Lead Service Line Inventory—EPA's Lead and Copper Rule Revisions

New Requirements

On January 15, 2021, the U.S. Environmental Protection Agency (EPA) issued Lead and Copper Rule Revisions (LCRR) that went into effect on December 16, 2021. Group A Community and non-transient non-community (NTNC) water systems are required to follow the LCRR, which is located in 40 CFR 141. At the same time, EPA announced that it was going to begin new rulemaking to update these same requirements, which they identified as the Lead and Copper Rule Improvements (LCRI). The part of the LCRR not expected to change in the LCRI is the requirements relating to the Lead Service Line Inventory or LSLI. All other requirements of the LCRR are subject to change under the LCRI.

What does this mean to Group A water systems? To comply with the LCRR, community and NTNC water systems need to develop and submit a Lead Service Line Inventory (LSLI) to the state by October 16, 2024; while continuing to comply with the monitoring, reporting, and treatment requirements of the prior version of the Lead and Copper Rule.

Guidance and Template for LSL Inventory

The rule requires all community and non-transient non-community (NTNC) Group A water systems to submit service line inventories to the state by October 16, 2024. This requires water system to dedicate efforts to review historic records and determine appropriate identification methods to obtain both private and utility owned service line information.

We developed publications and documents to help you complete a lead service line inventory.

Use one of the following MS Excel templates to capture the inventory details.

EPA Inventory Template Edited for Washington Small Public Water Systems (Excel). We simplified this template for community and NTNC water systems that serve less than 5,000 connections. To use, open/download the file, click on "Enable Content," and Save to your computer using your system ID number in the file name.
EPA Service Line Inventory Template (Excel). Open, click on “File,” click Save as “Download a copy to your computer,” then open the file saved in your Downloads folder and rename it using your system ID number in the file name.

Notification Requirements for Lead, GRR, or Unknown

Public Water Systems that report Lead Service Lines (LSLs), Galvanized Requiring Replacement (GRR), or have Unknown material service lines in their inventory must provide consumer notice to those individual customers. These notices must be provided to your customers and/or persons served by the service line no later than November 15, 2024. These consumer notices must be provided to customers by mail or by email following the same electronic delivery requirements you use to send the annual consumer confidence reports (CRR Publication 331-470). The templates below include required and proposed language. Please read the last page of each template to learn what information is required in the notice.

Group A Public Water Systems: Submit Your Inventory—This is a Two Step Process

Please Note: If you are a customer of a water utility, please contact your utility to share information regarding your service line. Do not use this portal.

To start the process, click on the next link to fill in a summary of your information: Department of Health Water Lead Service Line Inventory Submittal Portal. Fill out the form, making sure to fill out the required fields, and then submit the form.
You will then get an email response letting you know how to send in your detailed inventory file. Follow the instructions in the email. After uploading your inventory file, you will receive another email stating we have received your submission.

Key Points to Know

For funding opportunities relating to developing the inventory and replacing lead service lines, please visit our Drinking Water State Revolving Fund webpage.
All Community and non-transient non-community (NTNC) water systems must develop an initial inventory of service lines that meets the LCRR requirements, including service line materials classification and information sources, for both the public and private portions of every service line.
Each service line must be classified as either:
- Lead,
- Galvanized requiring replacement,
- Non-lead, or
- Lead status unknown.
Non-lead service lines must be determined through evidence-based record, method, or technique.
Water systems must submit their inventories by October 16, 2024.
Water systems must make their inventories publicly available. Large water systems, populations greater than 50,000 people, must post the inventories on their website.
Community systems must indicate in their Consumer Confidence Report how to access service line inventory information. Non-lead community water systems may include a statement that they have no lead service lines in their Consumer Confidence Report.
Water systems must notify every connection served by a lead, galvanized requiring replacement, or lead status unknown within 30 days of completing and submitting their inventories.
Systems will need to update the inventory regularly. Systems must identify and track information on service line materials as they are encountered in the course of normal operations.