LSL Inventories and Replacement

***Inventories will only be accepted in the Ohio EPA template format***
Ohio EPA Service Line Inventory Template and Documents:
*** LSL Instructions and Requirements ***
*** Service Line Inventory Template ***
Instructions for Service Line Inventory Template
Service Line Inventory Fact Sheet
FAQ for Service Line Inventories

Federal EPA Service Line Inventory Documents:
Guidance for Developing and Maintaining a Service Line Inventory
Guidance for Small Systems Developing and Maintaining Service Line Inventory
Fact Sheet for Developing and Maintaining a Service Line Inventory

Additional Lead Service Line Resources & Information
for Small & Rural Water Utilities

The following resources and information have been compiled and partially produced by the Ohio Rural Water Association to assist small and rural water utilities in the development of Lead Service Line Replacement Programs (LSLRP) with funding from the Ohio Environmental Protection Agency.

For Official In-Depth Guidance from USEPA please refer to:
USEPA's Guidance for Developing and Maintaining a Service Line Inventory

Every water utility is unique, and each LSLRP should be uniquely customized to best serve the utility and their cummunity. We sincerely hope that the information and documents below will save your utility valuable time & resources, and enable you to develop a thorough, effective, and financially efficient LSLRP that will empower your utility to remove all of the lead service lines in your community once and for all.

USEPA Guidance for Small Systems
Small Entity Compliance Guide - On June 28, 2023, EPA released Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide to support water systems, particularly small water systems, in complying with the Lead and Copper Rule Revisions (LCRR) initial inventory requirements. EPA’s Small Entity Compliance guide helps explains the inventory related actions small community and non-transient non-community water systems are required to take under the LCRR.

Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide (pdf) (1.47 MB, June 2023, 815-B-23-005)

Fact Sheet - On June 28, 2023, EPA released Fact Sheet for Developing and Maintaining a Service Line Inventory. The fact sheet can help water systems quickly identify the key LCRR inventory requirements, including inventory elements, planning, records review, investigations, public accessibility, and information for non-lead systems.

Fact Sheet for Developing and Maintaining a Service Line Inventory (pdf) (1.26 MB, June 2023, 816-F-22-001)

Important Dates

December 16th, 2021
LCRR Effective Date

August 4th, 2022
EPA Issued Final LSL Inventory Guidance

October 16, 2024
LCRR Compliance Deadline & Initial Inventories Due

(Prior To) October 16th, 2024
EPA to Finalize Lead and Copper Rule Improvements (LCRI)

Fundamental Steps in Developing an Effective LSLR Program

Education & Training on the Lead and Copper Rules and Revisions
Understanding and if necessary adopting new ordinances that address line ownership & access
Building an Initial Inventory by conducting preliminary research and reviewing existing documentation
Establishing reporting methods and procedures to collect and store information (lead line locations, lines replaced, financial info, etc.)
Developing and/or acquiring outreach and notification materials, and determining the proper procedures for when and who to distribute them to
Undertaking physical identification efforts to inspect and confirm unknown service line materials
Determining the most effective options available for the actual line replacements (in-house, local contractors, etc.)
Creating a Capital Improvement Plan that addresses the costs and timeframe for replacement of identified lead lines and working to secure funding

LCRR Lead Service Line Requirements

All CWSs and NTNCWSs must develop an inventory of service lines that meets the LCRR requirements, including service line materials classification, information sources, and public accessibility (40 CFR § 141.84(a)).
All Water systems must submit their initial inventories to their state by October 16, 2024 (40 CFR § 141.84(a)(1)) and 141.90(e)(1)).
All CWSs and NTNCWSs must notify all persons served by the water system at the service connection with a lead, GRR, or lead status unknown service line within 30 days of completing their service line inventory (40 CFR § 141.85(e)).
All LCRR requirements other than the initial inventory requirements are subject to change under the LCRI.

Developing the Initial Inventory

The initial inventory must include all service lines regardless of ownership (40 CFR §141.84(a)(2)).
The initial service line inventory must use historical records as described in Chapter 4 (40 CFR §141.84(a)(3)(i)-(iii)), information gathered during normal operations as described in Section 3.4, and any resource, information, or identification method provided by or required by the state (40 CFR §141.84(a)(3)(iv) and (a)(5)).
Non-lead must be determined not to be lead or galvanized requiring replacement (GRR) through an evidence-based record, method, or technique (40 CFR §141.84(a)(4)(iii)).
If the water system is unable to demonstrate that the galvanized service line was never downstream of a lead service line (LSL), it must presume there was an upstream LSL and classify it as GRR (40 CFR §141.84(a)(4)(ii)).

LSL Inventory Development Steps

Key Steps:
1) Identifying Staff and Resources
2) Select an Inventory Format
3) Develop Procedures for Collecting Service Line Information
4) Establish Partnerships with Third Parties
5) Continuous Improvement

Lead Service Line Replacement Plan Requirements

Systems with known lead lines, galvanized lines downstream of lead lines, and/or unknown lead status lines must develop a plan to replace and/or identify the line type(s) within 3 years of LCRR publication (September 16, 2024).

The plan must include
Strategy(ies) for determining unknown line material
Procedures to conduct full replacement of lead lines
Strategy to inform customers (full or partial)
Recommend replacement goal rate (population >10,000)
Procedures for customers to flush particulate lead
Prioritization strategy for replacement pipe segments/sections of the system
Funding strategy for customers unable to pay for their portion of the replacement

Lead service line replacement plans must also include
PWS system must complete their replacement within 45 days of customer replacement. Option: Provide filter or POU device with replacement cartridges until fully replaced.

System must submit updated plan no later than 30 days after the end of the water system’s annual lead service line replacement requirements, and continue to submit it each year it conducts lead service line replacement.

Systems also must track and report; the number of lead and galvanized lines remaining to be replaced, as well as the number of those replaced for each type each year, the number of lead status unknown service lines remaining in the inventory, the total number of service lines initially inventoried as “non-lead” later discovered to be a lead or galvanized requiring replacement, and the number of full lead and galvanized requiring replacement service lines that have been replaced and the address associated with each replaced service line.

Mandatory 3% replacement rate per year after a lead action level (>15 µg/L) exceedance that includes galvanized pipe presumed to be downstream of lead. Based on a rolling two-year average.

Mandated risk mitigation best practices after partial LSLR that may cause lead disturbances.

Small System Flexibility Options
Applies to populations of 10,000 or less

Systems exceeding the lead trigger level (>10 µg/L) during sampling events must evaluate and recommend one of four compliance alternatives:
Lead service line replacement
Corrosion control treatment
Point-of-Use filtration devices
Replacement of lead bearing plumbing materials

For lead action level (>15 µg/L) exceedance, the system must implement the following:
15-year lead service line replacement plan
Implement or re-optimize corrosion control treatment
POU devices must be maintained by the system. Customers must be provided filter cartridges until replacement is completed

Downloadable Resources

We will be continuing to add additional resources and information as it becomes available. If you know of any publicly available resources that you believe would benefit your fellow rural water utilities please Contact ORWA and we will add it to this page.