Service Line Inventory: Lead & Copper

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). You can find detailed information about service lines that must be included in the service line inventory 

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 requiring replacement. The written statement must include a description of the source(s) of information used to make this determination.

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.)

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.

30-Day Public Notification

Water systems must continue to provide notification to all consumers annually by December 1, with each service line identified as the following materials:

• Lead
• Galvanized requiring replacement (GRR)
• Unknown

For more information on the required public notification including templates, visit our communication toolkit website. Water systems have until July 1st, 2025, to submit a certificate of delivery for the public notification to DDW.

Disturbance notice

Disturbance Notifications will be required starting on November 1st, 2027.

Notification of service line disturbance is recommended following actions taken by a water system that cause a disturbance. This includes actions that result in a shut off or bypass of water to an individual service line or a group of service lines (e.g., operating a valve on a service line or meter setter, or reconnecting a service line to the main). This can also include other actions that cause a disturbance to a service line or group of service lines, such as undergoing physical action or vibration, that could result in pipe scale dislodging and associated release of particulate lead (  e.g., disturbances following inventorying efforts). For these disturbances, water systems are required to provide persons at the service connection with public education materials and instructions for a flushing procedure to remove particulate lead.

To identify which service lines require validation, water systems must first identify the validation pool. The validation pool consists of all non-lead service lines in the inventory excluding those that are identified by the following:

1. Records that indicate the service line was installed after April, 1989.
   • Non-lead lines identified by exclusively using other records must be included in the validation pool.
2. Visual inspection of the pipe exterior at a minimum of two points.
   • For example, a service line identified as copper based on a one-point visual inspection at the meter pit is required to be in the validation pool. However, if this service line material was also visually inspected a second point, such as inside the home, it would be excluded from the validation pool.
3. Previously replaced lead or GRR service lines. 

All unknown service lines must be identified by November 1st, 2037. Please find the list of all upcoming deadlines related to service line inventory and replacement on our calendar.

A service line inventory of the entire service area for both portions of the service line must be submitted to the Division of Drinking Water. 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. Water systems can access this template under “submit your inventory” on the main page. If you have been using the EPA’s inventory template, please copy over your inventory into DDW’s template.

A service line will be defined as a “galvanized requiring replacement” (GRR) 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 GRR’s.

Connector, also referred to as a gooseneck or pigtail, means a short segment of piping not exceeding three feet that can be bent and is used for connections between service piping, typically connecting the service line to the main. Lead connectors are not considered to be part of the service line.

Systems are required to review specified sources of information, such as construction and plumbing codes, permits, and records, that describe connector material and locations; and systems may use other sources of information not listed if approved or required by the Division. 

Systems must categorize connector material as “Lead”, “Non-lead”, “Unknown”, or “No connector present” where there is no connector at the location by November 1, 2027. 

A galvanized-lined lead pipe is a type of galvanized steel pipe that has a lead-based lining on the interior surface (used to protect the steel from corrosion). This type of service line is categorized as a lead service line per the LCRI. 

Systems that can verify they have all non-lead service lines can submit a Non-Lead Form. Systems will need to list the number of service lines and describe in detail the methods used to make the service line material determination. Systems will still need to have their detailed inventory internally. Keep in mind that additional inventory requirements will be implemented starting on November 1, 2027 following the publication of the LCRI.

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.

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 DDW’s Lead Service Line Inventory Outreach Toolkit.

YES! Under the LCRR and LCRI, 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: 

Classification of entire service line when ownership is split

Source: Exhibit 2-3 of Guidance for Developing and Maintaining a Service Line Inventory (USEPA, 2022)

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). You can find detailed information about service lines that must be included in the service line inventory.

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 requiring replacement. The written statement must include a description of the source(s) of information used to make this determination.

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.