Countdown to Compliance: A Roadmap to Climbing and Conquering the LCRR/LCRI

Galvanized Requiring Replacement (GRR) Defined

Galvanized Requiring Replacement (GRR): A galvanized service line that is or was at any time downstream of a lead service line or is currently downstream of an “unknown” service line.

If a water system cannot demonstrate the galvanized line has NEVER been downstream of a lead service line, then it must presume there was an upstream lead service line and categorize it as a GRR. To demonstrate that a line is not GRR, a water system must have historical or current records indicating the material type of any upstream service lines since the galvanized line was first installed.

What is a GRR and what is not?!

Read this table to find out how to classify your galvanized service lines.

* Under LCRR and for the October 16, 2024 service line inventory, any lead connector will not classify a service line as lead  

or GRR; however, under the proposed LCRI, lead connectors over a certain length may be classified as lead service lines, and galvanized lines downstream from those longer lead connectors may be classified as GRR. 

Common Scenario:

• Main line & service line replacement project was conducted. New mains and services were installed, but the old main and all old service lines were left in the ground. 
  • No information was ever noted about what material type the old service lines were because the operators/contractor never saw the old service lines or connectors when they did the new installation.
  • In this circumstance, there are two options for the customer service line material type:

1. Customer side is galvanized: classify customer line as GRR because no information was documented for the utility-owned section that was there before, even though new utility-owned service line is now non-lead/non-galvanized.
   • Exception: if utility has records demonstrating that the original utility-owned service line was some material besides lead (or records demonstrating that lead service lines had never been installed in the distribution system), classify the service line as non-lead.
2. Customer side is not galvanized: classify customer side as the actual material (non-lead or lead, as appropriate)

Reminder: Although service lines categorized as GRR will require replacement, water systems’ lead service line replacement plans are NOT due October 16, 2024 New deadlines and requirements for lead service line replacement plans will be established in the finalized LCRI.