There are overlapping local, state, and federal regulations concerning lead service line replacements. This page highlights certain regulations affecting Cook County communities. We will continue to update this information as it becomes available. For the most current, complete, and accurate understanding of lead service line replacement requirements, consult applicable laws, regulations, and ordinances established by the federal government, the State of Illinois, and local municipalities – many are linked here.
Lead Service Line Replacement Laws and Regulations in Illinois
Currently, Illinois communities must comply with the federal Lead and Copper Rule Revisions (LCRR, 2021) and, once adopted, the proposed Lead and Copper Rule Improvements (LCRI, 2023). In addition, the Illinois Lead Service Line Replacement and Notification Act was adopted in January 2022.
The US Environmental Protection Agency (EPA) first issued the Lead and Copper Rule (LCR) in 1991 under the Safe Drinking Water Act. The rule requires water systems to deliver minimally corrosive water to reduce lead and copper exposure. It also requires water systems to test for lead in water, educate customers on how to reduce lead levels in home drinking water, and take certain steps to mitigate exposure to lead when test samples exceed the “action level.” The current action level of 15 ppb will change to 10 ppb under the new Lead and Copper Rule Improvements (LCRI).
The US EPA has updated the LCR to better protect public health as our drinking water pipes age and health concerns related to lead in water continue. In 2021, the LCRR (LCR Revision) made initial changes such as requiring water systems to submit initial service line inventories. The LCRI further enhances public health protections by requiring full lead service line replacement, and many other measures discussed below.
The final LCRI was released on October 8, 2024. The US EPA retains the October 16, 2024, compliance date for the initial service line inventory, as stipulated in the LCRR. Water systems must identify service line materials and make their inventories publicly available. With limited exceptions, the US EPA proposes that water systems directly transition from the LCR to the LCRI for all other provisions.
Key provisions in the final LCRI include:
Requires the removal of all lead service lines within ten years in the majority of water systems.
- The 10-year timeline starts on the compliance date, three years after the LCRI is published in the Federal Register. For community water systems, this provides a timeline of 13 years for replacement, allowing for the 3 years between promulgation and enforcement.
Retains the requirement to regularly update service line inventories until all service line materials are known or replaced with a non-lead service line.
- Adds lead service line connectors to the inventory process.
- Adds the requirement to make lead service line replacement plans publicly available.
- Updates protocols to improve tap sampling: First and fifth liter samples collected with highest concentration used to calculate the ninetieth percentile.
- Lowers the lead action level from 15 ppb to 10 ppb and eliminates the LCRR “trigger level”.
- Strengthens protections to reduce lead in water exposure by requiring additional outreach and making filters certified to reduce lead in water available to customers.
Cook County TAP will review the Illinois Lead and Copper Rule Notification Act to assess how the LCRI may impact the work underway across Illinois water systems to address lead in water. The current regulations are listed below.
What is an “Action Level”?
US EPA defines the action level for lead in drinking water as 15 parts per billion (ppb), or 15 micrograms per liter (µg/L). It is used to determine whether a water system’s corrosion control treatment is working. If 10% of the samples in homes with known lead service lines exceed 15 ppb, the system must take action, such as providing public education or replacing lead service lines. The recently released LCRI will lower the action level to 10 ppb once fully enforced.
Illinois Regulations and Lead Service Line Replacement
Illinois EPA is the local regulatory agency overseeing Safe Drinking Water Act compliance, including the Lead and Copper Rule Revisions and the Lead Service Line Replacement and Notification Act, among others. Accordingly, the following deadlines and notices to occupants of potentially affected buildings are required for Illinois water systems. Find out more on the Illinois EPA Drinking Water Compliance and Enforcement webpage.
The Illinois Lead Service Line Replacement and Notification Act requires the operators of community water supplies to create a service line material inventory, develop a lead service line replacement plan, and notify customers of possible exposure to lead. Here are some highlights of the act:
Required Submission: Service Line Material Inventory
Due Dates:
- 4/15/22 – Develop initial service line material inventory
- 4/15/23 – Electronically submit service line material inventory
- Updates to be provided each year until a complete and final replacement plan is submitted
What’s Required: Details of each service line material in service area, updated with new identifications and replacements, including customer-side service line materials. The Illinois EPA can grant an extension.
Note that the State must report the LSLI to the US EPA on October 16, 2024.
Required Submission: Lead Service Line Replacement Plan
Due Dates:
- 4/15/24 – Initial electronic submission
- 4/15/25 & 4/15/26 – Update electronic
- 4/15/27 – Final electronic
What’s Required: Create and submit to the Illinois EPA a plan to replace each lead service line connected to the distribution system as well as galvanized lines that are (or were) connected downstream of a lead line.
Notification Type: Exceeding the action Level (15 ppb)
When: 60 days after the end of monitoring and the lead action level is exceeded and continues every 12 months as long as the lead action level is exceeded
Information Provided to Resident: Must be delivered to all customers and sensitive groups. The notice must include monitoring results, health effects of lead, how to reduce exposure, and water utility contact information.
The Lead and Copper Rule Revision (LCRR) added a newly defined trigger level* of 10 ppb.
*A "trigger level" indicates a point at which water suppliers must take certain actions to avoid exceeding the "action level."
Notification Type: Identified Lead Service Lines
When: 15 days after or ASAP to all affected building residents
Information Provided to Resident: Notification by mail or posted at the primary building entrance, including how to prevent exposure from lead in drinking water; and dangers of lead exposure to young children and pregnant women.
Notification Type: Lead Service Line Inventory
When: ASAP after completion
Information Provided to Resident: Post a copy on website or send to the IL EPA to post.
Notification Type: Lead Service Line Removal Plan
When: ASAP once adopted
Information Provided to Resident: Post a copy on website or send to the IL EPA to post. Must include: # and average cost of replaced; progress toward hiring requirements; % of customers waiving LSL removal; how LSLR is financed.
Notification: Planned Lead Service Line Replacement*
When: At least 45 days before conducting a planned LSLR
Information Provided to Resident: Attempt to contact the owner to request access and permission to proceed with replacement.
When: At least 14 days before work, written notification to all affected owner and occupants
Information Provided to Resident: Notice at least 14 days before work by mail, email and/or posted at the primary entryway.
When: Notify IL EPA within 15 days of owner refusal
Information Provided to Resident: If the owner refuses to grant access to complete the repair and does not sign a waiver to that effect.
Notification: Repairing or replacing water mains*
When: At least 14 days before, written notification to all affected owners and occupants
Information Provided to Resident: Notice by mail, email and/or posted at the primary entryway.
Notification: Emergency repair & Replacing or disturbing LSL
When: ASAP after repair/disturbance, written notification to all affected owners and occupants
Information Provided to Resident: Notice by mail, email, and/or posted at the primary entryway. Provide NSF/ANSI 53 and 42 filters for at least one fixture per unit affected.
* If the notification is required to the entire community due to emergency repairs or of a small system, typically serving <10,000 people, required notification can occur through local media outlets, social media, or similar means in lieu of written notification.
Partial lead service line replacements are prohibited under the Illinois Lead Service Line Replacement and Notification Act. There are limited exceptions which include emergency repairs. However, those actions must be coupled with written notification that the repair has been completed and delivered to the building's owner or operator, and any residents served by the lead service line.