Lead Service line Inventory - Frequently Asked Questions

    1. What is a service line inventory?
    2. Who is required to complete a service line inventory?
    3. When is the service line inventory required?
    4. Do I have to include every service line in my inventory?
    5. What other information do I need to submit as part of my inventory?
    6. How is each portion of the service line material categorized in the service line inventory?
    7. What if our system doesn’t have lead service lines? 
    8. If our system previously certified that there was no lead in the distribution system, is an inventory still required?
    9. What are galvanized service lines and why are they a concern?
    10. Are inactive service lines required to be in the inventory?
    11. What are the expectations for very small community water systems (CWS) and non-transient non-community (NTNC) systems?
    12. Are lead connectors such as goosenecks and pigtails considered to be a lead service line and are we required to include lead goosenecks or pigtails in our service line inventory?  
    13. What happens if we discover a lead gooseneck or pigtail during a project or repair?
    14. The LCRR requires an evidence-based record, method, or technique to support a material classification of “Non-Lead”. What is an evidence-based record, method, or technique?
    15. Do we have to field verify all the service lines to identify the material type?
    16. Do we have to review my records to identify service line materials?
    17. When were lead service lines prohibited from use?
    18. When did enforcement of the lead ban become effective in Louisiana?
    19. Can we safely assume that service lines installed after the Louisiana Lead Ban are non-lead?
    20. How do we handle our larger service lines?
    21. What other methods can be used for identifying service line materials when records are lacking?
    22. Do we have to classify the material type of every service line by October 16, 2024?
    23. What happens if we have LSL, GRR, or unknown in our initial inventory?
    24. We have identified lead service lines and galvanized required replacement service lines in our system, are we required to replace them?
    25. How will we have to submit our service line information to LDH?
    26. Is our service line inventory required to be publicly available?
    27. Can our inventory be updated after it is submitted?
    28. How often are inventory updates required to be submitted to LDH?
    29. How can I pay for development of the lead service line inventory?

Acronyms and Definitions


1. What is a service line inventory?

As part of the Lead and Copper Rule Revisions (LCRR), the Environmental Protection Agency (EPA) requires that all community water systems (CWS) and non-transient non-community water systems (NTNCWS) develop an inventory of all service line connections, regardless of ownership. Systems must prepare and submit an initial service line 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. 

A service line is the pipe that connects water mains to buildings to supply potable water for domestic use and sometimes to supply fire protection systems, irrigation or emergency connections. The service line may be owned by the water system, the property owner, or both.

2. Who is required to complete a service line inventory?

All community water systems (CWSs) and non-transient non-community water systems (NTNCWSs) must prepare an inventory of ALL service lines (including those not in use) connected to the distribution system.

3. When is the service line inventory required?

All initial service line inventories must be submitted to LDH by the compliance deadline of October 16, 2024.

4. Do I have to include every service line in my inventory?

Yes. Water systems must create and maintain an inventory that includes the street address associated with each service line connected to their distribution system. 

5. What other information do I need to submit as part of my inventory?

The following elements are required for each service line in your inventory: address, material classification for both the public and private portions of the service line along with a description of the basis of material identification.  In addition, systems must specify whether their system portion of the service line was ever lead (e.g., if your system-owned service line was previously lead but was replaced in the past).  

6. How is each portion of the service line material categorized in the service line inventory?

Systems are required to classify both the water-system-owned portion of the service line (water main to the meter) and the customer-owned portion of the service line (meter to the building inlet). Each portion (public and private) of all service lines must be categorized in the following manner:

  1. Lead - where the system-owned or customer-owned portion of the service line is made of lead. Lead connectors (i.e., goosenecks or pigtails) are not considered a lead service line.  However, under the proposed EPA Lead and Copper Rule Improvements (LCRI), systems will be required to include connector material in future updates to their inventory. Therefore, we strongly suggest including them in your initial inventory to reduce future burden.  Water systems must replace lead connectors when encountered during routine activities.
  2. 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, method, or 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 initial inventory requirements of 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.
  3. Non-Lead - where the service line is determined through an evidence-based record, method, or technique not to be lead or GRR. LDH encourages the water system to classify the actual material of the service line (e.g., plastic or copper) as often as possible as an alternative to classifying it as “Non-lead”.
  4. Unknown (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. Systems can classify these lines as “Unknown” or “Lead Status Unknown”.

7. What if our system doesn’t have lead service lines? 

Under the LCRR, even those systems with no lead service lines are required to submit a complete inventory to LDH by the compliance deadline.

8. If our system previously certified that there was no lead in the distribution system, is an inventory still required?

Yes. While previous investigations of service lines are valuable, every system needs to conduct an inventory of service lines under the rule and submit the results by the deadline of October 16, 2024. Previous certification did not account for the different classifications of the full (public and private) service lines, and for many systems, connections have increased.

9. What are galvanized service lines and why are they a concern?

A galvanized service line is iron or steel piping that has been dipped in zinc to prevent corrosion and rusting. Lead particles can attach to the surface of galvanized pipes and accumulate over time. These lead deposits can leach into the drinking water and pose a health hazard. A “Galvanized Requiring Replacement” is a galvanized service line that is or was at any time downstream of an LSL or is currently downstream of a lead status unknown service line. If the system is unable to demonstrate that the galvanized service line was never downstream of an LSL, it must presume there was an upstream LSL.

10. Are inactive service lines required to be in the inventory?

Yes. Systems must include all service lines, including inactive service lines, 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.

11. What are the expectations for very small community water systems (CWS) and non-transient non-community (NTNC) systems?

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 (or other source) to the building inlet for their inventory. EPA intends to develop a separate guidance that is tailored to small CWSs and NTNCWSs which is expected to be available by mid to late 2023.

12. Are lead connectors such as goosenecks and pigtails considered to be a lead service line and are we required to include lead goosenecks or pigtails in our service line inventory?  

No.  Under the LCRR, lead goosenecks and pigtails (see illustration below) are not considered lead service lines and do not have to be included in the inventory.  However, under the proposed EPA Lead and Copper Rule Improvements (LCRI), systems will be required to include connector material in future updates to their inventory. Therefore, we strongly suggest including them in your initial inventory to reduce future burden.

Figure 2 – Lead Connectors (e.g., Goosenecks, Pigtails)

     
 https://viroqua-wisconsin.com/city-of-viroqua/departments/water-sewer/water-department/what-is-a-water-service-and-why-is-it-important 

 

13. What happens if we discover a lead gooseneck or pigtail during a project or repair?

If a lead gooseneck or pigtail is discovered and exposed during routine activities, the system is required to replace it at the time of discovery. These types of connectors are not considered lead service lines under the LCRR but have to be replaced when exposed.

14. The LCRR requires an evidence-based record, method, or technique to support a material classification of “Non-Lead”. What is an evidence-based record, method, or technique?

An evidence-based record, method, or technique provides documentation that identifies a service line’s material or supports a classification of “non-lead”.  For this initial inventory, the LCRR requires water systems to make use of any relevant records available to the water system.  In instances where no records exist or where the records are known to be inaccurate, those locations would be classified as “unknowns” until the materials are verified.

15. Do we have to field verify all the service lines to identify the material type?

The LCRR does not require field verifications (e.g., excavations, meter box inspections, etc.) to determine service line material. However, under the LCRR systems are required to implement a policy to ensure service line materials are being identified and tracked in the inventory as they are encountered in the course of its normal operations (e.g., checking service line materials when reading water meters or performing maintenance or repair activities). Systems can take a more aggressive approach and actively conduct field verifications to reduce their number of unknowns. 

16. Do we have to review my records to identify service line materials?

Yes, under the LCRR, systems are required to review their records which can verify the presence or absence of lead service lines in many instances. Records for identification must be reliable. A system should not utilize a record for material classification in cases where they have seen conflicts between the material on record and the actual material. Where there are conflicts in records and field information, LDH recommends using a classification of “unknown” until the conflicts can be resolved.

17. When were lead service lines prohibited from use?

In 1986 Congress amended the Safe Drinking Water Act to prohibit the use of pipes and pipe fittings and fixtures that contain more than 8% percent lead and solder or flux that contained more than 0.2% lead. This effectively prohibited the use of lead service lines and is referred to as the Federal Lead Ban.  The Federal Lead Ban became effective on June 19, 1986.

18. When did enforcement of the lead ban become effective in Louisiana?

Enforcement of the lead ban began in Louisiana on September 20, 1988.

19. Can we safely assume that service lines installed after the Louisiana Lead Ban are non-lead?

Yes. Service lines installed after September 20, 1988 can be classified as “Non-Lead” in your service line inventory when a record of the date of service line installation or date of construction exists.

20. How do we handle our larger service lines?

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” if supported by records and the system is not aware of any lead service lines in their distribution system that are larger than 2-inches in diameter.

21. What other methods can be used for identifying service line materials when records are lacking?

Depending on the availability of historical records and the confidence in accuracy of records, systems may need to conduct field verifications to reduce the number of unknown service lines in their inventory. These methods are not required under the LCRR, but can be used where records are lacking. Such methods include:

  • 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. This method is not feasible in all cases as it depends on the type of meter box and arrangement of the service line tie in. If a system determines that visual identification is feasible, systems must document their findings for each location. LDH strongly recommends that photos are included as part of the documentation but it is not required.
  • 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. At a minimum, LDH requires 1 pothole approximately 18” to 24” from the meter box for each portion of the service line being verified.  Two potholes, approximately 18” to 24” from each side of the meter box would be required to physically verify both the public and private portions of the service line. This distance may vary from system to system and shall be selected based on the water system’s knowledge of how their service lines tie in with their meters. LDH strongly recommends that photos are included as part of the documentation but it is not required.
  • 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.

22. Do we have to classify the material type of every service line by October 16, 2024?

No. A system can use all available records to identify service lines and consider those without documentation as “lead status unknown” in the initial inventory. However, it is strongly recommended that systems take action to reduce the number of unknowns as they are treated like lead service lines in parts of the LCRR.

23. What happens if we have LSL, GRR, or unknown in our initial inventory?

Systems with service lines classified as “unknown”, “lead” or “galvanized requiring replacement” will be required to take additional action including:

  • Create and submit a lead service line replacement plan.
  • Notify customers when a “lead”, “GRR”, or “lead status unknown” service line is disturbed including those that results in the water to an individual service line being shut off or bypassed, such as operating a valve on a service line or meter setter.
  • Distribute point of use (POU) treatment or pitcher filters with six-months supply of filters when the disturbance of a “lead”, “GRR”, or “lead status unknown” service line results from the replacement of an inline water meter, a water meter setter, or gooseneck, pigtail, or connection.
  • Provide notification to people served by a “lead”, “GRR” or “lead status unknown” line within 30 days after completing the initial inventory and repeat it on an annual basis. The notification must include a statement that the service line material is “lead”, “GRR”, or “lead status unknown”, information on the health effects of lead, and steps to minimize exposure in drinking water. The notice must also include additional information about replacement and financing depending on the material classification of the service line. For example:
    • Lead Service Lines - 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.
    • Unknown - 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.

24. We have identified lead service lines and galvanized required replacement service lines in our system, are we required to replace them?

Under the LCRR systems are required to begin replacing lead service lines when more than ten-percent of their routine lead tap sample results exceed 10 parts per billion (ppb).  However, EPA is currently developing a new proposed National Primary Drinking Water Regulation titled: “Lead and Copper Rule Improvements (LCRI)” to address key issues and opportunities identified during their review of the LCRR. This could potentially change the trigger for when systems have to replace LSL, GRR or Unknown service lines.  We will not know until the proposed rule is published. EPA anticipates completing its initial LCRI rulemaking and publishing a proposed rule in late 2023.  

25. How will we have to submit our service line information to LDH?

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). However, systems can utilize any format that they prefer for internal tracking as long as it captures the minimum required elements included in the LDH service line inventory template.

26. Is our service line inventory required to be publicly available?

Yes. All Community Water Systems (CWSs) that serve more than 50,000 individuals must make their inventory available online (i.e., publish it on their website).  CWSs that serve less than 50,000 individuals are not required to post their inventory online, however, they must make their inventory available upon request. It is recommended that all CWSs, regardless of size, publish their inventories on their website so it is readily available to the public.   

NOTE: If the system does not have any “lead”, “GRR”, or “lead status unknown” service lines, they may use a written statement in lieu of having a publicly accessible inventory. The statement must include a description of the sources/methods used to make the no lead determination. The statement and summary of identification methods must be made publicly available in these cases. 

27. Can our inventory be updated after it is submitted?

Yes, it is expected that systems will identify and document service line materials in the inventory as they are encountered during normal operations or as systems take active steps to identify service line materials (i.e., visual inspections, excavations, etc.). The inventory must be updated as new information is discovered.

28. How often are inventory updates required to be submitted to LDH?

The LCRR requires water systems to provide updated inventories to the primacy agency annually or triennially, based on the system’s lead tap sampling frequency but not more frequently than annually.  

29. How can I pay for development of the lead service line inventory?

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 (DWRLF). 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.

Acronyms and Definitions

Acronyms:

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

 

Definitions:

Term   Definition
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).

 

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)).

 

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).