Guidance for Developing and Maintaining a Service Line Inventory

Guidance for Developing

and Maintaining a

Service Line Inventory

Office of Water (4606M)

EPA 816-B-22-001

August 2022

Guidance for Developing and Maintaining i August 2022

a Service Line Inventory

Disclaimer

This document provides recommendations to public water systems in developing and

maintaining a service line inventory. The guidance within this document can be used to comply

with the requirements under the Lead and Copper Rule Revisions (LCRR) that are in effect at the

time of document publication. As described in the Environmental Protection Agency’s (EPA’s)

Federal Register notice of December 17, 2021 (“Notification of conclusion of review”), EPA

intends to publish a proposal to revise the LCRR and take final action on the proposal by October

16, 2024, but EPA does not expect to propose changes to the requirements for information to be

submitted in the initial service line inventory. However, the rulemaking could include changes to

the requirements for inventory updates (USEPA, 2021a). This guidance can also assist public

water systems with financing applications for Bipartisan Infrastructure Law (BIL) (P.L. 117-58)

funds and for implementation once funding is received. Note that the BIL is also known as the

Infrastructure Investment and Jobs Act (IIJA). The BIL contains a historic $15 billion in dedicated

funding through the Drinking Water State Revolving Fund (DWSRF) for lead service line (LSL)

identification, planning, design, and replacement. LSL projects also may be funded using the

General Supplemental DWSRF fund of $11.7 billion as well as annual base appropriations for the

DWSRF. The BIL mandates that 49 percent of funds provided through the DWSRF General

Supplemental Funding and DWSRF Lead Service Line Replacement Funding must be provided as

grants and forgivable loans to disadvantaged communities. EPA encourages water systems to

begin service line inventory and replacement efforts as soon as possible. EPA emphasizes that

given the many benefits of lead service line replacement (LSLR), water systems should not wait

until their inventory is complete to begin replacement efforts. In fact, conducting replacements

while developing the inventory can have synergistic effects that enhance inventory development

while accelerating and increasing the efficiency of replacement programs. The statutory

provisions and EPA regulations described in this document contain legally binding requirements.

This document is not a regulation itself, nor does it change or substitute for those provisions and

regulations. Thus, it does not impose legally binding requirements on EPA, states, or the

regulated community. This document does not confer legal rights or impose legal obligations

upon any member of the public.

Although EPA has made every effort to ensure the accuracy of the discussion in this document,

the legally binding requirements applicable to public water systems are determined by statutes

and regulations. In the event of a conflict between the discussion in this document and any

applicable statute or regulation, this document would not be controlling.

The information collections associated with the LCRR have been submitted for approval to the

Office of Management and Budget (OMB) under the Paperwork Reduction Act. The

recordkeeping and reporting requirements described in this draft guidance align with the

existing regulations and this guidance also includes recommendations for voluntary expanded

data collection and recordkeeping. An agency may not conduct or sponsor, and a person is not

Guidance for Developing and Maintaining ii August 2022

a Service Line Inventory

required to respond to a collection of information unless it displays a currently valid OMB

control number. The OMB control number for the service line inventory is 2040-0297.

The recommendations provided here may not apply to a particular situation based upon the

circumstances. Because they are recommendations, and not legally binding requirements, public

water systems retain the discretion to follow the recommendations or adopt approaches that

differ from those described in this document. In some cases, recommendations may reflect the

existing custom and practices of some states.

Note that this document does not address lending requirements or state or local regulations

related to service line inventories that may apply.

Mention of trade names or commercial products does not constitute endorsement or

recommendation for their use.

This is a living document that EPA may revise periodically to reflect changes in regulatory

requirements and research regarding service line material identification. EPA welcomes

comment on this document at any time; please send comments to [email protected].

Guidance for Developing and Maintaining iii August 2022

a Service Line Inventory

Table of Contents

Chapter 1: Introduction ................................................................................................................ 1-1

1.1 The Benefits of a Comprehensive and Accurate Inventory ................................................ 1-1

1.2 Purpose and Audience ....................................................................................................... 1-2

1.3 Overview of Regulatory Requirements and LCRR Review .................................................. 1-3

1.3.1 Overview of the LCRR Inventory Requirements .......................................................... 1-3

1.3.2 Outcome of EPA Review of the LCRR .......................................................................... 1-6

1.3.3 Related Requirements under the LCR ......................................................................... 1-7

1.4 Document Organization ..................................................................................................... 1-8

Chapter 2: Elements of the Inventory ........................................................................................... 2-1

2.1 Inventory Materials Classifications .................................................................................... 2-1

2.1.1 Required Service Line Inventory Material Classifications ........................................... 2-1

2.1.2 Recommended Subclassifications and Additional Information (Not Required Under

LCRR) .......................................................................................................................... 2-6

2.1.3 Recommendations for Other Drinking Water Infrastructure ...................................... 2-7

2.2 Include All Service Lines Regardless of Ownership Status and Intended Use ..................... 2-8

2.2.1 Required under the LCRR............................................................................................ 2-8

2.2.2 Recommendations (Not Required under the LCRR) .................................................... 2-9

2.3 Location Identifiers .......................................................................................................... 2-10

2.3.1 Required under the LCRR.......................................................................................... 2-10

2.3.2 Recommendations (Not Required under the LCRR) .................................................. 2-10

2.4 Other Recommended Service Line Characteristics ........................................................... 2-11

Chapter 3: Inventory Planning ..................................................................................................... 3-1

3.1 Inventory Development Approach ..................................................................................... 3-1

3.2 Identifying Staff and Resources .......................................................................................... 3-2

3.3 Selecting an Inventory Format ........................................................................................... 3-3

3.3.1 List, Spreadsheet, or Database ................................................................................... 3-4

3.3.2 Maps ........................................................................................................................... 3-6

3.4 Develop Procedures for Collecting Service Line Information ............................................. 3-6

3.5 Establish Partnerships with Third Parties ........................................................................... 3-8

Chapter 4: Historical Records Review ........................................................................................... 4-1

4.1 Previous Materials Evaluation ............................................................................................ 4-3

Guidance for Developing and Maintaining iv August 2022

a Service Line Inventory

4.2 Construction and Plumbing Codes and Records ................................................................. 4-4

4.3 Water System Records ....................................................................................................... 4-7

4.4 Inspections and Records of the Distribution System ........................................................ 4-10

Chapter 5: Service Line Investigation Methods ............................................................................. 5-1

5.1 Visual Inspection of Service Line Material .......................................................................... 5-1

5.1.1 Visual Inspection of Service Line by Customers .......................................................... 5-3

5.1.2 CCTV Inspection by the Water System ....................................................................... 5-7

5.2 Water Quality Sampling ................................................................................................... 5-10

5.3 Excavation ........................................................................................................................ 5-12

5.3.1 Mechanical Excavation ............................................................................................. 5-13

5.3.2 Vacuum Excavation .................................................................................................. 5-14

5.4 Pros and Cons of Field Investigation Methods (Hensley et al., 2021) ............................... 5-14

5.5 Predictive Modeling ......................................................................................................... 5-17

5.6 Emerging Methods ........................................................................................................... 5-17

Chapter 6: Developing and Updating the Inventory ..................................................................... 6-1

6.1 Developing the Initial Inventory ......................................................................................... 6-1

6.1.1 Required under the LCRR............................................................................................ 6-1

6.1.2 Recommendations (Not Required under the LCRR) .................................................... 6-2

6.2 Prioritizing Field Investigations .......................................................................................... 6-6

6.3 Requirements and Recommendations for Systems with Only Non-Lead Service Lines ...... 6-8

6.3.1 LCRR Requirements .................................................................................................... 6-8

6.3.2 Recommendations (Not Required under the LCRR) .................................................... 6-8

6.4 Submitting the Initial Service Line Inventory .................................................................... 6-10

6.5 Notification of Known or Potential Service Line Containing Lead .................................... 6-11

6.6 Inventory Updates ........................................................................................................... 6-12

6.7 State Review and Reporting ............................................................................................. 6-13

6.7.1 State Review of the Initial Inventory ........................................................................ 6-13

6.7.2 State Reporting Requirements ................................................................................. 6-14

Chapter 7: Public Accessibility ...................................................................................................... 7-1

7.1 What Information to Include .............................................................................................. 7-1

7.1.1 Required under the LCRR............................................................................................ 7-1

7.1.2 Recommendations (Not Required under the LCRR) .................................................... 7-2

Guidance for Developing and Maintaining v August 2022

a Service Line Inventory

7.2 How to Make the Data Publicly Available .......................................................................... 7-5

7.2.1 Description of Available Web-Based Map Applications .............................................. 7-5

7.2.2 Web-Based Map Application Best Practices ............................................................... 7-6

7.2.3 Public Data Sharing Alternatives ................................................................................. 7-8

7.2.4 Public Input and Updates ........................................................................................... 7-9

7.3 Considerations for States ................................................................................................. 7-10

7.4 Consumer Confidence Report Inventory Requirements ................................................... 7-11

Chapter 8: References .................................................................................................................. 8-1

Appendix A: Blank Forms from the EPA Service Line Inventory Template .................................... A-1

Appendix B: Case Studies .............................................................................................................. B-1

Appendix C: Instructions for Self-Identifying LSLs and Information When Water System Conducts

Verification .......................................................................................................................... C-1

Appendix D: Summary of Lead Ban Provisions by State ................................................................ D-1

Appendix E: Michigan Minimum Service Line Verification Requirements .................................... E-1

Appendix F: Examples of Data Quality Disclaimer Language ........................................................ F-1

Guidance for Developing and Maintaining vi August 2022

a Service Line Inventory

List of Exhibits

Exhibit 1-1: LCRR Inventory Requirements ................................................................................... 1-4

Exhibit 2-1: Required Inventory Materials Classifications ............................................................. 2-2

Exhibit 2-2: Example of Service Line Ownership Distinction between the Water System and

Customer ...................................................................................................................................... 2-4

Exhibit 2-3: Classifying Service Line Materials When Ownership is Split According to the LCRR 40

CFR §141.84(a)(4) ......................................................................................................................... 2-5

Exhibit 3-1: Inventory Lifecycle ..................................................................................................... 3-2

Exhibit 3-2: Organization of EPA Inventory Template ................................................................... 3-5

Exhibit 4-1: Requirements for Historical Records Review for Initial Inventory Development under

the LCRR ....................................................................................................................................... 4-2

Exhibit 4-2: Illustrative excerpts from municipal codes, specifying that lead was allowed or

required as pipe material for service lines .................................................................................... 4-6

Exhibit 4-3: Water System Record Examples and Uses ................................................................. 4-8

Exhibit 4-4: Examples of Tap Cards with Lead Listed as Service Line Material .............................. 4-9

Exhibit 5-1: Examples of Commonly Found Pipe Materials ........................................................... 5-2

Exhibit 5-2: Example of Wiped Lead Joint ..................................................................................... 5-3

Exhibit 5-3: Example of Location of Exposed Service Line in Basement ........................................ 5-4

Exhibit 5-4: Example Stop Box Schematic from Des Moines Water Works, Iowa ......................... 5-8

Exhibit 5-5: Lead Pipe at a Curb Stop ............................................................................................ 5-9

Exhibit 5-6: Examples CCTV Camera Pictures for LSL, non-LSL, and Unable to Determine ........... 5-9

Exhibit 5-7: Example of Sequential Sampling .............................................................................. 5-11

Exhibit 5-8: Comparison of Service Line Identification Techniques (Hensley et al., 2021) .......... 5-16

Exhibit 6-1: Service Material Screening Process Based on Records .............................................. 6-3

Exhibit 6-2: LSLR Collaborative Flow Chart ................................................................................... 6-4

Exhibit 6-3: Recommended Documentation for Systems with all Non-Lead Service Lines ........... 6-9

Exhibit 7-1: Greater Cincinnati Water Works Service Line Information Map ................................ 7-7

Exhibit 7-2: Examples of Online Data Sharing Alternatives ........................................................... 7-8

Exhibit 7-3: Denver Water’s Lead Service Line Replacement Map .............................................. 7-10

Guidance for Developing and Maintaining vii August 2022

a Service Line Inventory

Acronyms

µg/L

Micrograms per liter

ACHD

Allegheny County Health Department

ASDWA

Association of State Drinking Water Administrators

AWWA

American Water Works Association

BIL

Bipartisan Infrastructure Law

CBI

Curb Box Inspection

CCR

Consumer Confidence Report

CCTV

Closed-Circuit Television

CFR

Code of Federal Regulations

CMMS

Computerized Maintenance Management System

CWS

Community Water System

DWINSA

Drinking Water Infrastructure Needs Survey and Assessment

DWSRF

Drinking Water State Revolving Fund

EDF

Environmental Defense Fund

EGLE

Michigan Department of Environment, Great Lakes, and Energy

EPA

United States Environmental Protection Agency

FTP

File Transfer Protocol

GCWW

Greater Cincinnati Water Works

GIS

Geographic Information System

GPR

Ground Penetrating Radar

GPS

Global Positioning System

GRR

Galvanized Requiring Replacement

GRWS

Grand Rapids Water System

IIJA

Infrastructure Investment and Jobs Act

LCR

Lead and Copper Rule

LCRI

Lead and Copper Rule Improvements

LCRR

Lead and Copper Rule Revisions

LSL

Lead Service Line

Guidance for Developing and Maintaining viii August 2022

a Service Line Inventory

LSLR

Lead Service Line Replacement

LWC

Louisville Water Company

NPR

National Public Radio

NTNCWS

Non-Transient Non-Community Water System

OMB

Office of Management and Budget

ORP

Oxidation-Reduction Potential

PWS

Public Water System

PWSA

Pittsburgh Water & Sewer Authority

PWSID

Public Water System Identification Number

SDWA

Safe Drinking Water Act

SOP

Standard Operating Procedure

USEPA

United States Environmental Protection Agency

WIIN

Water Infrastructure Improvements for the Nation

Guidance for Developing and Maintaining ix August 2022

a Service Line Inventory

Glossary

Term Definition

Curb stop

An exterior valve located at or near the property line that is used to turn on and

off water service to the building.

Community water

system

A public water system that serves at least 15 service connections used by year-

round residents or regularly serves at least 25 year-round residents (40 CFR

§141.2).

Full lead service line

replacement

Replacement of a lead service line (as well as galvanized service lines requiring

replacement) that results in the entire length of the service line, regardless of

service line ownership, meeting the Safe Drinking Water Act (SDWA) Section

1417 definition of lead free

applicable at the time of the replacement. See 40

CFR §141.2 for the full regulatory definition.

Galvanized requiring

replacement

A galvanized service line that is or was at any time downstream of a lead service

line or is currently downstream of a lead status unknown service line. If the

water system is unable to demonstrate that the galvanized service line was

never downstream of a lead service line, it must presume there was an

upstream lead service line (40 CFR §141.84(a)(4)(ii)).

Galvanized service line

Iron or steel piping that has been dipped in zinc to prevent corrosion and

rusting (40 CFR §141.2).

Gooseneck, pigtail, or

connector

A short section of piping, typically not exceeding two feet, which can be bent

and used for connections between rigid service piping. For purposes of this

subpart, lead goosenecks, pigtails, and connectors are not considered to be part

of the lead service line but may be required to be replaced pursuant to

§141.84(c)

(40 CFR §141.2).

Lead service line

A portion of pipe that is made of lead, which connects the water main to the

building inlet. A lead service line may be owned by the water system, owned by

the property owner, or both. For the purposes of this subpart, a galvanized

service line is considered a lead service line if it ever was or is currently

downstream of any lead service line or service line of unknown material. If the

only lead piping serving the home is a lead gooseneck, pigtail, or connector, and

it is not a galvanized service line that is considered a lead service line, the

service line is not a lead service line (40 CFR §141.2).

Lead status unknown

service line

A service line where the material is not known to be lead, galvanized requiring

replacement, or a non-lead service line, such as where there is no documented

evidence supporting material classification. It is not necessary to physically

verify the material composition (e.g.,, copper or plastic) of a service line for its

lead status to be identified (e.g., records demonstrating the service line was

installed after a municipal, state, or federal lead ban

) (40 CFR §141.2).

Non-lead

A service line that is determined through an evidence-based record, method, or

technique not to be lead or galvanized requiring replacement (40 CFR §

141.84(a)(4)(iii)).

Guidance for Developing and Maintaining x August 2022

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Term Definition

Non-transient non-

community water

system

A public water system that is not a community water system and regularly

serves at least 25 of the same persons over 6 months per year (40 CFR §141.2).

Service line

The pipe connecting the water main to the interior plumbing in a building.

The

service line may be owned wholly by the water system or customer, or in some

cases, ownership may be split between the water system and the customer.

State

State means the agency of the State or Tribal government that has jurisdiction

over public water systems. During any period when a State or Tribal

government does not have primary enforcement responsibility pursuant to

Section 1413 of the Act, the term “State” means the Regional Administrator,

U.S. Environmental Protection Agency (40 CFR §141.2).

Water main

A pipe that conveys water to a connector or customer's service line. In

residential areas, it is usually located underground.

Water meter

An instrument, mechanical or electronic, used for recording the quantity of

water passing through a particular pipeline or outlet.

Notes:

Definitions without a regulatory citation are recommended definitions for use in this guidance document.

Source: Seventh Drinking Water Infrastructure Needs Survey and Assessment: Lead Service Line

Inventory for America’s Water Infrastructure Act – State Survey Instruction (USEPA, 2021b).

In 1986, Congress amended the Safe Drinking Water Act (SDWA), prohibiting the use of pipes, solder, or

flux that were not “lead free” in public water systems or plumbing in facilities providing water for human

consumption. See Appendix D: Summary of Lead Ban Provisions by State. At the time, "lead free” was

defined as solder and flux with no more than 0.2 percent lead and pipes with no more than 8 percent. In

2011, Congress passed the Reduction of Lead in Drinking Water Act (RLDWA) that amended Section 1417

of SDWA and updated the definition for “lead free” as a weighted average of not more than 0.25 percent

lead calculated across the wetted surfaces of a pipe, pipe fitting, plumbing fitting, and fixture and not

containing more than 0.2 percent lead for solder and flux. On September 1, 2020, EPA published the final

regulation “Use of Lead Free Pipes, Fittings, Fixtures, Solder, and Flux for Drinking Water” to make

conforming changes to existing regulations based on the RLDWA.

https://www.federalregister.gov/documents/2020/09/01/2020-16869/use-of-lead-free-pipes-fittings-

fixtures-solder-and-flux-for-drinking-water

Section 141.84(c) of the January 15, 2021 Lead and Copper Rule Revisions (LCRR) specifies the operating

procedures for replacing lead goosenecks, pigtails, or connectors. The LCRR is under revision and all rule

provisions except for the initial inventory requirements may be subject to change.

Guidance for Developing and Maintaining 1-1 August 2022

a Service Line Inventory

Chapter 1: Introduction

This introductory chapter provides:

• The benefits of a comprehensive and accurate service line inventory (Section 1.1);

• The purpose of the guidance and its intended audience (Section 1.2);

• An overview of the inventory and related requirements of the January 15, 2021 Lead and

Copper Rule Revisions (LCRR) and related requirements under the Lead and Copper Rule

(LCR) (Section 1.3); and

• A brief discussion of how the remainder of the guidance is organized (Section 1.4).

1.1 The Benefits of a Comprehensive and Accurate Inventory

Given the many benefits of LSLR,

EPA encourages water systems to

begin LSLR as soon as possible,

regardless of the stage of their

inventory development.

Service line inventories are the foundation from which

water systems take action to address a significant

source of lead in drinking water - lead service lines

(LSLs). Establishing an inventory of service line

materials and identifying the location of LSLs is a key

step in getting them replaced and protecting public

health. Lead service line replacement (LSLR) is not

dependent on knowing the location of all LSLs; in fact,

simultaneously developing an inventory while conducting LSLR can have many benefits. For

example, systems can save costs by replacing LSLs when crews find them onsite during service line

investigations. Systems can also leverage the opportunity for LSLR by seeking customer consent

and private property access during service line investigation. Replacing LSLs in a safe and prompt

manner while crews are in the field for inventory development provides an opportunity for public

health benefits for consumers by more quickly eliminating this potential source of lead exposure

from drinking water.

Congress recognized the importance of LSLR when it appropriated supplemental Drinking Water

State Revolving Fund (DWSRF) funding as part of the 2021 Bipartisan Infrastructure Law (BIL) (P.L.

117-58). The BIL contains a historic $15 billion in dedicated funding through the DWSRF for LSL

identification and replacement. This funding is being provided to states with no match

requirement. The BIL also provided $11.7 billion over five years to enhance DWSRF base funding.

EPA is collaborating with state DWSRF programs to share models, guidance, and build state

capacity to assist local communities and ensure LSL funding is effectively and equitably deployed

(USEPA, 2022). DWSRF BIL LSLR funding, DWSRF BIL General Supplemental funding, and base

appropriations for the DWSRF can all be used for LSL identification, such as service line material

classification and validation, and replacement. The new resources available under BIL, in

particular, provide a tremendous opportunity to make rapid progress on permanently removing a

significant source of lead in drinking water and achieving major improvements in public health.

Guidance for Developing and Maintaining 1-2 August 2022

a Service Line Inventory

For the DWSRF, 49 percent of the DWSRF funding must be provided to disadvantaged

communities. Other federal programs also have available funding available for LSLR and related

technical assistance.

A comprehensive and accurate inventory has many additional benefits beyond regulatory

compliance. Inventorying service line material permits notification to consumers about potential

lead risks affecting them, which can facilitate customer actions to reduce lead in drinking water,

including flushing, use of filters certified to reduce lead, and customer-initiated LSLR. Inventories

allow water systems to publicly track their progress on LSL identification and replacement,

engaging the community and enhancing transparency. Inventories can also help water systems

and consumers determine the source of high lead levels in drinking water at a home or building

and the possible solutions for reducing exposure. Water systems with inventory information can

also proactively mitigate lead exposure caused by disturbances of a lead or galvanized requiring

replacement (GRR) service line, for example, during street construction. Inventories can also make

LSLR programs more efficient. Even incomplete inventories may create cost-saving opportunities

for water systems by better targeting locations served by LSLs, stretching the value of internal or

external funding that water systems receive, such as from the BIL. In addition, service line

inventories can help inform decisions for other drinking water rules and could inform future needs

surveys and potential future costs.

1.2 Purpose and Audience

The purpose of this document is to guide water systems as they develop and maintain service line

inventories and to provide states with needed information for oversight and reporting to EPA. The

guidance contained in this document can also position water systems to begin replacing LSLs as

soon as possible. Locating LSLs is the first and critical step to replacing them; however, water

systems do not need to complete the entire inventory process before designing and implementing

their LSLR programs.

This guidance covers the lifecycle of the inventory, including inventory creation, material

investigations, system reporting, state review, public accessibility of service line information, and

service line consumer notification. In addition, the guidance provides best practices, case studies,

and templates related to topics such as the classification of unknowns, goosenecks, and

galvanized plumbing; best practices for service line material investigations; inventory form and

format; inventory accessibility; tools to support inventory development and data tracking; and

ways to prioritize service line investigations.

Additional information is available at https://www.epa.gov/ground-water-and-drinking-water/funding-lead-service-

line-replacement.

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a Service Line Inventory

The practices surrounding service line material inventories are rapidly evolving as water systems

create their inventories and improve them over time. Additionally, emerging research on service

line identification methods is ongoing. Given the potential for new, relevant information to

become available, EPA anticipates that future updates to the guidance are possible. In addition,

although EPA anticipates this guidance will be useful for water systems of all sizes, EPA intends to

develop an additional tailored guidance for small community water systems (CWSs) and non-

transient non-community water systems (NTNCWSs).

1.3 Overview of Regulatory Requirements and LCRR Review

Section 1.3.1 provides an overview of the initial inventory requirements specified in the January

15, 2021 LCRR. Section 1.3.2 provides information on EPA’s review of the LCRR and plans to

develop the Lead and Copper Rule Improvements (LCRI). Section 1.3.3 discusses inventory-related

regulatory requirements under the LCR.

1.3.1 Overview of the LCRR Inventory Requirements

EPA published the LCRR in the Federal Register on January 15, 2021 (USEPA, 2021c). It applies to

all CWSs and NTNCWSs. The initial inventory requirements of the LCRR specify:

• Information that water systems must include in their service line inventory,

• When water systems must submit their initial inventories to their primacy agency

• Requirements for water systems to make their information publicly accessible and to

notify all persons served by the water system at the service connection with a lead, GRR,

or lead status unknown service line, and

• Reporting requirements for states.

Exhibit 1-1 provides a summary of these requirements with the relevant LCRR citations and the

section(s) in this guidance with additional information. Note that Exhibit 1-1 includes only the

LCRR initial inventory requirements that EPA stated would be retained for the LCRI. The LCRR

contains additional requirements that may be subject to change under the LCRI and are therefore

not included in the exhibit below.

EPA delegates primacy, which is primary enforcement responsibility to implement SDWA’s Public Water System

Supervision Program, for public water systems to states, territories, and Indian tribes if they meet special

requirements. Throughout this guidance, the terms “state” or “states” are used to refer to all types of primacy

agencies including U.S. territories, Indian tribes, and EPA Regions.

Note that this guidance addresses inventory requirements of the LCRR

only. All LCRR requirements aside from the initial inventory are subject to

change under the LCRI. See Section 1.3.2 for discussion.

Guidance for Developing and Maintaining 1-4 August 2022

a Service Line Inventory

Exhibit 1-1: LCRR Inventory Requirements

Inventory Requirement 40 CFR Citation

Information

Provided in:

WATER SYSTEM REQUIREMENTS

Inventory Specifications

Material Classification: Classify each service line or portion of

the service line where ownership is split as lead, galvanized

requiring replacement, non-lead, or lead status unknown.

§141.84(a)(4) Section 2.1

All service lines and ownership: Prepare an inventory that

includes the system- and customer-owned portions of all

service lines in the system’s distribution system.

§141.84(a), (a)(2) Section 2.2

Information to Identify Material: Use previous materials

evaluation, construction and plumbing codes/records, water

system records, distribution system inspections and records,

information obtained through normal operations, and state-

specified information.

§141.84(a)(3),

(a)(5)

Sections 3.4 &

Chapter 4

Deadlines for Submission

Initial Inventory: Submit an initial inventory or demonstrate

the absence of LSLs by October 16, 2024.

§141.80(a)(3)

ction 1.3.2 &

Section 6.4

Updates to Primacy Agency: Submit updated inventories to

the primacy agencies annually or triennially based on lead tap

sampling frequency, but not more frequently than annually

Water systems that have demonstrated the absence of LSLs

by October 16, 2024 are not required to provide an update.

However, if these systems subsequently find any LSL or

galvanized requiring replacement service line, they have 30

days to notify the state and prepare an updated inventory on

a schedule established by the state.

§141.90(e)(3),

§141.90(e)(3)(ii)

ctions 6.3 & 6.6

Public Accessibility and Consumer Confidence Report

Public Accessibility: Make the inventory publicly available and

include a locational identifier for LSLs and galvanized

requiring replacement. Water systems serving more than

50,000 people must provide inventories online.

§141.84(a)(8)

Section 2.3 &

Chapter 7

Guidance for Developing and Maintaining 1-5 August 2022

a Service Line Inventory

Inventory Requirement

40 CFR Citation

Information

Provided in:

Consumer Confidence Report (applies to CWSs only):

• CWSs with LSLs: Indicate how the public can access

the service line inventory information.

• CWSs with only non-lead service lines: Provide a

statement there are no LSLs and how to access the

service line inventory (or a statement in lieu of the

publicly accessible inventory with a description of

methods used to make this determination in 40 CFR

§141.84(a)(9)).

§141.84(a)(9),

§141.153(d)(4)(xi)

Section 7.4

Service Line Consumer Notification

Provide notification to persons served by the water system at

the service connection with an LSL, GRR, or lead status

unknown service line. If the water system serves communities

with a large proportion of non-English speaking consumers, as

determined by the state, public education materials must be

in appropriate languages or contain a telephone number or

address where persons served may contact the water system

to obtain a translated copy of the materials or to request

assistance in the appropriate language.

Timing: Notification within 30 days after completing of initial

inventory and repeated annually until only non-lead remains.

For new customers, water systems must also provide this

notice at the time of service initiation.

Content: Statement about service line material, lead health

effects, and steps to minimize lead exposure in drinking

water. If:

• Confirmed LSL, must include opportunities to replace

the LSL, any available financing programs, and

statement that the system must replace its portion if

property owners notify the system they are replacing

their portion.

• GRR, must also include opportunities for service line

replacement.

• Lead status unknown, must also include opportunities

to verify the material of the service line.

Delivery: By mail or by another method approved by the

state.

Reporting to states: Demonstrate that the water system

delivered the notification and provide a copy of the

§141.85(a)(1)(ii),

§141.85(e) &

§141.90(f)(4)

Section 6.5

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Inventory Requirement

40 CFR Citation

Information

Provided in:

notification and information materials to their states annually

by July 1 for the previous calendar year.

STATE REPORTING

Reporting to EPA: For each water system, the number of lead,

galvanized requiring replacement, and lead status unknown

service lines in its distribution system, reported separately.

§142.15(c)(4)(iii)(D)

EPA will include

additional details in

the data entry

instructions

guidance for the

LCRR.

Special Primacy: The LCRR specifies special primacy

requirements for states to adopt in 40 CFR §142.16(d)(5) that

include: (1) providing or requiring the review of any resource,

information, or identification method for the development of

the initial inventory or inventory updates, and (2) requiring

water systems whose inventories contain only non-lead

service lines and the water system subsequently finds an LSL

to prepare an updated inventory on a schedule determined

by the state.

§142.16(d)(5)

Chapters 4 – 6

EPA plans to include

additional

information in a

separate state

implementation

guidance.

Notes:

On June 16, 2021, EPA published a rule to extend the compliance date from January 16, 2024 to October 16,

2024 (40 CFR §141.90(e)(1), USEPA, 2021d).

Note that this guidance uses the terms “system-owned” and “customer-owned” because they are

consistent with the LCRR language. EPA recognizes that states and systems may use other terms

to describe ownership status such as “public” and “private” or other terms besides “ownership” to

describe the division of responsibility between the water system and the customer. EPA

recommends water systems using different terminology to provide clear explanations of those

terms to the state and the public.

1.3.2 Outcome of EPA Review of the LCRR

On June 16, 2021, EPA published the agency's decision to delay the effective and compliance dates

of the LCRR, published on January 15, 2021. The effective date was extended from March 16, 2021

to December 16, 2021, while the compliance date was extended from January 16, 2024 to

October 16, 2024 to ensure drinking water systems and primacy states continued to have the full

States may have laws or regulations for initial service line inventories that are

more stringent than federal requirements. For the most accurate and up-to-date

requirements, systems should reach out to their state primacy agencies.

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three years provided by the Safe Drinking Water Act to take actions needed for regulatory

compliance. They delay allowed time for EPA to review the LCRR in accordance with Presidential

directives issued on January 20, 2021, to the heads of federal agencies to review certain

regulations and conduct important consultations with affected parties (USEPA, 2021d). The

agency's review included a series of virtual public engagements to hear directly from a diverse set

of stakeholders.

EPA published the outcome of its review on December 17, 2021. The review stated that EPA

actions to protect the public from lead in drinking water should consider the following priority

areas for improvements: replacing 100 percent of LSLs is an urgently needed action to protect all

Americans from the most significant source of lead in drinking water systems; equitably improving

public health protection for those who cannot afford to replace the customer-owned portions of

their LSLs; improving the methods to identify LSLs and trigger action in communities that are most

at risk of elevated drinking water lead levels; and exploring ways to reduce the complexity of the

regulations. In the notice, EPA explained it would also consider changes to other areas of the rule

to equitably improve health protections and improve implementation of the rule to ensure that it

prevents adverse health effects of lead to the extent feasible (USEPA, 2021a). This could include

changes to the requirements applicable to the inventory updates.

To achieve these policy objectives, EPA announced its decision to proceed with a proposed rule

that would revise the LCRR while allowing the January 2021 rule to take effect. Through the LCRI,

EPA stated that it does not expect to propose changes related to the initial service line inventory

requirements because continued progress to identify LSLs is integral to lead reduction efforts

regardless of potential revisions to the rule. The LCRR effective date is December 16, 2021, and

the compliance date is October 16, 2024. In the review notice, EPA also highlighted non-regulatory

actions that EPA and other federal agencies can take to reduce exposure to lead in drinking water.

1.3.3 Related Requirements under the LCR

As mentioned in the previous section, EPA reviewed the requirements in the LCRR and published

its intent to revise the rule with the exception of the initial inventory requirements (USEPA,

2021a). Thus, this document focuses on guidance related to the LCRR initial inventory

requirements, while also including general best practices applicable to the later stages of the

inventory lifecycle.

This section describes existing LCR requirements that rely on service line inventory information

and provides recommendations on how these requirements can be supported by initial inventory

efforts. Water systems must comply with the requirements of the LCR (40 CFR §§141.80-141.91 as

codified on July 1, 2020) between December 16, 2021 and October 16, 2024 (40 CFR

§141.80(a)(3)).

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Inventory-Related Requirements in the Event of Action Level Exceedance

Under the LCR (40 CFR §141.84(b)), systems subject to LSLR requirements

must replace annually

at least seven percent of the initial number of LSLs in their distribution system. The initial number

of LSLs is the number of lead lines in place at the time the replacement program begins. Water

systems must identify the initial number of LSLs in their distribution system under this

requirement. EPA recommends that systems use information gathered for the initial inventory

under the LCRR to help identify the required initial number of LSLs.

How the Inventory Relates to the Tap Monitoring Requirements

Required lead and copper tap monitoring under the LCR is based on a tiering system for

prioritizing sample sites (40 CFR § 141.86(a)). Single family homes with LSLs are in the highest tier

(i.e., Tier 1), meaning systems should prioritize these locations for lead and copper tap monitoring.

Systems may gather more information on the location of LSLs under their initial inventory efforts.

1.4 Document Organization

The remainder of this document is organized as follows:

• Chapter 2: Elements of the Inventory includes information that must be included in the

service line inventory to meet LCRR requirements as well as additional information EPA

recommends that water systems consider tracking in their inventory.

• Chapter 3: Inventory Planning includes approaches for developing an inventory,

considerations for choosing an inventory format, procedures for collecting information

during normal operation, and guidelines for developing partnerships with third parties.

• Chapter 4: Historical Records Review summarizes the rule requirements for reviewing

historical records and provides additional recommendations on how the various types of

historical records can be used and where to find them.

• Chapter 5: Service Line Investigation Methods summarizes and compares service line

identification methods, including visual inspection, water quality sampling, excavation,

statistical data analyses, and emerging methods.

• Chapter 6: Developing and Updating the Inventory provides recommendations for

classifying service line materials, planning for proactive investigations, submitting the

initial inventory, and inventory updates. It includes requirements and recommendations

specific to systems with no LSLs and provides guidance to states related to inventory

Under the LCR, systems that exceeded the lead action level of 15 µg/L based on their 90

percentile sample result

after installing corrosion control and/or source water treatment (whichever sampling occurred later) are required to

replace 7 percent of their LSLs annually until they no longer exceeded the lead action level for two consecutive

monitoring periods (40 CFR §141.84(a)).

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review and reporting. This chapter also contains requirements and recommendations for

notifying customers with LSLs, GRR, or unknown service lines.

• Chapter 7: Public Accessibility includes LCRR requirements for water systems to make

their inventory publicly accessible and provides suggestions for inventory content and

effective presentation, promoting public input, considerations for states, and Consumer

Confidence Report inventory-related requirements.

• Chapter 8: References provides a full list of references that were used in the

development of this document.

This guidance also includes key points to remember at the end of Chapters 1 through 7. In

addition, these chapters are supported by the following appendices:

• Appendix A provides blank forms from EPA’s Service Line Inventory Template, which is a

companion tool to help water systems and states comply with the LCRR service line

inventory requirements. The blank forms can be used for documenting inventory

methods and an inventory summary. The appendix also contains a blank form for the

state review checklist.

• Appendix B includes case studies for three water systems that have begun developing

their service line inventories.

• Appendix C includes example instructions on how customers can identify their service

line materials and example customer materials when the water system conducts the

material service line verification of the customer-owned portion.

• Appendix D provides a summary of 1986 SDWA lead ban provisions by state.

• Appendix E includes Michigan’s Minimum Service Line Verification Requirements.

• Appendix F includes examples of data quality disclaimers regarding the accuracy of the

inventory provided to the public.

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Key Points to Remember

LCRR Requirements

 All CWSs and NTNCWSs must develop an inventory of service lines that meets the LCRR

requirements, including service line materials classification, information sources, and

public accessibility (40 CFR § 141.84(a)).

 Water systems must submit their initial inventories to their state by October 16, 2024 (40

CFR § 141.84(a)(1)) and 141.90(e)(1)).

 All CWSs and NTNCWSs must notify all persons served by the water system at the service

connection with a lead, GRR, or lead status unknown service line within 30 days of

completing their service line inventory (40 CFR § 141.85(e)).

 All LCRR requirements other than the initial inventory requirements are subject to change

under the LCRI.

Recommendations (Not Required under the LCRR)

 Water systems should not wait until their inventories are complete to begin conducting

LSLR. Replacing LSLs while developing the inventory may create synergies or introduce

opportunities for cost-savings.

 This guidance covers the lifecycle of the inventory, including inventory creation, inventory

updates, material investigations, system reporting, state review, and public accessibility

of service line information. The inventory is based on the best available data and should

improve over time with updated information.

 States may have passed laws or regulations for a service line inventory that are more

stringent than the federal inventory requirements.

 For water systems, a comprehensive and accurate service line inventory will facilitate

LCRR compliance, improve LSLR program efficiency, provide greater public health

protection, potentially assist in obtaining external funds for inventory development and

LSLR, and provide potential cost savings.

 For states, a robust inventory will provide information for oversight and reporting.

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Chapter 2: Elements of the Inventory

This chapter contains the required elements of the service line inventory based on the January 15,

2021 Lead and Copper Rule Revisions (LCRR) (USEPA, 2021c) and is organized as follows:

• Section 2.1 presents requirements and recommendations for materials classification for

service lines and other related infrastructure,

• Section 2.2 presents requirements and recommendations for what to include in the

inventory,

• Section 2.3 includes a discussion of location identifiers for service lines, and

• Section 2.4 provides other suggested service line information for inclusion in the

inventory.

2.1 Inventory Materials Classifications

This section summarizes the required service line material classifications and presents additional

classifications and subclassifications for states and water systems to consider.

2.1.1 Required Service Line Inventory Material Classifications

Under the LCRR, the inventory must use one of the following four material classifications to describe

the entire service line, including separate material classifications for the water system-owned and

customer-owned portions of each service line where ownership is split:

• Lead

• Galvanized requiring replacement (GRR)

• Non-lead (or the actual material, such as copper or plastic)

• Lead status unknown service lines (or unknown)

Exhibit 2-1 provides the required criteria for assigning each of the four material classifications and

additional information that may be helpful to states and water systems.

This guidance document uses the term lead status unknown interchangeably with unknown.

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Exhibit 2-1: Required Inventory Materials Classifications

Material

Classification

Use This Classification If:

Lead

The service line is made of lead (40 CFR §141.84(a)(4)(i)).

Keep in Mind:

• The LCRR updates the definition of a lead service line (LSL) as “a portion of pipe that

is made of lead, which connects the water main to the building inlet” (40 CFR

§141.2).

• If the only lead pipe serving the building is a lead gooseneck, pigtail, or connector

the service line is not considered an LSL under the initial inventory requirements of

the LCRR. EPA recommends that the system track the material of all components

that potentially contain lead, including connectors.

Galvanized

Requiring

Replacement

(GRR)

The galvanized service line is or ever was at any time downstream of an LSL or is

currently downstream of a lead status unknown service line. If the water system is

unable to demonstrate that the galvanized service line was never downstream of an LSL,

it must presume there was an upstream LSL (40 CFR §141.84(a)(4)(ii)).

Keep in Mind:

• Galvanized service lines that are or ever were downstream from an LSL can adsorb

lead and contribute to lead in drinking water.

• An example of a GRR service line is when the customer-owned portion from the

meter to the building is galvanized, and the system-owned portion from the water

main to the meter was previously lead but has been replaced. The customer-owned

portion of the service line would be GRR.

• Under the initial inventory requirements of the LCRR, a galvanized service line that

was never downstream of an LSL but is downstream or previously downstream of a

lead gooseneck, pigtail, or connector is not considered GRR. However, systems

should check with their states if they have more stringent requirements.

Non-Lead

The service line is determined through an evidence-based record, method, or technique

that it is not lead or GRR (40 CFR §141.84(a)(4)(iii)).

Keep in Mind:

• If a system can demonstrate that a galvanized service line was never downstream of

an LSL, it may be classified as non-lead.

• The water system may classify the actual material of the service line (for example,

galvanized, plastic, or copper) as an alternative to classifying it as non-lead.

• The term “non-lead” refers to the service line material only and does not include

other potential lead sources present in solder, connectors, and other plumbing

materials.

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Material

Classification

Use This Classification If:

Lead Status

Unknown

The service line material is not known to be a lead, GRR, or non-LSL, such as where there

is no documented evidence supporting material classification (40 CFR §141.84(a)(4)(iv)).

Keep in Mind:

• Water systems have the option to use the terminology of unknown instead of lead

status unknown service line (40 CFR §141.84(a)(4)(iv)).

• Water systems may elect to provide more information regarding their unknown

lines as long as the inventory clearly distinguishes unknown service lines from those

where the material has been determined through records or inspections (40 CFR

§141.84(a)(4)(iv)).

Note:

A lead gooseneck,

pigtail, or connector is defined as “a short section of piping, typically not exceeding two

feet, which can be bent and used for connections between rigid service piping” (40 CFR §141.2).

Some states include lead connectors in their definition of an LSL. In these instances, the state requirements

are more stringent than the LCRR and water systems must follow these requirements.

Exhibit 2-2 is a diagram of a possible division in service line ownership (or responsibility) between

the customer and water utility in which the system-owned portion of the service line is from the

water main to the curb stop and the customer-owned portion is from the curb stop to the water

meter. For some systems, the delineation may be different, (e.g., the ownership or responsibility

distinction is at the water meter or property line). In other instances, the water system may share

ownership with customers, or the water system or customer may have sole ownership of the

service line. Note that ownership of the property on which the service line is located does not

always equate to ownership or responsibility of the service line.

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Exhibit 2-2: Example of Service Line Ownership Distinction between the Water System and

Customer

While the LCRR requires the inventory to categorize each service line or portions of the service

line where ownership is split, a single classification per service line is also needed to support

various LCRR requirements, such as lead service line replacement (LSLR), tap sampling, and risk

mitigation. Systems should follow these guidelines to comply with the LCRR requirements when

classifying the entire service line when ownership is split:

• Service line is lead if either portion is a lead service line (LSL) (40 CFR §141.84(a)(4)(i)).

• Service line is GRR if the downstream portion is galvanized and the upstream portion is

unknown or currently non-lead, but the system is unable to demonstrate that it was

never previously lead (40 CFR §141.84(a)(4)(ii)).

• Service line is lead status unknown if both portions are unknown, or one portion is non-

lead and one portion is unknown (40 CFR §141.84(a)(4)(iv)).

• Service line is non-lead only if both portions meet the definition of non-lead (40 CFR

§141.84(a)(4)(ii)).

EPA recognizes that some segments of the system- or customer-owned service lines could be

made of more than one material. EPA recommends that systems follow the guidelines above to

classify the system-owned or customer-owned portion in these cases. Exhibit 2-3 provides

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examples for classifying the entire service line for various system-owned and customer-owned

material combinations.

Exhibit 2-3: Classifying Service Line Materials When Ownership is Split According to the

LCRR 40 CFR §141.84(a)(4)

System-Owned Portion Customer-Owned Portion

Classification for Entire Service

Line

Lead Lead Lead

Lead

Galvanized Requiring

Replacement

Lead

Lead Non-lead Lead

Lead Lead Status Unknown Lead

Non-lead Lead Lead

Non-lead and never previously

lead

Non-lead, specifically galvanized

pipe material

Non-lead

Non-lead, material other than

galvanized

Non-lead

Non-lead Lead Status Unknown Lead Status Unknown

Non-lead, but system is unable to

demonstrate it was not previously

Lead

Galvanized Requiring

Replacement

Galvanized Requiring

Replacement

Lead Status Unknown Lead Lead

Lead Status Unknown

Galvanized Requiring

Replacement

Galvanized Requiring

Replacement

Lead Status Unknown Non-lead Lead Status Unknown

Lead Status Unknown Lead Status Unknown Lead Status Unknown

If the only lead pipe serving a building is a lead gooseneck, pigtail, or other connector (i.e., a non-

LSL attached to a lead connector), then the line should not be designated as an LSL in the initial

service line inventory required under the LCRR. The line may be required to be identified

separately by the state. In addition, as will be discussed in more detail in Section 2.1.3, EPA

recommends water systems identify the lines with only these components separately in their

inventory. Also note that service material classifications can change over time as the system

gathers more information and updates the inventory.

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2.1.2 Recommended Subclassifications and Additional Information (Not Required Under

LCRR)

Water systems may also consider going beyond the requirements of the LCRR by subclassifying

service line materials and tracking additional information. These subclassifications are discussed

below and can provide additional information not only to help facilitate material classification, but

also to inform the public about service lines in their homes and community.

Recommended Subclassifications

A Lead Status Unknown’s “LSL Likelihood.” Some water systems have incorporated additional

information that indicates the probable material of an unknown service line, such as an “LSL

Likelihood.” For example, Flint, Michigan, categorized unknowns as low likelihood of lead, medium

likelihood of lead, and high likelihood of lead (see their online map showing these

subclassifications

). Systems using predictive models may also assign numerical probabilities to

unknowns representing the probability they are LSLs.

Systems could rely on historical records described in Chapter 4, service line material investigations

described in Chapter 5, and the methodology described in Section 6.1 to determine various

subclassifications of unknown service lines. For example, if an individual service line material is

unknown but was installed when lead was not commonly used in the system based on interviews

with experienced system staff and plumbers, the system could consider subclassifying the service

line as “Unknown- Unlikely Lead” or a similar designation. If the system has confirmed service line

materials in a representative number of locations in a neighborhood to be lead, it could consider

subclassifying the remaining unknown service lines in the neighborhood as “Unknown- Likely

Lead” or a similar designation until its material can be investigated.

Although systems are not required to track this information or include it in their publicly

accessible inventories or submittals to the state, internally tracking this information could help

focus proactive inventory investigations and LSLR efforts. If subclassifications are made available

to the public, EPA recommends that water systems clearly communicate this information to the

public by providing easy-to-understand definitions for each subclassification and explaining how

the subclassifications were determined.

GRR Known or Unknown to have been Downstream of an LSL. EPA recommends that systems

that identify GRR service lines, as defined in Section 2.1.1, consider tracking and differentiating

these lines into subclassifications to indicate if: 1) the galvanized pipe is known to be currently

downstream of an LSL, 2) if the galvanized pipe was previously downstream of an LSL, or 3) the

system is unable to demonstrate that the galvanized service line was never downstream of an LSL.

This information could be used for many purposes, such as informing an LSLR prioritization

https://flintpipemap.org/map. Accessed December 8, 2021.

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approach or serving as an input for a predictive model. The system could also consider

subclassifying galvanized service lines that are or were downstream of a lead gooseneck, pigtail, or

connector.

Lead-lined Galvanized Pipes. EPA is aware of the existence of lead-lined galvanized service lines

but found limited information indicating their prevalence

. A lead-lined galvanized service line is

consistent with the definition of an LSL under the LCRR (“a portion of pipe that is made of lead,

which connects the water main to the building inlet”) (40 CFR §141.2) and must therefore be

classified in the inventory as an LSL. These lines would be subject to the same LCRR requirements

as other LSLs in the inventory, such as LSLR, public education, tap sample tiering, and risk

mitigation. Inventorying these types of lines will be more straightforward where water systems

have records of their known or likely use. Given that these pipes may appear to be non-lead on

the exterior, attempts to identify their material by visual observation or excavation may not reveal

an interior lead lining. EPA recommends that water systems consider any available information

that indicates where (if ever) lead-lined galvanized pipes were used in the system, along with

approaches such as service line sampling, to populate the inventory with these types of

connections.

Actual Material for Non-lead. The LCRR states that water systems may classify the actual material

of the service line (e.g., galvanized, plastic, or copper) as an alternative to classifying it as non-lead

(40 CFR §141.84(a)(4)(iii)). If states and systems wish to classify these lines as non-lead, EPA

encourages water systems to track the actual materials as additional information internally and/or

as part of the publicly accessible inventory. Including these classifications could improve system

asset management and better inform a statistical model, if used.

2.1.3 Recommendations for Other Drinking Water Infrastructure

EPA encourages water systems to include information on lead-containing infrastructure in their

inventories, including:

• Goosenecks, Pigtails, and Connectors: EPA encourages water systems to identify the

location and material of goosenecks and pigtails (connectors) and to include this

information in their inventories. This would allow water systems to track and manage this

potential source of lead, improve asset management, and increase transparency with

customers. This could also help water systems identify where lead connectors are or

were previously upstream of galvanized pipe and to manage this additional potential

source of lead in their system. As previously discussed, lead from an upstream source can

adsorb onto the galvanized pipe over time. The LCRR requires that when lead connectors

http://sedimentaryores.net/Pipe%20Scales/Fe%20scales/Galvanized_lead-lined.html. Accessed December 6, 2021.

Guidance for Developing and Maintaining 2-8 August 2022

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are encountered, they be removed or disconnected.

In addition, funding sources, such

as the Drinking Water State Revolving Fund (DWSRF), Bipartisan Infrastructure Law (BIL),

and Water Infrastructure Improvements for Nations Act (WIIN), can be used to pay for

lead connector removal and replacement.

Note that systems must follow any state requirements that are more stringent than the

LCRR for these materials. For example, Michigan includes lead connectors in their

definition of an LSL (Michigan EGLE, 2018). California requires water systems to include

in their inventory lead fittings on a non-lead pipe, lead fittings on a lead pipe, and

fittings of unknown material (ASDWA, 2019).

• Lead Solder: EPA recommends that water systems track the presence of lead solder in

the service line or premise plumbing, such as after encountering information indicating

their presence in records or if seen during system inspections or maintenance. Tracking

the presence of lead solder in the service line improves system asset management and

can inform future actions for reduction of lead sources in drinking water. In addition,

knowing locations with lead solder in premise plumbing can help identify tap monitoring

locations under the Lead and Copper Rule (LCR) and LCRR.

• Fittings and Equipment Connected to the Service Line: Devices such as curb stops and

meters may be made of older brass that pre-date the effective date for the Reduction of

Lead in Drinking Water Act (January 4, 2014). These devices may not meet the revised

lowered lead-free standard

and could contribute to lead exposure (Sandvig et al., 2008).

EPA recommends water systems consider tracking these devices if information is

available.

2.2 Include All Service Lines Regardless of Ownership Status and Intended Use

2.2.1 Required under the LCRR

All community water systems (CWSs) and non-transient non-community water systems

(NTNCWSs) must prepare an inventory of all service lines connected to the public water

distribution system, regardless of ownership status (40 CFR §141.84(a)(2)). This means that any

service line connected to the public water system, even where the water system owns no portion

of the service line, must be included in the inventory. In those instances where ownership is split,

the inventory must include both the system-owned and customer-owned portions of the service

line. Water systems must internally track address locations of each service line and their

The LCRR is under revision and all rule provisions except for the initial inventory requirements may be subject to

change.

In 2011, Congress passed the Reduction of Lead in Drinking Water Act that amended Section 1417 of the Safe

Drinking Water Act (SDWA) and established an updated definition for “lead free” as a weighted average of not more

than 0.25 percent lead calculated across the wetted surfaces of a pipe, pipe fitting, plumbing fitting, and fixture and

not containing more than 0.2 percent lead for solder and flux.

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respective material classification (40 CFR §141.84(a)). Where a single service line serves multiple

units in the same building, the water system may choose to exclude unit numbers from the

address. Note that unit numbers may be required to comply with other LCRR requirements, such

as the notification requirements of 40 CFR §141.84(d) and 40 CFR §141.85(e). Because LSLs were

generally not constructed with an interior diameter over two inches, they will typically be

connected to single family homes or buildings with a limited number of units.

Note that some CWSs and NTNCWSs may not have an extensive distribution system, such as those

with a direct connection from a well to a single building. Systems must report the material from

the well to the building inlet for their inventory. EPA intends to develop a separate guidance that

is tailored to small CWSs and NTNCWSs.

Systems must include all service lines (40 CFR 141.84(a)(2)), regardless of the actual or intended

use. These include, for example, service lines with non-potable applications such as fire

suppression or those designated for emergency. These service lines could be repurposed in the

future for a potable or non-emergency use. Water systems must include in their inventory service

lines connected to vacant or abandoned buildings, even if they are unoccupied and the water

service is turned off.

2.2.2 Recommendations (Not Required under the LCRR)

Documentation that Describes System and Customer Responsibility or Ownership

As a best practice, where service line ownership or responsibility is divided between the customer

and the system, water systems may want to include with their inventory relevant information that

describes how ownership or responsibility is divided. Examples could include local ordinances or

local water utility tariff agreements or state laws or regulations. This information may be helpful

to provide to customers who have questions about how the responsibility for the service line is

divided as well as the utility’s authority to access and maintain the portion of the service line that

is located on the customer’s property.

Recommended Procedures for Service Lines of Vacant or Abandoned Buildings

Water systems could have service lines that connect to vacant or abandoned homes or buildings

that must be included in their inventory even if they are unoccupied and the water service is

Remember: States and systems may use other terms to describe ownership status

such as “public” and “private” or other terms besides “ownership” to describe the

division of responsibility between the water system and the customer. Systems

should include clear definitions in their publicly accessible inventory.

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turned off. EPA recommends water systems have procedures in place for managing the service

lines for these structures. For example, water systems could consider:

• Prioritizing occupied homes for service material investigation or replacement to achieve a

greater lead exposure reduction from their overall program, provided that the water is

turned off at the vacant or unoccupied structure.

• Investigating these structures’ service lines if they are doing maintenance or construction

work in the area.

• Identifying service material before service is restored, or not reconnecting LSLs on

previously vacant homes or buildings (or new construction built after demolition).

• Using the transfer of property as an opportunity for service line identification or LSLR.

2.3 Location Identifiers

This section describes the LCRR requirements for providing location identifiers for LSLs and GRRs

in the publicly available inventory as well as suggested identifier information.

2.3.1 Required under the LCRR

Water systems must make a service line inventory publicly available (40 CFR §141.84(a)(8)) that

includes a location identifier for any lead or GRR service lines, such as a street address,

intersection, or landmark (40 CFR §141.84(a)(8)(i)). The LCRR does not require water systems to

make an inventory with the exact street addresses publicly available. Some local or state privacy

laws may prohibit the publication of address-level information. The water system has flexibility to

determine which location identifier best meets the needs of its own community. If the street

address is not used, systems must use a meaningful location identifier. The location identifier

could be, for example, a block, intersection, landmark, GPS coordinates, emergency 911 address

for systems in rural areas, or an alternate indicator (such as water meter location). Regardless of

which identifier the water system chooses, it must not be so overly broad (e.g., census tract or zip

code) that the public could not adequately track general LSL locations or where the system is

making progress in replacing LSLs.

2.3.2 Recommendations (Not Required under the LCRR)

Include a Location Identifier for All Service Line Materials. Water systems are not required to

make a location identifier for lead status unknown service lines or non-lead service lines publicly

available. However, EPA suggests, as a best practice, systems publish locations of all service lines

for the greatest transparency and relevant information for its customers.

Consider Publishing Street Addresses. Although EPA determined in the LCRR that a federal

requirement for a publicly accessible inventory that uses specific addresses is not necessary, EPA

encourages states and water systems to consider including specific addresses in their publicly

Guidance for Developing and Maintaining 2-11 August 2022

a Service Line Inventory

accessible inventory. Relevant factors states and water systems might consider include: underlying

data quality, transparency and consumer awareness, simplification of inventory development and

public communication, availability, impacts on replacement program participation, environmental

justice concerns, state or local privacy laws or constitutional protections, and potential property

value impacts (both positive and negative). EPA also suggests that systems that serve multiple

municipalities include the city or town with the street address.

Include Additional Location Descriptors When Multiple Service Lines Serve the Same Address.

Sometimes multiple service lines serve the same address (e.g., hospital or apartment building).

Water systems should consider adding additional descriptors that would allow each service line to

be uniquely identified.

2.4 Other Recommended Service Line Characteristics

EPA recommends that water systems consider tracking additional service line characteristics, such

as the information source(s) used to identify material for each service line, pipe diameter, and

installation date. These are not LCRR requirements, but tracking this information could benefit the

water system, as discussed below.

Source(s) of information for each service line. This includes recording the source(s) of information

used to identify the material of each service line. Refer to Chapter 4 and Chapter 5 for a

description of possible sources. Tracking this information is valuable for systems to assess their

confidence in the accuracy of an individual service line’s material classification, evaluate the

reliability of certain records or identification methods as a whole, and facilitate updates to the

inventory in the future. This information can also assist states in reviewing the inventory.

Pipe diameter. As explained in Chapters 4 and 6 of this guidance, pipe diameter can be an

important input to determining service material classification, considering that LSLs are often 2

inches or smaller in diameter. Tracking pipe diameter is important for asset management and can

be useful for other information collection efforts such as the Drinking Water Infrastructure Needs

Survey and Assessment (DWINSA). States may have their own requirements. For example,

Wisconsin requires material reporting to their public service commission by diameter.

Installation or replacement date. As detailed in Chapter 4 and Chapter 6, the date of service line

construction or replacement can be an important input in screening for potential LSLs. This

information should also be tracked for general asset management purposes. Where precise dates

are not available, the year (e.g., 1985) or estimated date range (1950-1960) of installation or

replacement can be provided.

See https://blogs.edf.org/health/2020/04/16/latest-wisconsin-data-on-water-service-lines-provides-important-

insights-reveals-over-150000-lead-pipes/.

Guidance for Developing and Maintaining 2-12 August 2022

a Service Line Inventory

Key Points to Remember

LCRR Requirements

 The inventory must include all service lines connected to the public water distribution

system regardless of intended use (40 CFR §141.84(a)(2)). Lead connectors, gooseneck,

and pigtails are not required to be included unless required by the state.

 The inventory must include information on both the system- and customer-owned

portions where ownership is split (40 CFR §141.84(a)(4)).

 Service lines must be classified as lead, GRR, non-lead (or the actual material), or lead

status unknown service lines (or unknown) (40 CFR §141.84(a)(4)).

 A classification of non-lead must be supported by evidence-based records, methods, or

techniques to prove it is not lead or GRR (40 CFR §141.84(a)(4)(iii)).

 The water system must create and maintain an inventory that includes the exact address

associated with each service line connected to the public water system. (40 CFR

§141.84(a)).

 An inventory of lead and GRR service lines must be made publicly available, but the LCRR

does not require the publicly available inventory to include the specific address of each

lead and GRR service line. Systems may use a location identifier for any lead and GRR

service lines (40 CFR §141.84(a)(8)(ii)).

Recommendations (Not Required under the LCRR)

 EPA encourages water systems to consider including street addresses, when available, as

their location identifier for all service lines in its public-facing inventory. Identifiers should

be significantly detailed to allow the identification of a specific service line.

 EPA encourages water systems to expand their inventories to include service line

subclassifications, other plumbing components such as lead connectors, and other details

such as source of information, pipe diameter, and installation date.

Guidance for Developing and Maintaining 3-1 August 2022

a Service Line Inventory

Chapter 3: Inventory Planning

This chapter addresses planning steps that systems should consider when developing their

inventory. This information is intended to be helpful for all systems, regardless of where they are

in their inventory process. The chapter is organized as follows:

• Section 3.1 provides an introduction to the inventory development process,

• Section 3.2 includes considerations when identifying staff and resources needed for

inventory development,

• Section 3.3 includes options and considerations for water systems in the selection of an

inventory format,

• Section 3.4 provides recommendations for developing procedures for the collection of

service line information, and

• Section 3.5 suggests partnering with third parties for assistance in obtaining information

on service line materials.

3.1 Inventory Development Approach

As stated in Chapter 1, this guidance covers the lifecycle of the inventory, including inventory

creation, material investigations, system reporting, state review, and public accessibility of service

line information. As noted previously, water systems should not wait to replace lead service lines

(LSLs) until they have identified the materials of all service lines. In fact, verification of service line

materials during lead service line replacement (LSLR) could be part of a water system’s strategy to

continuously improve its inventory over time. Exhibit 3-1 provides a schematic of this inventory

lifecycle.

Guidance for Developing and Maintaining 3-2 August 2022

a Service Line Inventory

Exhibit 3-1: Inventory Lifecycle

Other best practice approaches for developing an inventory are available in the literature (Liggett

et al., 2022; LSLR Collaborative, 2021; Hensley et al., 2021). No matter the specific approach and

steps used, water systems should treat the inventory as a living dataset that is continuously

improved over time as the inventory is updated. The number of unknowns in the inventory should

decrease as systems gather new information through normal operation and any proactive

material identification activities in which the water system is engaged. The water system should

also gain confidence over time in the accuracy of the inventory as records or material

identification methods are assessed. As a reminder, water systems should review state regulations

and follow required steps that are more stringent than the Lead and Copper Rule Revisions (LCRR)

when developing the initial inventory.

3.2 Identifying Staff and Resources

The level of effort needed to prepare an initial inventory is highly dependent on the size of the

system, the availability of historical records, the format and condition of those records, LSL

investigation methods chosen by the water system, and methods required and/or approved by

the state (Liggett, 2021; Hensley et al., 2021; Liggett et al., 2022).

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a Service Line Inventory

When records are in paper format, large systems have hired temporary staff (e.g., interns) to

digitize the data. Liggett et al. (2022) notes that “staff requirements ranged from 2-3 full time

employees working 6 days a week for 2 months to several employees working continuously from

the start of their lead reduction program” based on a survey of 10 large water systems serving

approximately 100,000 to 1.5 million people. All surveyed systems indicated that a significant

allotment of staff was needed for at least an initial period. Where customers were engaged in the

inventory process, water systems staff were needed to assist customers, gather information from

customers, and in some cases verify the information (Liggett et al., 2022).

Interviews with experienced system staff and plumbers can be used to focus the inventory effort

and verify utility practices (LSLR Collaborative, 2021; Bukhari et al., 2020). Experienced staff may

also know where relevant historical records are located. Classifications of service line materials

based on interviews, however, should not be used as a sole source of information for the initial

inventory. Systems may also consider interviewing their neighboring water systems to inquire

about regional practices (California Water Board, 2020).

3.3 Selecting an Inventory Format

EPA does not require a specific format for the service line inventory. In some states currently

requiring submission of inventory information, systems have submitted spreadsheets, geospatial

maps, lists, and handwritten notations. ASDWA (2022) notes that states that have required

inventory information prefer an electronic submittal over paper or PDF submissions that only

provide “a snapshot in time.” The subsections below discuss lists, spreadsheets, databases, and

maps. Systems should check with their states for any specific requirements.

When water systems consider the inventory format, they should consider that the service line

inventory will change over time as new information is added, records evaluations and

investigations are conducted, and LSLs are replaced. The format should be flexible enough to

accommodate updates, be easily transmittable to the state, include location identifiers, and be in

a format that can be made publicly accessible. Water systems should also consider whether a

format will be easy-to-use and understand for consumers, community-based organizations, and

other organizations that may be interested in using this information, for example to identify

whether a consumer is served by an LSL, support community outreach, or develop additional

research or data tools for consumers.

Systems may also wish to internally track additional information that is not required but is

recommended as best practices in Chapter 2. For central internal data tracking of required and

additional inventory elements, EPA recommends that systems consider how they will use their

internal data system to generate regulatory state submittals and the publicly accessible inventory.

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a Service Line Inventory

3.3.1 List, Spreadsheet, or Database

Systems may be able to create a simple list of all addresses with a service line material designation

for each. While a location identifier is sufficient for a publicly accessible inventory, some states

may require systems to include the source of information used to classify each line to ensure the

requirements in 40 CFR §141.84(a)(3) are met. See Section 2.4 for other recommended inventory

elements to include.

Electronic spreadsheets and databases have an added advantage over lists for tracking additional

information fields. Spreadsheets and databases can be organized in a way that information can be

searched, filtered, sorted, and updated. They can be configured to include photos of service line

material. The ability to store and communicate a large amount of information in one central

location makes electronic spreadsheets and databases a useful inventory method, particularly for

systems with large numbers of LSLs. General recommendations for preparing a spreadsheet

inventory from a white paper by the Association of State Drinking Water Administrators (ASDWA)

and BlueConduit (2020) include the following:

• Each home/service line is a row in the spreadsheet.

• Each column refers to different data points available for each service line (e.g., address,

installation date, service line materials classification, and source of information).

• System-owned and customer-owned portions, if applicable, are tracked separately.

• Information regarding goosenecks, pigtails, and connectors is tracked separately.

• Labeling is consistent across the data, and the spreadsheet has a data dictionary to

define the column headers.

• Previous information is not lost when new information is found, which will help the utility

evaluate the accuracy of historical records.

EPA developed a spreadsheet template that systems may consider using to organize their

inventory. The template contains color-coded worksheets for documenting system information,

inventory methods, and how the system is making the inventory publicly accessible. The template

also includes a detailed worksheet that systems can use to track the materials and other relevant

information for each individual service line. This detailed inventory worksheet is designed for

users to enter information on one service line, including the system-owned and customer-owned

portions where ownership is split, in a single row. It includes columns for required and

recommended elements and dropdown menus for some columns to expedite data entry and

analysis. The detailed inventory worksheet is customizable; systems can add or delete columns to

fit their needs.

A description of each inventory template worksheet is provided in Exhibit 3-2. Some cells in the

spreadsheet are linked, (i.e., the system’s name and Public Water System Identification Number

(PWSID) entered on the public water system (PWS) information sheet carry over to the heading of

Guidance for Developing and Maintaining 3-5 August 2022

a Service Line Inventory

the other worksheets). The inventory summary includes a formula that will auto-calculate the

total numbers of each of the four service line materials classifications based on the detailed

inventory. In addition to the electronic version, fillable forms for several worksheets (PWS

information, Inventory Methods, Inventory Summary, Public Accessibility Documentation, and

State Checklist) are in Appendix A. The detailed inventory template is available electronically at

https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule. Water

systems can save a copy of the template to their network or computer and submit the entire file

to their state.

Exhibit 3-2: Organization of EPA Inventory Template

Source: EPA Inventory Template (https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-

copper-rule).

Other spreadsheet templates are available for download. For example, ASDWA’s website

(https://www.asdwa.org/lead-and-copper-rule-lcr/) provides a link to their separate inventory

Worksheet Type Worksheet Name Description

Template

Instructions_System

Contains detailed instructions for systems.

Template

Instructions_States

Contains detailed instructions for states.

Classifying SLs

Summarizes requirements for classifying the entire service line when

ownership is split (i.e

. , when the system owns a portion and the

customer owns a portion).

PWS Information

For systems to document basic system information.

Inventory Methods

For systems to document the methods and resources they used to

develop and update their inventory.

Inventory Summary

For systems to provide a summary of their service line inventory,

including information on ownership, inventory format, and the number

of se

rvice lines for each of the four required materials classifications.

Systems can enter the totals into this worksheet or automatically

generate totals based on information in the Detailed Inventory

worksheet.

Detailed Inventory

Provides a customizable format water systems can use to track materials

for each service line in their distribution system. Each row equals one

rvice line connecting the water main to the customer's plumbing.

Separate columns track location information, the system-owned portion,

the customer-owned portion, other possible sources of lead,

information for assigning a tap sample tiering classification, and

information for lead service line replacement (LSLR). Systems can

customize the worksheet by adding or deleting columns.

Public Accessibility Doc.

For systems to provide documentation to states on how they met the

public accessibility requirements of the LCRR.

Templates for States State Checklist

Provides a checklist that states can use to determine and document if

water systems met all of the January 15, 2021 LCRR requirements for

the

ir Initial Inventory including timely submission, required elements,

use of information sources, public accessibility, and public notification of

service line materials.

Templates for Water Systems

Background

Guidance for Developing and Maintaining 3-6 August 2022

a Service Line Inventory

template spreadsheets for community water systems (CWSs) and non-transient non-community

water systems (NTNCWSs). Another example is the template developed by Kansas Department of

Environmental Health.

In addition to the information needed to track material classifications

including GRR for system- and customer-side portions of the service line, their template includes

columns for additional elements. For example, it includes water main material, connector material

and replacement, installation dates, sources of information used for service line identification, and

other data needed to assign a lead tap sampling tier to the service line. In addition, Kansas’

template includes color-coded instructions to highlight cells in which data must be typed and

columns containing drop-down menus or auto-calculation. Systems should check with their states

to determine if they have developed an electronic template that they should or must use to

organize and/or report their detailed inventory.

3.3.2 Maps

Many water systems have developed simple or interactive web-based maps to present their

service line inventory, share information with the public, and inform their LSLR program. These

maps provide systems with an easily updatable platform for storing inventory data while also

having the ability to instantaneously share that data in an intuitive, easy-to-use format with

anyone with internet access. Moreover, geospatial databases supporting online maps can store

attribute information. For example, systems with high-level mapping capabilities can link image

files of historical tap cards with LSL locations (Liggett, 2021). Additional benefits of mapping may

include the ability to more easily plan LSLRs along with planned capital improvement projects or

to identify LSLR priority locations using existing environmental justice map tools (such as EPA’s

EJSCREEN

) along with a system’s map. Also, maps can be augmented over time to include

additional information, such as important infrastructure (e.g., water mains and water towers), to

improve a system’s asset management. See Section 7.2.2 for additional information on web-based

map applications, including best practices from recent publications by Hiltner et al. (2019) and

Woods and Webb (2021).

Two examples of water system maps are DC Water and Greater Cincinnati Water Works, which

are described in Appendix B. Note that these maps were developed prior to the LCRR and do not

include GRR. EPA recommends that water systems maps also include a color scheme for GRR.

3.4 Develop Procedures for Collecting Service Line Information

Under the LCRR, systems must identify and track information on service line material as they are

encountered in the course of normal operations (40 CFR §141.84(a)(5)). This information could be

based on visual inspection – see Section 5.1 for guidance on visually identifying service line

material.

The template is available at https://www.kdhe.ks.gov/547/Lead-Copper-Rule.

https://www.epa.gov/ejscreen.

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a Service Line Inventory

Information collection by water system staff and contractors, who typically have relevant

experience and/or training regarding lead in drinking water, enhances quality control of the

information they collect (LSLR Collaborative, 2021). Opportunities for data collection under

normal operation include but are not limited to:

• Water meter reading

• Water meter repair or replacement (see picture of an

excavated meter with service line material exposed)

• Service line repair or replacement

• Water main repair or replacement

• Backflow prevention inspections

• Other street repair or capital projects with open cut

excavations

Inventory activities should be considered as something that can be

worked into the day-to-day activities of the system rather than treated as

an independent effort. Systems should consider developing standard

operating procedures (SOPs) or modifying existing SOPs to document how

their staff and contractors will collect this information and use it to

update their inventory. SOPs can help ensure that a consistent method

of tracking, updating, and reporting is used for staff and contractors of

all experience levels. Written SOPs can also provide a way for water systems to document how

they met the requirement to collect information during normal operations. SOPs can be brief, but

the key is to disseminate them to appropriate staff and contractors, use them to conduct training,

and ensure that they are incorporated into normal operations. Water systems should consider

incorporating quality assurance reviews into their SOPs and procedures that ensure accountability

before a project is completed.

One way to facilitate information

collection and inventory updates is the

use of electronic field capture records.

Water systems should consider

developing procedures for customer

service representatives and other staff or

contractors that have interactions with

customers. Any one-on-one interaction is

an opportunity to educate customers

about the importance of the service line inventory and to obtain permission for water system

personnel to access the home for service line material investigation, or an interaction can be used

to provide information to the customer on how to self-identify the material for their portion of the

Example of Meter Pit

Source LSLR Collaborative 2018

Example of Meter Pit

Source: LSLR Collaborative 2018

Example: Custom app for information collection

The Pittsburgh Water and Sewer Authority

(PWSA) developed specific service line and meter

replacement work orders in the tablet-based

application used by utility workers and plumbers,

allowing them to update service line material

observations and record information on

replacements in the field.

Guidance for Developing and Maintaining 3-8 August 2022

a Service Line Inventory

service line and submit it to the system. See Section 5.1.1 for additional guidance on customer

self-identification and Appendix C for examples of customer service line material instructions from

water systems.

3.5 Establish Partnerships with Third Parties

EPA encourages water systems to reach out and partner with plumbers, plumber trade

organizations, local plumber union organizations, and other third parties to obtain as much

information as possible on service line materials and coordinate LSLR where possible. There are

many potential third parties that could be included, such as homeowner associations, community-

based organizations, building agencies, building inspectors, social services, landlords or realtors,

public health departments, departments of education, universities, Tribal Consortia, religious

organizations, and technical assistance providers.

There are different ways that third parties can help systems obtain this information:

• The third party may be able to determine service line material as part of their normal

field procedures (e.g., plumbing modifications, building inspections, etc.).

• The third party may be able to facilitate outreach and engagement with specific

communities, encouraging residents to conduct self-identification of service line and

plumbing materials and to report this information to the water system.

Coordination and training should take place early in the process to ensure third parties are aware

of the purpose, schedule, and procedures for the inventory and the importance of notifying the

water system with any information on service line materials.

Real world examples of successful partnerships include:

• The Pittsburgh Water and Sewer Authority (PWSA), Pennsylvania, partners with their

local health department to obtain information during plumbing inspections. PWSA works

with their local health department to add service line inspection and reporting to

plumbing inspection forms. PWSA automatically receives information by email whenever

a plumbing inspection report contains customer-side service line information (Duffy and

Pickering, 2021). See the PWSA case study in Appendix B for more information.

• Denver Water, Colorado, partners with community organizations to remove barriers.

Denver Water’s Ambassador Program focuses on developing partnerships with trusted

community organizations to help eliminate possible barriers that could prevent

communities from understanding and participating in their Lead Reduction Program. The

Ambassadorship Program works in a neighborhood-by-neighborhood basis to share

information about the Lead Reduction Program in multiple languages, so everyone

receives the same information and resources, regardless of their background. One goal of

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a Service Line Inventory

this program is to encourage homeowners to confirm if they have an LSL and to sign a

consent form allowing Denver Water to replace it at no direct charge to customers.

• The City of Newark, New Jersey, partnered with Clean Water Action, local residents, and

retired utility workers as volunteers and trusted messengers to talk to residents. The City

of Newark used door hangers and lawn signs to reach renters, who make up

approximately 74 percent of residents. An interactive website was key to providing

information to customers regarding their service line material (LSLR Collaborative, 2020).

• Grand Rapids Water System (GRWS), Michigan, partners with rental property owners. In

Grand Rapids, many LSLs serve rental properties. Because only property owners can sign

the agreements for LSLR in Grand Rapids, GRWS met with rental property owner

associations to encourage participation in their LSLR program. The water system met well

in advance of scheduled replacements to present information about the LSLR program

and answer questions that property owners might have (USEPA, 2021e).

Real estate transactions may also provide additional opportunities for educating residents,

engaging them to identify service line material, and ultimately facilitate LSLR. McCormick et al.

(2017) noted that four states (Connecticut, Delaware, New York, and Pennsylvania) required

mandatory disclosure of lead pipes or fixtures. Six additional states (Illinois, Michigan, New

Mexico, North Carolina, South Carolina, and Wisconsin) and the District of Columbia required

mandatory disclosure of pipe material; however, lead was either not specifically addressed or was

only included if the seller identified conditions as unsafe (McCormick et al., 2017). Lu et al. (2019)

found that when homebuyers have access to a seller’s disclosure, indicating the presence of an

LSL, the sellers were willing to negotiate to replace it or provide compensation for the

replacement cost. Water systems can work with real-estate agents and home inspectors to

support disclosures of identified service line materials (ideally through an online inventory) and

provide procedures for customer service line self-identification or verification by trained

personnel. See Chapter 7 for recommendations related to inventory accessibility and Section 5.1.1

and Appendix C for customer self-identification guidance.

(https://www.denverwater.org/your-water/water-quality/lead/events-outreach). Accessed November 2, 2021.

Guidance for Developing and Maintaining 3-10 August 2022

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Key Points to Remember

LCRR Requirements

 Systems must identify and track information on service line material as they are

encountered in the course of normal operations (40 CFR §141.84(a)(5)).

Recommendations (Not Required under the LCRR)

 EPA recommends systems consider a continuous improvement approach for

inventory development.

 The inventory is a living dataset that is continually improved over time with new

and better information including when LSLs are replaced.

 Interviews with experienced staff and plumbers can help focus the inventory effort

and locate system records.

 Water systems should consider interviewing neighboring water systems about

regional construction practices.

 Systems can use a variety of formats for the inventory; however, an electronic

format is recommended over paper or PDF formats.

 Water systems should consider developing or modifying SOPs to document how

they will collect service line information during normal operations and update their

inventories.

 Inventory activities should be considered as something that can be worked into the

day-to-day activities of the system rather than treated as an independent effort.

 EPA encourages water systems to partner with plumbers and other third parties to

obtain information on service line materials.

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Chapter 4: Historical Records Review

The Lead and Copper Rule Revisions (LCRR) specifies the types of historical records that water

systems must review to develop their initial service line inventory. Sections 4.1 through 4.4 provide

guidance on how the required types of historical records can be used and where to find them.

EPA recognizes that service line configuration and existing records may vary widely. For example,

water systems will have different numbers of lead service lines (LSLs) and unknowns, varying

ownership delineations, and access to historical records of varying accuracy. In addition, systems will

have different avenues of information gathering and priorities that are tailored to their specific

community.

Systems should document the records they reviewed as a best practice. Templates are available in

an electronic form, “Inventory Methods” from EPA’s template available at EPA’s website,

https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule or the hard

copy form in Appendix A to document each type of record reviewed and when it was reviewed.

Systems should also consider tracking and including the records used to identify the material of

each portion of the service line (e.g., plumbing code or water system record) in their inventory.

Water systems should continue to gather information on service line materials after they have

been classified and assess the accuracy of historical records. As the Association of State Drinking

Water Administrators (ASDWA) states in their white paper about using data science for inventory

development (ASDWA, 2019), “the process of learning just how accurate (or otherwise) a system’s

records are is a powerfully informative piece of this data-driven approach.” ASDWA points out

that some types of records will be more accurate than others, given each community’s unique

historical development patterns. For example, more recent records resulting from confirmation

during road construction may be more reliable than decades-old tap cards. EPA recommends

evaluation of the accuracy of historical records and that, if a specific record source proves to be

inaccurate, systems consider reclassifying service line materials that rely solely on that record

source as “unknown” until additional information can be gathered.

Exhibit 4-1 lists required records systems must use to identify service line materials for the initial

inventory under the LCRR (40 CFR §141.84(a)(3)). The last column of the exhibit includes how the

records can be used to develop the initial inventory.

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a Service Line Inventory

Exhibit 4-1: Requirements for Historical Records Review for Initial Inventory Development

under the LCRR

Type of Historical

Records

Regulatory Requirement

(citation)

Primary Uses for Inventory

Development

(Including but not limited to)

Previous Materials

Evaluation

Water systems must use the information on

lead and galvanized iron or steel that it

identified under 40 CFR § 141.42(d)

when

conducting the inventory of service lines in its

distribution system for the initial inventory (40

CFR §141.84(a)(3)).

• Reporting construction

materials present in their

distribution systems.

• Identifying LSL material for

subset of sites that were used

for lead and copper tap

monitoring.

Construction and

Plumbing Codes

and Records

Systems must review all construction and

plumbing codes, permits, and existing records

or other documentation which indicates the

service line materials used to connect

structures to the distribution system to

identify service line materials for the initial

inventory (40 CFR §141.84(a)(3)(i)).

• Identify when LSLs were

allowed/specified or banned

from use.

• Identify service areas most likely

to have LSLs by home/building

construction date and service

line size.

• Review construction and

plumbing permits for

identification of service line

(customer and/or system-

owned) and plumbing materials.

Water System

Records

Systems must review all water system records,

including distribution system maps and

drawings, historical records on each service

connection, meter installation records,

historical capital improvement or master

plans, and standard operating procedures, to

identify service line materials for the initial

inventory (40 CFR §141.84(a)(3)(ii)).

• Identify service line material for

system-owned and customer-

owned sides.

Distribution

System

Inspections and

Records

Systems must review all inspections and

records of the distribution system that

indicate material composition of the service

connections that connect a structure to the

distribution system to identify service line

materials for the initial inventory (40 CFR

§141.84(a)(3)(iii)).

• Identify service line material for

system- and customer-owned

portions.

• Verify construction and water

system records.

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Type of Historical

Records

Regulatory Requirement

(citation)

Primary Uses for Inventory

Development

(Including but not limited to)

State

Requirements

Systems must review any resource,

information, or identification method

provided or required by the state to assess

service line materials, to identify service line

materials for the initial inventory (40 CFR

§141.84(a)(3)(iv)).

• Identify service line material for

system- and customer-owned

portions.

Note:

Under 40 CFR §141.42, water systems were required to identify and report to their state if certain

construction materials were present in their distribution system in the early 1980s (USEPA, 1980). Under the

1991 Lead and Copper Rule (USEPA, 1991a), water systems were required to use this evaluation to identify a

pool of targeted sampling sites that meet the tiering criteria for lead and copper tap monitoring and was

sufficiently large enough to meet the required number of lead and copper tap samples.

4.1 Previous Materials Evaluation

Under 40 CFR §141.42(d), or special monitoring for corrosivity characteristics, water systems were

required to identify if certain construction materials were present in their distribution system that

included:

• Lead from piping, solder, caulking, interior lining of distribution mains, alloys, and home

plumbing;

• Copper from piping and alloys, service lines, and home plumbing;

• Galvanized piping, service lines, and home plumbing;

• Ferrous piping materials such as cast iron and steel; and

• Asbestos cement pipe.

In addition, there may be additional state requirements for the identification and reporting of

other materials. EPA requires systems to use the information they identified on lead and

galvanized iron or steel under 40 CFR §141.42(d) when preparing their initial inventory.

In addition to the previous materials evaluation described above, other previous material

evaluations can be useful in developing the inventory. Under the 1991 Lead and Copper Rule (LCR)

(USEPA, 1991a), water systems were required to complete a materials evaluation of their

distribution systems to identify a pool of targeted sampling sites that met the sample site

requirements and was sufficiently large to meet the required number of lead and copper tap

samples (40 CFR §141.86(a) of the LCR). The LCR also required in 40 CFR §141.86(b) that water

systems review:

• Information collected under the pre-LCR materials evaluation under 40 CFR §141.42(d);

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• All plumbing codes, permits, and records in the files of the building department(s) that

document the plumbing materials installed within publicly- and privately-owned

structures connected to the distribution system;

• All inspections and records of the distribution system that indicate the material

composition of the service connections that connect a structure to the distribution

system; and

• All existing water quality information that includes the results of all prior analyses of the

system or individual structures connected to the system, indicating locations that may be

particularly susceptible to high lead or copper concentrations.

Also under the LCR, systems subject to lead service line replacement (LSLR) requirements

were

required to identify the initial number of LSLs in their distribution system, including the portion(s)

owned by the system, based on the prior materials evaluations (40 CFR §141.84(b)).

In addition to previous materials evaluations described above, EPA recognizes that systems may

have previously reviewed historical records proactively for asset management, pre-LCRR inventory

efforts, and LSLR activities. It is important to note that records already reviewed for service line

material information need not be reviewed again. EPA recommends that water systems document

previous reviews as part of their initial inventory effort, including the date and scope of the

reviews.

4.2 Construction and Plumbing Codes and Records

Systems must review all construction and plumbing codes, permits, and existing records or other

documentation that indicate the service line materials used to connect structures to the

distribution system (40 CFR §141.84(a)(3)(i)). Each of these record types is described below.

Construction and Plumbing Codes

Municipal construction codes (also known as “building codes”) and plumbing codes may indicate

when the use of lead or lead-containing pipes for potable use applications were prohibited by the

code. This information, combined with distribution system and building records, can identify

structures that were built after lead bans became effective and would not have LSLs.

The 1986 Safe Drinking Water Act (SDWA) amendments prohibited the use of pipe, solder, and

flux that were not “lead free” as defined in 1986 in new installations and repairs

and directed

Refer to footnote 3.

In 1986, Congress amended the Safe Drinking Water Act (SDWA) to prohibit the use of pipes, solder, or flux that

were not “lead free” in the installation or repair of public water systems or plumbing in residential and non-residential

facilities providing water for human consumption. At the time, "lead free” was defined as solder and flux with no

more than 0.2 percent lead and pipes with no more than 8 percent. This is often referred to as the 1986 SDWA lead

ban.

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states, as a condition of receiving grants for the Public Water System Supervision program, to

enforce the provision effective 24 months after June 19, 1986, through state or local plumbing

codes or other means (42 U.S. Code §300g-6(b)). Some states adopted their own laws before the

federal requirement. Thus, water systems should check with their state to determine the

appropriate date. See Appendix D for a summary of lead ban provisions by state (USEPA, 1991b).

In addition to information on when LSLs were allowed

and banned, municipal construction and plumbing

codes can also indicate a maximum diameter of LSLs.

Most LSLs are 2 inches or less in diameter and serve

primarily single-family homes or small multi-family

residences. Larger apartment complexes and

commercial and industrial building are typically served

by larger diameter service lines. There have been very

few cases of installed LSLs as large as 3 inches (LSLR

Collaborative, 2021). The service line material

verification requirements in Michigan exclude service

lines that are 4 inches or more in diameter (Michigan EGLE, 2018).

Systems should also review any local ordinances relevant to LSLs. For example, systems may be

aware of an ordinance which prohibits reburial of exposed lead pipe in their community. Water

systems could compare the ordinance effective date with records of construction projects subject

to the ordinance requirements to determine if service line material can be inferred.

Possible locations for construction and plumbing codes include (Liggett, 2021; LSLR Collaborative,

2021):

• Municipal building permit/code enforcement department

• Agency overseeing state plumbing code

• Local governing body (e.g., city or town council)

Other possible locations include city archives, which are often in city public libraries. Additionally,

online databases have many historical city codes and reports available online.

States and municipalities often adopt into state or local law national or international building or

plumbing codes written by trade organizations. The codes may be adopted into law as written or,

they may be modified. In addition to checking with the state on the date they enforced the 1986

lead ban as recommended above, systems may also check with their state or local government for

any additional requirements related to adoption of codes. Exhibit 4-2 provides examples of

municipal code language and its meaning from Hensley et al., 2021.

Most Lead Service Lines are Old!

LSLs were primarily installed from

the late 1800s to the 1940s

(Hensley et al., 2021). Some

communities, however, continued

to install them through the 1980s

until they were banned at the

federal level.

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Exhibit 4-2: Illustrative excerpts from municipal codes, specifying that lead was allowed or

required as pipe material for service lines

Source: Hensley et al., 2021.

Permits

Water system, local government, or local plumbing codes may require plumbers to obtain permits

to install or replace service lines. These permits should include the location and the date of

installation or replacement and may include information on service line materials. In addition,

there may be an inspection record that accompanies the permit.

If permits do not specify service line material, systems may be able to cross-reference the permit

with construction practices at the time of replacement. Systems may be able to find these permits

at their municipal building department, code enforcement department, or municipal water system

(LSLR Collaborative, 2021).

Other relevant permits may include those for general renovation or other plumbing-related

building activities. Many jurisdictions require permits and inspections when plumbing is modified

for remodeling for renovations or additions.

Other Existing Records and Documentation

In addition to construction and plumbing codes and permits, other records may exist that indicate

the service line materials used to connect structures to the distribution system. For example,

municipal tax records typically contain the date of building construction, which when cross-

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referenced with construction practice information from other sources, could help identify service

line materials. Also, the date of building construction can be compared to water main installation

records. A newer tap installation date for an older home could mean the service line was partially

replaced on the system side. The reverse could also be true – a newer building construction date

compared to tap installation date could indicate a partial service line replacement on the

customer side. These records may be found at the municipal tax assessor’s office or the

centralized municipal government geographic information system (GIS) office (LSLR Collaborative,

2021).

Community planning documents and maps may also contain information on the date of

construction, which can be useful to identify potential locations of LSLs. These documents may be

found at municipal planning departments, regional planning agencies, the public library, or the

local historical society (LSLR Collaborative, 2021). Property appraisal records might include the

year a structure was built and when it was modified. County or city council meeting minutes may

also contain additional relevant records.

4.3 Water System Records

Water system records are a key source of information and are one of the many sources that systems

must review to identify service line materials and develop the initial inventory. Systems can use any

relevant water system records they may have to develop their inventory, but at minimum must

review the water system records listed in 40 CFR §141.84(a)(3)(ii).

Exhibit 4-3 lists the type of water system record that must be reviewed, what the record may

contain, and the possible formats of the records. Other possible water system records that could be

used to develop the initial inventory include historical water system standard operation procedures

(SOPs), water main replacement records, water loss studies, and annual reports. Additional

discussion of a key type of record, service line installation records or “tap cards”, follows the exhibit.

Note when reviewing historical SOPs, systems should review past

procedures for connecting a new building and if they allowed

connection to an old service line. If allowed, this could indicate that

some newer construction could be potentially connected to an LSL.

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Exhibit 4-3: Water System Record Examples and Uses

Type of Water System Record

Required under the LCRR

Relative information Possible Formats

Distribution system map and

drawings

Date of construction of different

parts of the distribution system

may help inform when and where

LSLs were used.

Hard copy maps, digital maps, or

web-based map applications

Historical records on each

service connection

Detailed information on service

line material, location, and size.

Ledgers, cards (e.g., tap cards or

drill records), or databases

Meter installation records

May contain the service line

material. Meter size and/or type

can indicate service line size or

building usage.

Water system files and records

Historical capital improvement

or master plans

Historical installation patterns may

help inform when LSLs were used.

Archived report or electronic

document

Standard operating procedures

Allowable materials for

construction of service lines and

for service line repairs.

Specifications and standards used

by the water system

Notes:

Each type of water system record must be reviewed to develop the initial inventory (40 CFR §141.84(a)(3)).

Historical records on service connection installation may be in the form of tap cards (also called

drill records), which are recorded when a service line is tapped into the water main and connected

to an individual home or building. They are often handwritten index cards that contain the

installation date, pipe diameter,

and pipe material. Exhibit 4-4

provides examples of tap cards

specifying lead pipe material.

The LSLR Collaborative (LSLR

Collaborative, 2021)

recommends digitally

categorizing tap cards as one of

the first steps in building an

inventory.

Example: Scanning tap cards as a starting point

In 2017, the Pittsburgh Water and Sewer Authority (PWSA)

scanned almost 130,000 paper service record folders and

3,000 microfiche records and created an initial database with

the results. PWSA found that many of these records, however,

were inaccurate because of maintenance conducted since

they were initially installed (Duffy and Pickering, 2021). See

Appendix B for the PWSA case study.

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Exhibit 4-4: Examples of Tap Cards with Lead Listed as Service Line Material

Source: Hensley et al., 2021

Source: Bukhari et al., 2020, Figure 3-1 from American Water, 2019.

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Bukhari et al. (2020) notes that “using tap cards alone can be challenging since information can be

inconsistent, unreliable, or altogether absent.

For example, there may be situations where a

line was repaired or replaced, but the

location-specific tap card was never

updated.” Moreover, tap cards may only

contain information on the system-owned

portion of the service line (Duffy and

Pickering, 2021). It is important to

supplement tap card information with service

line replacement or repair data; water main

installation, rehabilitation, or replacement records; meter installation records; and other field data

and investigations.

4.4 Inspections and Records of the Distribution System

Historical records of inspections might indicate service line materials. Sources of information

include responses to customer complaints, inspections to locate leaks, or inspections to

investigate meter issues. Cross connection inspections may also provide information on service

line material. Systems may store this information electronically, for example, using a

computerized maintenance management system (CMMS) (Liggett, 2021).

Water systems have opportunities to directly view the service line materials during a variety of

maintenance activities. See Section 3.4 for recommendations for collecting service line material

information during normal operations.

Example: Meter Installation as an Information

Source

The City of Evanston, Illinois, replaced approximately

one-third of their meters in 2018. They documented

the service material type and inputted the

information into their computerized maintenance

management system (CMMS) (AWWA, 2021).

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Key Points to Remember

LCRR Requirements

 Water systems must use any information on lead and galvanized iron or steel that it has

identified pursuant to 40 CFR §141.42(d); review the records explicitly identified in the

LCRR; as well as use any additional resource, information, or identification method

required by the state to develop the initial inventory (§141.84(a)(3)).

Recommendations (Not Required under the LCRR)

 Water systems should document the records they reviewed as a best practice and include

the source of material classification in their inventory.

 Water systems should continue to gather information on service line materials after they

have been classified and assess the accuracy of historical records.

 If systems find certain historical records to be unreliable, they should consider

reclassifying service line materials that rely solely on those records as “unknown” until

additional information can be gathered.

 Water systems should incorporate previous reviews (as required by the LCRR and other

reviews done to comply with LCR or other proactive activities) into their initial inventory

and document the date and scope of the reviews. Records already reviewed for service

line material information do not need to be reviewed again.

 Tap cards are often handwritten index cards that contain the installation date, pipe

diameter, and pipe material. The LSLR Collaborative recommends digitizing tap cards as

one of the first steps in building an inventory.

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Chapter 5: Service Line Investigation Methods

This chapter provides a description of the service line investigation methods that water systems

have used to verify historical records and gather information when service line material is

unknown. These methods are not required under the Lead and Copper Rule Revisions (LCRR), but

rather provide examples for systems to consider. The methods included here are:

• Visual inspection of service line material (Section 5.1)

• Water quality sampling (Section 5.2)

• Excavation (Section 5.3)

• Predictive modeling (Section 5.5)

• Emerging methods (Section 5.6)

Section 5.4 provides a comparison of methods from the literature.

Some of these methods require state approval before use for service line classification, such as

water quality sampling, predictive modeling, and emerging methods. Water systems should

consider the method(s) that are best suited to their particular distribution system and community,

considering state approval, cost, labor skill requirements, disruption to consumers, overall time,

and accuracy. Water systems should be aware of identification methods provided or required by

their state under the LCRR (40 CFR §141.84(a)(3)(iv)). If a water system chooses an investigation

method not specified by the state under 40 CFR §141.84(a)(3)(iv), state approval is required (40

CFR §141.84(a)(3)). States may want to consider identifying approved methods that can be used

by any system in their state to classify service lines. States could approve different methods for

classifying lead, galvanized requiring replacement (GRR), and non-lead. This chapter provides

states with information they can use to make their approval decisions. Note that service line

investigation methods are evolving; states may wish to revisit approval decisions in the future

based on new research or other information.

As noted previously in this guidance, EPA recommends that systems consider including the

sources of the material classification (e.g., excavation or visual inspection by customer) in their

inventory. In some cases, systems may replace lead service lines (LSLs) when they find them in the

field during investigations. EPA recommends systems document where there was an LSL, as

recording lead service line replacement (LSLR) activities may be useful for systems to track and

demonstrate the LSLR rate achieved.

5.1 Visual Inspection of Service Line Material

The material composition of a service line can be identified through visual inspection. Exhibit 5-1

provides a comparison of common service line materials:

• Plastic is a smooth pipe of various colors (e.g., white, blue, black, and green).

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• Lead is a soft metal that is a dull, silver-gray color. It is easily scratched with a coin or key,

and the scratched areas will be shiny. It is non-magnetic, meaning a magnet will not stick

to it. Lead pipe is commonly attached to other pipe with a “wiped” joint.

• Copper is the color of a penny.

• Galvanized is a dull, silver-gray color that is difficult to scratch. It is magnetic, meaning a

magnet will stick to it.

Exhibit 5-1: Examples of Commonly Found Pipe Materials

Source: https://www.epa.gov/ground-water-and-drinking-water/protect-your-tap-quick-check-

lead-0.

Lead can also be distinguished from other materials by a “wiped” joint, which is a rounded ball of

lead that connects the lead pipe to other materials. See Exhibit 5-2 for a picture of a wipe joint on

an LSL.

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Exhibit 5-2: Example of Wiped Lead Joint

Source: https://www.skokie.org/766/Lead-Water-Line-Information

The remainder of this section describes service line materials identification approaches through

visual inspection without excavation. See Section 5.3 for a description of excavation techniques.

5.1.1 Visual Inspection of Service Line by Customers

Many utilities have enlisted the public’s help to identify the material of the customer-owned

portion of the service line. The service line may be visible where it comes into the building, such as

in the basement where it connects to the water meter and/or premise plumbing. Exhibit 5-3

shows the possible location of the visible portion of the line connected to the water meter. Note

that incoming service lines may have different configurations, which can make it difficult for

customers to locate the service line entering the home. DC Water has created a video to assist

customers, advising them to locate the meter pit in the yard to estimate where the service line

enters the building.

Systems may wish to provide guidance on typical configurations to assist

customers in finding their water service lines.

https://www.dcwater.com/do-you-have-lead-pipes-let-us-help-you-find-out.

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Exhibit 5-3: Example of Location of Exposed Service Line in Basement

Source: Philadelphia Water System. https://water.phila.gov/pool/files/how-to-check-your-service-line-for-lead.pdf.

Accessed December 20, 2021. Right edge of image represents basement wall in contact with soil.

After locating the service line, the customer can visually inspect the pipe. A common approach to

determine pipe material is a scratch and magnet test. If the pipe is a silver metallic color, the

customer can carefully scratch the pipe with a key or coin. It is important to not use a sharp object

that could puncture the pipe. If the pipe is soft, scratches easily, and reveals a shiny silver color,

the pipe is likely lead. The customer can use a magnet to confirm the material since magnets will

only react to steel and will not stick to lead (Hensley et al., 2021). Customers can also look for a

wiped joint as shown in Exhibit 5-2 that can be an indicator of an LSL. Systems may want to

suggest that customers wear gloves when performing a scratch test and cleaning up debris.

In addition to the scratch and magnet test, lead paint test kits can be used to test the pipe for lead

(Hensley et al., 2021; LSLR Collaborative, 2021). Surface swab kits approved by EPA for lead paint

will change color after coming in contact with a lead surface. A list of approved test kits are

available on EPA’s website (https://www.epa.gov/lead/lead-test-kits). Care should be taken in

interpreting results because the kits can react to lead paint if the pipe is painted.

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EPA developed the online step-by-step guide “Protect Your

Tap: A Quick Check for Lead”

to help people identify LSLs in

their homes. It also provides tips on actions to reduce lead

exposure in drinking water, information on certified

laboratories for water testing, and other resources. The guide

is for everyone, and EPA has provided Protect Your Tap

outreach toolkits for community groups, government and

health organizations, and water utilities. The guide is also

available in Spanish. To access this information and the online

guide, refer to EPA’s website at https://www.epa.gov/ground-

water-and-drinking-water/protect-your-tap-quick-check-lead.

Examples of instructions for identifying service line materials

prepared by the Philadelphia Water Department; Rockford,

Illinois; and Newark, New Jersey, are provided in Appendix C.

The independent, non-profit media organization National

Public Radio (NPR) has also developed an interactive tool

available on their website

that instructs customers on how

to determine if their service line is lead. Other innovative

examples of systems that enlist the customer to self-identify

their portion of the service line include:

• Greater Cincinnati Water Works (GCWW), Ohio, provides instructions for the scratch

test on their website

, along with a fillable form asking for name, email, return phone

number, and property address. Customers can select copper, lead, or other from a

dropdown menu to specify their service line material. The website asks users to “please

upload a picture of your meter setting that we can use to help identify the pipe material.”

• The City of Grand Rapids, Michigan, has used free video conferencing software to guide

homeowners through the verification process. This approach worked especially well

during the COVID pandemic, when customers were reluctant to let others into their

homes and could be replicated for harder-to-reach customers who are more comfortable

with a video call than letting system personnel enter their homes (USEPA, 2021e).

• Madison, Wisconsin, distributed customer surveys to residents in 2000, asking them to

perform scratch tests on their exposed portion of service lines in their homes (Bukhari et

al., 2020). During that time, the City of Madison held meetings to teach customers how

to perform scratch tests. Madison Water Utility still provides instructions on how to

https://www.epa.gov/ground-water-and-drinking-water/protect-your-tap-quick-check-

lead#:~:text=Protect%20Your%20Tap%20Outreach%20Toolkits%20%20%20,Article%20%28Utilities%29%20%28docx%

29%20%206%20more%20rows%20. Accessed December 17, 2021.

https://apps.npr.org/find-lead-pipes-in-your-home/. Accessed December 15, 2021.

https://la.mygcww.org/do-i-have-a-lead-service-line/. Accessed December 8, 2021.

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perform scratch tests on their website

, along with a number and email to contact if an

LSL is discovered.

Water systems can also use community surveys to enlist residences to self-identify service line

material (see above for Madison, Wisconsin). Outreach and education can improve the quality of

the survey results (Hensley et al., 2021). Systems can also offer financial assistance for customer-

side LSLR as an incentive to inspect their service line. The Association of State Drinking Water

Administrators (ASDWA) (2022) recommends that systems consider providing incentives for

service line identification such as credits on water bills or gift cards.

EPA recommends that systems ask customers to submit a photograph of their service line

entering the home to the utility to increase confidence in the customer’s response and additional

visual verification by the water system. Hensley et al. (2021) notes that even with outreach and

education, service line material information from residents may be inaccurate and a water

system’s confidence could be increased with an additional verification step (such as reviewing a

customer-submitted photograph of the service line) by the water system staff, a licensed plumber,

or other trained personnel. Note that the system’s data management structure may need to be

revised in order to accept and organize uploaded photos. Partnerships with plumbers and other

third parties, such as building inspectors, can facilitate visual inspection and service material

identification (see Section 3.5 for recommendations on establishing partnerships).

Note that some water systems elicit customer assistance by requesting access to the customer’s

home for verification rather than asking the customer to perform visual inspection themselves.

For example, the City of Menasha Utilities Electric & Water in Wisconsin sends postcards to

residents where the customer-owned portion of the service line material has not been verified.

The postcard includes water system contact information to schedule a free service line material

inspection by the water system. Those accepting the system’s offer receive follow-up information

on what the customer can expect during the inspection process, and reminders (see Appendix C

for a copy of the postcard and water service inspection information). Inspection by the system or

other trained personnel, or asking the customer to submit a photo along with their identification,

can increase the degree of confidence the system has in the service line’s material classification.

Water systems could also determine if existing ordinances already give them access rights to the

inside of the home for inspections and/or maintenance, including inspection of the service line

material.

https://www.cityofmadison.com/water/water-quality/lead-service-replacement-program/lead-in-water-what-you-

should-know. Accessed December 20, 2021.

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5.1.2 CCTV Inspection by the Water System

This section describes visual inspection using closed-circuit television (CCTV). Note that visual

inspection by the water system during normal operations is discussed in Section 3.4.

CCTV has been used widely by the wastewater industry to inspect the interior of gravity sewer

lines. Recently, probe or insertion style CCTV cameras have been used by water utilities to visually

inspect service line material. CCTV inspections usually fall into one of two categories: 1) inspection

of the interior of the service pipe of the service line or 2) inspection of the exterior (Bukhari et al.,

2020).

External CCTV Inspection

External inspections involve inserting the CCTV camera into the curb box to view the outside of

the pipe on either side of the shutoff valve. As previously shown in Exhibit 2-2, a curb stop could

be flanked with the system-owned portion and customer-owned portion on either side. Bukhari et

al. (2020) notes the following about curb box configurations:

“There are a variety of curb box styles on the market, but in cold climates, they usually consist

of a telescoping pipe that extends vertically from the ground surface down to the shut-off

valve, which is typically situated 3 to 5 feet below grade. In warmer climates, curb stop boxes

may be larger plastic or fiberglass enclosures buried at shallower depths. The bottom of the

curb box is frequently arched, so the service line passes through the arch without the valve

box resting on the line itself.”

Exhibit 5-4 shows an example schematic of a curb or stop box with a telescoping pipe from Des

Moines Water Works.

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Exhibit 5-4: Example Stop Box Schematic from Des Moines Water Works, Iowa

Source: Des Moines Water Works, IA (https://www.dmww.com/water_service/service_lines/index.php).

Accessed December 20, 2021.

A small diameter CCTV camera can be inserted into the curb box to visually inspect the exterior of

the service line connected at each side of the valve. A bulb-shaped “wiped joint” connection to

the curb stop indicates an LSL. It is often necessary to first vacuum soil and debris out of the curb

box before inspection (Bukhari et al., 2020). Exhibit 5-5 shows a picture of a lead pipe that was

excavated and previously connected to a curb stop (LSLR Collaborative, 2021). Exhibit 5-6 shows

example pictures from CCTV inspection in Pittsburgh, Pennsylvania, showing an LSL, a non-LSL,

and a service line that is not identifiable. Water systems using this method should use it first on

known LSLs and other service lines of known materials to determine the visual elements that

allow them to differentiate among the pipe materials.

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Exhibit 5-5: Lead Pipe at a Curb Stop

Source: LSLR Collaborative, 2021 from Philadelphia Water Department, PA

Exhibit 5-6: Examples CCTV Camera Pictures for LSL, non-LSL, and Unable to Determine

Source: Baribeau, 2021

In 2018, the Pittsburgh Water and Sewer Authority (PWSA), Pennsylvania, implemented a curb

box inspection program and inspected approximately 45,000 locations. They found that there

were no usable data for approximately 75 percent of the locations for the following reasons (Duffy

and Pickering, 2021):

• Problems with locating the curb box,

• An inability to access the curb box because the box was damaged or misaligned,

• Degradation of the line, and/or

• Lack of clarity of the photograph.

Results were very accurate when an LSL was identified (PWSA confirmed 97 percent of LSLs

identified through curb box inspections via excavation). However, lead was found at

approximately 35 percent of locations where the curb box inspection indicated a non-LSL. Duffy

and Pickering (2021) explain that, in some locations, this happened because the curb box and a

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small portion of the service line were replaced but the remainder of the service line was still lead

(see PWSA case study in Appendix B for more information). For these reasons, PWSA no longer

uses curb box inspections “to verify the presence of non-lead” (Bolenbaugh, 2022, personal

communication). EPA recommends that water systems using this method consider conducting a

pilot study at a subset of sites to determine its accuracy, possibly supplementing determinations

of non-LSLs with additional evidence prior to expanding its use to the entire distribution system.

Internal CCTV Inspection

Some water systems have used high-resolution cameras equipped with a flexible, fiber optic scope

and a light source to inspect the service line material from inside the pipe (Bukhari et al., 2020).

Tucson Water, Arizona, and Green Bay, Wisconsin, used internal CCTV inspections after shutting

off water service and disconnecting the water meter located inside the curb box. A benefit of this

technology is that a greater length of the service line can be visually inspected. However, the

drawbacks are that the method is ineffective when the line is coated with corrosion scale and the

method itself can cause disturbance to the pipe (Bukhari et al., 2020; Hensley et al., 2021).

Hensley et al. (2021) recommend measures be taken to reduce scale disturbances and lead

release when using this method. For example, the LSLR Collaborative has guidance on alerting

customers to potential disturbances of LSLs.

The LSLR Collaborative also has guidance on actions

customers can take to reduce lead exposure after a replacement or disturbance.

Systems could

also consider immediately replacing service lines identified as LSLs where possible.

5.2 Water Quality Sampling

Water quality sampling protocols have been used by water systems to detect the presence of LSLs.

Three sampling protocols are described in Hensley et al. (2021), each with varying degrees of cost,

complexity, accuracy, and customer cooperation required:

• Targeted service line sampling involves flushing out the volume of water in the premise

plumbing and collecting and analyzing a sample from the service line. The volume of

water from the tap to the service line can be estimated based on pipe diameters and

lengths. Cartier et al., 2012 (as cited in Hensley et al., 2021) found that based on typical

premise plumbing volumes in Montreal, Quebec, a lead concentration threshold of 3

micrograms per liter (µg/L) in the second liter after 15 minutes of stagnation was

indicative of an LSL.

• Flushed sampling involves collecting a sample from the customer’s tap after a set

flushing time. For example, flushing for five minutes could result in a sufficient difference

in lead levels to distinguish LSL sites from non-LSL sites (Cartier et al., 2012; Deshommes

et al., 2016). This method is simple and can be done as an initial screening.

https://www.lslr-collaborative.org/disturbing-lead-service-lines.html.

https://www.lslr-collaborative.org/techniques-to-control-lead-exposure-from-lsl-replacement.html.

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• Sequential sampling uses series of consecutive samples (typically 500 mL to 1 L) collected

from an interior tap after a stagnation period (typically 6 hours or more). The number of

samples needed depends on the length and diameter of the plumbing from the tap

through the length of the premise plumbing and service line, but it is commonly between

8 and 15 liters (Hensley et al., 2021). See Exhibit 5-7 for an example of sequential

sampling. Although sequential sampling can be a sensitive tool for identifying LSLs, it is

relatively invasive to the resident and more complex than other water quality sampling

methods (Schock et al., 2021; Hensley et al., 2021).

Exhibit 5-7: Example of Sequential Sampling

Note: The number of bottles for each part of the plumbing system and service line is site-specific.

It is important to note that water quality sampling is a more appropriate screen for the presence

of LSLs since low and non-detect lead levels may not reliably detect the absence of LSLs (Hensley

et al., 2021). The key to using water quality sampling for identifying LSLs is establishing a

community-specific threshold above an indicator for the possible presence of an LSL. Examples of

water systems using water sampling protocols and thresholds to screen for LSLs include:

• Denver Water (Denver, CO), which uses pH adjustment for corrosion control, uses a

subset of three samples to assess if a location has an LSL: a first draw, a second draw

after a 30-second flush, and a third draw after another 30-second flush. If the average

lead concentration is 5 µg/L or greater, they consider it an LSL (Denver Water, 2019, cited

in Hensley et al., 2021).

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• DC Water (Washington, DC), which uses orthophosphate for corrosion control, conducts

sequential sampling and uses a screening value of 5 µg total lead mass in ten 1-liter

sequential samples (Schmelling, 2019, cited in Hensley et al., 2021; Bukhari et al., 2020).

• Three Canadian utilities (Montreal, Quebec; Guelph, Ontario; and Ottawa, Ontario) use

either targeted service line sampling or flushed sampling protocols and thresholds of 1 to

5 µg/L to screen for LSLs (Schock et al., 2021).

A study by Schock et al. (2021) investigated the reliability of using the flushed sampling protocol

and the sequential sampling protocol at two communities with varying levels of corrosion control.

They were able to establish community-specific threshold levels to identify LSL sites based on the

maximum flushed sample lead concentration and the weighted average sequential profile lead

concentration. The authors recommend a four-step sampling approach for identifying LSLs as

follows:

(1) Establish baseline threshold lead concentrations for fully flushed and sequential samples

from homes that have never had LSLs.

(2) Collect fully flushed and sequential samples from homes with LSLs.

(3) Collect fully flushed samples from homes with unknown service line materials suspected

to be lead (i.e., unknown, likely lead).

(4) Collect sequential samples from the same homes in step 3 if fully flushed samples do not

clearly indicate the presence of an LSL.

Researchers found this combination of sampling to be robust in predicting the presence of LSLs

under different corrosion control and household plumbing scenarios (Schock et al., 2021).

5.3 Excavation

If a service line is not accessible for visual inspection, the water system may need to excavate soil,

and potentially remove portions of the road, sidewalk, or other obstacles to determine service line

materials. Excavation methods require different levels of disturbance, time investment, and cost

as well as coordination with the property owner. This section discusses two approaches:

mechanical excavation and vacuum excavation, which are described in Sections 5.3.1 and 5.3.2,

respectively.

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5.3.1 Mechanical Excavation

Mechanical excavation involves using a backhoe or

other mechanical excavator to dig a “pothole” or test

pit to expose the service line (Hensley et al. 2021).

This is typically done at the curb box or shutoff valve.

A full trench can also be dug, exposing the entire

length of the service line. Digging a full trench can

have a higher accuracy than methods that only expose

sections of the service line because it typically exposes

a longer length of the service line, up to 10 feet in

some situations (Weaver, 2018). However, it is labor-

and time-intensive, and it is more likely to result in

disturbance or damage to the yard, service lines, and

nearby infrastructure (Katerndahl & Bizal, 2003; Lewis

et al., 2017 (as cited in Hensley et al., 2021)).

Disturbances to LSLs can cause elevated lead levels in

drinking water (Del Toral et al., 2013). If an LSL is

found during trench excavation which unearths the

entire service line, EPA recommends replacing it right away given the efficiency gained by

conducting an LSLR under such circumstances. If an LSL or GRR is disturbed during the excavation,

EPA recommends alerting the customer that such disturbance can potentially cause temporarily

elevated lead levels in drinking water and providing them with information about how to reduce

lead levels, such as flushing.

This risk may be mitigated by using a handheld shovel in combination with machinery for delicate

work. Further, this method of identification can be costly for utilities and residents as some non-

LSLs may be dug up and reburied and the site restored (e.g., paving and landscape restoration).

See the PWSA case study in Appendix B.

Example of a Mechanical Excavation

Source: Duffy and Pickering, 2021

Example of a Mechanical Excavation

Source: Duffy and Pickering, 2021

Example of a Mechanical Excavation

Source: Duffy and Pickering, 2021

Example of a Mechanical Excavation

Source: Duffy and Pickering, 2021

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5.3.2 Vacuum Excavation

Vacuum excavation

involves using a

water jet or compressed air to loosen soil,

which is vacuumed up resulting in a small

hole to access the service line. This

method is faster, less intrusive, less likely

to disrupt or damage the service line or

other buried utilities, and cheaper than

mechanical excavation (Abernethy et al.,

2018; Feick, 2018; Kuhl, 2018; Oswald,

2018; Zahra, 2019, as cited in Hensley et

al., 2021; Bukhari et al., 2020).

Excavation can be done at the curb box

to access sections of the customer-owned and system-owned portions of the service line and

might be within the water system’s authority to conduct without customer approval, though EPA

encourages prior notification to the resident. However, due to the size of the inspection hole,

there is a risk of missing an LSL segment in a service line, such as when a service line is partially

replaced (Kuhl, 2018, as cited in Hensley et al., 2019; Bukhari et al., 2020). This can be mitigated

by conducting vacuum excavation at multiple points along the service line or by combining

vacuum excavation with another identification method, such as visual inspection where the

service line enters a building. If an LSL or GRR is disturbed during the excavation, EPA recommends

alerting the customer that such disturbance can potentially cause temporarily elevated lead levels

in drinking water and providing them with information about how to reduce lead levels, such as

flushing.

5.4 Pros and Cons of Field Investigation Methods (Hensley et al., 2021)

Hensley et al. (2021) provides a comparison table of service line investigation methods that is

shown as Exhibit 5-8 and includes visual observation, water quality sampling, and excavation

methods. This table can be used by systems to help select service line identification methods that

are best suited to their particular distribution system and community. Note that the first row is

community records review, which are required under the LCRR.

This technique is also referred to as “hydro-excavation” when water is used instead of air (Bukhari et al., 2020).

Example of Vacuum Excavation.

Source: Hensley et al., 2021

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Rankings for each service line investigation method are based on cost, skill (labor and technical

interpretation), disruption to the customer (water service interruption, property damage, and

involvement), disturbance (service line and traffic flow), overall time, and accuracy.

Exhibit 5-8 was developed using feedback from three anonymous water utilities and is included as

a guide. Experiences of other utilities may differ. Thus, the effectiveness of the approaches should

be validated by the water system.

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Exhibit 5-8: Comparison of Service Line Identification Techniques (Hensley et al., 2021)

Source: Table 2: Relative pros and cons of lead service line identification methods using a ranking system of H: high, M: medium, and L: low (Hensley

et al., 2021).

Note: This table does not include CCTV investigations in the evaluation of the basic/visual observation method.

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a Service Line Inventory

5.5 Predictive Modeling

Predictive models look for patterns in a dataset to develop rules or algorithms. Geostatistical

models use attributes from known locations to make inferences about areas of unknown

condition. Examples of model inputs may include water system or community data, such as the

distribution of known materials, along with other factors, such as building age and location. These

models are typically built using an initial dataset and can be continually “trained” or improved as

more data are added (Muylwyk, 2020).

Geostatistical models have been used by water systems to estimate the probability that a service

line is lead, prioritizing areas for service line investigations and expediting LSLR (Abernathy et al.,

2018; Muylwyk, 2020; Bukhari et al., 2020; Hensley et al., 2021). These models can be enhanced

by incorporating machine learning algorithms in which the model improves itself as new data are

added. Information on sensitive subpopulations and socioeconomic factors can be added as layers

to enhance planning and prioritization of LSLR (Muylwyk, 2020).

The literature provides successful examples of geostatistical and machine learning modeling in

Flint, Michigan, and Denver, Colorado (Abernathy et al., 2018; Muylwyk 2020; Walker 2020).

Detroit, Michigan, is also using these models to inform their service line investigation and LSLR

programs.

A key factor in the success of predictive modeling is the use of representative data.

Using a representative set of known data on service line material is important in maximizing

accuracy and reliability and minimizing bias.

For more information and examples of how predictive modeling has been used in Flint, Michigan,

and Denver, Colorado, systems and states can refer to the 2020 ASDWA webinar, “Predictive Tools

for Lead Service Line Inventories” ( ASDWA, 2020).

5.6 Emerging Methods

Service line material identification technology is the subject of ongoing research. A review of

emerging methods is provided in Hensley et al. (2021) and Bukhari et al. (2020). A central theme

of these techniques is identifying creative ways to isolate the service line material and location

based on physical signatures of the pipe, largely by assessing how service line materials respond to

stimuli such as electrical or wave energy and pairing that information with documented

characteristics of potential service lines in the evaluation area. Many of these emerging methods

apply the basic tenets of subsurface material identification from a different discipline. In many

cases, general information about service line materials in the area is required to inform data

collected in the field. For example, ground-penetrating radar (GPR) can accurately detect service

line location and diameter; however, it lacks the ability to discern service line material. Local

knowledge of lead pipe diameter versus diameters of other pipe materials allows GPR to

Detroit will use predictive modeling to find its 80,000 lead service lines (detroitnews.com).

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a Service Line Inventory

potentially function as a service line inventory technique by linking the detected diameter of the

pipe with the corresponding service line material for that diameter (Deb et al., 1995; Bukhari et

al., 2020). Other examples of emerging technologies include electrical resistance testing and stress

wave propagation.

Application of these emerging technologies can be limited by signal interferences, caused by the

presence of other pipe materials and subsurface environments, and the development of signal

processing algorithms. Hensley et al. (2021) notes that emerging methods have “technical basis

but limited research or field implementation to demonstrate their effectiveness.”

Key Points to Remember

LCRR Requirements

 Water systems should be aware of identification methods provided or required by their

state under the LCRR (40 CFR §141.84(a)(3)(iv)).

Recommendations (Not Required under the LCRR)

 Service line investigation methods can be used to verify historical records and gather

information when service line material is unknown.

 Investigative methods include visual observation, water quality sampling, and excavation.

 Many systems have enlisted the public’s help in visually identifying service line material

where the service line enters the building.

 Water quality sampling has been used to identify the presence of LSLs. There are several

approaches in the literature – including to establish a system-specific threshold above

which may indicate the presence of an LSL.

 Some water systems have found water quality sampling and CCTV to be reliable in

positively identifying LSLs but not in confirming the absence of LSLs.

 Mechanical and vacuum excavation can be used to visually inspect service line material.

Mechanical inspection can be more accurate than vacuum excavation if it exposes a larger

length of service line but is often more expensive and likely to disturb or damage service

lines and nearby infrastructure.

 Predictive models have been used to estimate the probability that a service line is lead,

prioritize areas for service line investigations, and to expedite LSLR.

 Water systems should select the method(s) that are best suited to their particular

distribution system and community, considering cost, labor skill requirements, disruption

to homeowners, overall time, and accuracy.

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Chapter 6: Developing and Updating the Inventory

This chapter provides guidance on preparing the initial inventory under the Lead and Copper Rule

Revisions (LCRR) and improving it over time. This section is organized as follows:

• Section 6.1 provides requirements and recommendations for developing the initial

inventory.

• Section 6.2 provides recommendations for prioritizing service line investigations.

• Section 6.3 includes requirements and recommendations specific to systems with only

non-lead service lines.

• Section 6.4 includes guidelines for submitting the initial inventory to the state.

• Section 6.5 presents requirements for notifying customer of known or potential lead

sources in their service lines.

• Section 6.6 provides requirements and guidance for updating the inventory.

• Section 6.7 provides recommendations for state review of the initial inventory.

6.1 Developing the Initial Inventory

6.1.1 Required under the LCRR

Systems should review Chapters 1 through 4 for a complete listing of initial inventory

requirements under the LCRR. Key requirements systems should keep in mind as they prepare an

initial inventory include:

• The initial inventory must include all service lines regardless of ownership (40 CFR

§141.84(a)(2)).

• The initial service line inventory must use historical records as described in Chapter 4 (40

CFR §141.84(a)(3)(i)-(iii)), information gathered during normal operations as described in

Section 3.4, and any resource, information, or identification method provided by or

required by the state (40 CFR §141.84(a)(3)(iv) and (a)(5)).

• Non-lead must be determined not to be lead or galvanized requiring replacement (GRR)

through an evidence-based record, method, or technique (40 CFR §141.84(a)(4)(iii)).

• If the water system is unable to demonstrate that the galvanized service line was never

downstream of a lead service line (LSL), it must presume there was an upstream LSL and

classify it as GRR (40 CFR §141.84(a)(4)(ii)).

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6.1.2 Recommendations (Not Required under the LCRR)

EPA recommends that systems create an initial inventory that is as thorough as possible. Doing so

would minimize the number of unknowns and benefit water systems and customers by:

• Potentially reducing the number of field investigations conducted by water systems to

identify unknowns.

• Providing service line material information more quickly to customers, thereby allowing

them to take steps to minimize their lead exposure, including replacing their LSLs and

GRR.

• Facilitating access to the current funding available for lead service line replacement

(LSLR) activities, allowing for systems to demonstrate the need and scope of LSLR

projects.

EPA recommends that systems check their inventory for completeness by comparing the total

number of service lines to the number of service connections in their system. Additional

recommendations for reviewing historical records, demonstrating that a galvanized pipe is not

GRR, and conducting service line investigations are discussed below.

Approaches to Historical Records Review

When starting their review of historical records, systems may want to refer to an approach from

the literature. Remember that no matter the approach, systems must review all historical records

as listed in the LCRR and laid out in detail in Chapter 4. Example approaches include:

• Initial Screening Process (Liggett et al., 2022): Exhibit 6-1 shows a possible approach

from Liggett (2021) to screen service lines using historical records. The starting dataset at

the top of the diagram represents all service lines. Non-lead service lines can be screened

out based on lead ban and construction records (i.e., service lines constructed after the

1986 Safe Drinking Water Act lead ban became effective are unlikely to have an LSL).

That dataset is then further reduced by screening out non-lead lines based on size, such

as a maximum diameter of lead pipe that was manufactured or installed. The dataset in

black represents the remaining number of service lines that could potentially be lead or

GRR. See Chapter 4 for information and guidance on reviewing these types of historical

records. EPA recommends that systems track pipe diameter and installation date in their

inventories and document the municipal and plumbing codes and construction records

used to make determinations under this approach.

EPA recommends that systems track the sources of the material

classification (e.g., specific historical record, visual inspection,

records and inspection) in their inventory.

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a Service Line Inventory

Exhibit 6-1: Service Material Screening Process Based on Records

Source: Liggett, 2021 (April 2021 webinar slides)

• Asking Key Questions (LSLR Collaborative, 2022): The Lead Service Line Replacement

(LSLR) Collaborative provides a flowchart with key questions on their website titled,

“Preparing an Inventory: Where Do We Start?” The flowchart is included here as Exhibit

6-2. It outlines key questions to ask when starting the process of preparing an initial

inventory and points the reader to available sources. Liggett et al. (2022) notes that

several of the water systems interviewed for case studies found this resource to be a

beneficial starting point. Similar to the initial screening approach above, EPA

recommends that systems document the municipal and plumbing codes and construction

records used to make their determinations under this approach.

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Exhibit 6-2: LSLR Collaborative Flow Chart

Source: LSLR Collaborative website: Preparing an Inventory: Where do we Start? - LSLR

Collaborative (lslr-collaborative.org). Accessed April 25, 2022.

• Weight-of-Evidence Approach: DC Water uses a weight-of-evidence approach to

evaluate multiple historical records and field information to classify service line materials

(Schmelling, 2021). A weight-of-evidence approach involves compiling all data indicating

an individual service line’s material composition and assessing the system’s confidence in

each record and investigative technique in order to classify a service line’s material for

the inventory. Corroboration of historical records by another method makes a strong

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case for any service line classification. However, some water systems have reported

finding conflicting records. EPA recommends using a conservative approach whereby

service lines with unresolved conflicts in records and field information are assigned as

unknown (or lead, where one or more data sources indicate that lead is present) until

they can be resolved.

Demonstrating a Galvanized Service Line is Non-lead

Under the initial inventory requirements of the LCRR, if a system can demonstrate with an

evidence-based record that a galvanized service line was never downstream of an LSL, it may be

considered non-lead for inventory classification. Some examples of evidence to support a

demonstration that a service line is not a GRR could include:

• An original tap card from installation showing the material is not lead.

• The date lead was banned or not used. Service lines installed after that date would be

non-lead.

• Construction practices showing uniform pipe material was installed (e.g., galvanized steel

was used for the entire service line).

• Any other record showing lead was not used at a particular site.

See Chapter 4 for information on historical records related to those described here.

Conducting Service Line Investigations

Although water systems are not required to conduct on-site investigation of service lines under

the LCRR for the initial inventory, if on-site investigations are performed and documented, they

would be a required source of information for the inventory because they would be a water

system record and a record of an inspection. In addition, they can be useful for verifying existing

records and reducing the number of unknowns. Water systems should review the information in

Chapter 5 to assist in identifying appropriate additional investigation methods for their situation.

The literature suggests that multiple records and investigation techniques can increase confidence

in a service line’s material classification (Abernethy et al., 2018; Feick, 2018; Kuhl, 2018; Oswald,

2018; Zahra, 2019, as cited in Hensley et al., 2021). Water systems should be aware of

identification methods provided or required by their state under the LCRR (40 CFR

§141.84(a)(3)(iv)). For example, see Appendix E for the State of Michigan’s requirements.

Remember that if a water system chooses an investigation method not specified by the state

under 40 CFR §141.84(a)(3)(iv), state approval is required (40 CFR §141.84(a)(3)).

Section 6.2 identifies possible approaches that water systems could consider for prioritizing

locations for on-site investigations. Note that the Association of State Drinking Water

Administrators (ASDWA) recommends that systems develop their own specific process of

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identifying unknowns and improving the inventory through service line investigations (ASDWA,

2022).

EPA expects initial inventories to have varying percentages of unknowns, depending on the

condition of existing records and prior inventory development. EPA discourages systems from

submitting inventories to states with all unknowns. EPA notes that as part of the LCRR initial

inventory requirements, systems must identify and track service line materials as they are

encountered during normal operations, such as when performing maintenance activities (40 CFR

§141.84(a)(5)). EPA recommends that water systems also begin engaging customers and

conducting proactive, on-site investigations before the compliance date.

Systems should continue to gather information on service line materials after service lines have

been designated non-lead and assess the accuracy of records and investigative techniques in

accordance with the continuous improvement framework recommended in Chapter 3. If water

systems later find a certain information source to be unreliable, they should consider reclassifying

service line materials that rely solely on that method as unknown until additional information is

gathered. Remember, water systems must update their inventory as better information becomes

available (40 CFR §141.84(a)(6)).

6.2 Prioritizing Field Investigations

EPA recommends that systems conduct on-site investigations to reduce the number of unknowns in

the system as quickly as possible. The extent of proactive service line investigations should be based

on the following:

• The completeness of historical records (e.g., how many of the total service lines are

included, and how much of the distribution service area is covered)

• Confidence in the accuracy of historical records (e.g., based on cross-checking with other

records and field investigations)

• The extent the system will already be in the field doing work, such as meter replacement

and LSLR

• Previous service line investigations

• Number of unknowns

There are many ways to prioritize locations for service line investigations. Examples are described

below and are not necessarily listed in order of importance. EPA recommends that systems

consider using multiple prioritization criteria in planning for investigations.

Consider vulnerable or environmental justice populations when targeting areas for

investigations. For example, a water system may want to consider prioritizing investigations at

locations served by unknown service lines where children are present, such as schools or child

care facilities. In some cases, smaller child care facilities operated out of single family residences

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could be more likely to be served by an LSL based on the diameter of the service line. Water

systems could consider prioritizing other factors as well, such as populations that have been

disproportionately exposed to lead from all sources or face additional disparities that may make it

more difficult to cope with the impacts of lead exposure. Systems could also consider income-

based prioritization, conducting investigations at sites serving customers who qualify for reduced

rates. Systems could also consider referencing requirements of external LSLR funding they have

received. For example, if the customer eligibility for LSLR funding is based on income, water

systems could consider prioritizing investigations of unknowns based on the same criteria to

facilitate use of the LSLR funding.

Target areas with the most unknowns. Systems with many unknowns may want to consider

targeting proactive investigations in areas where there are many unknowns to improve efficiency.

Prioritize investigations by the likelihood of finding LSLs. Prioritizing investigations of service lines

that are unknown-likely lead and replacing them if found can lower costs and save time related to

access agreements, traffic control, and field crew mobilization. This approach may also reduce the

costs associated with false negatives (i.e., digging up a suspected lead line and finding that it is

non-lead). This prioritization approach can benefit from predictive modeling by indicating the

probability that a service line is lead. EPA also recommends replacing lead and GRR service lines

when found to expedite LSLR and improve public health.

Prioritize investigation in areas undergoing LSLR. Systems with existing LSLR programs could

prioritize proactive investigations in areas undergoing LSLR projects to save time and cut costs

related to access, traffic, and crew mobilization.

Use field investigations to verify historical records. Systems can use field investigations to verify

the accuracy of historical records. One possible approach is as follows:

(1) Select a random set of addresses where service line material has been assigned based on

historical records.

(2) Use one or more of the investigation methods described in Chapter 5 (e.g., visual

observation, excavation) to identify the service line material for the system- and

customer-owned portions.

(3) Compare field results to historical records.

An example is the approach required by the Michigan Department of Environment, Great Lakes,

and Energy (EGLE). Michigan requires a minimum number of service line investigations with the

goal of reaching a 95 percent confidence level in the accuracy of historical records. See Appendix E

for minimum service line materials verification requirements in the state of Michigan.

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6.3 Requirements and Recommendations for Systems with Only Non-Lead Service Lines

6.3.1 LCRR Requirements

Systems may be able to demonstrate through evidence-based records, methods, or techniques

that all service lines in their system (both system- and customer-owned) are non-lead. Water

systems with only non-lead service lines are subject to the following requirements under the

LCRR:

• Develop an initial inventory that complies with the requirements to use and review

certain information as described in 40 CFR §141.84(a)(3). Submit the initial inventory by

October 16, 2024 (40 CFR §141.90(e)(1), USEPA, 2021d). Remember that all systems,

even those with initial inventories that identify all service connections as non-lead service

lines, are required to create and submit their initial inventory to the state (40 CFR

§141.80(a)(3)).

• Systems whose initial inventory contain only non-lead service lines may provide a written

statement that the system has no LSLs or GRRs and a general description of methods

used to make the determination to meet inventory public accessibility requirements of

the LCRR (40 CFR §141.84(a)(9)).

• Include language in their annual Consumer Confidence Report (CCR) explaining how

customers can access the inventory or provide a statement with the description of

methods used to make the determination (40 CFR §141.153(d)(4)(xi)). Note that this

requirement applies to community water systems (CWSs) only.

• Notify the state within 30 days and prepare an updated inventory on a schedule

established by the state if the system subsequently finds an LSL or GRR service line (40

CFR §141.90(e)(3)(ii)).

6.3.2 Recommendations (Not Required under the LCRR)

Recommended Approaches and Documentation for Demonstrating all Service Lines are Non-

Lead. Water systems can use different approaches to demonstrate that all service lines are non-

lead. Some may be able to use municipal codes and construction dates to show that all service

lines were constructed after lead was banned in the system (i.e., the system never had LSLs).

Others may be able to positively identify non-lead materials (e.g., copper or PVC) for all service

lines through historical records, field investigations, or both. Other water systems may be able to

demonstrate that they have no LSLs or GRRs because they have replaced both the system- and

customer-owned portions everywhere in the system. Water systems can use a combination of

evidence-based records, methods, or techniques; for example, when a portion of their distribution

system was constructed after the lead ban, and the remainder is verified as non-lead based on

historical records and verification. Exhibit 6-3 recommended documentation for different types of

systems with all non-lead service lines depending on their basis of determination.

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Exhibit 6-3: Recommended Documentation for Systems with all Non-Lead Service Lines

Scenario Basis of Determination

Recommended Documentation

Never had LSLs

Municipal codes and construction

dates (e.g., all service lines were

installed after lead was banned)

• Relevant municipal code language and

dates and references/web links to

materials that are available online.

• Dates when service lines were constructed,

and a list of service line materials used

instead of lead.

• Confirmation that no LSLs have ever been

found in the system.

Detailed historical records on service

line material, location, and size

indicating that all service lines are a

material other than lead (e.g., copper

or PVC)

• Description of historical records including

format of the records and condition.

• Specific standard operating procedures

(SOPs) or policies regarding LSL installation.

• Description of how the system verified the

accuracy of historical records including the

method(s) and number of verified service

lines records compared to the total.

• Confirmation that no LSLs have ever been

found in the system.

Field investigations

• Description of methods including how the

system inspected the material of the

system-owned and customer-owned

portion, if applicable.

• The number of service lines that were

investigated using each method.

• Confirmation that no LSLs have ever been

found in the system.

Replaced all

LSLs and GRR

Detailed historical records of non-lead

lines and records showing when each

LSL and GRR service line was replaced

• Description of historical records

documenting non-lead service line material

along with description of how the system

verified the accuracy of non-lead records.

• Specific SOPs or policies regarding LSL

installation.

• Detailed list of where and when each LSL

and GRR was replaced.

Notes:

Basis of determination for systems that have all non-lead service lines can be a combination of the

information shown. Systems should include all relevant documentation for all their bases of determination.

Should include records for both the system-owned and customer-owned portions where ownership is split.

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Submitting the Initial Inventory to the State. Systems with all non-lead service lines must still

submit an initial inventory to their state by October 16, 2024. The inventory should have all

service lines categorized as non-lead or a non-lead subclassification (e.g., copper or plastic) and

zero service lines categorized as lead, GRR, or unknown. EPA developed an inventory template to

support systems as they prepare and submit their inventory. The template materials are described

in Section 3.3.1 with the electronic version available at EPA’s website

as well as blank forms in

Appendix A. EPA recommends that systems check with their primacy agency if they have specified

a mechanism or format for their inventory submission. States may require additional information

be submitted as well.

Discovery of LSLs or GRRs after submission of initial inventory with no LSLs, GRRs, or Unknowns.

EPA recognizes that even when systems’ inventory and LSLR efforts have progressed such that all

service lines have been classified as non-lead, it is possible that an LSL or GRR may subsequently

be found. Systems should work closely with their state if they discover an LSL, notifying the state

as soon as possible (within 30 days as stated above in Section 6.3.1). The system must prepare an

updated inventory in accordance with 40 CFR §141.84(a) on a schedule established by the state

(40 CFR §141.84(a)(6)(i)). Although not required, EPA recommends systems strive to replace the

LSL as soon as practicable as well as investigate the circumstances of LSLs (e.g., when was it

installed and who installed it).

EPA recommends that states consider whether the LSL discovery was an isolated event that is

unlikely to occur again or a potential indicator of additional LSLs in the distribution system. If the

state determines that the discovery of an LSL is an indicator of other potential LSLs in the system,

EPA suggests that the state work with the water system to determine which service lines should

be reclassified as unknown and develop a plan for field investigations.

6.4 Submitting the Initial Service Line Inventory

Systems must submit their initial inventory of service lines in accordance with 40 CFR §141.84(a)

to their state by October 16, 2024 (40 CFR §141.90(e)(1); USEPA, 2021d). The initial inventory

must include the system- and customer-owned portions of all service lines in the system’s

distribution system (40 CFR §141.84(a)(2)) and each service line or portion of the service line must

be classified as lead, GRR, non-lead, or lead status unknown (40 CFR §141.84(a)(4)).

The LCRR does not require a specific format for the inventory; however, states may have

additional requirements or recommendations regarding inventory format. See Section 3.3 for a

discussion of possible inventory formats. As noted in Section 3.3.1, EPA developed a multi-

worksheet template to assist water systems and states in developing their service line inventory.

An electronic version of the template is available at https://www.epa.gov/ground-water-and-

drinking-water/revised-lead-and-copper-rule, and blank forms for each template worksheet are

https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule.

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also provided in Appendix A. The template includes an “Inventory Methodology” worksheet to

document the methods and resources used to develop the inventory. The “Inventory Summary”

worksheet supports documenting service line ownership and reporting the total number of service

lines by the four material classifications. These templates are presented as a possible tool; there is

no requirement that a system or state use these templates.

6.5 Notification of Known or Potential Service Line Containing Lead

Water systems with LSL, GRR, or lead status unknown services lines must provide notification to

people served by these lines within 30 days after completing the initial inventory. For new

customers, the notice must be provided at the time of service initiation. The notification must be

repeated annually until the entire service line is no longer a lead, GRR, or lead status unknown

service line (40 CFR §141.85(e)). Delivery must by mail or another state-approved method (40 CFR

§141.85(e)(4)).

All notifications must include the following:

(1) A statement that the service line material is lead, GRR, or lead status unknown

(2) Information on the health effects of lead. Details on required health effects language are

available in 40 CFR §141.85(a)(1)(ii)

(3) Steps to minimize exposure in drinking water

Additional content is required based on service line material classification as follows for:

• Confirmed LSLs, the notification must also include information about opportunities to

replace the LSL, any available financing programs, and statement that the system must

replace its portion if the property owners notify the system that they are replacing their

portion.

• GRR, the notification must also include information about opportunities for service line

replacement.

• Lead status unknown, the notification must also include a statement that the service line

is unknown but may be lead and information about opportunities to verify the material

of the service line.

Water systems serving communities with a large proportion of non-English speaking consumers,

as determined by the state, must provide public education materials, including those in 40 CFR

§141.85(e), in the appropriate language(s) regarding the importance of the notice or contain a

telephone number or address where persons served may contact the water system to obtain a

translated copy of the public education materials or to request assistance in the appropriate

language. Water systems must demonstrate that they delivered the notification and provide a

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copy of the notification and information materials to their states annually by July 1 for the

previous calendar year (40 CFR §141.90(f)(4)).

Recommendations (Not Required under the LCRR)

While not required by the LCRR, EPA recommends that water systems develop notifications that are

easy-to-use and understand for consumers and adhere to best practices that are most likely to

prompt consumers to take action to protect their households from lead exposure.

• Water systems should use simple, plain language and short sentences that can be easily

understood by the members of the public. Notices should avoid long paragraphs or

legalistic language.

• Notices should be designed to convey the urgency of the information, differentiate the

notice from other mail that a household receives, and draw consumers’ attention to key

information. For example, notices can use colored envelopes, large-sized envelopes, or

text on the external envelope to make the notice stand out compared to other mail.

Notices can also use bold design practices to draw consumers’ attention to key

information, including large, bold, underlined, or colored font, bullet points or numbered

points, or boxes around key information.

• Notices should be action-oriented, emphasizing the key steps consumers can take and

providing specific instruction on how to do so. Water systems should consult their local

health department on resources that consumers can be directed to, including water

filters and blood lead level testing.

6.6 Inventory Updates

EPA anticipates that water systems will improve and update their inventory over time, decreasing

the number of unknowns and confirming service line material classifications. The LCRR includes

requirements for systems to update their inventory based on all applicable sources described in

40 CFR §141.84(a)(3) and (5) and any LSLRs or service line material inspections that may have

been conducted. As with the initial inventory, the water system may use other sources of

information if approved by the state and must use other sources of information provided or

required by the state. The LCRR also requires submission of the updated version of the inventory

on the same schedule as a system’s tap sampling monitoring, but no more frequently as annually

(40 CFR 141.90(e)(3)); however, EPA may revise the inventory requirements under the Lead and

Copper Rule Improvements (LCRI). Until any change in the regulation, systems must comply with

the LCRR inventory requirements, including the update requirement.

As will be discussed in Chapter 7, EPA suggests that systems consider updating their publicly

accessible inventory in real-time. Systems should also follow any state requirements for updates and

submittals.

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6.7 State Review and Reporting

6.7.1 State Review of the Initial Inventory

Required under the LCRR

State review of each water system’s initial inventory for compliance with LCRR requirements:

• The inventory must include all service lines connected to the public water distribution

system regardless of ownership status (40 CFR §141.84(a)(2)).

• The system must use and review the sources of information listed in 40 CFR §141.84(a)(3)

and other sources of information if approved by the state. In addition, water systems must

identify and track service line materials as encountered in the course of normal operations

(40 CFR §141.84(a)(5)).

• Service lines, or portion of the service line where ownership is split, must be categorized as

lead, GRR, non-lead, or lead status unknown (40 CFR §141.84(a)(4)).

• A publicly accessible inventory must include location identifiers for each lead and GRR

service line (40 CFR §141.84(a)(8)(i)).

• Water systems with lead, GRR, or lead status unknown services lines in their inventory

must inform all persons served by the water system at the service connection within 30

days of completion of the initial inventory and repeat the notification on an annual basis

until the service connection is no longer a lead, GRR, or lead status unknown line (40 CFR

§141.85(e)(1) and (2)). The notification must comply with the content requirement in 40

CFR §141.85(e)(3) and delivery requirements in 40 CFR §141.85(e)(4). In addition, water

systems must demonstrate that they delivered the notification and provide a copy of the

notification and information materials to their states annually by July 1 for the previous

calendar year (40 CFR §141.90(f)(4)). Refer to Section 6.5 for additional detail.

Recommended (Not Required Under the LCRR)

EPA has developed a checklist for the initial inventory submittal with recommended

considerations for states to use in their review. States can refer to a fillable copy of the state

checklist in Appendix A or the electronic version in the EPA Inventory Template, available at EPA’s

website, https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule.

The checklist has sections for reviewing timely submission, required elements, information

sources, public accessibility, and customer notification of service line material.

The ASDWA State Implementation Framework (2022) provides additional recommendations for

states to consider in their review of the initial inventory. They note that states may want water

systems to submit the evidence used and attest to the non-lead areas of the distribution system.

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States may also want to perform a cursory review of historical lead sampling data. Lead tap

monitoring results could reinforce non-lead service line classifications or indicate that more

documentation from the water system is needed (ASDWA, 2022).

For systems with all non-lead service lines, ASDWA’s framework includes a suggestion for states to

consider requiring verification from the water system that there is no lead and a description of the

evidence the system used to make this determination. The state could consider tap monitoring

results when evaluating the initial inventory for non-lead systems. ASDWA (2022) notes that “a

state should feel more comfortable accepting a non-lead certification if there are no lead

detections and the records show distribution installation after the state’s effective date of the

June 19, 1986, Lead Ban.”

6.7.2 State Reporting Requirements

The LCRR requires that states report separately the number of lead, GRR, and lead status

unknown service lines for each water system. EPA is potentially revising reporting requirements

for inventory updates under the LCRI.

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Key Points to Remember

LCRR Requirements

 All systems, including systems with all non-lead service lines, must create and submit their

initial inventory of service lines to their state by October 16, 2024 (40 CFR §141.90(e)(1),

USEPA, 2021d). Water systems must begin tracking materials as they are encountered

during normal operations before the rule compliance date (40 CFR §141.84(a)(5)).

 Non-lead service lines must be determined through an evidence-based record, method, or

technique not to be lead or GRR (40 CFR §141.84(a)(4)(iii)).

Recommendations (Not Required under the LCRR)

 Water systems should begin engaging customers and conducting proactive, on-site service

line material investigations as soon as possible to improve their inventory, verify existing

records, and reduce the number of unknowns. Water systems should capture as much

information as possible for unknowns and consider assigning a likelihood that they are

lead.

 Non-lead classification could be based on when LSLs were banned and service lines were

installed, along with pipe diameter (most LSLs are less than 2 inches).

 When systems have conflicting records of service line materials, they should consider

classifying the line as unknown (or lead if one or more information sources suggest lead is

present) until the conflict is resolved.

 EPA discourages water systems from submitting an initial inventory with all unknowns.

 The inventory is a living document that should be continually improved over time.

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Chapter 7: Public Accessibility

Under the Lead and Copper Rule Revisions (LCRR), community water systems (CWSs) and non-

transient non-community water systems (NTNCWSs) must make a portion of their inventory

publicly available (40 CFR §141.84(a)(8)). This chapter describes those requirements and provides

recommendations for implementation of the public accessibility requirement.

In addition to the public accessibility requirements, the LCRR also requires all systems to inform all

persons served by the service connection with a lead service line (LSL), galvanized requiring

replacement (GRR), or unknown service line of their service line material within 30 days following

completion of the initial inventory

(40 CFR §141.85(e)). See Section 6.5 for additional detail.

Informed customers are better equipped to take actions to limit exposure to lead in drinking

water, make decisions regarding replacement of their portion of a lead or GRR service line, and

understand the prevalence of lead sources in drinking water systemwide.

Chapter 7 includes:

• Inventory information water systems must make publicly accessible and other useful

information to consider in Section 7.1.

• Suggestions on how to make the inventory information publicly accessible and real-world

examples in Section 7.2.

• Recommendations for states to review and facilitate public accessibility of inventory

information in Section 7.3.

• A discussion of the Consumer Confidence Report (CCR) inventory-related requirements

for CWSs in Section 7.4.

7.1 What Information to Include

7.1.1 Required under the LCRR

Under the LCRR, systems are required to provide the public with a location identifier, such as a

street address, block, intersection, or landmark, associated with each service line classified as lead

or GRR (40 CFR §141.84(a)(8)(i)). As described in Section 6.3, water systems that have

demonstrated they have no lead, GRR, or lead status unknown service lines in their inventory (i.e.,

have only non-lead service lines regardless of ownership) may, in lieu of publishing their

inventory, provide a written statement that there are no LSLs along with a general description of

the sources specified in the regulations used to make that determination (40 CFR §141.84(a)(9)).

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7.1.2 Recommendations (Not Required under the LCRR)

EPA encourages water systems to consider including other information in their publicly available

inventory, including but not limited to:

• Location identifier for all service lines, regardless of material. The LCRR requires a

system’s publicly accessible inventory to include location identifiers for LSLs and GRRs. As

discussed in Section 2.3.2, EPA recommends that systems include a location identifier for

all service lines in their publicly accessible inventory. Doing so provides consumers with

up-to-date information on their service line material and allows them to track progress

on lead service line replacement (LSLR) in their entire community over time. This

information could incentivize consumers to assist in the identification of their service line

material and those with LSLs to participate in the LSLR program.

• A street address as the location identifier. As mentioned above, water systems are

required to provide a location identifier in their publicly available inventory associated

with each LSL and GRR. EPA recommends that water systems consider including street

addresses (or emergency 911 addresses for rural areas) as their location identifiers. EPA

also suggests that systems include the town with the street address if they serve several

counties that have the same street address (e.g., 100 Main Street). In addition, EPA also

recommends when multiple service lines serve the same address, e.g., hospital or

apartment building, the water system should include additional descriptors that would

allow each service line to be uniquely identified.

A few examples of maps and databases that are searchable by street address or

customer account number include the following:

o DC Water, Washington D.C.

, Greater Cincinnati Water Works, Ohio

, and

Tucson Water, Arizona

have an interactive map on their website that allows

users to enter an address to learn if they might have an LSL.

o Milwaukee, Wisconsin, provides lists of addresses with LSLs on their website

extracted from their database as PDF files. The list includes house number range,

street name, city, state, and zip code. Milwaukee Water Works advises residents

to search their address to determine if they have an LSL. For more information,

visit their website.

https://geo.dcwater.com/Lead/. Accessed December 16, 2021.

https://gcww.maps.arcgis.com/apps/webappviewer/index.html?id=0a170c268c694e46a8a4e394630df0bd.

Accessed December 8, 2021.

https://cotgis.maps.arcgis.com/apps/webappviewer/index.html?id=8dd30cd29ad64d58bbf1d7ebe86d6abc.

Accessed December 8, 2021.

https://city.milwaukee.gov/water/WaterQuality/LeadandWater/Lead-Service-Line-Records. Accessed December 8,

2021.

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o Louisville Water Company (LWC), Kentucky, has a tool on their website

where

customers can use their LWC account number to determine if the Louisville

Water-owned lines are lead, but not the customer-owned lines. Note, to comply

with the LCRR, customer-owned service lines will need to be included.

• Actual material for non-lead. The LCRR gives water systems the option to classify the

actual material of the service line that is non-lead (e.g., galvanized, plastic, or copper) as

an alternative to classifying it as non-lead (40 CFR §141.84(a)(4)(iii)). EPA encourages

water systems to consider providing the actual materials as part of the publicly accessible

inventory for greater transparency.

• A summary of the total number of LSLs, GRRs, unknowns, and non-lead. Summary

information allows the public to more easily track a system’s overall progress in

identifying service line materials and replacing LSLs. For example, Denver Water,

Colorado,

and the City of Newark, New Jersey, publish the number of LSLs replaced on

their websites

to communicate their progress.

• Clear disclaimer language. A disclaimer will help water systems communicate any

uncertainty inherent in their inventory, such as the varying reliabilities of some data

sources. The inventory represents the best data the water system has at a certain point

in time. Some water systems include disclaimer language about the quality of the

information and require users to accept the disclaimer before they have access to the

inventory information. Appendix F includes a few examples of disclaimer language.

• Instructions on how to read and interpret the inventory. These instructions will depend

on the inventory format selected by the water systems. For example, a spreadsheet

could provide a definition of material classifications and any sub-classifications, include a

data element dictionary, and provide clear labeling of column headings. Additional

recommendations for communicating information using maps is provided in Section

7.2.2.

• Information on steps that consumers served by LSLs can take to protect themselves.

Because some consumers may learn for the first time through the inventory that their

home is served by an LSL, water utilities should provide links or references to information

on steps that consumers can take to reduce lead or protect themselves from lead

exposure. For example, water utilities may consider sharing information from EPA

their local health department.

• Statements that other lead sources may exist in drinking water plumbing or the

building. Systems should raise customer awareness that even when LSLs or GRRs are not

https://www.louisvillewater.com/servicelinelookup. Accessed December 8, 2021.

https://www.denverwater.org/your-water/water-quality/lead/dashboard. Accessed April 21, 2022.

https://www.newarkleadserviceline.com/replacement. Accessed December 8, 2021.

See, e.g., https://www.epa.gov/sites/default/files/2017-

08/documents/epa_lead_in_drinking_water_final_8.21.17.pdf

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present, other lead sources may remain. Examples include materials inside the home or

building, such as copper pipes with solder installed prior to the state’s lead ban,

some

faucets purchased prior to January 4, 2014,

and lead paint in homes that pre-date

1978

. In addition, lead can be present in dust and soil. EPA’s website

includes

information prepared by EPA and other agencies about different sources of lead and how

consumers can protect themselves. Water systems could include a statement about the

possible presence of these lead sources, e.g., on their website, in materials distributed to

their customers in hard copy or electronically, or in their CCR.

• A schedule for investigating unknowns. This could include the date that specific

neighborhoods or other areas of the town or city have been scheduled for investigation.

• Information on the water systems’ actions to reduce lead. This could include actions on

how the water system is reducing lead and opportunities for customers to participate in

the inventory and LSLR efforts (USEPA, 2017).

• Information about tap sampling. The system may inform customers about ways they can

test their water for lead, such as if the system has a lead testing program, or directing

customers to certified laboratories that can provide testing services.

• System contact information. Systems could direct customers to different departments

depending on the request, such as general inquiries about lead in drinking water or how

to submit inventory information (such as customer-owned service line material

identification). This could also include links to the information in other languages, other

information about the LSLR program, and instructions on how customers can identify

their service line materials. See Appendix B, the City of Newark, for an example.

EPA recommends that systems weigh the benefits of making additional and/or detailed inventory

information publicly accessible with the drawback of compromising a user’s ability to find the

most relevant information. Water systems could consider indicating what other inventory

information is available on request, and systems providing the data electronically could include

links to the information.

In 1986, Congress amended the Safe Drinking Water Act (SDWA), prohibiting the use of pipes, solder, or flux that

were not “lead free” in public water systems or plumbing in facilities providing water for human consumption. At the

time, "lead free” was defined as solder and flux with no more than 0.2 percent lead and pipes with no more than 8

percent lead. See Appendix D for a summary of lead ban provisions by state.

The Reduction of Lead in Drinking Water Act, which became effective on January 4, 2014, revised the definition of

lead-free as a weighted average of not more than 0.25 percent lead calculated across the wetted surfaces of pipe,

pipe fitting, plumbing fitting, and fixtures and not containing more than 0.2 percent lead for solder and flux. It also

prohibited the use or sale of such items that did not meet the revised lead-free definition.

In 1978, the Consumer Products Safety Commission banned consumer uses of lead-based paint, but some states

banned it even earlier.

https://www.epa.gov/lead/protect-your-family-sources-lead#older. Accessed April 26, 2022.

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7.2 How to Make the Data Publicly Available

Required under the LCRR

Water systems must make the inventory publicly accessible, including a location identifier for each

LSL and GRR. The LCRR requires water systems that serve more than 50,000 people to provide

their inventory online (40 CFR §141.84(a)(8)).

Recommendations (Not Required under the LCRR)

There are many factors to consider in determining how to best reach the target audience. When

first considering the best method for sharing inventory data with the public, a water utility may

consider the following questions:

• Do our customers have internet access?

• Does our water system currently have a website? If not, do we have the resources to

create one?

• Does our water system have someone that understands how to create maps using

geographic information system (GIS) tools?

• What format of information would be easiest to use for the public?

As mentioned above, only water systems serving more than 50,000 people must post their

inventory online. Water systems serving 50,000 or fewer people are not required to post their

inventories online, as long as they are publicly accessible in some fashion. This may include

availability by mail or in-person at the water system’s office. EPA encourages all water systems to

consider providing online inventory access. This approach could decrease water system burden by

eliminating costs to print and mail inventories on request as well as eliminating staff time to

process additional customer transactions. For smaller water systems that do not currently have a

website, providing their inventory online could be as simple as uploading a list, spreadsheet, or a

simple map to a free filesharing service or publicly viewable social media account for the system.

NTNCWSs that do not have a website could consider using email, posting the information in

frequented locations (e.g., breakroom or notice board), or include the information in a newsletter.

In addition, systems that do not have a website can check if their state has an option to host the

inventory.

7.2.1 Description of Available Web-Based Map Applications

An effective means for distributing service line inventory information is via an online map. Online

inventory maps allow interested parties to view a water system’s service line materials anywhere

there is access to the internet. The primary advantages of making inventory data available via web

maps are user accessibility, data transparency, and the system’s ability to regularly update the

data.

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Systems that collect inventory data with GPS coordinates (latitude and longitude) can save those

points with corresponding attribute information (e.g., service line material, address, data

inventoried, etc.) to one of various file types. Systems could also collect inventory data via GPS

devices, such as smart phones that have a mapping app, and can upload GPS files directly from

those devices (.gpx). Once uploaded, the collected point locations can be overlaid with base maps

and the point symbology (e.g., point locations represented by dots versus “X” symbols) and the

legend information and symbology can be customized to the inventory dataset. Alternatively,

street addresses can be converted to point locations using a process called geocoding. Geocoding

assigns a latitude and longitude to a location using text information to make the determination,

such as address or place name. For example, a dataset of street addresses with service line

information can be converted to point locations that could then be easily displayed in a map

application.

7.2.2 Web-Based Map Application Best Practices

Web-based map applications are one of the most effective methods for conveying service line

inventory information to the public. As Hiltner et al. (2019) explained, interactive online maps can

be a more powerful tool for disseminating location-based LSL information than static maps and

tabular databases. Key components of effective interactive maps include the deliberate use of

data, thoughtful selection of colors and symbology, and awareness of inclusivity. Exhibit 7-1 shows

how the Greater Cincinnati Water Works, Ohio uses colors to denote materials information for

service lines by property.

Fundamental to an inventory map is a layer of locational data that displays the service line

material, such as points or polygon boundaries. The locational data should be the primary data

displayed on the map. A best practice for map development is to only display informative data to

the users. For example, while utilities may have access to geospatial railway data, adding this layer

to the map is not critical to the user and distracts from the intention of the map. Layer attributes

in online maps can be displayed using pop-up tables, color-coding, or map symbology to display

attributes. Of particular note is the use of service line symbology to denote the service line

material on the customer-owned side versus the system-owned side of the service line, as

demonstrated in Exhibit 7-1.

Guidance for Developing and Maintaining 7-7 August 2022

a Service Line Inventory

Exhibit 7-1: Greater Cincinnati Water Works Service Line Information Map

Source: Greater Cincinnati Water Works Service Line Information map.

https://gcww.maps.arcgis.com/apps/webappviewer/index.html?id=0a170c268c694e46a8a4e394630df0bd

Accessed December 16, 2021.

Accessibility and inclusivity considerations should be made throughout the map development

process (Woods and Webb, 2021). These include:

• Using a color-blind safe color scheme,

• Using simple terminology and defining acronyms, and

• Offering text in multiple languages, where appropriate.

Color-blind sensitive map color schemes are simple to create using free online tools. Alternatively,

map interfaces could include a check box to allow users to select their preferred color scheme

from a list of options. Another important component of map accessibility is terminology. The

inventory process involves acronyms and terms generally unfamiliar to the intended public

audience. Map text should be carefully reviewed for these types of language and edited

accordingly. Lastly, the map interface should be made available in multiple languages, as

appropriate, depending on the population served by the system. For example, to serve the

Guidance for Developing and Maintaining 7-8 August 2022

a Service Line Inventory

Spanish-speaking population of the Tucson, Arizona, the service line map

displays all map text

both in English and Spanish. Water systems may also want to consider providing alternate text for

maps that can be read aloud using software for the visually impaired.

7.2.3 Public Data Sharing Alternatives

Some systems may not have the capacity for online GIS map applications. In these cases, there

may be other online data sharing methods that better fit the needs of systems and their users.

Important first steps are to determine what established online data sharing capabilities and

protocols are already in place and what types of inventory information are going to be shared

(e.g., tabular data versus narrative information).

Many systems may have a website where a new webpage or subsection could be added for

hosting inventory document downloads and updates. Depending on the website structure and

server limitations, this option may only be available for small-sized documents. Some systems may

have a File Transfer Protocol (FTP) site where the data could be hosted and linked to for

download. Utilizing an FTP server may be optimal for some systems because FTP sites are better

suited for transferring large data files. If systems do not have the capacity to provide downloads

via their own servers, there are many options for cloud-based server storage that can easily be

shared and downloaded. See Exhibit 7-2 for a summary of online data sharing alternatives.

Exhibit 7-2: Examples of Online Data Sharing Alternatives

File Sharing Method Description

Online Cloud-based

Data Sharing

Cloud-based storage and data sharing allows access to files from any computer,

hosted by a third-party vendor; base storage plans may be free.

Online Spreadsheet

Cloud-based spreadsheets, some of which can be accessed online without any

product licensure or installation requirements; this may be a good option for

systems with little data infrastructure.

FTP/SFTP Server

Standard file sharing protocol for transferring files from a server to another

computer (client); water systems may already have FTP functionality they can

use.

System Website

Data may be hosted on a system’s website as text or image or can be made

available in a downloadable format.

The best platform for online data sharing will vary by system. Another key part of that decision-

making process is the data format and complexity. For example, a system without their own

online data sharing platform (server) and a simple spreadsheet-based inventory may elect to use

https://cotgis.maps.arcgis.com/apps/Cascade/index.html?appid=13b3899bb7374156a031414de36007fe. Accessed

December 8, 2021.

Guidance for Developing and Maintaining 7-9 August 2022

a Service Line Inventory

an online spreadsheet. Users could then access the inventory spreadsheet via a weblink on the

system’s website. Systems wanting to share high-resolution PDF maps, however, may consider a

data sharing option optimized for large file sizes. This may be a good option if the system already

has an FTP server for public file sharing. If not, a cloud-based file sharing option could be a good

solution.

The circumstances of some systems and users may not allow for web-based data sharing of any

kind. In these cases, systems will need to develop a plan for effectively distributing inventory

information without the use of electronic data sharing. Potential data sharing options include:

• Printed service line maps

• Printed tabular data

• Information in water utility mailings or newsletters

• Information available at the water system’s office

7.2.4 Public Input and Updates

Active community participation in the inventory process helps cultivate a more robust inventory

dataset and engage the community on public health issues potentially affecting them. LSL data can

be strengthened by asking for public feedback on existing inventory data or possible updates to

information on LSLs or GRRs not already reflected in the inventory. Given this participatory

process, there is also a higher likelihood of continued and widespread engagement with the

inventory and LSLR efforts throughout a system’s distribution network.

Public feedback can take many forms. For example, the system can provide contact information

on the system’s website for individuals to submit corrections and updates via email or phone.

Another example can be a user submission form where customers identify the service line

material and include photographic evidence, providing an additional level of confidence to their

classification. Inventories that are updated regularly based on public input should consider

indicating the dataset version or the date of the last update in an obvious location.

Providing a platform for public input provides an opportunity for users to learn about their own

service line and the presence of LSLs more broadly. An additional consideration for encouraging

community awareness is offering an email subscription for regular updates on the service line

inventory, such as Denver Water who offers a subscription opportunity within their service line

inventory map (Exhibit 7-3).

Guidance for Developing and Maintaining 7-10 August 2022

a Service Line Inventory

Exhibit 7-3: Denver Water’s Lead Service Line Replacement Map

Source: https://dw.maps.arcgis.com/apps/View/index.html?appid=cb5d6630085b4e4b96ff7fd1adf39025.

Accessed December 15, 2021.

EPA suggests updating the inventory in real-time (or as close as possible) to provide the public

with the most up-to-date information. Externally facing updates to the inventory may require

quality assurance and quality control or may be most efficiently processed in batches rather than

updated continuously.

7.3 Considerations for States

States seeking to determine a system’s compliance with the LCRR inventory requirements may use

the checklist in Appendix A. One component of that review is determining a system’s compliance

with its public accessibility requirements. Appendix A includes a checklist that states can use to

help document if systems meet these requirements. This form is also available electronically at

EPA’s website (https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-

rule).

In their 2022 framework, the Association of State Drinking Water Administrators (ASDWA)

recommends that states consider additional ways to make the relevant information available to

the public, including hosting information on the state’s website (ASDWA, 2022). For example,

states could consider creating a portal or using another method to allow systems to upload their

Guidance for Developing and Maintaining 7-11 August 2022

a Service Line Inventory

information directly. For a full list of additional considerations, refer to ASDWA’s framework

(ASDWA, 2022).

7.4 Consumer Confidence Report Inventory Requirements

The LCRR requires CWSs to include in their annual CCR a statement that they have prepared a

service line inventory and instructions on how to access the inventory (40 CFR §141.84(a)(10) and

§141.153(d)(4)(xi)). Systems with no lead, GRR, or lead status unknown service lines can instead

provide a statement that they have no LSLs or GRRs with the description of methods used to make

that determination (40 CFR §141.84(a)(9)). EPA may potentially revise these requirements under

the Lead and Copper Rule Improvements (LCRI). Regardless of the final LCRI requirements, EPA

recommends that systems provide inventory-related information in their CCRs.

Guidance for Developing and Maintaining 7-12 August 2022

a Service Line Inventory

Key Points to Remember

LCRR Requirements

 Water systems must make an inventory of the lead and GRR service lines publicly

accessible. The publicly accessible inventory must include a location identifier associated

with each lead or GRR service line (40 CFR §141.84(a)(8)(i)). The identifier could be a

specific address; however, this is not required under the LCRR.

 Water systems serving more than 50,000 people must provide their inventory online (40

CFR §141.84(a)(8)(ii)).

 Non-lead systems can fulfill the requirement to make the inventory publicly accessible by

providing a statement they have no LSLs and including a general description of how they

made that determination (40 CFR §141.84(a)(9)).

 CWSs must indicate in their CCR how to access service line inventory information. Non-

lead CWSs must also include a statement they have no LSLs in their CCR (40 CFR

§141.84(a)(10)).

 Within 30 days of completion of the initial inventory, systems must notify persons served

by lead, GRR, and lead status unknown lines (40 CFR §141.85(e)).

Recommendations (Not Required under the LCRR)

 Water systems should consider their data sharing infrastructure, customer demographics,

and staff limitations when selecting the best method for sharing data with the public.

 An interactive online mapping application can be an effective means for distributing

service line inventory information and allows users to comprehensively evaluate a water

system’s service line materials anywhere there is access to a basic computer and internet.

 Accessibility and inclusivity considerations should be made throughout the map

development process, e.g., using a color-blind safe color scheme, providing alternate text

that can be read aloud using software for the visually impaired, using simple or defined

terminology, and offering text in multiple languages.

 Other online data sharing options are available for water systems, such as online cloud-

based sharing, online spreadsheet, FTP/SFTP server, and website hosted download.

 Non-web-based data sharing options include printed service line or tabular data as well as

information on water utility mailings or newsletters.

 Active community participation in the inventory process helps cultivate a more robust

inventory dataset.

 EPA suggests water systems update their inventories in real-time or as close as possible.

Guidance for Developing and Maintaining 8-1 August 2022

a Service Line Inventory

Chapter 8: References

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search for lead pipes in Flint, Michigan. Proceedings of the 24th ACM SIGKDD International

Conference on Knowledge Discovery and Data Mining, 5–14.

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American Water Works Association (AWWA). 2021. Developing Lead Service Line Inventories –

Minimizing Regrets [Webinar]. June 30, 2021. https://www.youtube.com/watch?v=a6hDAB7cJKo

Association of State Drinking Water Administrators (ASDWA). 2019. August 2019 White Paper.

Developing Lead Service Line Inventories. Not Published.

ASDWA. 2020. Predictive Tools For Lead Service Inventories. https://www.asdwa.org/past-events-

webinar-recordings/?mgi_158=19130/predictive-tools-for-lead-service-line-inventories.

ASDWA and BlueConduit. 2020. Principles of Data Science for Lead Service Line Inventories and

Replacement Programs.

ASDWA. 2022. State Implementation Framework for the Lead Service Line Inventory

Requirements under EPA’s Lead and Copper Rule Revisions (LCRR). February 2022.

https://www.asdwa.org/wp-

content/uploads/2022/02/ASDWA_Framework_Lead_Service_Line_Inventories_Feb.-2022.pdf.

Baribeau, H. 2021. Lead Service Line Identification Tools to Develop Material Inventories. AWWA

Virtual Summit: Lead & Water Quality, April 7-8, 2021.

Bolenbaugh, S. and Pickering, W. 2018. Locating the Lead in Pittsburgh. May 2018. Pennsylvania

AWWA. https://www.paawwa.org/wp-content/uploads/2018/05/Bolenbaugh.pdf.

Bukhari, Z., Ge, S., Chiavari, S., and Keenan, P. 2020. Lead Service Line Identification Techniques.

The Water Research Foundation.

California Water Board. 2020. Preparing a Service Line Inventory: How to Get Started and Where

to Find Information.

https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/documents/leadservicelin

einvpws/sls_sguide_v1.pdf

Cartier, C., Bannier, M., Pirog, M., Nour, S., and Prevost, M. 2012. A rapid method for lead service

line detection. Journal AWWA, 104(11), E596–E607. https://doi.org/10.5942/jawwa.2012.104.0143

Deb, A. K., Y. J. Hasit, and F. M. Grablutz. (1995). Innovative Techniques for Locating Lead Service

Lines. Water Research Foundation.

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a Service Line Inventory

Denver Water. 2019. Lead Reduction Program Plan. Draft for Public Comment. Version 1.0. July 11,

2019. lead-reduction-program-plan.pdf (denverwater.org). Accessed December 2, 2021.

Del Toral, M., Porter, A., & Schock, M. (2013). Detection and evaluation of elevated lead release

from service lines: A field study. Environmental Science & Technology, 47, 9300–9307.

Deshommes, E., Bannier, A., Laroche, L., Nour, S., & Prevost, M. 2016. Monitoring-based

framework to detect and manage lead water service lines. Journal AWWA,108(11), E555–

E570.https://doi.org/10.5942/jawwa.2016.108.0167

Duffy, D. T., and Pickering, W. J. 2021. Developing and Verifying a Water Service Line Inventory.

Journal-American Water Works Association, 113(3), 6-13.

Feick, J. (2018). Flint water line replacement company says, "this is costing us serious money."

Sinclair Broadcast Group. https://nbc25news.com/news/local/flint-water-line-replacement-

company-says-this-is-costing-us-serious-money

Hensley, K., Bosscher, V., Triantafyllidou, S., and Lytle, D. A. 2021. Lead service line identification: A

review of strategies and approaches. AWWA Water Science, 3(3), e1226.

Hiltner, S., Romero-Canyas, R., McCormick, L., & Neltner, T. (2019). Using online tools to publicize

lead service line locations and promote replacement. AWWA Water Science, 1(1), e1124.

Katerndahl, D., & Bizal, T. (2003). Damage prevention project—final report. Mid-America Regional

Council. https://www.marc.org/Government/Local-Government-Services/pdf/Damage-Prevention-

Full-Report.

Kuhl, R. (2018). Letter to Angela Wheeler and William Kim (City of Flint, Department of Law). State

of Michigan, Department of Attorney General.

Lewis, C. M., Couillard, L. A., Klappa, P. J., & Vandenbush, T. D. (2017). Lead water service lines:

Extensive sampling and field protocol protect public health. Journal AWWA, 109(1), 34–41. https://

doi.org/10.5942/jawwa.2017.109.0016.

Liggett, J. 2021. Revised Lead and Copper Rule Inventory Requirements [Webinar]. AWWA Virtual

Summit: Lead & Water Quality, April 7-8, 2021.

Liggett, J., Baribeau, H., Deshommes, E., Raisle, M., Lytle, D., Masters, S., Muylwyk, Q., and

Triantafyllidou, S. February 2022. Service Line Material Identification Strategies: The Experiences of

Ten North American Water Systems.

LSLR Collaborative. 2018. Counting and Communicating the Number and Location of LSLs. Preparing

a Lead Service Line Inventory [Webinar]. October 10, 2018. https://www.lslr-

collaborative.org/webinars/counting-and-communicating-the-number-and-location-of-lsls

Guidance for Developing and Maintaining 8-3 August 2022

a Service Line Inventory

LSLR Collaborative. 2020. Engaging Communities in Planning and Communicating about LSL

Replacement [Webinar]. September 16, 2020. https://www.lslr-

collaborative.org/webinars/engaging-communities-in-planning-and-communicating-about-lsl-

replacement

LSLR Collaborative. 2021. Preparing a Lead Service Line Inventory. Accessed: October 12, 2021.

https://www.lslr-collaborative.org/preparing-an-inventory.html

Lu, H., Romero-Canyas, R., Hiltner, S., Neltner, T., McCormick, L., & Niederdeppe, J. 2019. Research

to move toward evidence-based recommendations for lead service line disclosure policies in home

buying and home renting scenarios. International journal of environmental research and public

health, 16(6), 963.

McCormick, L., S. Lovell, and T. Neltner. 2017. Grading the Nation: State Disclosure Policies for Lead

Pipes. EDF Health. Revised March 14, 2017.

https://www.edf.org/sites/default/files/content/edf_lsl_state_disclosure_report_final-031317.pdf.

Michigan Department of Environment, Great Lakes, and Energy (EGLE). 2018. Michigan

Administrative Code. Supplying Water to the Public. https://www.michigan.gov/egle/0,9429,7-

135-3313_3675_3691-9677--,00.html. Accessed December 7, 2021.

Michigan EGLE. 2021. Minimum Service Line Material Verification Requirements. Revised March

2021. https://www.michigan.gov/documents/egle/egle-dwehd-min-service-line-material-

verification-req_720143_7.pdf

Muylwyk, Q. (2020). Denver water's LSL inventory predictive model and LSLR prioritization

[webinar]. Association of State Drinking Water Administrators. https://www.asdwa.org/wp-

content/uploads/2020/04/Quirien-Muylwyk-Predictive-Tools-for-Lead-Service-Line-

Inventories.pdf.

National Public Radio. (2016). Do you have lead pipes in your home? Retrieved from NPR Find the

lead pipes in your home (npr.org). Accessed December 15, 2021.

Oswald, E. (2018). Letter to Karen W Weaver (Mayor of Flint, MI). State of Michigan, Department

of Environmental Quality.

Sandvig, A., P. Kwan, G. Kirmeyer, B. Maynard, D. Mast, R.R. Trussell, S. Trussell, A. Cantor, and A.

Prescott. 2008. Contribution of Service Line and Plumbing Fixtures to Lead and Copper Rule

Compliance Issues. Denver, CO: AWWA Research Foundation.

Schock, M., Lytle, D., James, R., Lal, V., Tang, M. 2021. Rapid and simple lead service line detection

screening protocol using water sampling. AWWA Water Science, 3(5), e1255.

https://doi.org/10.1002/aws2.1255

Guidance for Developing and Maintaining 8-4 August 2022

a Service Line Inventory

Schmelling, M. 2019. Lead service line identification and replacement webinars. Retrieved from

USEPA website. https://www.epa.gov/dwreginfo/lead-service-line-identification-and-

replacement-webinars

Schmelling, M. 2021. DC Water’s Service Line Inventory and Display Maps. ASDWA Annual

Conference 2021. ASDWA Annual Conference 2021 Lead Service Line Inventories - YouTube.

(https://www.youtube.com/watch?v=IaZEbnXnQpQ). Accessed January 19, 2022.

United States Environmental Protection Agency (USEPA). 1980. Interim Primary Drinking Water

Regulations; Final Rule. Federal Register 45(168): 57346. August 27, 1980. Washington, D.C.:

Government Printing Office. https://www.govinfo.gov/content/pkg/FR-1980-08-27/pdf/

FR-1980-08-27.pdf#page=1. Accessed December 15, 2021.

USEPA. 1991a. Drinking Water Regulations; Maximum Contaminant Level Goals and National

Primary Drinking Water Regulations for Lead and Copper; Final Rule. Federal Register 56(110):

26460. June 7, 1991. Washington, D.C.: Government Printing Office.

USEPA. 1991b. Lead and Copper Rule Guidance Manual. Volume I: Monitoring. September 1991.

Prepared by Black & Vetch and Malcolm Pirnie, Inc. for EPA’s Office of Ground Water and Drinking

Water.

USEPA. 2017. Concerned About Lead in Drinking Water? Sources of Lead in Drinking Water. 2017.

epa_lead_in_drinking_water_final_8.21.17.pdf. Accessed December 6, 2021.

USEPA. 2021a. Review of the National Primary Drinking Water Regulation: Lead and Copper Rule

Revisions (LCRR); Notification of conclusion of review. Federal Register 86(240): 71574. December

17, 2021. Washington, D.C.: Government Printing Office.

USEPA. 2021b. Seventh Drinking Water Infrastructure Needs Survey and Assessment: Lead Service

Line Inventory for America’s Water Infrastructure Act – State Survey Instruction. January 2021.

USEPA. 2021c. National Primary Drinking Water Regulations: Lead and Copper Rule Revisions;

Final Rule. Federal Register 86(10): 4198. January 15, 2021. Washington, D.C.: Government

Printing Office.

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Delay of Effective and Compliance Dates. Final Rule. Federal Register 86(114): 31939. June 16,

2021. Washington, D.C.: Government Printing Office.

USEPA. 2021e. USEPA virtual video meeting with Grand Rapids Water System. October 13, 2021.

USEPA. 2022. Memorandum - Implementation of the Clean Water and Drinking Water State

Revolving Fund Provisions of the Bipartisan Infrastructure Law. Radhika Fox, Assistant

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Administrator of Water. March 8, 2022. https://www.epa.gov/system/files/documents/2022-

03/combined_srf-implementation-memo_final_03.2022.pdf.

Walker, E. (2020). 120Water: Lead service line probability finder and predictive intelligence

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Weaver, K. 2018. RE: MDEQ July 23, 2018 letter regarding Lead Service Line Identification and

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Built A Better Map for Flint, MI [Webinar]. BlueConduit. AWWA Virtual Summit: Lead & Water

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https://www.mlive.com/news/flint/ 2018/10/post_513.html.

APPENDICES

• Appendix A: Blank Forms from the EPA Service Line Inventory Template

• Appendix B: Case Studies

• Appendix C: Instructions for Self-Identifying LSLs and Information When Water System

Conducts Verification

• Appendix D: Summary of State Lead Ban Provisions by State

• Appendix E: Michigan Minimum Service Line Verification Requirements

• Appendix F: Examples of Data Quality Disclaimer Language

Guidance for Developing and Maintaining A-1 August 2022

a Service Line Inventory

Appendix A: Blank Forms from the EPA Service Line Inventory Template

PWS Information

Inventory Methodology

Inventory Summary

Public Accessibility Documentation

State Checklist

See EPA’s website at:

https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule for a

downloadable, spreadsheet version of the template which contains the forms below as well as

additional sheets for inventory tracking.

•

Guidance for Developing and Maintaining A-2 August 2022

a Service Line Inventory

PWSID:

Population Served

(number of people):

Number of Service

Connections:

PWS Type:

CWS NTNCWS

Indicate "Yes" or "No"

State: Zip Code:

Title:

Email:

Title/Affiliation:

Email:

PWS Information

Purpose of this worksheet:

For water systems to document basic system information.

Street or P.O. Box:

City or Town:

Water System Name:

Facility Information

Mailing Address

If you are a CWS, do multi-family residences comprise at least 20% of

the structures you serve?

System Contact Person

Telephone:

Name:

Person Who Prepared Inventory (if different from above)

Name:

Telephone:

•

Guidance for Developing and Maintaining A-3 August 2022

a Service Line Inventory

Enter Date Last Updated:

Type of Record

1. Previous Materials Evaluation

Example: Locations of Tier 1 lead tap sampling

locations that are served by a lead service

line.

2. Construction Records and Plumbing Codes

Examples: Local ordinance adopting an

international plumbing code. Permits for

replacing lead service lines.

3. Water System Records

Examples: Capital improvement plans.

Standard operating procedures. Engineering

standards.

4. Distribution System Inspections and

Records

Examples: Distribution system maps. Tap

cards. Service line repair/replacement

cords. Inspection records. Meter installation

records.

5. Additional Records Required by Your State

6. Other Records

Inventory Methodology

Part 1: Historical Records Review

Purpose of this worksheet: For water systems to document the methods and resources they used to develop and

update their inventory.

PWS Name:

PWSID:

Describe the Records Reviewed for Your Inventory and Indicate

Your Level of Confidence (e.g. , Low, Medium, or High)

•

Guidance for Developing and Maintaining A-4 August 2022

a Service Line Inventory

Water meter reading Water main repair or replacement

Water meter repair or replacement

Backflow prevention device

Service line repair or

replacement

Other

Indicate "Yes" or

"No"

Visual Inspection at the Meter Pit Water Quality Sampling - Other

Customer Self-Identification Mechanical Excavation

CCTV Inspection at Curb Box - External Vacuum Excavation

CCTV Inspection at Curb Box - Internal Predictive Modeling

Water Quality Sampling - Targeted Other

Water Quality Sampling - Flushed

Water Quality sampling - Sequential

Inventory Methodology (Continued)

Part 3: Service Line Investigations

1. Identify the service line investigation methods your system used to prepare the inventory (check all that

apply). If a water system chooses an investigation method not specified by the state under 40 CFR

§141.84(a)(3)(iv), state approval is required. Note that investigations are not required by the LCRR but can be

used by systems to assess accuracy of historical records and gather information when service line material is

unk

nown.

If "Other", please explain:

2. If "Predictive Modeling", please briefly describe the model and inputs used:

3. How did you prioritize locations for service line materials investigations? For example, did you consider

environmental justice and/or sensitive populations, did you use predictive modeling, and/or did you target

areas with high number of unknowns?

1. During which normal operating activities are you collecting information on service line material? Check all

If "Other", please explain:

2. Did you develop or revise standard operating procedures to collect service line

material information

If "Yes", please describe:

Part 2: Identifying Service Line Material During Normal Operations

•

Guidance for Developing and Maintaining A-5 August 2022

a Service Line Inventory

Enter Date Last Updated:

1. Is this the Initial Inventory or an Inventory Update?

2a. Who owns the service lines in your system?

2b. Is there documentation that defines service line ownership in your system, such as a local ordinance? If yes, please

describe below and explain where ownership is split (e.g., property line, curb stop).

Describe your inventory format in the space provided below (e.g. , the Detailed Inventory worksheet, custom

spreadsheet, GIS map). Provide the filename and/or web address if applicable. Note that the state may require you to

submit your detailed inventory of each service line in your distribution system.

5. What is your overall level of confidence in the inventory (i.e. , "Low", "Medium", or "High.") Please explain your

rationale below.

Indicate "Yes", "No", or "Don't Know"

3b. When were lead service lines banned in your system? Reference the state or local ordinance that banned the use of

lead in your system.

Inventory Summary

Part 1. General Information

PWS Name:

PWSID:

Purpose of this worksheet: For water systems to provide a summary of their service line inventory, including information

on ownership, inventory format, and the number of service lines for each of the four required materials classifications.

Part 2. Inventory Format

4. Do you have lead goosenecks, pigtails or connectors in your system?

3a. Describe when lead service lines were generally installed in your system.

•

Guidance for Developing and Maintaining A-6 August 2022

a Service Line Inventory

Service Line Material

Classification

Total Number of Service Lines

(REQUIRED to be reported

under the LCRR)

Lead

Galvanized Requiring

Replacement (GRR)

Non-Lead

Lead Status Unknown

Notes

Inventory Summary (Continued)

A lead-lined galvanized service line is consistent with the definition of an LSL under the LCRR (“a portion of pipe that is made of

lead, which connects the water main to the building inlet”) (40 CFR §141.2) and must therefore be classified in the inventory as an

LSL. Do NOT, however, count non-lead service lines with a lead gooseneck or pigtail as lead service lines unless required by your

state.

Enter the number of service lines in the aqua-colored cells. Remember this is the classification for the entire service line.

This summary table is for reporting material for the entire service line connecting the water main to the customer's plumbing. See

Section 2.1 for additional guidance on assigning a materials classification to the entire service line when ownership is split.

Remember that systems must track the system-owned and customer-owned portions separately in their inventory.

TOTAL

The service line material is not known to be lead or GRR.

For the entire service line or a portion of it (in cases of split

ownership), there is not enough evidence to support

material classification.

Part 3. Inventory Summary Table

Definition

Any portion of the service line is known to be made of

lead.

All portions of the service line are known NOT to be lead or

GRR through an evidence-based record, method, or

technique.

The service line is not made of lead, but a portion is

galvanized and the system is unable to demonstrate that

the galvanized line was never downstream of a lead service

line.

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Guidance for Developing and Maintaining A-7 August 2022

a Service Line Inventory

Enter Date Last Updated:

Address

Street

Block

Intersection

Landmark

GPS Coordinates

Other

Interactive online map

Static online map

Online spreadsheet

Printed service line map

Printed tabular data

Information on water utility mailings or newsletter

Hard copy information available in water system office

Other

If "No", explain. Remember that location identifiers are required for service lines that are lead and galvanized

requiring replacement.

Public Accessibility Documentation

Purpose of this worksheet: For systems to provide documentation to states on how they met the public

accessibility requirements of the LCRR.

3. How are you making your inventory publicly accessible? Check all that apply. Remember that if your system

serves > 50,000 people, you must provide the inventory online.

If "Other", please describe:

1. Select the location identifiers that you use for your service line inventory. Check all that apply.

If "Other", please describe:

PWS Name:

PWSID:

2. Does every service line have a location identifier? Indicate "Yes" or "No"

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Guidance for Developing and Maintaining A-8 August 2022

a Service Line Inventory

Title:

Email:

Indicate "Yes" or "No"

3. Did the system classify all service lines as either Lead, Galvanized

Requiring Replacement (GRR), Non-Lead, or Lead Status Unknown?

Consider if the system completed each row of the inventory summary table in the Inventory Summary

worksheet, Part 3. Some rows may be zero.

4. In the space below, provide additional comments/documentation related to required elements of the

system's initial inventory.

2. Does the inventory include portions owned by the water system and

the customer?

Check the service line ownership type selected in the Inventory Summary worksheet, Part 1, Question 2a.

If the system selected "Ownership is Split" check that their inventory includes information for both the

system-owned and customer-owned portions.

1. Does the inventory include all service lines connected to the

distribution system?

Consider if the total number of service lines in the Inventory Summary worksheet, Part 3, matches sanitary

survey and monitoring data in the state’s database (e.g., S

DWIS /State ) based on population served, number

of service connections (including those for non-potable use), number of accounts, census data, or other

information.

Part 2: Review for Timely Submission

1. Was the initial inventory submitted by the deadline of October 16,

2024?

Consider post-mark or date sent via email or reported into a state data system.

Part 3: Review for Required Elements

State Checklist for Initial Inventory Submittal

Purpose of this worksheet: For states to determine and document if water systems met all of the January 15,

2021 Lead and Copper Rule (LCRR) requirements for their Initial Inventory i

ncluding timely submission, required

elements, use of information sources, public accessibility, and public notification of service line materials.

Part 1: Person Completing This Checklist

Name:

Telephone:

PWS Name:

PWSID:

Enter Date Last Updated:

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Guidance for Developing and Maintaining A-9 August 2022

a Service Line Inventory

Indicate "Yes" or "No"

Part 4: Review for Information Sources

State Checklist for Initial Inventory Submittal (Continued)

This is not required by the LCRR but recommended by EPA to verify historical records and gather information

where records do not exist to reduce the number of unknowns in the system as quickly as possible. Consider:

• If the system checked one or more of the investigative methods on the Inventory Methods worksheet, Part 3.

• If in their inventory, the system indicated that the materials classification was based on investigations.

• The number of unknowns - EPA strongly discourages systems from submitti ng inventories with all unknowns.

If all service line materials are lead status unknown, consider asking the water system to conduct

investigations.

1. Did the system use the following historical records to prepare their

initial inventory: previous materials evaluation, construction and

plumbing codes/records, water system records, distribution system

inspections and records.

2. Is the system collecting service line material information during normal

operations?

3. Has the system conducted investigations to verify service line material?

Consider reviewing the method by which the water system is making its inventory publicly accessible as

identified in the Public Accessibility Doc. worksheet, Question 3. Check that systems serving more than

50,000 people have posted their service line inventories online.

3. In the space below, provide additional comments/documentation related to public accessibility of the

system's initial inventory.

4. In the space below, provide additional comments related to information sources used to develop the

system's initial inventory.

1. Does the inventory include location identifiers for each service line that

is lead or galvanized requiring replacement?

Consider checking the inventory for location identifiers and reviewing the system's answers in the Public

Accessibility Doc. worksheet, Questions 1 and 2.

2. Did the system make its inventory publicly accessible?

Part 5: Review for Public Accessibility

Consider if the system checked one or more normal operations activities in the Inventory Methods worksheet,

Part 2. Consider asking the systems to submit updated or new standard operating procedures documenting

service line material information collection.

Consider if the system identified historical records in each row of the Inventory Methods worksheet, Part 1,

Rows 1 through 4. Consider if the system completed Row 5 if additional records are required in your state.

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Guidance for Developing and Maintaining A-10 August 2022

a Service Line Inventory

Indicate "Yes" or "No"

6. In the space below, provide additional comments/documentation related to customer notification for

people served by an LSL, GRR, or lead status unknown service line.

c. For Unknowns, does the notification include:

Indicate "Yes" or "No" or "N/A"

5. If the water system serves communities with a large proportion of non-

English speaking consumers, as determined by the state, did they provide

public education materials, including those in 40 CFR §141.85(e), in the

appropriate language(s) or containing a telephone number or address

where persons served may contact the water system to obtain a

translated copy of the materials or to request assistance in the

appropriate language?

• A statement that the service line material is lead status unknown,

• Information on lead health effects including mandatory health l

effects language of 40 CFR §141.85(a)(ii),

• Steps to minimize exposure to lead in drinking water, and

• Opportunities to verify the service line material?

b. For GRRs, does the notification include:

Indicate "Yes" or "No" or "N/A"

• A statement that the service line material is GRR,

• Information on lead health effects including mandatory health

effects language of 40 CFR §141.85(a)(ii),

• Steps to minimize exposure to lead in drinking water, and

• Opportunities for service line replacement?

a. For confirmed LSLs, does the notification include:

Indicate "Yes" or "No" or "N/A"

• A statement that the service line material is lead,

• Information on lead health effects including mandatory health

effects language of 40 CFR §141.85(a)(ii),

• Steps to minimize exposure to lead in drinking water,

• Opportunities for service line replacement,

• Available financing programs, and

• A statement that the system must replace its portion if the

they are replacing their portion?

If No, complete questions 2 through 5. If Yes, stop here.

2. Did the water system deliver the notification to people served by a lead

service line (LSL), GRR, or lead status unknown service line within 30 days

of completing the initial inventory?

3. Did the water system demonstrate that they delivered the notification

and provide a copy of the notification to the state by July 1 for the

previous calendar year?

4. Did the notification include the required content?

Part 6: Review of Customer Notification of Service Line Material

1. Does the water system's inventory consist of all Non-Lead Service lines?

Indicate "Yes" or "No"

State Checklist for Initial Inventory Submittal (Continued)

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Guidance for Developing and Maintaining B-1 August 2022

a Service Line Inventory

Appendix B: Case Studies

DC Water

Greater Cincinnati Water Works

Pittsburgh Water and Sewer Authority

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Guidance for Developing and Maintaining B-2 August 2022

a Service Line Inventory

DC Water

Background/Water Utility Description

DC Water provides approximately 92 million gallons of treated drinking water per day to

about 700,000 residents of the District of Columbia. DC Water is a consecutive system,

purchasing treated water from the Army Corp of Engineers. The Army Corp treats water from

the Potomac River using conventional treatment with chlorine for primary disinfection and

chloramines for secondary disinfection. Orthophosphate is added for corrosion control, along

with pH adjustment. The DC Water distribution system is comprised of approximately 1,350

miles of water main. DC Water estimates that they have 28,000 lead or galvanized iron

service lines with plans to replace them all by 2030 (DC Water, 2021a).

Consider the Inventory as a Living Data System

DC Water has a long history of identifying and replacing lead service lines (LSLs) in response

to exceeding the lead action level in 2002 through 2004 (Deignan, 2021). Schmelling (2021)

stressed that the inventory is not a one-time data extraction, but a living dataset that can be

updated as new information is collected and records are improved over time. DC Water also

records information on the integrity of the data, such as the data source.

DC Water uses many sources and methods to gather service line information, including

(Schmelling, 2019, 2021):

• Research done to identify service line materials for the original Lead and Copper

Rule (LCR) in 1991, i.e., interviews with plumbers to determine when LSLs stopped

being installed in Washington, DC (DC Water found this to be an excellent starting

point for their inventory);

• Historical records, including tap cards, permits, and engineering documents;

• Construction records on when service lines were replaced in coordination with

water main replacement or in response to service line leaks;

• Customers reporting that they replaced their service lines;

• Customer self-identification;

Key Topics

• Consider the Inventory as a Living Data System

• Water Quality Sampling to Identify LSLs

•

Making Inventory Information Publicly Accessible

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Guidance for Developing and Maintaining B-3 August 2022

a Service Line Inventory

• Water meter replacement; and

• Water quality sampling.

DC Water is also working with the Water Research Foundation to investigate non-invasive

service line identification techniques, such as x-ray diffraction, stress wavers, and acoustic

technology (Schmelling, 2021).

Water Quality Sampling to Identify LSLs

DC Water assessed the ability of 6-hour stagnation sequential samples to predict the

presence of LSLs (Bukhari et al., 2020; Schmelling, 2019). Customers collected 10 sequential

1-liter samples, indicated the suspected service line material at the point of entry (i.e., lead,

copper, brass, galvanized iron, or not visible), and provided a supporting picture when

possible. DC Water predicted that half of the 172 homes in the study had lead pipes based on

the trend of lead concentrations in the 10-bottle set. They also determined that a total lead

mass of at least 5 micrograms (µg) from all 10 samples was another factor supporting the

presence of LSLs in their system. Subsequent service line work indicated that DC Water

correctly predicted 26 of 30 homes to be lead and 2 of 4 to be non-lead. DC Water concluded

that sequential sampling is a useful tool for predicting the presence of LSLs, but it cannot

predict the absence of lead pipe due to factors that may impact the stagnation period prior to

sampling (e.g., leaks, water use, and dripping faucets). DC Water also notes the water

sampling effort is time consuming considering sample distribution and customer

communication; therefore, there is still a significant need for another non-invasive pipe

material identification technology (DC Water, 2022).

Making Inventory Information Publicly Accessible

DC Water provides an interactive map with service line pipe material data for the public and

private sides in their entire service area, which is available on their website (DC Water,

2021b). Each service address is indicated by a circle that contains two color-coded semi-

circles for the service line type: one for the public space and another for the private side.

Gray denotes lead, green indicates non-lead, and no shading indicates no information. A

screenshot of the map is provided as Figure 1.

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Guidance for Developing and Maintaining B-4 August 2022

a Service Line Inventory

Figure 1: Screenshot of DC Water Interactive Service Line Map (DC Water, 2021b).

When a service address is selected, a pop-up box appears that includes the type and

description for the public and private portions separately as well as a link to frequently asked

questions and a fact sheet on how customers can identify their water service pipe material.

The description field includes the source for the determination, e.g., when the service line

was replaced and if it was verified by test pit or visual observation (shown as “excavation”).

An example of the pop-up box is shown as Figure 2.

Figure 2: Screenshot of Description Field (DC Water, 2021b).

DC Water took several steps to clearly communicate service line information to the public.

For example, they developed a standard process for translating internal documentation for

their service line data system into plain language for the online publicly accessible map. An

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Guidance for Developing and Maintaining B-5 August 2022

a Service Line Inventory

example is shown below in Figure 3 (Schmelling, 2021). DC Water also provides their

inventory in list format as a downloadable CSV file (DC Water, 2021c).

Figure 3: DC Water Translation of Data to Public Information (Schmelling, 2021).

DC Water worked with their legal department to develop disclaimer language, as shown

below. Schmelling (2021) noted that disclaimer language is important because it recognizes

that, although the inventory is based on the best available information at the time, the

inventory is dynamic and there may be inaccuracies.

Figure 4. DC Water Disclaimer Language for Their Interactive Service Line Map (DC Water, 2021b).

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Guidance for Developing and Maintaining B-6 August 2022

a Service Line Inventory

Summary of Main Points

• DC Water’s service line inventory is a living dataset designed to add and revise data

from multiple sources over time.

• DC Water has found sequential water sampling to be a useful tool for predicting the

presence of LSLs, but it is not a good predictor of the absence of lead pipe due to

factors that may impact the pre-sampling stagnation period.

• An interactive online map is a useful tool for communicating information on service

line material to the public. It is important to translate technical data into public

information and include clear disclaimer language to communicate the limitations of

the service line inventory.

Resources

Bukhari, Z., Ge, S., Chiavari, S., and Keenan, P. 2020. Lead Service Line Identification

Techniques. The Water Research Foundation.

https://www.waterrf.org/system/files/resource/2020-06/DRPT-4693.pdf

DC Water. 2021a. Lead Free DC by 2030. https://www.dcwater.com/lead. Accessed

December 3, 2021.

DC Water. 2021b. DC Water – Service Line Information https://geo.dcwater.com/Lead/.

Accessed December 3, 2021.

DC Water. 2021c. Service Line Materials Dashboard. https://www.dcwater.com/service-line-

materials-dashboard. Accessed 1/25/2022.

DC Water. 2022. Personal communication between EPA staff and Maureen Schmelling, DC

Water. April 19, 2022.

Deignan. John. 2021. DC Water’s LSR Program Journey from Mandated to Planned [Webinar].

AWWA Virtual Summit: Lead & Water Quality, April 7-8, 2021.

https://www.awwa.org/Events-Education/AWWA-Virtual-Summits/Lead-Water-Quality-

Summit#11394909-event-faqs

Schmelling, M. 2019. Lead service line identification and replacement webinars. Retrieved

from USEPA website. https://www.epa.gov/dwreginfo/lead-service-line-identification-and-

replacement-webinars

Schmelling, M. 2021. DC Water’s Service Line Inventory and Display Maps [Webinar]. ASDWA

Annual Conference: 2021. Lead Service Line Inventories. October 18 & 19, 2021. Available at:

https://www.youtube.com/watch?v=IaZEbnXnQpQ. Accessed 1/19/22.

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Guidance for Developing and Maintaining B-7 August 2022

a Service Line Inventory

Greater Cincinnati Water Works

Background/Water Utility Description

Greater Cincinnati Water Works (GCWW) provides water services to Cincinnati, Ohio and

several surrounding counties. GCWW treats around 132 million gallons of water daily. They

use high consistent oxidation-reduction potential (ORP) (free chlorine at approximately 1.3

mg/L) and pH promoting lead (IV) scales to control corrosion (Liggett et al., 2022). GCWW

serves over 1.1 million customers through 3,180 miles of water mains (GCWW, 2021a).

In 1927, the City of Cincinnati stopped installing lead service lines (LSLs), yet some of those

LSLs still remain. GCWW estimates they have a total of 39,165 service lines that are part or all

lead, including 25,980 private, 13,085 full, and 100 public LSLs in their service area (GCWW,

2022).

Following EPA’s 1991 Lead and Copper Rule, GCWW launched a lead reduction program

(Arnette, 2020). For years, GCWW has replaced LSLs and used corrosion control treatment. In

2016, GCWW launched their Enhanced Lead Program, a two-tiered strategy that focused on

consumer education and outreach (Tier 1) and removal of all LSLs (Tier 2) (GCWW, 2021b,

Burlingame et al., 2018).

Building and Updating the Service Line Inventory

In 2000, GCWW began their effort to populate an inventory of public-side materials in GIS

using billing system information, the branch or service line number, and water main project

inspection reports (Arnette, 2020). Later, to develop an inventory of customer-side materials,

GCWW created a new attribute in GIS for the customer-side material type (Arnette, 2020). To

populate customer-side data, GCWW used the following sources of information (Arnette,

2020; Liggett et al., 2022; GCWW, 2016):

• Historical records and asset management records.

• Maintenance, repair, and replacement work.

• Work orders.

• Water main replacement inspections.

• Water main and service line records.

Key Topics

• Building and Updating Service Line Inventory

•

Interactive Public Inventory Map

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Guidance for Developing and Maintaining B-8 August 2022

a Service Line Inventory

• Customer-initiated replacement inspection reports.

• Visual inspections.

Following the effort in 2000, GCWW found that at branch number 101808, the public service

line materials transitioned from lead to copper. For the private side, GCWW also designated

the service line as lead or copper based on their branch numbers as follows:

• Branch numbers 102000 or higher and diameter of 2 inches or less as copper.

• Branch numbers below 102000 as lead except if GCWW had evidence that the

customer renewed the line, then designated as copper.

In 2016, GCWW created an electronic tool to collect information from their water main

project inspections, update their inventory, and allow the information to be available to the

public the next day (Arnette, 2020). This is accomplished using an electronic form on

inspectors’ phones created using Microsoft Power Apps. The information is sent directly to

GIS Editors. A snapshot of this app is provided as Figure 1.

Figure 1: Screenshot of Water Main Project Inspection App (Arnette, 2020).

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Guidance for Developing and Maintaining B-9 August 2022

a Service Line Inventory

The inventory is continuously updated as GCWW retrieves more data, including information

provided by customers who verify the service line material on their property using a scratch

test and an online form on the GCWW website. Step-by-step instructions, along with contact

information, are provided on GCWW’s website (GCWW, 2021c). Figure 2 below shows a

screenshot of the online form with instructions for customers to upload a picture of their

meter setting to help identify the pipe material.

Figure 2: Screenshot of Instructions and Online Form from GCWW’s website (GCWW, 2021c).

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Guidance for Developing and Maintaining B-10 August 2022

a Service Line Inventory

Interactive Public Inventory Map

GCWW developed the interactive Lead Look-up Map to provide the public with easy access to

information from their service line inventory (GCWW, 2021d). After reading and accepting a

disclaimer regarding the accuracy and use of the data (see Figure 3), users can search their

address to view a map of their service lines and materials. The map includes a legend that

identifies materials on the public and private side, shown as a divided rectangle (left side is

public side and right side is private side). The map uses a combination of colors and

symbology. A green checked box denotes non-lead, yellow and an X is lead, and gray and no

symbol indicates no information. GCWW updates their map regularly as they retrieve more

data. A snapshot of the map is provided in Figure 4.

Figure 3: Screenshot of GCWW Disclaimer Language (GCWW, 2021d).

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Guidance for Developing and Maintaining B-11 August 2022

a Service Line Inventory

Figure 4: Snapshot of the GCWW Lead Look-up Map (GCWW, 2021d).

Summary of Main Points

• Use Multiple Information Sources to Develop the Inventory. GCWW used a variety

of records to initially build the inventory and then verified and improved accuracy

using a custom-built app as well as information provided by customers.

• Develop User-friendly Tools. It is important to ensure that public-facing tools are

understandable by a range of users. Hiltner et al. (2019) found the GCWW map very

comprehensible, especially in comparison to other similar tools. A visual, with clear

legends can aid users’ understanding. Providing property-specific LSL information,

distinguishing private- and public-side information, being clear about what is not

known, and choosing legend colors and icons carefully, are all factors that can

improve the usability and understandability of a tool.

Resources

Arnette, V. 2020. Greater Cincinnati Water Works Lead Service Line Replacement – Inventory,

Identification, and Replacement. The Water Research Foundation. Lead Service Line

Identification, Inventories, and Replacement Webcast. June 23, 2020.

https://www.waterrf.org/sites/default/files/file/2020-

06/WRF%20LSL%20Inventory%20Webcast_FINAL.pdf. Accessed February 7, 2022.

Burlingame, G.; C. Bailey; J. Nelson; V. Arnette; S. Bradway; A. Holthouse Putz; A. Stark; P.

Schwer; L. Sanborn; J. E. Tobiason; S. Via. 2018. Lessons Learned From Helping Schools

Manage Lead in Drinking Water to Protect Children’s Health. Journal AWWA. October 2018.

https://awwa.onlinelibrary.wiley.com/doi/abs/10.1002/awwa.1169

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a Service Line Inventory

Greater Cincinnati Work Works (GCWW). 2016. H20connection. December 30, 2016.

https://la.mygcww.org/wp-content/uploads/2019/02/2017_January_H2Oconnection.pdf.

GCWW. 2021a. 2020 GCWW Water Quality Report. https://www.cincinnati-

oh.gov/water/water-quality-and-treatment/water-quality-reports/2020-water-quality-

report/. Accessed December 14, 2021.

GCWW. 2021b. Enhanced Lead Program. https://la.mygcww.org/enhanced-lead-program/.

Accessed December 14, 2021.

GCWW. 2021c. Identify Your Service Line. https://la.mygcww.org/do-i-have-a-lead-service-

line/. Accessed December 14, 2021.

GCWW. 2021d. Greater Cincinnati Water Works Service Line Information.

https://gcww.maps.arcgis.com/apps/webappviewer/index.html?id=0a170c268c694e46a8a4e

394630df0bd. Accessed December 14, 2021.

GCWW. 2022. Personal communication between EPA and GCWW staff. Feb 2, 2022.

Hiltner, S., Romero-Canyas, R., McCormick, L., Neltner, T. 2019. Using online tools to publicize

lead service line locations and promote replacement. AWWA Water Science e1124 1-15.

https://awwa.onlinelibrary.wiley.com/doi/abs/10.1002/aws2.1124

Liggett, J., Baribeau, H., Deshommes, E., Raisle, M., Lytle, D., Masters, S., Muylwyk, Q,

Triantafyllidou, S. 2022. Service Line Material Identification: Experiences from North

American Water Systems. Journal AWWA. January 2022.

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Guidance for Developing and Maintaining B-13 August 2022

a Service Line Inventory

Pittsburgh Water and Sewer Authority

Background/Water Utility Description

The Pittsburgh Water and Sewer Authority (PWSA) provides water to 520,000 people in the

Pittsburgh area (USEPA, 2021). Publicly owned and operated, the system produces a daily

average of 69.6 million gallons of finished water (PWSA, 2021a). Approximately 965 miles of

water lines and 11 tanks comprise the distribution system (PWSA, 2021b). Water is treated

using a clarifier pretreatment system and rapid sand filtration system (PWSA, 2021c). In the

spring of 2019, PWSA also optimized their corrosion control treatment by switching to

orthophosphate, resulting in consistently lower lead levels (PWSA, 2021d). The initial water

distribution system was put into service in 1828 and expanded over time through the early

half of the 1900s (PWSA, 2021c). In November of 2020, PWSA estimated that in their system,

there are 10,995 public and 28,171 private lead service lines (LSLs), and 14,440 public and

4,997 private service lines of unknown material (Liggett et al., 2022).

Inventory Approach

Unless otherwise noted, the source of information for the inventory approach is the 2021

Journal AWWA Article Developing and Verifying a Water Service Line Inventory. Duffy, D. and

Pickering, W. (2021).

Overview

PWSA began updating their inventory of service line materials in 2016. To organize and

publicize their service line inventory, PWSA launched an online Lead Map on their website

(Figure 1). They update the map monthly as they gather more data. Users can search their

unique address on the map to display the results for their service line materials on the public-

and private-side, as well as to display the source of that data (Figure 2). Data sources include

historical records, verification by excavation, replacement information, and curb box

inspection (CBI) results.

Key Topics

• Dealing with Uncertain Historical Records

• Experience with Field Techniques

• Statistical (Predictive) Data Analysis

• Innovative Field Data Forms

• Example of the Continuous Improvement

Approach

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Guidance for Developing and Maintaining B-14 August 2022

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Figure 1: Snapshot of PWSA Lead Map (PWSA, 2021e).

Figure 2: Snapshot of a neighborhood in Pittsburgh, PA, as viewed on the PWSA Lead Map (PWSA,

2021e).

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Guidance for Developing and Maintaining B-15 August 2022

a Service Line Inventory

Dealing with Uncertain Historical Records

To begin their service line inventory update, PWSA reviewed historical drill records of water

main tapping and material identification endeavors, and historical private-side service line

inspections. PWSA digitized over 130,000 hard copies of these records and published them to

their Lead Map.

Because many service lines had been maintained and repaired since being installed, PWSA

found that only 63 percent of their historical records were accurate. Further, prior to 1984,

water main tapping and material identification were only done on the public-side. Private-

side service line inspection records had not been consistently updated or prepared at every

drill record site. As such, PWSA has a disclaimer on their online Lead Map (PWSA, 2021e),

cautioning that some of the historical records are inaccurate and that PWSA will update as

more information becomes available. PWSA began gathering data through alternative

approaches, including through the field techniques described below.

Experience with Field Techniques

PWSA began excavating curb stops where the location either had no historical record or had a

record of lead. PWSA requires a minimum of 24 inches be excavated on each side of the curb

stop because in many instances they found that the curb stop and small part of the service

line had been replaced with non-lead materials but tied back into lead. PWSA used an ArcGIS

Collector app to add a photo of each curb stop and log the type of service line materials.

Although effective, this excavation process was slow, less efficient due to the larger required

excavation size, and very costly to PWSA. In 2018 and 2019, PWSA spent $5 million

excavating sites that they found to not contain LSLs.

To evaluate a more efficient service line identification approach, PWSA began doing CBIs

using small cameras sent down into the curb stop where the public and private service lines

were visible to identify the material. After inspecting approximately 15,000 locations in 2018,

PWSA found that about 25 percent of the data was usable. Often, they were either unable to

locate a curb box, reach the curb stop, or identify the service line material because of its

degradation or the photo quality. When CBI identified lead, results were very accurate (97

percent of locations were verified as LSLs. However, lead was later discovered at 35 percent

of locations identified by CBI as non-lead. Duffy and Pickering (2021) explain that this is

because in some locations, the curb box and a small length of the service line was replaced

but not the entire service line. PWSA began considering other ways to gather information on

service line material, as described below.

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Guidance for Developing and Maintaining B-16 August 2022

a Service Line Inventory

Statistical (Predictive) Data Analysis

The University of Pittsburgh helped PWSA develop a model to predict service line materials at

locations across their system. The model used data from various sources, including property

assessments, tap sampling water results, and service line records, to predict what houses

might also have lead levels in their water above 15 micrograms per liter (Hajiseyedjavadi et

al., 2020). With an accuracy of 73 percent, the model was ultimately only slightly more

accurate than the historical records. Thus, PWSA decided not to use the model to estimate

service line materials but is using the model to prioritize LSL replacement areas.

Innovative Field Data Forms

PWSA developed specific service line and meter replacement work orders in the tablet-based

application used by its utility workers and plumbers. Utility workers and plumbers update

service line material observations and record data for any replacements they conduct. In

addition, the Allegheny County Health Department (ACHD) uses an app for their plumbing

inspectors to record data about the private-side service line inspections they complete.

ACHD’s app sends PWSA an email with the information logged during each inspection that

helps PWSA update the private-side of their service line material inventory.

Example of the Continuous Improvement Approach

PWSA’s approach to developing an inventory fits into the EPA-recommended Continuous

Improvement framework to build and update the inventory using new and better data as

follows:

• Upon identifying the action level exceedance in 2016, PWSA began updating their

inventory of residential service line materials by reviewing historical records.

• PWSA began reviewing historical drill records and private-side service line

inspections.

• Upon review, PWSA realized there were too many gaps, inaccuracies, and

inconsistencies to solely rely on the historical records. The data were only 63

percent accurate.

• PWSA began exploring alternative approaches that would be more cost effective and

increase accuracy.

They modified their approach for conducting excavations at the curb box to use cameras to

try to reduce costs and improve the likelihood of finding LSLs. Although less invasive and

reliable for identifying LSLs, CBIs were less reliable for confirming that no LSLs were present.

Then PWSA experimented with predictive modeling but found that the model was only

slightly more accurate than historical records. Thus, PWSA decided not to use predictive

modeling to estimate service line materials but instead uses it to prioritize LSL replacements.

•

Guidance for Developing and Maintaining B-17 August 2022

a Service Line Inventory

PWSA has found that no one method is superior to all others and that a combination of

methods works best (see Lessons Learned).

Lessons Learned

Duffy and Pickering (2021) provided a summary of lessons learned from their efforts to build

a service line inventory:

• Use Multiple Data Collection Methods. Although PWSA could not solely depend on

historical records and CBI to update the service line inventory, these methods added

value to the inventory and ultimately helped refine PWSA’s approach. Further,

although the predictive data analysis could not be used to estimate service line

materials, PWSA is using that analysis to prioritize lead service line replacement

areas.

• Understand Your Historical Data and Limitations. Upon further evaluation, PWSA

discovered that water main replacements before the 1970s only replaced a few feet

of service line. Thus, they could not classify all water main replacements as non-lead.

• Use Electronic Forms and Apps. PWSA developed multiple apps and tools along the

way, including their Lead Map and ArcGIS Collector app. The map is user-friendly

and consistently updated. The app eases the service line material reporting process

for workers. In short, the tools meet the needs of both the back-end and front-end

users.

Resources

Duffy, D. and Pickering, W. (2021). Developing and Verifying a Water Service Line Inventory.

Journal AWWA, 6-13. https://awwa.onlinelibrary.wiley.com/doi/abs/10.1002/awwa.1686

Hajiseyedjavadi, S., Blackhurst, M., and Karimi, H. (2020). A Machine Learning Approach to

Identity Houses with High Lead Tap Water Concentrations. Association for the Advancement

of Artificial Intelligence, 13300-13305. https://ojs.aaai.org/index.php/AAAI/article/view/7040

Liggett, J., Baribeau, H., Deshommes, E., Raisle, M., Lytle, D., Masters, S., Muylwyk, Q,

Triantafyllidou, S. Anticipated publication January 2022. Service Line Material Identification

Strategies: The Experiences of Ten North American Water Systems.

Pittsburgh Water and Sewer Authority (PWSA). 2021a. 2020 Year in Review.

https://www.pgh2o.com/about-us/performance/2020-year-review. Accessed December 7,

2021.

PWSA. 2021b. Water. https://www.pgh2o.com/water. Accessed December 7, 2021.

PWSA. 2021c. Our History. https://www.pgh2o.com/about-us/our-history. Accessed

December 7, 2021.

•

Guidance for Developing and Maintaining B-18 August 2022

a Service Line Inventory

PWSA. 2021d. New Water Quality Report Shows PWSA Meeting or Exceeding State and

Federal Regulations. https://www.pgh2o.com/news-events/news/press-release/2021-06-29-

new-water-quality-report-shows-pwsa-meeting-or-exceeding. Accessed December 13, 2021.

PWSA. 2021e. Lead Map. https://lead.pgh2o.com/your-water-service-line/planned-water-

service-line-replacement-map/. Accessed December 7, 2021.

United States Environmental Protection Agency (USEPA). 2021. Water System Summary.

SDWIS Federal Report Search. Third Quarter 2021.

https://sdwis.epa.gov/ords/sfdw_pub/f?p=108:200. Accessed December 15, 2021.

•

Guidance for Developing and Maintaining C-1 August 2022

a Service Line Inventory

Appendix C: Instructions for Self-Identifying LSLs and Information When

Water System Conducts Verification

Examples of Customer Service Line Material Identification

Instructions

Philadelphia Water System

Rockford, Illinois

Newark, New Jersey

Washington, DC

Water Service Verification Materials from Menasha, WI

•

Guidance for Developing and Maintaining C-2 August 2022

a Service Line Inventory

Philadelphia Water System Customer Instructions for Self-Identifying LSLs

Source: https://www.phila.gov/media/20211208161245/HowToCheckYourServiceLineForLead-21.12.07.pdf.

•

Guidance for Developing and Maintaining C-3 August 2022

a Service Line Inventory

Rockford, IL System Customer Instructions for Self-Identifying LSLs

Source: https://rockfordil.gov/city-departments/public-works/water-division/lead-and-drinking-water/.

Accessed November 2, 2021.

•

Guidance for Developing and Maintaining C-4 August 2022

a Service Line Inventory

Newark, NJ Customer Instructions for Self-Identifying LSLs

•

Guidance for Developing and Maintaining C-5 August 2022

a Service Line Inventory

Newark, NJ Customer Instructions for Self-Identifying LSLs (continued)

Source: https://www.newarkleadserviceline.com/check-your-line. Accessed December 21, 2021.

•

Guidance for Developing and Maintaining C-6 August 2022

a Service Line Inventory

DC Water Customer Instructions for Self-Identifying LSLs

•

Guidance for Developing and Maintaining C-7 August 2022

a Service Line Inventory

DC Water Customer Instructions for Self-Identifying LSLs (continued)

Source:

https://www.dcwater.com/sites/default/files/Lead-

Testing/DCWPipeMaterialIdentificationGuide_2021.pdf.

•

Guidance for Developing and Maintaining C-8 August 2022

a Service Line Inventory

Customer Information When System Verifies Customer Service Line Material –

Menasha Utilities Postcard

[Insert Contact information]

•

Guidance for Developing and Maintaining C-9 August 2022

a Service Line Inventory

Customer Information When System Verifies Customer Service Line Material –

Menasha Utilities Information When Appointment is Scheduled

Water Service Verification

Appointment Expectations

Water service lines can be made of lead, copper, galvanized steel, or plastic. Without excavating the service

line to expose the pipe, Menasha Utilities employees can determine the pipe material by locating the pipe that

connects the water meter to the water main (usually in the basement). Once the pipe is located, employees

will conduct a scratch test and find out if the pipe is magnetic to determine the service line material. Images of

the different service line materials are shown below.

Reminders

• All Menasha Utility employees have photo identification. Please request to see credentials if they are

not visible.

•

Someone 18 years or older must be present for the entire

appointment.

• Please secure and maintain control of pets.

• Menasha Utility employees will need a safe and clear path to access the water meter.

•

Guidance for Developing and Maintaining C-10 August 2022

a Service Line Inventory

Menasha Utilities Information When Appointment is Scheduled (continued)

• Bronze to brown in color

• Not magnetic

• When scratched the pipe will shine like a penny

• Blue or black

• Not magnetic

• When scratched the pipe does not change

• Dull gray color

• Magnetic

• Very hard when scratched

• Dull gray color

• Not magnetic

• Soft and shiny silver when scratched

Source:

https://www.menashautilities.com/sites/menashautilities.com/files/Water%20Service%20Verifications%20w

ebpage%20content%202019.pdf. Accessed November 29, 2021.

Guidance for Developing and Maintaining D-1 August 2022

a Service Line Inventory

Appendix D: Summary of Lead Ban Provisions by State

Below is a summary of the 1986 lead ban provisions by EPA Region and then by state. The tables have been recreated with some

modification to the format from Table 3-1 of EPA’s Lead and Copper Rule Guidance Manual. Volume I: Monitoring (USEPA, 1991b),

but the content has not been updated. Thus, water systems should verify the lead ban effective dates with their states.

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region I

Connecticut

Yes

Public Act No. 66-192; Sec.

29-261 General Statutes;

State Plumbing Code

12/31/88

Governor

03/29/89

Requires solder warning

label

Maine

Yes

Internal Plumbing Rules 10-

144A CMR238; Chapter

9,8,10; Chapter 3, Table 3,5;

and Chapter II.D.1

08/01/87

Commissioner,

Dept. of Human

Services

02/23/89

State purchased Pb

solder test kits for

inspectors, etc. to use in

field testing.

Massachusetts

Yes

State Plumbing Code, 2-18

CMR; Pg. 55, 201, 208, 207

01/01/86

Commissioner,

Dept. of Env.

Protection

03/08/89

New

Hampshire

Yes

State Plumbing Code,

Chapter ??? 700, Part ???

701

08/01/87

Governor

03/28/89

Adopted BOCA

Rhode Island

Yes

Regulation S.B.C.-3; Article 4,

P402.3 and P402.4; and

Article 5, P508.4 and P509.5

01/01/87

Governor

03/28/89

Adopted BOCA

Vermont

Yes

VT Residential plumbing

code, ABC Envir. Protection

Rules for public buildings

12/28/88

09/10/82

Commissioner of

Health, 03/27/89

New legislation eff. June

1989 consolidating

plumbing codes and

clarifying lead ban.

Guidance for Developing and Maintaining D-2 August 2022

a Service Line Inventory

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region II

New Jersey

Yes

Uniform Construction

Code, Plumbing Subcode

5:23-3,15

02/02/87

Governor

02/02/89

Pipe is covered under

Bureau of SDWA

Regulations

New York

Yes

Executive Law, Section

905,5 of Titles 9 NYCRR

01/01/86

Commissioner of

Health 01/11/89

Lead ban law; Load

labeling law

Puerto Rico

Yes

Planning Board Regulation

#7 (Building Regulation)

Article V- 8-10

06/19/88

Governor

Virgin Island

Yes

VI Interim Primary DW

Standards Title 12, VI Rules

& Regs. Chapter 51,

Section 1303

02/06/89

Governor

02/06/89

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region III

Delaware

Yes

State Plumbing Code,

Section 119 Chapt. 79,

Sec. 7906; Chapt. 1, Sec.

122e

06/17/88

Secy. Dept. Health

& Social Services

Adopted BOCA

D.C.

Yes

D.C. Plumbing Code

Supplement of 1986,

Article 5

08/19/88

Requires PN; bans>8%

pipe, but not fittings

Maryland

Yes

COMAR 09.20.05.02.,

09.20.11.10E,0901.01.09/

01.03

08/16/88

Secy. Environment

09/15/88

Effective 03/30/89 for

pipes and fittings

Pennsylvania

Plumbing System Lead

Ban and Notification Act

of 7/69

01/06/91

Act also bans the sale

of materials that are

not lead free

Virginia

Yes

Uniform Statewide

Plumbing code P-501.7.3,

P-501.8.4 and P-210-1,4

04/01/86

Governor

Adopted BOCA

04/15/87

Guidance for Developing and Maintaining D-3 August 2022

a Service Line Inventory

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

West Virginia

Yes

Legislative Rules, Dept. of

Health, Plumbing

Requirements 64 CSR 57

06/19/88

Governor

Requires PN

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region IV

Alabama

Yes

State Lead Ban Act,

ADEM Admin. Code

R.335-7-11-05

05/10/88

01/89

Governor/ADEM

Director

Florida

Yes

Florida Statues,

Subsection 553.11 and

553.06

06/10/88

12/88

Governor/DER

Secretary

Dept. of Community

Affairs to adopt

amended State

Plumbing Codes

Georgia

Yes

State Plumbing code,

Section 402.1, Section

114.5, and Section

1109.1; State Regs.

07/87

01/89

Kentucky

Yes

State Plumbing Code,

Section 17, PC-60-3

01/04/88

Commissioner of

Bd. Of Housing

Mgr. D.w. Branch

Formalization of

enforcement

procedures with the

Div. of Plumbing with

the next few months.

(11/90)

Mississippi

Yes

Board of Health, Envir.

Regs. Division 300-Water

Supply, Part 301 Section

301.5(c)

04/13/88

05/88

Exec. Secy. Bd. Of

Health/Asst. Dir.

Div. Water Supply

Requires PN

North

Carolina

Yes

State Plumbing Code

Volume II, Section 602.4

(solder & flux) Section

1008 (solder, pipe, flux)

03/87

Comm. of

Insurance/head

Public Water

Supply Branch

Requires PN

Guidance for Developing and Maintaining D-4 August 2022

a Service Line Inventory

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

South

Carolina

Yes

State SDWA, 61-58.4 (1)

11/88

Chief Bureau DW

Program

Requires PN; State

Plumbing Codes

expected to be

amended during next

legislative session.

Tennessee

Yes

Tennessee Code

Annotated, Title 88,

Chapter 13, Part 7

03/18/88

Governor/Dir. Div.

Water Supply

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region V

Illinois

Yes

Illinois Administrative

Code, Chapter 1, Section

890.620d

04/86

Dir. Of H. EPA &

Dir. Of Dept. of

Health, 09/13/88

Indiana

Yes

IN Plumbing Code, title

675, Sec 7 Subsec. 113g

and Sec. 602, Subsec. d

03/01/87

Michigan

Yes

Mi Construction Code

Act

06/07/88

Governor

11/21/88

Minnesota

Yes

Minnesota Statues,

Chapter 326, Section

326 371, MN Plumbing

Code

06/01/85

Comm. Of Health

09/27/88

Sellers of lead solder

must display warning

sign.

Ohio

Yes

OH Basic Building Code

09/12/88

OH EPA &

Governor

9/26/88

Wisconsin

Yes

Wisconsin

Administrative Code

1986

Governor

09/28/88

Guidance for Developing and Maintaining D-5 August 2022

a Service Line Inventory

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region VI

Arkansas

Yes

State Plumbing Code, 10.1.6

and 10.1.7

06/01/88

Governor Bill

Clinton

06/16/88

Louisiana

Yes

State Sanitary Code, chapter

XII (Water Supplies)

09/20/88

Dept. Asst. Secy.

of Dept. of Health

& Hospitals

09/12/88

Requires PN

New

Mexico

Yes

State Plumbing Regulations

04/01/87

Governor Garrey

Carruthers

12/06/88

Requires PN

Oklahoma

Yes

Rules and Regulations

Governing Plumbers

05/06/87

Governor Henry

Bellman

Adopted BOCA

Texas

Yes

Rules and Regulations for

Public Water Systems,

337.206(b)

07/01/88

Governor

Clemenis

09/29/88

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region VII

Iowa

Yes

IA Administrative Code,

Chapters 40 and 41

09/14/88

Larry Wilson

Exec. Fir. Of IDNR

Requires PN

Kansas

Yes

KS Statutory Authority 65-

1710 and 65-171R

04/19/88

Dr. Stanley C.

Grant Secy. KDHE

Requires PN

Missouri

Yes

10CSR 60-10.040 and 60-

8.020; and MS Released

Statues, Chapters 311.060

08/31/88

Dr. F. Brunner

Dir. MDNR

Requires PN

Nebraska

Yes

NB Safe Drinking Water Act,

Title 179, Chapter 2, Sections

003, 004, 005

05/88

Greg Wright, Dir.

Dept of Health

Requires PN

Guidance for Developing and Maintaining D-6 August 2022

a Service Line Inventory

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region VIII

Colorado

Yes

CO Plumbing Code,

Chapters 8 and 10

01/31/88

Governor

11/21/91

Adopted Uniform

Plumbing Code

Montana

Yes

Administrative Rules,

8.70.304, Plumbing

Permits (4)

12/31/87

Chief, Water

Quality Bureau,

10/11/88

North

Dakota

Yes

State Plumbing Code,

Sections 62-03--033,1-

08(5), 63-03-04-02(4)

01/01/88

Governor

09/19/88

South

Dakota

Yes

State Plumbing Code

09/03/87

Secy. Dept. of

Water Resources

Utah

Yes

State Plumbing Code

04/24/89

Dir. Division of

Env. Health

03/08/89

Wyoming

The Region is trying to implement a lead ban at the local level while pursuing the adoption of a state lead ban.

Guidance for Developing and Maintaining D-7 August 2022

a Service Line Inventory

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region IX

Arizona

Yes

AZ Revised Statues, 49-

353.A2(k) and 49-353.B

08/18/87

Governor

08/28/88

Requires PN, Adopted

uniform plumbing

code.

California

Yes

Health and Safety Code,

SB164 Sections 300.6 and

300.7

07/01/86

Gov. George

Daukmejian,

03/28/89

Effective 01/01/88 for

pipes solder warning

label

Hawaii

Yes

HI Revised Statues,

Chapter 340B

06/05/87

Dir. Dept. of

Health 03/22/89

Requires PN; fines

Nevada

Yes

NAC, Chapter 445,412,

Revised Statues

01/89

State Health

Officer 02/18/89

Requires PN

American

Samoa

Yes

AS D.W. Regs. Sec.

25.0431.1

01/89

Yes

N. Mariana

Is.

Yes

CNMI Drinking Water

Regs. Section 5.51

03/13/89

Gov. Pedro

Tenorio 03/13/89

Guam

Yes

Revised Uniform

Plumbing Code, 1988

03/01/88

Gov. Joseph p.

Ada, 04/07/89

Rep. of Palau

Trust Territory

Guidance for Developing and Maintaining D-8 August 2022

a Service Line Inventory

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

EPA Region X

Alaska

Yes

Section 1, AS 18.60.705

06/05/88

Governor,

04/11/88

Covers all water

systems as of 4/89

Idaho

Yes

Idaho Code Chapter 26,

Title 54

08/11/88

Governor,

03/30/89

Adopted Uniform

Plumbing Code

Oregon

Yes

Health Division Rules 333-

61-020, 333-61-040 and

333.61.087

09/04/84

Governor,

03/10/89

Warning Labels;

removal of lead

service lines; public

notification lead flux

was banned in 1988

Washington

Yes

State Building code,

Chapter 551-16 WAC,

Section 15-16 060

04/27/87

03/17/88

Governor,

03/30/89

State

Implemented

Lead Ban

Method

Date

Effective

Certification

Signature

Requires

Solder

Use of

Flux

Lead

Pipe

Notes

Total

All

Yes: 54

No: 3

Guidance for Developing and Maintaining E-1 August 2022

a Service Line Inventory

Appendix E: Michigan Minimum Service Line Verification Requirements

In 2018, Michigan EGLE revised their regulations to require systems to prepare a complete

distribution system materials inventory by January 1, 2025. One goal of the materials inventory

is to “ . . . Demonstrate through physical verification that the inventory is accurate.” Michigan

designed their verification process using the principles outlined in their “Minimum Service Line

Verification Requirements (Michigan EGLE, 2021). These requirements in their entirety are

provided as Appendix E.

Guidance for Developing and Maintaining E-2 August 2022

a Service Line Inventory

Guidance for Developing and Maintaining E-3 August 2022

a Service Line Inventory

Guidance for Developing and Maintaining E-4 August 2022

a Service Line Inventory

Guidance for Developing and Maintaining E-5 August 2022

a Service Line Inventory

Guidance for Developing and Maintaining E-6 August 2022

a Service Line Inventory

Guidance for Developing and Maintaining E-7 August 2022

a Service Line Inventory

Guidance for Developing and Maintaining E-8 August 2022

a Service Line Inventory

Guidance for Developing and Maintaining E-9 August 2022

a Service Line Inventory

Guidance for Developing and Maintaining F-1 August 2022

a Service Line Inventory

Appendix F: Examples of Data Quality Disclaimer Language

DC Water

Greater Cincinnati Water Works

Pittsburgh Water and Sewer Authority

Guidance for Developing and Maintaining F-2 August 2022

a Service Line Inventory

Below are just a few examples of disclaimer language from DC Water, Greater Cincinnati Water

Works, and Pittsburgh Water and Sewer Authority’s websites regarding the accuracy of the

inventory information provided to the public. This information can be adapted for use.

DC Water

Source: https://geo.dcwater.com/Lead/. Accessed December 21, 2021.

Guidance for Developing and Maintaining F-3 August 2022

a Service Line Inventory

Greater Cincinnati Water Works

Source:

https://gcww.maps.arcgis.com/apps/webappviewer/index.html?id=0a170c268c694e46a8a4e394630df0bd

Accessed December 21, 2021.

Guidance for Developing and Maintaining F-4 August 2022

a Service Line Inventory

Pittsburgh Water and Sewer Authority

Source: https://lead.pgh2o.com/your-water-service-line/planned-water-service-line-replacement-map/.

Accessed December 21, 2021.