Lead and Copper Rule Revisions

Who has to complete a service line inventory?

All community and non-transient non-community (NTNC) systems must complete a service line inventory of their entire service area for both portions of the service line. Systems with any lead, galvanized requiring replacement, or lead status unknown service lines must include a location identifier (street address, and/or GPS coordinates), the material classification, ownership status, and each lead, galvanized requiring replacement, or lead status unknown service line in their inventory. DDW’s Inventory Template is available now, and will be the only inventory template accepted. If you have been using the EPA’s inventory template, please copy over your inventory into DDW’s template.

What if my system does not have lead pipes? 

Systems that can verify they have all non-lead service lines can submit a Non-Lead Form. You will need to list the number of service lines and describe in detail the methods used to make the service line material determination. hey will still need to have their detailed inventory internally. Keep in mind that additional inventory requirements are being considered in the EPA’s proposed LCRI. 

How does a system identify a non-traditional service line?

Most likely non-transient non-community public water systems have non-traditional service lines. For systems with a single service connection that consists of a source plumbed into a building, the pipe that runs from the source into the building is the service line and the material needs to be identified. If there are additional buildings plumbed to the system, the in-ground pipe material that serves each building must be identified as well.

How can a water system encourage homeowners to assist in complying or determining the service line connections? 

The water system can send out a survey, provide rebates, and educational materials encouraging their consumers that it is in their best interest to identify their service line.

For more guidance please see AWWA’s communication toolbox. DDW’s toolbox will be coming soon.

Does a water system have to show an inventory for both the city-owned side and the customer side? 

YES!  Under the LCRR, all community and Non-Transient Non-Community water systems must identify the material of the entire service line in the distribution system regardless of ownership. The entire service line can be identified using the following table: 

Table: Classification of Entire Service Line when Ownership Is Split

System-Owned Portion	Customer-Owned Portion	Classification for Entire Service Line
Lead	Lead	Lead
Lead	Galvanized Requiring Replacement	Lead
Lead	Non-lead	Lead
Lead	Lead Status Unknown	Lead
Non-lead	Lead	Lead
Non-lead and never previously lead	Non-lead, specifically galvanized pipe material	Non-lead
Non-lead	Non-lead, material other than galvanized	Non-lead
Non-lead	Lead Status Unknown	Lead Status Unknown
Non-lead, but system is unable to demonstrate it was not previously Lead	Galvanized Requiring Replacement	Galvanized Requiring Replacement
Lead Status Unknown	Lead	Lead
Lead Status Unknown	Galvanized Requiring Replacement	Galvanized Requiring Replacement
Lead Status Unknown	Non-lead	Lead Status Unknown
Lead Status Unknown	Lead Status Unknown	Lead Status Unknown

Are lead connectors required to be inventoried? 

No, lead connectors are not required to be inventoried under the rule, but do need to be replaced when encountered during planned or unplanned infrastructure work, including goal-based or mandatory service line replacement triggered under the LCRR. We recommend taking inventory of connector materials while filling out the service line inventory for your records. 

Per the proposed EPA Lead and Copper Rule Improvements LCRI, water systems would be required to include connector material in the lead service line inventory by the compliance date (three years after the final LCRI is published).

What is a galvanized line requiring replacement(GLRR)? 

A service line will be defined as a galvanized line requiring replacement (GLRR) if it was at any time downstream of a lead service line or is currently downstream of a “Lead Status Unknown” service line. It is possible Water systems may not have records that indicate whether or not galvanized service lines have ever been downstream of lead. If this arises, a water system may determine that a galvanized service line does not require replacement (i.e., can be classified as non-lead) only if: No LSLs are found within the water system service area during the course of records review; There are no known records or knowledge of previous lead service line replacement programs; and No LSLs have been found during field investigations.

If a water system has classified galvanized lines as not requiring replacement based on the above criteria and discovers LSLs or lead upstream of a galvanized line at any point in the future, the water system must inform the Division within 30 days. The Division will work with the water system regarding further investigations or may classify similar galvanized lines as GRR.

If a water system is unable to demonstrate that all the above criteria have been met or cannot demonstrate through other methods detailed in this document for identification i.e. inspections, modeling, sampling, or anecdotal evidence it must presume there was an upstream LSL, and the galvanized line must be classified as “galvanized requiring replacement” per the LCRR. For more information, go to our methods guidance on how to identify GLRR’s.

Nearly all systems will have unidentified or unknown service line materials. What action is required for unknowns? 

Customers must be notified within 30 days of their initial inventory being submitted, that their service line has Lead Status Unknown service line materials. Keep in mind that additional inventory requirements are being considered in the EPA’s proposed LCRI

Do I need to include service lines that are no longer in use in the inventory? 

Yes, all potable service lines must be included in the inventory. As long as the service line remains connected to the system, even if it is not in use (for example, vacant or abandoned buildings).

Do I need to make the lead service line inventory publicly available? 

Yes, service line inventories must be publicly accessible and provide a location identifier (street address, customer number, block, intersection, landmark, or other geographic marker) for each lead or galvanized service line downstream of the lead pipe requiring replacement. 

If your system serves more than 50,000 people, you must make your inventory publicly available online. To meet this requirement, you may use your website, cloud-sharing applications, or social media. Systems serving less than 50,000 people that do not have their inventory online must make copies of the inventory available for review upon request.

Systems that only have non-lead service lines in their inventory do not need to make their inventory publicly available, and instead may provide a written statement that there are no lead or galvanized service lines downstream of lead pipe requiring replacement. The written statement must include a description of the source(s) of information used to make this determination. 

Are all water systems required to submit a lead service line replacement (LSLR) plan? 

No, only public water systems with one or more lead, galvanized line requiring replacement (GLRR), or lead status unknown service lines in their distribution system must complete and submit a LSLR plan. The LSLR plan is intended to help systems comply with the lead service line replacement requirements of the LCRR and to ensure systems have a strategy for identifying lead status unknown service lines.

Can I start removing lead service lines before the LCRR compliance date? 

Though not required, water systems may choose to proactively remove lead or galvanized-requiring-replacement lines that are known to exist or are encountered during inventory investigations prior to the LCRI. We encourage this practice when possible, but water systems should follow best practices when completing a service line replacement that will be required under the Lead and Copper Rule Revisions, including:

• Notifying the customer of the replacement. If service line ownership is shared, explain that the system will replace the portion of the line it owns and offer to replace the customer-owned portion. Note: The system is not required to pay for replacing the customer-owned portion of the service line.
• Completing a full lead service replacement, when possible. Partial replacements may cause short-term elevations in drinking water lead concentrations.
• Provide the customer with a pitcher filter and enough filter replacements for six months.
• Provide instructions to the customer about service line flushing after the replacement.
• Offer to sample the home for lead 3-6 months after the replacement.
• Remove lead goosenecks, pigtails, connectors when encountered.

If the customer has lead or galvanized on their side of the meter who is responsible for replacing the line? 

The water system is responsible for alerting customers of the material of their service line. Replacement of service lines must be done as full replacements, so the water system and customer will need to replace both sides of the line at the same time. The rule does not require water systems to cover the cost of the customer side of the line, however, full replacements are required. The division has funding available to assist with replacement costs and incentives for customers to replace their lines when that time comes.

Once our inventory is submitted, will we have to put a service line replacement plan into action? How many service lines would need to be replaced per year? 

Replacement plans will be due three years after the LCRI is finalized. Once the LCRI is finalized, we will better understand all the requirements needed for completing a replacement plan.

What funding and technical assistance is available to help a water system complete a service line inventory? 

Small Systems Assistance Program (SSAP)

We are accepting applications from small community water systems (≤10,000 population served) that seek assistance from our contractor, Sunrise Engineering. This program is for assistance completing the Service Line Inventories and/or Lead Service Line Replacement Plans required under the Lead and Copper Rule Revisions (LCRR). We will pay the contractor directly, so no payment or reimbursement is required of the water system. 

Expedited Approval Funding

The Drinking Water Board has approved an expedited approval application process for systems seeking funding at or below $100,000 to develop service line inventories and/or lead service line replacement plans. Funding will be awarded as either grants or 0% interest loans. In order to receive grant funding, a water system must meet hardship criteria for disadvantaged communities. 

Expedited funds can be used for planning projects related to completing the service line inventory or replacement plan. This breakdown may include categories such as personnel salary and fees, community outreach and education tools, or equipment/software purchases or rentals.

Funding will be provided on a reimbursement basis. However, reimbursement can include planning work that has been performed prior to application approval. Final reimbursement will not be approved until a completed Initial Service Line Inventory and/or completed Lead Service Line Replacement Plan has been submitted and approved by the division. All Community and Non-Transient Non-Community water systems are eligible. 

Additional Funding 

Identifying service line materials at schools and licensed childcare facilities is one of our top priorities. If a system discovers lead service lines (LSLs) serving schools through their inventory efforts, additional funding (beyond the system’s initial award through this program) may be awarded for construction projects for the replacement of those LSLs. Systems seeking this additional funding for replacement of LSL at schools will need to submit an additional application outlining funding needs.

Any applications for funding above $100,000 or construction projects will need to be submitted through the normal Drinking Water State Revolving Fund (DWSRF) process. You can find more information about the DWSRF process including contacts at the DWSRF Webpage.

What is the difference between the SSAP and Expedited Approval Funding programs? 

Water systems may only receive support from one of these programs. The following table outlines the differences between the two programs: 

How is “residential service connection” defined? 

A residential service connection typically refers to a meter setting. If a duplex has one meter for both units it is defined as one connection. Beyond a duplex, each unit typically has its own meter (four meters for a fourplex, etc.)

How is “Number of all other connections/ Equivalent Residential connections” defined? 

For all other connections, typically Equivalent Residential Connections (ERC) is used. ERC is a measure of how much water a store, business, factory or cattle trough uses compared with the average residential user. For example, if the average residence uses 3,000 gallons per month and a convenience store uses 15,000 gallons per month, the store is equivalent to five residences (5 ERCs). This data is used to determine assistance levels from average residential monthly bills and to understand how many connections the system is serving to determine  priority.

What funding is available for service line inventory and replacement?

We are providing funding and technical assistance to help water systems complete their service line inventory and future replacement plans. We also have funding available to help with the water system’s service line replacement efforts. Learn more about current funding assistance at lcrr.utah.gov.