Lead Service Line Inventory (LSLI)
| LDH Lead Service Line Inventory (LSLI) Templates and User Guides
|LDH LSLI Template Small (MS Excel) (For Water Systems with ≤ 10,000 Service Connections)|
|LDH LSLI Template Medium (MS Excel) (For Water Systems with < 50,000 Service Connections)|
|LDH LSLI Template Large (MS Excel) (For Water Systems with > 50,000 Service Connections)|
|LDH LSLI Template User Guide (pdf) (User Guide to Assist Systems of All Sizes)|
LDH LSLI Frequently Asked Questions
Service Line Inventory Demos and Videos (Youtube)
LDH SLI Template Demonstration 1 - Template Ovewrview (6 min): https://youtu.be/udrJ9K_gtAg
LDH SLI Template Demonstration 2 - PWS Records Worksheet (9 min): https://youtu.be/-vZhZ42f3oo
LDH SLI Template Demonstration 3 - PWS SL Inventory Worksheet (18 min): https://youtu.be/NKHsbRsCC-k
LDH SLI Webinar (Community Water Systems) (2 hr 53 min): https://youtu.be/9p6ERuK2I4Y
Quick Links Menu
Initial Service Line Inventory Requirements
Funding Opportunities and Useful Links
Initial Service Line Inventory Requirements
Key Components of the Initial Service Line Inventory:
As part of the Lead and Copper Rule Revisions (LCRR), the EPA requires that all community water systems (CWSs) and non-transient non-community (NTNC) water systems develop an inventory of all service line connections, regardless of ownership. Systems must prepare and submit an inventory that includes the system-owned and customer-owned portions of all service lines in the system’s distribution system to the Louisiana Department of Health (LDH) by October 16, 2024.
Each portion of the service line must be categorized in the following manner:
- Lead - where the system-owned or customer-owned portion of the service line is made of lead. Lead connectors (e., goosenecks or pigtails) are not considered a lead service line and are not required to be included in the inventory but the EPA recommends including lead connectors where records exist. Water systems must replace lead connectors when encountered during routine activities.
- Galvanized requiring replacement (GRR) - where a galvanized service line 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 (through an evidence-based record, identification method, or identification technique) that the galvanized service line was never downstream of a lead service line, it must presume there was an upstream lead service line and classify it as a GRR service line.
Under the LCRR, a galvanized service line that is (or ever was) downstream of just a lead gooseneck or pigtail connector is not considered a GRR service line.
- Non-Lead - where the service line is determined through an evidence-based record, method, or technique not to be lead or GRR. The water system may classify the actual material of the service line (g., plastic or copper) as an alternative to classifying it as “Non-lead.”
- Lead status unknown - where the service line material is not known to be lead, GRR, or a non-lead service line, such as where there is no documented evidence supporting material classification. This classification is also referred to as an “unknown”.
The LCRR [40 CFR §141.80(f)(3) and 40 CFR §141.84(a)] specifically requires systems to develop their service line inventories using previous materials evaluations, construction and plumbing codes/records, water system records, distribution system inspections/maintenance records, and information obtained through normal operations. Water systems should treat the inventory as a living dataset that is continuously improved over time. The number of “unknowns” in the inventory should decrease as systems gather new information through normal operations and any proactive material identification activities in which the water system is engaged.
The following list highlights the identification methods and techniques approved by LDH:
- Historical Records Review: The first step in developing a service line inventory is completing a records review. It is vital that water systems do a thorough review to reduce the number of “lead status unknown” lines and to potentially avoid having to rely on more intensive and disruptive identification methods later. Under the LCRR, system are required to review records. Required records include: all construction and plumbing codes, permits, existing records which indicate service line materials, all water system records such as maps of the distribution system, lead and copper sample plans, historical records on each service connection, meter installation records, historical capital improvement or master plans, standard operating procedures, and all other inspection reports or records of the distribution system that indicate service line materials.
- Existing data about service line materials comes from different sources and the accuracy and reliability of these records varies by record type and location. Therefore, if a system is aware of discrepancies between their records and their knowledge of service line material, or if there is a lack of confidence in the accuracy of the records, the system shall classify the service line as “lead status unknown” until further action is taken to verify the service line material.
- Day-to-Day Operations: Under the LCRR, systems are required to identify and track information on service line material as they are encountered in the course of normal operations. Opportunities for data collection under normal operation include but are not limited to water meter reading, water meter repair or replacement, service line repair or replacement, water main repair or replacement, backflow prevention inspections, other street repair or capital projects with open cut excavations. Systems should develop a process or standard operating procedure now to document how their staff and contractors will collect this information and use it to update their inventory.
- Plumbing Codes: The official effective date of Lead Ban in Louisiana was September 20, 1988. Therefore, all service lines installed after this date can be classified as “non-lead” where a record of the date of construction or service line installation exists.
- Service Line Size: The use of lead piping greater than 2-inches was extremely rare. Therefore, LDH will allow all service lines larger than 2-inches, regardless of installation date, to be classified as “non-lead” where a record indicates larger service lines are non-lead and the system is not aware of any lead service lines in their distribution system that are larger than 2-inches in diameter.
- Visual Inspection: In some cases, water systems may be able to conduct a visual inspection to determine service line materials. One example includes inspecting meter boxes or curb boxes to determine the public and private service line materials. However, this method is not feasible in all cases as it depends on the type of meter box and arrangement of the meter tie in with the service line. If a system determines that visual identification is feasible, systems are required to document their findings for each location. LDH strongly recommends that photos are included as part of the documentation.
- Excavation/Physical Verification: Excavation methods are the most accurate but require different levels of disturbance, time investment, and cost as well as coordination with the property owner. Manual, mechanical or vacuum excavation can be used to dig a “pothole” or test pit to expose a portion of the public and private service line on each side of the water meter. Excavation can be used as a standalone identification method, or it can be used as a tool to validate the accuracy of information obtained from records, interviews, visual inspections or other identification methods. At a minimum, LDH requires 1 pothole approximately 18” to 24” from the meter box for each portion of the service line being verified. Therefore, 2 potholes (one on each side of the meter), would be required to physically verify both the public and private portions of the service line. The distance of the pothole may vary from system to system and shall be selected based on the water system’s knowledge of how their meters tie in with their service lines and to minimize disturbance to other utilities or property.
- Interviews/Questionnaires: Interviews and questionnaires with experienced system staff, plumbers and others with knowledge of service line materials can be used to focus the inventory effort and verify system records. Experienced staff may also know where relevant historical records are located. Classifications of service line materials based on interviews or questionnaires however, shall not be used as a sole source of information for the inventory. All documented interviews and questionnaires are required to be signed and dated by the individual providing the information and shall include the individual’s affiliation with the water system and details of various projects or job duties that afforded the individual knowledge of service line materials.
- Other: LDH will consider other identification methods and techniques on a case-by-case basis. This includes: statistical analysis, predictive modeling, emerging technologies or other techniques systems feel confident will assist in their material identification efforts.
To support public water systems and state primacy agencies, EPA has prepared guidance on developing lead service line inventories. The guidance includes best practices, case studies for inventory development and detailed information on various lead service line identification methods and techniques. To view the guidance document please visit: https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule.
- Under the LCRR, all CWSs and NTNC water systems are required to create and maintain a complete inventory that includes the exact address associated with each service line connected to the public water distribution system. This includes those systems who are able to demonstrate that all of their service lines (both public and private) are non-lead.
- Systems must prepare and submit an inventory that includes the system-owned and customer-owned portions of all service lines in the system’s distribution system classified as either “Lead”, “Galvanized Requiring Replacement”, “Non-Lead” or “Lead Status Unknown”.
- Systems must provide the basis of material classification for each portion of the service line (public and private) in the service line inventory (i.e., date of service line installation, service line size, records, excavation, visual inspection, etc.). A classification of “non-lead” must be supported by evidence-based records, methods, or techniques to prove it is not lead or GRR. Systems are not expected to submit their detailed records as part of their service line submittal but rather a description of the records, methods and techniques used to complete their inventory. Systems shall retain and be prepared to present their detailed records to LDH upon request.
- Due to the large amount of data LDH expects to receive, all systems are required to submit their service line information using the LDH Service Line Inventory Template (MS Excel). Systems may prefer to utilize other methods of tracking their service line materials (i.e., customized spreadsheet, database, software, billing system, etc.), however, the information must be complied into the LDH Service Line Inventory Template for submittal to LDH.
Other Key LSL Inventory Requirements
- Within 30 days of completion of the initial lead service line inventory, all water systems must inform all persons served by the water system at the service connection with a “lead”, “GRR”, or “lead status unknown service line”. The notice must be provided by mail or by another method approved by the State. The notification must be repeated on an annual basis until the entire service connection is no longer a “lead”, “GRR”, or “lead status unknown service line” service line. LDH encourages systems to notify persons served by a lead service as soon as practical upon discovery.
- Systems with a "lead", "GRR" or "lead status unknown" are required to prepare a lead service line replacement plan to the state.
- Some CWSs and NTNC water systems 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 manual that is tailored to small CWSs and NTNC water systems which should be available mid to late 2023.
- Water systems must make their service line inventory publicly available.
- Water systems serving greater than 50,000 persons must make the publicly accessible inventory available 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.
Louisiana is eligible to receive $42 million per year over the next five years in dedicated funding for Lead Service Line (LSL) identification and replacement. This funding is part of the Bipartisan Infrastructure Law (BIL) signed by President Biden on November 15, 2021. Any project funded under this appropriation involving the replacement of a lead service lines must replace the entire lead service line (both public and private owned portions), unless a portion has already been replaced or is concurrently being replaced with another funding source.
Under the BIL, 49% of funds awarded to a LSL replacement project would be in the form of grants or principal forgiveness (free) and 51% would be in the form of no-interest loans (up to 30 year terms). Funding for this program will be managed by the Louisiana Revolving Loan Fund Program. For a project to be eligible for funding, it must be otherwise DWRLF eligible. For information on how to apply, please contact the DWRLF program at: 225-342-7499 or visit us on the web @ LDH DWRLF.
- Environmental Protection Agency (EPA):
- EPA Guidance on Developing Lead Service Line Inventories and Service Line Inventory Template: https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule.
- EPA Lead and Copper Rule Revisions (LCRR): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-141/subpart-I.
- EPA Lead and Copper Rule Improvements (LCRI): https://www.epa.gov/ground-water-and-drinking-water/lead-and-copper-rule-improvements
- Association of State Drinking Water Administrators (ASDWA):
- In February 2022, ASDWA held an 8-part webinar series on various lead service line inventory topics, such as case studies, funding for inventory, inventory templates, and other tools. Presentation slide decks and recorded webinars can be accessed at the ASDWA Lead Service Line Symposium page.
- ASDWA State Implementation Framework for the Lead Service Line Inventory Requirements under EPA’s Lead and Copper Rule Revisions (LCRR): https://www.asdwa.org/wp-content/uploads/2022/02/ASDWA_Framework_Lead_Service_Line_Inventories_Feb.-2022.pdf.
- Additional ASDWA papers, communications, webinars and resources for the LCRR can be accessed at: https://www.asdwa.org/lead-and-copper-rule-lcr/#:~:text=The%201991%20Lead%20and%20Copper,copper%20within%20the%20distribution%20system
- The Association of State Drinking Water Administrators (ASDWA) is also hosting a webinar series: Implementation Tools and Best Practices for Lead Inventories and Replacements. This webinar series is open to the public and will be held on Thursdays from 10:00 to 11:30 AM PST. Please register for each webinar individually. Recordings for past webinars are available on their website:
- Session 1 (11/10/2022) – Technologies for Lead Service Line Inventories and Mapping (Youtube Video)
- Session 2 (12/15/2022) – Consultants' Roundtable for Inventories and Mapping (Youtube Video)
- Session 3 (1/12/2023) – Records Review for Inventory Development ( Youtube Video)
- Session 4 (2/9/2023) – Service Line Material Field Validations (Youtube video)
- Session 5 (3/9/2023) – Opportunities for Technical Assistance (Youtube video)
- Session 6 (4/13/2023) – Regulatory Roundtable: https://attendee.gotowebinar.com/register/8488697484753368078
Acronyms and DefinitionsAcronym
CWS Community Water System
|LCRR Lead and Copper Rule Revisions|
|EPA U.S. Environmental Protection Agency||LSL Lead Service Line|
|GRR Galvanized Requiring Replacement||
NTNCWS Non-Transient Non-Community Water System
|Community water system (CWS)||
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).
|Galvanized requiring replacement (GRR)||
A galvanized service line that is or was at any time downstream of a lead service line or is currently downstream of 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)4 (40 CFR §141.2).
|Lead service line (LSL)||
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).
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)).
|Non-transient non-community water system (NTNCWS)||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).|