- A customer of my PWS is requesting a lead and copper sample after receiving their notice of service line material. Does my PWS have to pay for this sample?
Public water systems are not required to cover the cost of customer-requested/non-compliance lead and copper samples following the delivery of service line material notifications. Systems can choose to cover these costs and collect the samples on the customer’s behalf, or they can choose to facilitate this process by:
1. Sharing a list of labs in the state that offer lead and copper sample analysis and/or
helping the customer choose a lab.
2. Ordering the sample materials for the customer or assisting them with the order.
3. Explaining the sample collection protocol, general timeline of the process, what to expect,
and helping the customer understand their results once they are received.
If the results are elevated, the system could remind the customer to use cold water,
flush their taps, and share more information such as a filter guide.
It is recommended that systems document how they intend to handle these requests and include a description of their policy regarding who is responsible for covering the costs of sampling.
- Who must complete a Service Line Inventory (SLI)?
All Community and Non-Transient Non-Community (NTNC) public water systems (PWS) must develop an inventory to identify service line materials connected to the PWS distribution system.
- When is the Service Line Inventory due?
Completed Service Line Inventories are due October 16, 2024.
- When do I need to submit my Service Line Inventory public notice?
Completed Service Line Inventory public notices must be submitted to DWPMOR@maine.gov no later than November 15, 2024.
- What must be included in the SLI?
The SLI must include a list of all service line addresses in the PWS’s distribution system and a characterization of the materials on both the private and public portion of each service line, as well as a characterization of the whole service line as either lead, non-lead, galvanized requiring replacement (GRR) or unknown.
- Which service lines are included?
The LCRR service line inventory must include all service lines, regardless of the actual or intended use. These include non-potable applications such as fire suppression, and industrial water connections. Inventories must include service lines to vacant or abandoned buildings, even if they are unoccupied and the water service is turned off.
EPA’s Guidance for Developing and Maintaining a Service Line Inventory defines a Service Line as “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.” (Section 2.2.1 and Glossary)
Lines that do not meet this definition, such as non-potable irrigation lines that do not connect to the interior plumbing in a building, do not have to be included in the inventory.
- What are “unknown” service lines?
A PWS may classify service line materials as “lead status unknown” or “unknown” where the service line 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. The LCRR does not require the LSL inventory to identify the material of every service line by the compliance date. However, the EPA has dis-incentivized having large numbers of unknown service lines by requiring annual public education and other requirements for all service connections listed as unknown. Please see 40 CFR 141.85 for more information.
- What are non-lead service lines?
The EPA defines non-lead service lines as “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)).
- What are galvanized service lines requiring replacement?
A galvanized requiring replacement (GRR) line is defined as “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)).
- Do goosenecks/pigtails need to be included in the inventory?
Not at this time, but it is recommended that the location of goosenecks be documented since future regulations may require that they be inventoried. 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).
- Do lead goosenecks, pigtails, or connectors cause a service line to be classified as a lead service line under the LCRR?
No, the presence of lead goosenecks, pigtails or connectors do not by themselves cause a service line to be classified as a lead service line.
- Do lead goosenecks, pigtails, or connectors cause a service line to be classified as a galvanized requiring replacement service line under the LCRR?
No, the presence of lead goosenecks, pigtails or connectors do not by themselves cause a service line to be classified as a galvanized requiring replacement service line.
- Does the inventory include documenting lead fittings at the curb stop and the main?
No, fittings aren’t considered lead service lines, so they don’t need to be inventoried. When possible, these should be removed from the distribution system.
- In what format does the SLI need to be submitted?
In Maine, the Small System Service Line Inventory Form (form B2) may be used by small, non-municipal systems with 25 or fewer service lines.
If a PWS has more than 25 service lines or has a mix of system-owned and customer-owned portions of lines, the system must use the Large System Service Line Inventory Template (form B1). EPA’s Guidance for Developing and Maintaining a Service Line Inventory can be used to determine how to complete the spreadsheet.
- How do I submit my inventory?
All Community and NTNC waterworks must submit a service line inventory to the Drinking Water Program by the compliance date of 10/16/2024. Click here for submittal instructions.
- Do I need to include any pictures, maps, or blueprints used as evidence in my submission that is due October 16, 2024?
Pictures, maps, and documents that are being used as evidence for line classification are not required to be submitted with the initial inventory.
- Do I need to tell my customers about my inventory?
All systems must make their SLIs available to the public. In addition, all systems serving greater than 50,000 people must post their SLI on the internet.
- Do I still need to tell my customers about my inventory if it contains only non-lead lines?
If a public water system’s service line inventory is confirmed to contain all non-lead lines, the PWS can choose to make the inventory publicly available or provide a written statement that the system has no lead service lines, galvanized requiring replacement lines, or unknown lines. The statement must also include a general description of the methods used to determine service line materials. If the PWS serves more than 50,000 people, the inventory or written statement must be posted online. If the PWS serves less than 50,000 people, the inventory or written statement is not required to be posted online. Hand-delivery, or “direct delivery” to all customers is not required, but it must be publicly accessible in some way. For NTNC systems, posting in common areas like breakrooms or notice boards is acceptable. Community water systems must include a statement about the inventory in the consumer confidence report beginning in 2025.
- What methods are available for determining the materials for unknown service lines?
Use previous materials evaluation, construction and plumbing codes/records, water system records, distribution system inspections and records, information obtained through normal operations, visual inspection of service line material, including at meter setting and inside home/building, customer self-identification, TV inspection, use of lead swabs or surface test kits, and excavation, including vacuum and mechanical excavation. Other methods will be reviewed on a case-by-case basis.
- Can a PWS submit a statement that there are no lead service lines in lieu of an inventory?
The LCRR calls for all Community and NTNC water systems to develop the inventory and submit it to the state. There is no provision in the LCRR for a statement in lieu of developing and submitting the inventory.
- What if a PWS has no lead service lines and no galvanized service lines requiring replacement?
PWSs that can demonstrate that they have only non-lead service lines must submit an initial inventory by the compliance date but are not required to provide inventory updates to the State or the Public.
- Is there funding available to develop the SLI?
Yes. The Lead Service Line Inventory Assistance Grant is available to Community or Non-Transient, Non-Community water systems to assist with lead service line inventory activities.
For more information or to apply, click here, or contact Greg Connors: Email or phone (207) 592-3409.
- Is there funding available to replace lead service lines?
Yes, funding is available to help cover these costs. Click here for more information.
- What is the LCRR definition of a 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. For purposes of § 141.86(a) only, a galvanized service line is not considered a lead service line.”
- What is the LCRR definition of a gooseneck or pigtail?
“…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).”
- If a galvanized line is located downstream of a lead gooseneck, must it be classified as a “Galvanized Requiring Replacement” (GRR)?
If a PWS can document that their galvanized line was never downstream from an LSL, but the galvanized line was downstream of a lead gooseneck, they do not need to call their galvanized line a GRR.
- Are Community water systems responsible for determining service line material past the master meter in manufactured housing facilities, school campuses, hospitals, etc.?
All Community and Non-Transient Non-Community (NTNC) public water systems 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. 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.
- What efforts are required to identify the material of service lines to mobile homes located in parks that are public water systems (PWS) as well as those in parks served by municipal systems?
The service line to every mobile home lot, regardless of whether it is occupied, must be included in the service line inventory. This inventory must be done by the park itself if it is a PWS, and by the municipality if the park is served by the municipal system.
Parks/lots built in or after 1989 may be classified as non-lead based on the age of the park. For older parks, effort must be made to obtain plans or any other construction or purchasing information that is available. If reliable information indicates that the service lines within the park are non-lead – even if this information is only a written statement by someone with experience working within the park – then visual inspection of a subset of lines is acceptable. Systems should determine the number of lines that will be visually inspected based on the records available and their level of confidence in the accuracy of these records. This determination should be documented in the methods section of the inventory.
If the park was constructed in sections, then at least one visual inspection should be done per section. Visual inspection of a small portion of the line under the skirting of the mobile home is acceptable for characterization. If there is no reliable information at all about the construction of the park, then, technically, each mobile home service line should be inspected. An alternate, park-specific plan may be submitted for approval to reduce the inspection requirement to a percentage of the mobile homes.
The Manufactured Housing Board (MHB) has provided the following information:
• There are some physical plans on file from old parks, but they likely don’t have specs of the type of piping used, and most would not have any piping maps either as it hasn’t been part of the requirements. There is a provision for the Board to waive the site plan requirement under certain circumstances so there is no guarantee that there would be a plan on file.
• There are no requirements on piping materials at old or new parks – no prohibition of materials used in the service lines. There is not enough information for any kind of global statement on the types of piping used, since many of the parks are old and may have had many system upgrades/ repairs over time. There are likely a lot of galvanized steel or PE pipes in the parks especially from the mains to the homes in the park.
• Municipalities and parks that are PWS’s can contact the Manufactured Housing Board (email peter.holmes@maine.gov) to see if there are plans available. Municipalities that need help getting information from consecutive parks can also contact the MHB and they will reach out to the park to encourage cooperation.
- Can employees who’ve worked on the construction project of installing a main or service line verify now, from memory, the material that was put in or that they saw?
Employees can document what they know in writing, and this information can be added to the inventory. Include a description of this in the documentation. If this is the only information available, this area should be prioritized for verification through investigation.
- Can a water system assume a service line with a diameter greater than 2 inches is non lead?
Combined with the required historical records review, public water systems may use the line size threshold of 2 inches to support a material classification of non-lead.
- Are tie cards adequate for identifying service line materials?
Tie card information can be used in the inventory, and this source of information can be documented. If there is a history of inaccurate tie cards in an area, they should be prioritized for verification through investigation.
- Is a PWS required to verify its information is correct?
The PWS must document the source of the information. Some of this information may be more reliable than other information – for instance, documentation of a curb stop excavation where both sides of the service line were physically viewed recently may be more reliable than a decades-old tie card. The PWS can continue to update the inventory as more information is gathered, prioritizing areas with minimal or unreliable data.
- Can statistical modeling be used, and if so, how?
Statistical modeling is most appropriate in instances where both lead service lines and service lines of unknown material are known to be located within the distribution system. It can then be used to predict which of the unknown service lines may be likely to be lead. In PWS where few/no lead service lines have been identified but limited inventory information is available, it is possible to use statistical methods to identify a certain percentage of unknown lines for investigation and demonstrate with a degree of accuracy that there are no lead service lines present.
- What type of identification methods are allowed?
There are various methods allowed. Please see EPA guidance for more information. All identification methods must be documented.
- Can a PWS use funding to hire an intern or pay existing staff to go through data or our programmer to upgrade our database?
Yes.
- Will there be a simple process to access those funding resources instead of going through the formal loan/SRF/Capacity grant process?
The DWP is working on creating a streamlined process for smaller systems (<200 service connections) to access funding resources. Larger systems will need to apply through the DWSRF process.
- Does my public water system need to consider the Reduction of Lead in Drinking Water Act (January 4, 2014) when completing the inventory?
In 2014 the Reduction of Lead in Drinking Water Act revised the definition of lead-free to a weighted average of not more than 0.25 percent lead calculated across the wetted surfaces of pipe, pipe fitting, plumbing fitting, and fixtures. Devices such as curb stops and meters may be made of older brass and not meet the revised lowered lead-free standard and could contribute to lead exposure. EPA recommends but does not require that water systems consider tracking these devices if information is available (sections 2.1.3 and 7.1.2 of the Guidance for Developing and Maintaining a Service Line Inventory).
- What year does the DWP find acceptable to help filter/classify service line in regard to lead ban of 1986?
Service lines installed in 1989 or later can be classified as Non-lead in your inventory.
- The Maine Plumbing Code from 1926 shows a lead ban for all service lines starting at that time. Does that mean that a PWS can automatically character all service lines from homes built after that date as non-lead?
There is evidence that this lead ban was in place starting in 1926, and that is a good starting place for prioritizing further investigation at homes built before that date. However, additional documentation, such as tie card contents and local ordinances, should also be used to document service line materials.
- How should brass service lines be categorized?
Brass lines can be characterized as non-lead, with a comment identifying them as brass, since brass lines are not included in the definition of lead service lines. However, brass can be a source of lead leaching into drinking water, so the PWS should document the location of brass in the distribution system and work toward removing it.
- How should lead-lined service lines be categorized?
Categorize as Lead and put a comment in the spreadsheet about lead lining.
- What level of documentation is sufficient to call a service line “Non-Lead?”
There is a range of potential documentation levels and the PWS will need to make this determination based on the weight of available evidence. Service lines with limited information should be prioritized for additional investigation. Consult with the Drinking Water Program on specific circumstances.
- If a PWS has a well serving a single building, what should be reported?
Report the pipe material from the well to the building inlet for the inventory.
- Is there a requirement to collect new information and update the inventory?
Systems must identify and track information on service line material as they encounter the service lines during normal operations (e.g., checking service line materials when reading water meters or performing maintenance activities). Systems must update the inventory based on all applicable sources and any lead service line replacements or service line material inspections that may have been conducted.
- Where can I find more information about the LCRR?
The DWP will post guidance materials on our website as they become available. During the interim, we encourage all water systems to visit the Lead & Copper Rule page of EPA’s website at for more information.
- My public water system is collecting Lead and Copper samples in 2024. If I exceed the lead action level, do I need to complete a 24-hour public notice?
Systems scheduled to collect lead and copper samples during the annual (YR) and triennial (3Y) monitoring periods of June 1 ‐ September 30 will not be subject to the 24-hour PN requirements under LCRR in 2024. Systems scheduled to collect lead and copper samples during the six-month (6M) monitoring period between July 1 ‐ December 31, 2024, will be subject to the 24-hour PN requirements if results are reported to the state after October 16, 2024. Systems sampling during the July 1 ‐ December 31 monitoring period whose results are reported and accepted by DWP prior to October 16, 2024, will not be subject to the 24-hour PN requirements under LCRR in 2024. EPA has published PN guidance on the Lead and Copper Rule Implementation Tools webpage.
- My public water system has LSLs, GRRs, or unknown SLs and has made the inventory available to the public. Are there any other public notification requirements specific to the inventory?
Within 30 days of the completion of the initial LSL inventory, you must provide a public notice of the service line material to every customer served by an LSL, GRR, or unknown SL. You must repeat the notification annually until the entire service connection is no longer an LSL, GRR, or unknown SL. For new customers, you need to provide the notice at the time-of-service initiation.
