The Alabama Department of Environmental Management is the primacy agency for implementation of the Lead and Copper Rule in Alabama. ADEM’s lead and copper regulations are in Division 7, specifically Chapter 335-7-11. The State’s lead ban is in Chapter 335-7-8, which became effective January 4, 1989.
On December 16, 2021, revisions to the EPA Lead and Copper Rule (LCRR) became effective with a compliance date of October 16, 2024. Simultaneously, EPA announced that while the inventory requirements of the new rule would remain intact, the agency plans to make further revisions to the remainder of the rule (Lead and Copper Rule Improvements, or LCRI). EPA plans to announce the LCRI and make it effective by October 16, 2024. ADEM plans to incorporate the federal rule into its regulations once the LCRI is finalized.
Of immediate concern to public water systems is the service line inventory requirement of the LCRR. Community and non-transient non-community water systems must submit a complete inventory of all service lines connected to the distributions system, including both the public and the private side of the line. The applicable regulation for this requirement is at 40 CFR 141.84. On August 4, 2022 EPA released its Guidance for Developing and Maintaining a Service Line Inventory.
On June 28, 2023, EPA released Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide to support water systems, particularly small water systems, in complying with the initial inventory requirements. EPA’s Small Entity Compliance guide helps explains the inventory related actions small community and non-transient non-community water systems are required to take under the LCRR. Also On June 28, 2023, EPA released Fact Sheet for Developing and Maintaining a Service Line Inventory. The fact sheet can help water systems quickly identify the key LCRR inventory requirements, including inventory elements, planning, records review, investigations, public accessibility, and information for non-lead systems.
Service Line Inventory
Every community and non-transient non-community water system must submit a detailed service line inventory to ADEM by October 16, 2024. ADEM has developed a spreadsheet for water systems to use for their service line inventories; optionally, water systems may export data from other databases using our schema to upload to eDWRS. The required fields, which are slightly different from the EPA template, are highlighted in yellow on the ADEM template.
If your system needs assistance in preparing a service line inventory, free technical assistance may be available from EPA’s WaterTA program. For more information, and to submit a request for technical assistance, please visit: https://www.epa.gov/water-infrastructure/water-technical-assistance-waterta. Funding opportunities may be available to assist with the completion of the Lead Service Line Inventory via ADEM’s SRF Program.
ADEM Service Line Inventory Files
ADEM Service Line Inventory Template (Microsoft Excel, Version 1.4 (10/30/24), 10MB)
ADEM Service Line Inventory Certification Form
ADEM Service Line Inventory Instructions (Updated 6/2/23)
XML Schema (Contact us for more information.)
Notification of Known or Potential Service Line Containing Lead
All water systems with lead, galvanized requiring replacement, or lead status unknown service lines in their inventory must inform all persons served by the water system at the service connection with a lead, galvanized requiring replacement, or lead status unknown service line. The deadline for providing this notification is November 15, 2024 for those water systems that submitted an inventory by October 16, 2024. Any system that completes its inventory after the deadline must provide their notifications within 30 days of completion. The notices must be repeated on an annual basis until the service line is no longer lead, galvanized requiring replacement, or lead status unknown.
More information, including links to templates containing the required information can be found on EPA’s website here.
Tier 1 Public Notice for Lead Action Level Exceedance
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. Should your water system become aware of a lead action level exceedance, it is essential that you communicate with the Drinking Water Branch immediately, so that you will have time to issue this notice. To assist water systems with this requirement, EPA has developed a template and fact sheet, both of which are available here.