Template and Guidance: Customer notification of Lead and Potential Lead Service lines
Training: Submitting Your Baseline Inventory - September 2025
Data Summary: Service Line Inventories reported by Virginia Waterworks
Guidance from VDH-ODW
Preparing for 2027 Lead and Copper Improvements
ODW has developed several documents to help water systems in Virginia navigate the Lead and Copper Rule Revisions. ODW will continue to update these documents and develop new guidance materials as the EPA continues to release new information.
Training hosted by VDH ODW
Lead and Copper Rule Copper Rule Improvements: What’s New and Different in the Proposed Rule?
- 3/26/24 Webinar Slides: Lead and Copper Rule Improvements: What’s New and Different in the Proposed Rule?
Lead and Copper Rule Revisions: Submitting a Service Line Inventory
- Community and Large NTNC Waterworks Webinar 2/8/24 | Slides |
- Small NTNC Waterworks Webinar 2/13/24 | | Slides |
Lead and Copper Rule Revisions: Guidance for Developing and Maintaining a Service Line Inventory
Lead and Copper Rule Improvements: Preparing Your Baseline Inventory
Consistent with the Lead and Copper Rule Improvements in the National Primary Drinking Water Regulations, Virginia waterworks are required to submit a baseline inventory by November 1, 2027. VDH ODW continues to work with waterworks that have not submitted their initial inventory. Generally, VDH ODW is not requiring resubmittal or update of the initial inventory, although VDH ODW required this as a condition of grant funding for some waterworks. Some waterworks are submitting updates to their initial inventory on a voluntary basis.
Since the requirements of the baseline inventory are somewhat different than the initial inventory, VDH ODW anticipates transitioning the templates and SWIFT Submittals portal to accept the baseline inventory in early 2027.
Preparing Your Baseline Inventory Webinar – September 17, 2025
Videos from EPA
EPA released a video message asking customers to play an important role to assist with identifying lead pipes on the customer’s property or in the home.
English: https://youtu.be/6et78HZRquI
Spanish: https://youtu.be/bVAcojQgfUI
LCRI Guidance from EPA
On October 8, 2024, EPA issued the Lead and Copper Rule Improvements (LCRI) requiring drinking water systems across the country to identify and replace lead pipes within 10 years. It also requires more rigorous testing of drinking water and a lower lead action level to protect people from lead exposure in water. In addition, the final rule improves communication within communities so that families are better informed about the risk of lead in drinking water, the location of lead pipes, and plans for replacing them.
Information about the LCRI is available here.
Technical Fact Sheets and other Supporting Materials are available here.
LCRR Guidance from EPA
EPA released Guidance for Developing and Maintaining a Service Line Inventory on August 4, 2022. This guidance is intended to help water systems to comply with the requirement of submitting an initial service line inventory by October 16, 2024 set by the Lead and Copper Rule Revisions. It includes best practices on how to prepare and maintain a service line inventory and communicate this information to the public. EPA also released an Inventory Template to accompany this guidance. Both documents are available to download below and are also available on the EPA's website.
- Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide (pdf)
- Fact Sheet for Developing and Maintaining a Service Line Inventory (pdf)
- Revised Lead and Copper Rule Webpage
- Guidance for Developing and Maintaining a Service Line Inventory
Webinars
- EPA: Getting the Lead Out: Guidance for Developing Service Line Inventories and funding Information on BIL (August 10, 2022)
Recording
LCRR/LCRI Technical Assistance
The Virginia Department of Health Office of Drinking Water is offering free technical assistance related to the requirements in the LCRR and LCRI. The technical assistance provider is TruePani, Inc. Technical assistance topics include:
- Guidance for Inventory and Inventory Submittal Assistance
- Strategies to Identify Unknowns
- Lead Service Line Replacement Plans
- Communications and Outreach
- Tap Sampling Requirements and Plans
Technical Assistance Hotline: 804-409-6964
Inquiry Form: bit.ly/VALCRRAssistance
Email: valcrr@truepani.com
Consumer Notification Templates for LSL, GRR, and Unknown Service Lines
All water systems with lead, galvanized requiring replacement, or lead status unknown service lines in their service line inventory must inform all persons served by the water system with a lead, galvanized requiring replacement, or lead status unknown service line. A water system must provide the initial notification within 30 days of completion of the lead service line inventory and repeat the notification each calendar year until the entire service connection is no longer a lead, galvanized requiring replacement, or lead status unknown service line. For new customers, water systems shall also provide the notice at the time of service initiation.
ODW has developed templates for required notifications under the Lead and Copper Rule Revisions. Virginia waterworks may use the ODW templates or EPA template (link below). Waterworks that choose to deviate from the ODW or EPA template should request their field office to review and approve the changes.
Following the customer notification, waterworks must complete the certification statement no later than July 1, and return it to their field office, along with copies of the customer notifications.
Dates to Remember:
- December 31, 2025 - Send consumer notifications to consumers with lead service lines, galvanized service lines requiring replacement, or service lines of unknown materials.
- July 1, 2026 - Submit the consumer notification certification statement to the appropriate Field Office of VDH-ODW covering calendar year 2025, to include new customer notifications.
*The Lead and Copper Rule Revisions Rule (LCRR) requires consumer notification to new customers with lead service lines, galvanized service lines requiring replacement, or service lines of unknown materials at the time of service initiation. Waterworks need to establish a new business process to ensure this notification is completed.
ODW Templates
Consumer Notice Confirmed LSL
Consumer Notice Galvanized Requiring Replacement
Consumer Notice Lead Status Unknown
Certification – Known or Potential SL Containing Lead
EPA Templates
- EPA Templates for Notification of Known or Potential Service Lines Containing Lead
- Plantillas para la notificación de presencia o posible presencia de líneas de servicio de plomo
Lead Action Levels Trigger a Tier 1 Public Notification
Effective October 16, 2024, the 2021 Lead and Copper Rule Revisions require water systems to issue a Tier 1 Public Notification (PN) when there is an exceedance of the lead action level no later than 24 hours after the systems learns of an exceedance. This document provides a template that water systems can use to develop a Tier 1 PN for a lead action level exceedance.
ODW Tier 1 PN Following a Lead Action Level Exceedance Template
EPA:
- EPA Tier 1 PN Following a Lead Action Level Exceedance
- Instrucciones para la notificación publica sobre excedencia del nivel de acción del plomo
Following the Tier 1 public notification, waterworks must complete and return the certification statement within 10 days to their field office, along with copies of the Tier 1 public notification.
Tier 1 PN Certification Statement
Other Info/Readings
Lead service line identification: A review of strategies and approaches (Hensley et al., 2021)