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."
Residential Water Service Line Notification Requirements
This table does not include Safe Drinking Water Consumer Confidence Report notification requirements.
Notification Type | Information Provided to Resident/Building Owner | When | Regulatory Authority |
|---|---|---|---|
| Lead service line inventory (LSLI) | Complete an LSLI and make it available to the public. For community water suppliers serving more than 50,000 customers, post a copy online. For community water suppliers serving fewer than 50,000 customers, send the LSLI to the Illinois EPA to post. LSLI notification template and other resources are available.
| ASAP after completion of inventory starting April 15, 2022. The INITIAL material inventory was required to be electronically submitted to the Illinois EPA by April 15, 2023. The baseline LSLI was due to the Illinois EPA on April 15, 2024. Updates are due each year on April 15 or until all service line materials are identified. A complete and final LSLI is due to the Illinois EPA on April 15, 2027, and will be submitted to the U.S. EPA by the Illinois EPA in compliance with LCRR/I by November 1, 2027. | Illinois Lead Service Line Replacement and Notification Act (Illinois LSLRNA) PART 611 Primary Drinking Water Standards; Section 611.360 Reporting LCRR/I: 40 CFR 141.84(a)(1)
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| Lead service line replacement (LSLR) plan | Complete an LSLR plan and make it available to the public. For community water suppliers serving more than 50,000 customers, post a copy online. For community water suppliers serving fewer than 50,000 customers, send this to the Illinois EPA to post. Must include number and average cost of replacement; progress toward hiring requirements; percent of customers waiving replacement; and how replacement is financed. | April 15, 2024, or ASAP once the plan has been adopted. Community water suppliers must update and resubmit their replacement plans annually on April 15 until a complete and final plan is officially approved by the state no later than April 15, 2027. Final plans are due to the U.S. EPA from the states by November 1, 2027. | PART 611 Primary Drinking Water Standards; Section 611.360 Reporting LCRR/I: 40 CFR 141.84(c)
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| Annual water service line material notification | Notify customers of known or potential service lines containing lead (including galvanized lines requiring replacement and lines of unknown material) annually until all are known and none contain lead. Customizable notification letters are available.
| 30 days after the submission of the LSLI. The next systemwide notification for Illinois is due between May 15 and December 31, 2026. Note that under LCRR/I the next systemwide notification is due December 31, 2026, and annually thereafter. However, Illinois’ notification requirement takes precedence. | IL LSLRNA: Required as of May 15, 2024 LCRR/I 40 CFR 141.85(e): Required as of November 15, 2024 |
| Identified lead service line | Notification by mail or posted at the primary building entrance, including information about how to prevent exposure from lead in drinking water and the dangers of lead exposure to young children and pregnant women. | 15 days after identification or ASAP to all affected residents. Note that Illinois’ rule is more restrictive and takes precedence. | IL LSLRNA: Required as of May 15, 2024 LCRR/I 40 CFR 141.85(e)(3)(i): Required as of November 15, 2024 |
| Emergency repairs resulting in a partial LSLR | Notification posted at the primary building entrance for known lead service line, galvanized requiring replacement, or unknown material, with information about the potential for elevated lead levels in drinking water from the disturbance. Must also begin the process of replacing the remaining portion of any identified lead service line or line that is galvanized requiring replacement. | At the time emergency repair begins, written notification must be provided to all affected owners and residents of the building. Note that Illinois’ rule is more restrictive and takes precedence. | IL LSLRNA: Required as of January 1, 2022 LCRR/I 40 40 CFR 141.84(h): Required as of November 15, 2024
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| Emergency repair follow-up; building owner notification to initiate full LSLR | When an emergency repair results in a partial lead service line replacement, the process of replacing the full and remaining portion of the line must begin. This includes outreach to the building owner to complete full lead service line replacement. | ASAP after emergency repairs are completed. Note that full replacement must be initiated within 30 days of emergency repairs. See the customizable notification letter for more information. | IL LSLRNA: Required as of January 1, 2022* LCRR/I 40 CFR 141.84(h): Required as of November 15, 2024 *The amendment, SB4025, to the IL LSLRNA was passed in May 2026, allowing CWS access to the private side of the service line for LSLR without building owner approval if the replacement is free. |
| Planned water service line disturbance | Notification by mail or posted at the primary building entrance for known lead service line, galvanized requiring replacement, or unknown material. Must provide customers and the persons served by the water system at the service connection with information about the potential for elevated lead levels in drinking water from the disturbance. | At least 14 days before a planned disturbance; written notification to all affected owners and occupants. | IL LSLRNA: Required as of January 1, 2022 LCRR/I 40 CFR 141.85(f): Required as of November 15, 2024
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| Planned repairs or replacement of a water main | Notification by mail or posted at the primary building entrance for known lead service line, galvanized requiring replacement, or unknown material. Must provide customers and the persons served by the water system at the service connection with information about the potential for elevated lead levels in drinking water from the disturbance. | At least 14 days before work begins; written notification to all affected owners and occupants. | IL LSLRNA: Required as of January 1, 2022 LCRR/I 40 CFR 141.85(f)(2): Required as of November 15, 2024
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| Notification of planned LSLR denial by the property owner | Notify Illinois Department of Public Health if a building owner refuses to grant access to complete lead or galvanized service line replacement and does not sign a waiver to that effect. Waiver of Complete Lead Service Line Replacement Mail forms to: Illinois Department of Public Health | Notify the Illinois Department of Public Health within 15 working days of owner refusal.
| IL LSLRNA: Required as of January 1, 2022 LCRR/I 40 CFR 141.84(i): Provide notification to the State. Required as of November 15, 2024
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School and Child Care Facility Notification Requirements
Notification Type | Information Provided to School or Child Care Facility | When | Regulatory Authority |
| School and child care facility inventory | All community water suppliers must submit a school and child care inventory (list of schools and child care providers served by the community water supplier) to the Illinois EPA. The template can be found on the Illinois EPA Lead Service Line Information site. | May 15, 2025: Submit your complete list of schools and childcare facilities via email to EPA.Leadandcopper@illinois.gov Update yearly as needed to add or remove facilities by July 1 with the submission of the “School and Child Care Public Education and Sampling Reporting Form.” The final compliance date for the state to submit information to the U.S. EPA is November 1, 2027, with recertification once every five years thereafter. | LCRR/I: 40 CFR 141.92(b) |
| School and child care facility outreach and education | Annually, provide information about health risks from lead, a notice of the proposed sampling schedule, and details about the lead sampling process. Customizable notification letters will be available soon. | Start date: October 30, 2024. Mandatory sampling is no longer required at the end of the five-year sampling period. The final compliance date for states to submit information to the U.S. EPA is November 30, 2027. | PDWS for Schools and Child Care Facilities LCRR/I: 40 CFR 141.92(c) |
| School and child care facility sampling event | Thirty days before any sampling event, community water suppliers must provide schools and child care facilities with instructions on identifying outlets for lead sampling and preparing for the event. | 30 days before a sampling event | PDWS for Schools and Child Care Facilities LCRR/I: 40 CFR 141.92(c) |
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.