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TCEQ urges water systems to finish lead service line inventories; baseline and replacement deadlines loom
Summary
TCEQ staff reviewed requirements from the Lead and Copper Rule revisions and improvements, reminded systems that initial inventories were due Oct. 16, 2024, and explained baseline inventory and replacement-planning deadlines under LCRI that take effect by Nov. 1, 2027.
Seth Kramer, the TCEQ lead and copper monitoring team leader, told the GWAG that while the agency is still focused on getting initial lead service line (LSL) inventories into its system, utilities must prepare for the baseline inventory and replacement planning that the Lead and Copper Rule Improvements (LCRI) will require.
"All water systems have to develop this whether you know that you don't have any lead or not, you still have to submit some inventory to us," Kramer said, describing the initial inventory requirement that came due Oct. 16, 2024. He said a baseline inventory with additional fields such as connectors will be required by the LCRI compliance date on Nov. 1, 2027.
The nut graf: TCEQ staff reiterated that submission and public accessibility of a service-line inventory is mandatory for every water system, even if the inventory shows no lead service lines. Systems should register for and use TCEQ's SWIFT submittal portal now, the agency said, because the portal will be expanded to support baseline inventories, tiering calculations and replacement-rate tracking ahead of the 2027 LCRI compliance deadlines.
Kramer summarized the recent rule timeline: the Lead and Copper Rule Revisions (LCRR) went into effect Oct. 16, 2024, requiring initial certified inventories, certain public notices and a 24-hour notice for lead action-level exceedances; the LCRI was finalized and will become enforceable on Nov. 1, 2027. He stressed two practical items utilities should track now: connectors (which become required in baseline inventories) and the need to include known lead and potential lead service lines in sampling tier pools.
TCEQ staff also discussed compliance tools and outreach. The agency noted that it will allow utilities to maintain and update inventory data in SWIFT before formal submission, and that systems that reported inventories accepted by TCEQ currently cover an estimated 94% of the state population though only 73% of bulk systems had submitted inventories at the time of the meeting. Kramer and other staff encouraged early use of the state's lead testing program for schools and child-care facilities as a practical compliance path.
Ending: TCEQ will continue to post guidance and EPA fact sheets for LCRR/LCRI on its web pages and advised systems to use the SWIFT portal to start collecting connector data and preparing replacement plans well before the 2027 deadlines.
