The Lead and Copper Rule(s) Going Forward - Highlights of the Lead and Copper Rule Improvements - Compliance Requirements/Changes on October 16, 2024

Sep 16, 2026

Guidance outlines how the Alabama Department of Environmental Management (ADEM) will implement the Lead and Copper Rule(s) improvements, including the interim primacy approach and enforcement responsibilities between ADEM and EPA. It details key compliance changes effective October 16, 2024, focusing on Initial Service Line Inventory (SLI) development and submission, required education materials, and accelerated public notice for lead and copper sampling tied to ALEs under the WIIN Act. The document further specifies SLI content elements, connector handling, and consequences and timelines when satisfactory submission is not achieved.

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Pages17

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Highlights of the Lead and Copper Rule Improvements

Primer on Primacy

Compliance Requirements/Changes on October 16, 2024

Service Line Inventory (SLI)

LCRI 40 CFR § 141.84(a)

SLI Categories: Post-October 16, 2024

Failure to Submit Satisfactorily by October 16, 2024

The Lead and Copper Rule(s) Going Forward Robert Compton Water Supply Engineering Section Drinking Water Branch Alabama Department of Environmental Management October 16, 2024 Highlights of the Lead and Copper Rule Improvements Primer on Primacy ADEM is planning to incorporate the new rule by reference. This means Division 7 will contain references to the specific federal rule that the Department has adopted and will enforce. Until ADEM receives interim primacy, ADEM will administer the rule, but any formal enforcement would be carried out by EPA directly. ADEM will continue to enforce the LCR promulgated in 1991 and codified in the Division 7 regulations except for the Service Line Inventory, ALE requirements, and Public Notification/Education materials . Compliance Requirements/Changes on October 16, 2024 All Community and Non-Transient/Non-Community drinking water systems must develop an “Initial Service Line Inventory” and submit it prior to October 16, 2024 Multiple types of “Education Materials” are required to be delivered under certain circumstances (i.e. service line material classification, service line replacement, Action Level Exceedance…) Public Notice for Lead and Copper Sampling is required at an accelerated timeline for ALEs (Required due to WIIN Act) Service Line Inventory – LCRI 40 CFR § 141.84(a) • Required for all Community and NonCommunity/Non-Transient Drinking Water systems – Even systems without any lead materials. • ADEM should receive the initial SLI no later than October 16, 2024 – 40 CFR § 141.90(e)(1) . 􀂙 That is today! • The Department will be reviewing submitted ISLIs and contacting systems for any required changes . • [https://adem.alabama.gov/programs/water/drin](https://adem.alabama.gov/programs/water/drin)[kingwater/leadcopper.cnt](kingwater/leadcopper.cnt) SLI – The Inventory Must Include: • Street address associated with each service line – or – a Locational identifier for services without a unique address [40 CFR § 141.84(a)(4)] • Service line material for both the system owned portion and customer owned portion: Material types are dropdown options on the template • Connector material: Each service must identify if there is a connector and if it is lead or non-lead. Notes: • Connector material does not change the classification of the service line but must be replaced when encountered in either planned or unplanned infrastructure work. • Connectors are now defined within the LCRI. SLI Categories: Post-October 16, 2024 The system does not submit a satisfactory SLI Template as well as a completed SLI Certification Form OR The system submits a satisfactory SLI Template as well as a completed SLI Certification Form A. The System has lead service lines, GRR service lines, Unknown service lines, Lead connectors, Unknown connector materials B. The System does not have lead service lines, GRR service lines, Unknown service lines, Lead connectors, Unknown connector materials Failure to Submit Satisfactorily by October 16, 2024 Notice Letter issued by ADEM of non-compliance from the LCRR/LCRI requirements EPA issues Violations along with any potential Enforcement Actions directly to the Water System Thirty days after satisfactory submission of SLI, the Water System must notify all persons served by a lead, GRR, or unknown service line that the Service Line is known to or may potentially contain lead using required verbiage. (LCRI verbiage!) SLI Category A – Satisfactory submission with Lead, GRR, or Unknowns • *New customers must be informed at the time-ofservice initiation • Prior to November 15, 2024*, the Water System must notify all persons served by a lead, GRR, or unknown service line that the Service Line is known to or may potentially contain lead using required verbiage. • The notification will repeat annually until the service is no longer Lead, GRR, or unknown • Instructions to access the inventory must

FAQs

How will primacy be handled for the Lead and Copper Rule(s) going forward?

ADEM plans to incorporate the new rule by reference. Until interim primacy is received, ADEM administers the rule, while EPA would carry out formal enforcement.

What service line inventory requirements apply to community and non-transient/non-community water systems?

Systems must develop an “Initial Service Line Inventory” and submit it before October 16, 2024, even if they have no lead materials.

What happens if a system does not submit a satisfactory SLI by October 16, 2024?

ADEM issues a non-compliance notice letter, and EPA issues violations with potential enforcement actions to the water system.

Sep 16, 2026

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