Frequently Asked Questions (FAQ)- Lead and Copper Rule Improvements
For Minnesota Public Water Systems

On this page:

• Service Line Replacement Funding
• Schools and Child Care Requirements
• General Questions about the LCRI
• Community Water System (CWS) questions and answers
• Noncommunity Water System (NWS) Questions and Answers

Service line replacement funding questions and answers

Is the funding for Lead Service Replacements coming from the federal or state level?

The funding will be from the federal level but will be coming through Minnesota's Drinking Water Revolving Fund. For specific questions about the LSL Funding, contact Corey Mathisen at corey.mathisen@state.mn.us.

Will there be funding available for LSL replacement?

Funding is available to cities to pass on to their residents to replace LSLs on private property. The funds are in the form of a principal forgiveness grant to the city for up to 50 percent of the project cost. Grants are only awarded if the entire LSL is replaced. The grant cap is currently $250,000. The remaining balance of the private LSL replacement or replacement of the publicly-owned portion can be covered by a below-market-rate loan through the Drinking Water Revolving Fund (DWRF). DWRF applications are accepted annually and need to be submitted to MDH by the first Friday in May.

You must apply to be listed on the DWRF Project Priority List to be eligible. Funding is not directly available to individual residents through this program.

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Schools and Childcares requirements questions and answers

Who, at schools, are responsible for testing under state statute?  

Each school is responsible for designating staff to do sampling. This is usually a facility maintenance staff person, or sometimes schools will contract with an Environmental Health consultant.

Does each school district have a protocol set up with a public water system? 
There is no specific requirement for schools to work with their public water system on school sampling under the state statute although it is recommended that schools reach out to their water system for information on incoming water quality, sharing results, and creating consistent messaging about lead in drinking water.

Schools must follow a Model Plan for testing. The model plan is intended for use by all public school districts and charter schools in Minnesota. The model plan is required for public schools and charter schools per legislation but also appropriate for other types of buildings such as, other types of schools, businesses, child care facilities, etc.

Who determines compliance if the results are not provided in schools to MDH?
If MDH finds out a school has not tested by the deadlines in statute, then MDH will follow up with the school and MDE to provide education about the statute.

Does the age of the school building make a difference in required testing? For example, we have a new school building (5 years old) in our community.
No, the age of the building does not change the testing requirements. Both old age school and new school are required to test.

The age of the school will impact the plumbing materials. The state rule does not allow testing to be opted out for new buildings. Even modern low-lead plumbing materials can leach lead depending on the building water quality/water use patterns.

Will cities be responsible for school and day care testing after 2024?
After 2024, there is shared responsibility for testing and education. Currently, only public schools are required to test under state statute. CPWS will require the federal LCRR to offer testing to schools on top of the existing state requirements schools must meet. Schools and child care programs will still have free testing through the state from the WIIN grant. MDH will work with EPA to evaluate if they may waive some portions of the school testing for systems due to our existing state programs; however, we will have to wait until we have more information from EPA on what will be allowed to be waived.

What resources are there for schools and child cares to test. What resources are there for education on drinking water for school staff and educators?
Check out resources for schools and child cares at Drinking Water in Schools and Child Cares.
Resources for staff and educators can be found at Resources and Training for Educators.
(All water topics not lead focused)

What is the definition of child care used by the LCRR/WIIN grant?
The Safe Drinking Water Act (SDWA) definition of child care facility is a location that houses a licensed provider of child care, daycare, or early learning services to children, as determined by the state, local, or tribal licensing agency.

WIIN Grant:

• Licensed Child Care Programs (both public and private) (no limit on the number of children served).
• Local Education Agency such as public or charter schools.
  • a Local Education Agency (as defined in section 8101 of Elementary and Secondary Education Act of 1965 [20 USC7801]).

How are CWS's required to work with schools for lead sampling under the new rule?

MDH is working with EPA on how the LCRR requirements overlap with Minnesota Statute, 121A.335 Lead in School Drinking Water. Public and charter schools are required to test lead in drinking water since 2018. Testing results must be available to the public.

MDH is planning to provide guidance documents and notification templates that CWSs will use to communicate and ensure required sampling is completed at schools and childcares. EPA has not yet published its technical guidance for states.

A new Lead in drinking water testing program is available to schools and child care providers. This grand-funded program is part of the Water Infrastructure Improvements for the Nation (WIIN) from the EPA. The program provides sample kits for lead testing free of charge. MDH is collaborating with the Minnesota Department of Education and the Minnesota Department of Human Services to get the word out to schools and child care providers. More information about the testing program and to see if your school or childcare program is eligible, can be found at Minnesota Lead Testing in Schools and Child Cares in Drinking Water.

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General questions and answers about the LCRI

What is the compliance date for the revised rule?
The compliance date for the LCRI is November 1, 2027.

Please be aware that all of the current Lead and Copper Rule requirements remain in place. You will need to keep following these until the new provisions go into effect.

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Community Water System (CWS) questions and answers

How should my CWS start preparing for the LCRI?

The Minnesota Department of Health (MDH) recommends CWSs begin preparing by:

• Watching for regular MDH email updates.
• Continually updating your service line inventory.
  • Gathering contact information on schools and childcare facilities you serve.
  • Conducting service line replacements.
• Adding connector information for all service connections. 
• Evaluating ways to lower lead levels if your most recent sampling rounds were above 10 ppb for lead. 
• Reviewing your lead/copper site plan and determine if there are changes needed to comply with the LCRI.

Sampling and analysis

What changes are being made to lead sample collection procedures?

In addition to the current first liter samples, samples collected at lead service line sites will be required to be a first and fifth-liter sample. This second sample will help better measure the lead level in the water resting in the lead service line. Samples from non-lead service line sites must continue to be first-draw one-liter samples. MDH will finalize the instructions for collecting first and fifth-liter samples and those procedures will be provided in sample kits during your next scheduled monitoring round.

Will Chain of Custody forms (COCs) and bottles still be provided by MDH prior to the required sampling?

MDH will continue to provide COCs and sample materials to CWSs for their lead/copper sampling.

What laboratories will CWSs use for lead sample analysis? 

Lead/Copper compliance samples go to Pace Analytical in Minneapolis, RMB Environmental Labs in Detroit Lakes, Minnesota Valley Testing Labs in New Ulm or The Minnesota Department of Health Public Health Laboratory in Saint Paul. Lead/Copper labs are assigned by the county you are in for convenience.

CWSs can conduct their own follow-up for investigative sampling and use any accredited lab for analysis. Any sample results need to be reported to MDH, even if you do the sampling on your own.

Public notification and education

What public education will be required for residences served by LSLs?

CWSs will be required to:

• Notify residents served by a f lead, galvanized requiring replacement or unknown service line within 30 days MDH notification that your annual  service line inventory update is approved. This is an annual requirement; MDH will provide the documents needed to complete these notifications each year.
• Update their lead/copper site plan to include the highest priority sites that exist in their system. If lead service line sites exist in the system, those should be represented on the site plan.
• Distribute service line disturbance notices to residents before and after a service line replacement and if there is a disturbance to a lead, galvanized requiring replacement, or unknown service line during other maintenance work.
  • Follow up with all sample results from homes served by lead service lines during LSL replacement.
  • Conduct follow-up sampling and education before and after LSL removal.
• Conduct a distribution system and site assessment there are individual site results above the action limit.
  • Systems will be required to notify residents of individual sample results that exceed 10 ppb for lead within 24 hours of MDH notification.
  • MDH will provide systems information on completing the distribution system and site assessment if they have a sample results that exceeds 10 ppb for lead.

The requirement for education materials (and possibly sampling and filters) for residents that have had disturbances such as shut-offs – when does this come into effect?

Systems must begin providing customers with notifications and educational materials for these disturbances on November 1, 2027. Visit Lead Service Line Replacement Plans For Minnesota Public Water Systems for more information on the service line inventory disturbance notifications. 

Service line inventories

What do I need to do for the service line inventory and when does it need to be completed?

Annually systems must submit an updated service line inventory to MDH by the first Friday in June (June 4, 2027). This annual inventory update must include information on connectors/gooseneck for all service lines in the system and information on schools and childcares in the system. Visit Service Line Inventory Guidelines for more information on annual service line inventory updates.

How can residents identify LSLs?

As a resident, if you want to know how lead might be affecting your water, you can contact your water system and/or try using the method below to determine if you may have a lead service line. Find the lead pipes in your home (npr.org).

Once my CWS has a service line inventory, do I have to sample all sites with LSLs? Or will the number of sample points still be the same for my CWS?

The number of sample points will remain the same, in that a system’s number of required samples will still depend on the system’s monitoring schedule, sample results, and system size in terms of population. Systems will need to redefine their lead and copper sample site list to prioritize homes that are served by lead service lines.

Service Line Identification and Replacement Plan

What is the new service line identification and replacement plan requirement?

All CWS with at least one lead, galvanized requiring replacement, or unknown service line must complete and submit a service line identification and replacement plan to MDH by October 1, 2027 and annually thereafter.

All service line identification and replacement plans must be publicly accessible. If your system serves >50,000 people, your service line identification and replacement plan must be available online.

• MDH will notify systems to complete their replacement plan upon approval of their annual service line inventory submittal.
• Visit Lead Service Line Replacement Plans For Minnesota Public Water Systems for more information on the service line identification and replacement plan.

Corrosion Control treatment

Does MDH have any guidance on the corrosion control treatment requirements for CWSs that serve populations over 50,000?

The LCRI requires large CWSs to conduct a corrosion control study or re-optimize corrosion control upon exceeding the trigger or action level. Systems with LSLs will be required to conduct pipe loop studies using harvested lead pipe.

To prepare for LCRI, large systems can:

• Review existing treatment and practices to identify ways to reduce lead.
• Contact MDH before making treatment changes.
• Review historic LC results and distribution residuals to assess risk of exceeding an action or trigger level.

MDH has reached out to discuss corrosion control treatment requirements for large systems that do not yet have corrosion control. One good resource is EPA’s Optimal Corrosion Control Treatment Evaluation Technical Recommendations.

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Noncommunity Water System (NWS) questions and answers

Do the Lead and Copper Rule Revisions apply to NWSs? 
Since these are modifications to the current Lead and Copper Rule, the revisions do apply to nontransient NWSs. However, some of the revisions, such as those regarding lead service lines, are likely to be less impactful for noncommunity systems than for community systems. Neither the current nor the revised rule applies to transient NWSs.

How should my nontransient NWSs start preparing for the revised rule?
You are encouraged to become familiar with the rule revisions, as described above. MDH staff will also keep you informed as further guidance becomes available from US EPA and as we develop MDH’s plans for implementing the revisions. In the meantime, please be aware that all the current rule requirements remain in place, so you will need to keep following these until the new provisions go into effect.

Return to Lead and Copper Rule Revisions

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