (MRWA) has Circuit Riders who are available to assist small water systems (population under 10,000) with completing their service line inventories.  Please visit their website or contact them at info@md-rwa.org​ for additional information.​

New!Lead and Copper Rule Improvements


On December 6, 2023, the proposed Lead and Copper Rule Improvements (LCRI), were published in the Federal Register. The proposal builds on the 2021 Lead and Copper Rule Revisions (LCRR) and the 1991 Lead and Copper Rule (LCR).​ The LCRI will delay the implementation of portions of the LCRR beyond the October 16, 2024, compliance date, however, EPA maintains the October 16, 2024, compliance date for the lead service line inventories. Water systems are to keep their current tap sampling plans until the LCRR comes into effect on October 16, 2024. For more information on the LCRI, see https://www.epa.gov/ground-water-and-drinking-water/lead-and-copper-rule-improvements.​

How do I know if my tap water is lead free?


Whether you receive water from a public water system or from your own private well, testing your home's drinking water is the only way to confirm if lead is present. Most water systems, based on their number of customers, test for lead at a certain number of high-risk homes within their service area as part of their regulatory water monitoring requirements. These tests provide a system-wide snap shot of whether or not corrosion is being controlled within the distribution system, but do not reflect conditions at every customer tap served by that water system. If your home is served by a lead service line, has lead interior pipes (lead is a dull gray metal that is soft enough to be easily scratched with a house key), or if you are concerned about lead levels in your drinking water, you may want to consider  testing your water and havinge it analyzed by a State-certified laboratory.

Information on testing your home's drinking water for lead and steps you can take if you are concerned about lead in your home​ ​can be found on EPA's website.

[back to top ↑]​

Lead and Copper Rule Testing Forms


​Click here for a list of Lead​ and Copper forms fo​r testing ​your ​CWS or NTNCW​S​​​.

[back to top ↑]

For More Information

Please contact the Water Supply Program at Reporting.LeadCopperRule@maryland.gov​ or 410-537-3702​.

[back to top ↑]​

Human Trafficking GET HELP

National Human Trafficking Hotline - 24/7 Confidential

1-888-373-7888 233733 More Information on human trafficking in Maryland

Customer Service Promise

The State of Maryland pledges to provide constituents, businesses, customers, and stakeholders with friendly and courteous, timely and responsive, accurate and consistent, accessible and convenient, and truthful and transparent services.

Take Our Survey

Help Stop Fraud in State Government

The Maryland General Assembly’s Office of Legislative Audits operates a toll-free fraud hotline to receive allegations of fraud and/or abuse of State government resources. Information reported to the hotline in the past has helped to eliminate certain fraudulent activities and protect State resources.

More Information