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 nontransient noncommunity (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 are 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? While EPA works on the LCRI, water systems need to develop and submit a Lead Service Line Inventory (LSLI) by October 16, 2024; while continuing to comply with the prior version of the Lead and Copper Rule. 

We will update this page regularly.

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 dedicated effort to review historic records and determine appropriate identification methods to obtain both private and utility owned service line information.

To help you with how to complete a lead service line inventory, we developed a new publication—Lead Service Line Inventory Guidance 331-711 (PDF). There may be upcoming funding opportunities for lead service line related tasks.

Key Points to Know

  • 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 their LSLI.
  • Water systems must use any information on lead and galvanized iron or steel that it has identified per their materials assessment required per 40 CFR 141.42(d), and review any record explicitly identified in the LCRR.
  • The inventory will need to be updated regularly. Systems must identify and track information on service line materials as they are encountered in the course of normal operations, so digital versions may be beneficial for updates.

Please email your questions to LCRRassistance@doh.wa.gov or contact your regional office from 8 AM to 5 PM, Monday through Friday. Eastern Region, Spokane Valley 509-329-2100. Northwest Region, Kent 253-395-6750. Southwest Region, Tumwater 360-236-3030.

Lead Service Line Frequently Asked Questions 331-712 (PDF)

Statistical Guidance for Group A PWS Evaluation of Unknown Service Lines 331-723 (PDF)

Resources

Lead Service Line Inventory-related Information and Tools

General LCRR Information