Lead and Copper Rule Revisions / Lead Service Line Inventory

 

Page Index

Service Line Inventories

Forms and Guidance

Submitting Completed Inventories

Frequently Asked Questions

The Lead and Copper Rule Revisions (LCRR) represent the first major update to the Lead and Copper Rule (LCR) in nearly 30 years. “EPA’s new rule strengthens every aspect of the LCR to better protect children and communities from the risks of lead exposure. The new LCR will better protect children at elementary schools and child care facilities, get the lead out of our nation’s drinking water, and empower communities through information.” – US Environmental Protection Agency

 

A Service Line Inventory is a critical element in the effort to address sources of lead in drinking water and protecting public health.  All Community and Non-transient, Non-community (NTNC) public water systems must develop and submit a comprehensive and accurate inventory of every service line in their distribution system, regardless of whether any lead is present. Each service line, for every address served by the PWS, must be characterized regardless of the ownership of the line or its current use.

Service Line Inventories must be complete and submitted by October 16, 2024.

• For Trainings or Individualized Assistance please contact the Maine Rural Water Association (MRWA) at: LSLI@mainerwa.org

The inventory form requires key information such as the number of service lines in the system, a characterization of the composition of each service line, documentation of the method used to identify service line material, and the means that will be used to make the information in the inventory publicly accessible. This inventory must be amended in future years as new information becomes available or service lines are modified.

The DWP encourages all applicable PWS to begin work on their Service Line Inventories as soon as possible. It may take a significant amount of time to complete the inventory, and the submittal deadline is firm. Training on service line inventory completion by the DWP and our partners will be announced soon.

The inventory is required to be submitted electronically on one of two inventory form templates (downloads below):

• The Large System Inventory Template (form B1) must be used by
  • All municipal systems, and
  • Any other PWS with more than 25 service lines in their distribution.
• The Small System Inventory Form (form B2)
  • A shortened, simplified version that may be used by PWS with 25 or fewer service lines.

Inventories should be completed electronically to ensure accuracy and data integrity.  If a small PWS needs a hard (paper) copy of form B2 to assist with their inventory, please contact Paulo Ribeiro:  Email or phone (207) 441-0854.

 

Forms and Guidance

Large System Service Line Inventory (Form B1)

• Large System Service Line Inventory Template (XLSX)  Revised 3/18/2024
• EPA Service Line Inventory Guide (PDF)

Small System Service Line Inventory (Form B2)

• Small System Service Line Inventory Form (PDF)
  

  This form is an electronically fillable PDF. To ensure all functions operate properly, the form should be opened and completed using Adobe^® Reader.
  Click here to download and install the application.  This is a safe and free download from Adobe^®.

• Form B2 Instructions (PDF)
• How to Use PDF Forms
  

  Form B2 can be printed and completed by hand or filled-in using your computer. To ensure all functions operate properly, the form should be downloaded, then opened and completed using Adobe^® Reader.  Click here to download and install the application.  This is a safe and free download from Adobe^®.
  IMPORTANT:  If using the ‘fillable PDF’ option on a PC, do not attempt to complete these forms in a web browser such as Chrome or Edge, as some functions may not be available.  Mac users may find those functions work best when the form has been opened in the Safari browser.
  To use PDF forms on your computer, simply follow these easy steps:
     1.  Download the form and save it to your computer, either on your desktop or in a folder you can easily access.
     2.  Open the blank form at its location on your computer using the PDF Reader.
     3.  ‘Save As’, re-naming the form using pertinent information that will help identify the document in the future.
     4.  Using your computer keyboard, fill-in all applicable fields; use the TAB key to navigate through the document.
          Remember:  For the DETAILED INVENTORY (Part 3), columns A, B, and I are required.
     5.  Click ‘Save’.  You may return to the form at a later time to revise and/or complete your work. Be sure to 'Save' subsequent additions/revisions.
   
  

• EPA Small System Service Line Inventory Guide (PDF)

Public Notice Templates

• No Lead, Galvanized Requiring Replacement (GRR), or Unknown service lines were found.  Download (DOCX)
• Lead, Galvanized (GRR), and/or Unknown service lines were identified.  Download (DOCX)

Please Note: Completed Service Line Inventory public notices must be submitted to DWPMOR@maine.gov no later than November 15, 2024

Federal Lead and Copper Rule Revisions  Click here to learn more.

Financial Assistance for Service Line Inventories is available.  Click here to learn about funding options.

Training and/or Individualized Assistance is available from the Maine Rural Water Association (MRWA). For more information, email MRWA at LSLI@mainerwa.org.

 

Submitting Completed Inventories

Completed inventories must be submitted to the DWP no later than October 16, 2024.

• Service Line Inventory forms under 25 MB:  Submit via email to DWPMOR@maine.gov
• Service Line Inventory forms 25 MB and larger:  Upload to SOM SharePoint. For instructions, contact Paulo Ribeiro – Email or phone (207) 441-0854.

 

Frequently Asked Questions

1. 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.
   

2. When is the Service Line Inventory due?
   

   Completed Service Line Inventories are due October 16, 2024.
   

3. 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.
   

4. 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.
   

5. 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.
   

6. 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.
   

7. 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)).
   

8. 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)).
   

9. 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).
   

10. 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.
    

11. 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.
    

12. 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.
    

13. 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.
    

14. 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.
    

15. 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.
    

16. 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.
    

17. 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.
    

18. 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.
    

19. 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.
    

20. 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.
    

21. Is there funding available to replace lead service lines?
    

    Yes, funding is available to help cover these costs.   Click here for more information.
    

22. 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.”
    

23. 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).”
    

24. 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.
    

25. 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.
    

26. 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.
    

27. 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.
    

28. 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.
    

29. 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.
    

30. 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.
    

31. 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.
    

32. 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.
    

33. 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.
    

34. 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).
    

35. 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.
    

36. 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.
    

37. 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.
    

38. How should lead-lined service lines be categorized?
    

    Categorize as Lead and put a comment in the spreadsheet about lead lining.
    

39. 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.
    

40. 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.
    

41. 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.
    

42. 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.
    

Updated 4/23/2024