PWSs

Lead and Copper Rule Revisions (LCRR) (Renewal)

LCRR Service Line Inventory Template.xlsx

PWSs

OMB: 2040-0297

Document [xlsx]
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Overview

Introduction
Template Instructions_Systems
Template Instructions_State
Classifying SLs
PWS Information
Inventory Methods
Inventory Summary
Detailed Inventory
Public Accessibility Doc.
State Checklist


Sheet 1: Introduction





Service Line Inventory Template, V.3.1

Date last updated: July 20, 2022




What is the purpose of this template?
The purpose of this draft template is to help water systems and states comply with the service line inventory requirements of the January 15, 2021 Lead and Copper Rule Revisions (LCRR). This template supplements the draft EPA document, Guidance for Developing and Maintaining a Service Line Inventory (2022) by providing fillable forms and tables that water systems can use to document their methods, organize their inventory, submit the initial inventory and inventory updates to the state, and document how they are making the inventory publicly available. This template also provides a checklist for state review. Note that EPA does NOT require systems use this template for their inventory. Refer to EPA's 2022 Inventory Guidance for minimum inventory requirements and recommendations.





How is the template organized?
The worksheets in this template are color coded:
Yellow sheets are instructions and background.
Dark blue sheets are templates for systems.
The dark green sheet is a template for states.

See the table below for a description of each worksheet.
The cells in this template are also color coded:
Gray cells are background or instructions.
Light blue cells are fillable cells for systems.
Aqua cells are the required fields in the Detailed Inventory worksheet.
Light green cells are fillable cells for states.





Template Organization
Worksheet Type Worksheet Name Description
Background Template Instructions_System Contains detailed instructions for systems.
Template Instructions_States Contains detailed instructions for states.
Classifying SLs Summarizes requirements for classifying the entire service line when ownership is split (i.e., when the system owns a portion and the customer owns a portion).
Templates for Water Systems PWS Information For systems to document basic system information.
Inventory Methods For systems to document the methods and resources they used to develop and update their inventory.
Inventory Summary For systems to provide a summary of their service line inventory, including information on ownership, inventory format, and the number of service lines for each of the four required materials classifications. Systems can enter the totals into this worksheet or automatically generate totals based on information in the Detailed Inventory worksheet.
Detailed Inventory Provides a customizable format water systems can use to track materials for each service line in their distribution system. Each row equals one service line connecting the water main to the customer's plumbing. Separate columns track locational information, the system-owned portion, the customer-owned portion, other possible sources of lead, information for assigning a tap sample tiering classification, and information for lead service line replacement (LSLR). Systems can customize the worksheet by adding or deleting columns.
Public Accessibility Doc. For systems to provide documentation to states on how they met the public accessibility requirements of the LCRR.
Templates for States State Checklist Provides a checklist that states can use to to determine and document if water systems met all of the January 15, 2021 LCRR requirements for their Initial Inventory including timely submission, required elements, use of information sources, public accessibility, and public notification of service line materials.
Note: Hidden rows below are for drop down lists. Do not modify or delete.



Sheet 2: Template Instructions_Systems






































































































































































Sheet 3: Template Instructions_State



Sheet 4: Classifying SLs





Classifying the Entire Service Line When Ownership Is Split




Purpose of this worksheet: To summarize EPA's requirements for classifying the entire service line when ownership is split.




Introduction
In many cases, service line ownership is split meaning that the system owns a portion and the customer owns a portion of the service line. Exhibit 1 below is a diagram of a possible division in service line ownership between the water system and customer. The LCRR requires systems to classify the service line material for each portion separately. However, a single classification per service line is needed by states to report initial inventory data to EPA and supports the lead service line (LSLR) and tap sampling requirements under the existing Lead and Copper Rule (LCR) and potential revised requirements under the Lead and Copper Rule Improvements (LCRI). Table 1 below indicates how to classify the material for the entire service line when ownership is split between the water system and customer. For more information, see EPA's, Guidance for Developing and Maintaining a Service Line Inventory (2022).




Exhibit 1. Example of Service Line Ownership Distinction between the Water System and Customer




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




Table 1: 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
Source: Exhibit 2-2 of Guidance for Developing and Maintaining a Service Line Inventory (USEPA, 2022).

Sheet 5: PWS Information





PWS Information

Purpose of this worksheet: For water systems to document basic system information.




Facility Information
Water System Name:
Sunny View Water System
PWSID: Population Served (number of people): Number of Service Connections: PWS Type:
XX0000001

CWS NTNCWS
If you are a CWS, do multi-family residences comprise at least 20% of the structures you serve? Select "Yes" or "No"
Mailing Address
Street or P.O. Box:

City or Town: State: Zip Code:



System Contact Person
Name: Title:


Telephone: Email:


Person Who Prepared Inventory (if different from above)
Name: Title/Affiliation:


Telephone: Email:



Sheet 6: Inventory Methods




Inventory Methodology
PWS Name: Sunny View Water System
PWSID: XX0000001
Enter Date Last Updated:



Purpose of this worksheet: For water systems to document the methods and resources they used to develop and update their inventory.



Part 1: Historical Records Review
Type of Record Describe the Records Reviewed for Your Inventory and Indicate Your Level of Confidence (e.g., Low, Medium, or High)
1. Previous Materials Evaluation
Example: Locations of Tier 1 lead tap sampling locations that are served by a lead service line.

2. Construction Records and Plumbing Codes
Examples: Local ordinance adopting an international plumbing code. Permits for replacing lead service lines.

3. Water System Records
Examples: Capital improvement plans. Standard operating procedures. Engineering standards.

4. Distribution System Inspections and Records
Examples: Distribution system maps. Tap cards. Service line repair/replacement records. Inspection records. Meter installation records.

5. Additional Records Required by Your State
6. Other Records



Part 2: Identifying Service Line Material During Normal Operations
1. During which normal operating activities are you collecting information on service line material? Check all that apply.



Water meter reading Water main repair or replacement
Water meter repair or replacement Backflow prevention device inspection
Service line repair or replacement Other



If "Other", please explain:

2. Did you develop or revise standard operating procedures to collect service line material information
during normal operation?
Select "Yes" or "No"
If "Yes", please describe:


Part 3: Service Line Investigations
1. Identify the service line investigation methods your system used to prepare the inventory (check all that apply). If a water system chooses an investigation method not specified by the state under 40 CFR §141.84(a)(3)(iv), state approval is required. Note that investigations are not required by the LCRR but can be used by systems to assess accuracy of historical records and gather information when service line material is unknown.



Visual Inspection at the Meter Pit Water Quality Sampling - Other
Customer Self-Identification Mechanical Excavation
CCTV Inspection at Curb Box - External Vacuum Excavation
CCTV Inspection at Curb Box - Internal Predictive Modeling
Water Quality Sampling - Targeted Other
Water Quality Sampling - Flushed

Water Quality sampling - Sequential




If "Other", please explain:

2. If "Predictive Modeling", please briefly describe the model and inputs used:

3. How did you prioritize locations for service line materials investigations? For example, did you consider environmental justice and/or sensitive populations, did you use predictive modeling, and/or did you target areas with high number of unknowns?



Sheet 7: Inventory Summary






Inventory Summary
PWS Name: Sunny View Water System
PWSID: XX0000001
Enter Date Last Updated:






Purpose of this worksheet: For water systems to provide a summary of their service line inventory, including information on ownership, inventory format, and the number of service lines for each of the four required materials classifications.





Part 1. General Information
1. Is this the Initial Inventory or an Inventory Update? Select One
2a. Who owns the service lines in your system? If other, please explain below. Select Ownership Type


2b. Is there documentation that defines service line ownership in your system, such as a local ordinance? If yes, please describe below and explain where ownership is split (e.g., property line, curb stop). Select "Yes" or "No"


3a. Describe when lead service lines were generally installed in your system.


3b. When were lead service lines banned in your system? Reference the state or local ordinance that banned the use of lead in your system.


4. Do you have lead goosenecks, pigtails or connectors in your system? Select "Yes" or "No" or "Don't Know"
5. What is your overall level of confidence in the inventory (i.e., "Low", "Medium", or "High.") Please explain your rationale below.







Part 2. Inventory Format
Describe your inventory format in the space provided below (e.g., the Detailed Inventory worksheet, custom spreadsheet, GIS map). Provide the filename and/or web address if applicable. Note that the state may require you to submit your detailed inventory of each service line in your distribution system.







Part 3. Inventory Summary Table 1
If you are using the Detailed Inventory worksheet, the classifications you select in the Column "Entire Service Line Material Classification" (Column X) will be used to calculate the total number of service lines for each of the four material classifications below. Otherwise, enter the number of service lines in the aqua-colored cells. Remember this is the classification for the entire service line.
Service Line Material Classification Definition Total Number of Service Lines
(REQUIRED to be reported under the LCRR)

Lead Any portion of the service line is known to be made of lead.2 1
Galvanized Requiring Replacement (GRR) The service line is not made of lead, but a portion is galvanized and the system is unable to demonstrate that the galvanized line was never downstream of a lead service line. 3
Non-Lead All portions of the service line are known NOT to be lead or GRR through an evidence-based record, method, or technique. 2
Lead Status Unknown The service line material is not known to be lead or GRR. For the entire service line or a portion of it (in cases of split ownership), there is not enough evidence to support material classification. 2
TOTAL 8
Notes



1 This summary table is for reporting material for the entire service line connecting the water main to the customer's plumbing. See the Classifying SLs worksheet for additional guidance on assigning a materials classification to the entire service line when ownership is split. Remember that systems must track the system-owned and customer-owned portions separately in their inventory.
2 EPA recommends including lead-lined galvanized pipe as lead in the inventory because potential lead exposure is similar to that of a lead service line. Do NOT, however, count non-lead service lines with a lead gooseneck or pigtail as lead service lines unless required by your state.

Sheet 8: Detailed Inventory




































Detailed Inventory























PWS Name: Sunny View Water System























PWSID: XX0000001























Date Last Updated:





























































Purpose of this worksheet: To provide a customizable format water systems can use to track materials for each service line in their distribution system.

General Instructions: Each row in this worksheet represents one service line connecting the water main to the customer's plumbing. The worksheet includes required and recommended elements; the columns with the aqua shading are required by the LCRR. Systems can customize by adding or deleting columns. Important notes for each column are in Row 12; also see the Template Instructions worksheet for detailed instructions. Note that users can freeze panes to enable them to see the headings and notes when entering data. The worksheet includes examples in rows 13 - 20 and is formatted for approx 10,000 entries.
























































Location Information System-Owned Portion Customer-Owned Portion Entire Service Line
Material Classification
Other Potential Sources of Lead Additional Information to Assign Tap Monitoring Tiering Lead Service Line Replacement (LSLR)

Unique Service Line ID Location Identifier Sensitive Population? (Yes/No) Disadvantaged Neighborhood? (Yes/No) System-Owned Portion
Service Line Material Classification
If Non-Lead in Column G,
Was Material Ever Previously Lead?
Service Line Installation Date Service Line Size Basis of Material Classification Was the Service Line Material Field Verified? If "Yes" Service Line Material Was Field Verified: Notes Customer-Owned Portion
Service Line Material Classification
Service Line Installation Date Service Line Size Basis of Material Classification Was the Service Line Material Field Verified? If "Yes" Service Line Material Was Field Verified: Notes Is there a Lead Connector? Is there Lead Solder in the Service Line? Describe Other Fittings and Equipment Connected to the Service Line that Contain Lead Building Type Connected to Service Line Point-of-Entry or Point-of-Use Treatment Present? Does the Interior Building Plumbing Contain Copper Pipes with Lead Solder Installed Before Your State's Lead Ban (Generally 1986 - 1988)? Current LCR Sampling Site? Date of System-owned LSLR Date of Customer-owned LSLR

Street Address Other Location Identifier Describe the Field Verification Method Enter the Date of Field Verification Describe the Field Verification Method Enter the Date of Field Verification

A Unique ID is recommended for each service line. Water systems must track addresses of all service lines in their internal inventory. For the publicly accessible version, location identifiers are required for lead and galvanized requiring replacement. If the system does not use addresses for their location identifier, other options could include GPS coordinates, landmark, intersection, block, or other details to specify service line locations. Select Yes if sensitive subpopulation, e.g., day care, school, multifamily home. If Yes-Other, describe in the Notes field. Does location meet state affordability guidelines or other measures? Dropdown list includes recommended subclassifications. If "Non-Lead Other", describe in Notes field Select Yes, No, or Don't know. Important for determining if downstream/ customer-owned galvanized service line requires replacement Date, year, or estimated date range when the service line was installed or replaced Diameter in inches Select option from drop down list. If "Other," describe in the Notes field Select Yes or No Select option from drop down list. If "Other," describe in the Notes field Enter approximate date of field verification or date that the record was updated Can use this field for documenting additional relevant information, including when classification changes. Dropdown list includes recommended subclassifications. If non-lead other, describe in Notes field. Date, year, or estimated date range when the service line was installed or replaced Diameter in inches Select option from drop down list. If "Other," describe in the Notes field Select Yes or No Select option from drop down list. If "Other," describe in the Notes field Enter approximate date of field verification or date that record was updated Can use this field for documenting additional relevant information, including when classification changes. Dropdown list includes four required service line classifications of Lead, Non-lead, Galvanized Requiring Replacement, or Unknown For example, lead gooseneck or pigtail where the water main is connected to the service line Select Yes, No, or Don't Know For example, backflow preventer or meter containing lead Note: This information may be helpful for identifying lead tap monitoring locations.



Example 1 1234 Test St., City, State, Zip Code Intersection of Test and Elm St. No No Non-Lead - Plastic Yes 1997 2 Installation date after lead ban Yes Visual inspection at the meter pit 5/1/2019
Non-Lead - Plastic 2012 2 Installation date after lead ban No


Non-Lead No No
Single Family Residence Yes No No



Example 2 4321 Test St., City, State, Zip Code Intersection of Test and Main St. No No Non-Lead - Plastic No Fall 1980 2 Installation record (e.g., tap card) Yes Mechanical excavation at one location 9/10/2020
Galvanized Fall 1980 2 Installation record (e.g., tap card) Yes Mechanical excavation at one location 9/10/2020
Non-Lead No No
Single Family Residence No No No



Example 3 16 Capital St., City, State, Zip Code
No No Non-Lead - Copper Don't know 1985 1 1/2 Service line repair or replacement record No


Galvanized 1908 1 1/2 Installation record (e.g., tap card) No


Galvanized Requiring Replacement Don't Know Don't Know
Other Unknown Unknown No



Example 4 1 Water Avenue, City, State, Zip Code
No No Unknown - Likely Lead
1940's 2
No


Galvanized 1940's 2
Yes Customer self-identification 8/8/2020
Galvanized Requiring Replacement Don't Know Yes
Single Family Residence No Unknown Yes



Example 5 67 Children's Place, City, State, Zip Code
Yes - Day Care No Unknown - Material Unknown
1950-1960 3/4
No


Unknown - Material Unknown 1950-1960 3/4
No


Unknown Don't Know Yes
Single Family Residence No Yes No



Example 6 30 Price Street, City, State, Zip Code
No No Lead-lined galvanized
1955 2 Installation record (e.g., tap card) Yes CCTV investigation at curb stop - internal 8/8/2020
Lead-lined galvanized 1955 2 Installation record (e.g., tap card) No


Lead Yes No
Single Family Residence No Yes Yes



Example 7 123 System Ave., City, State, Zip Code Building A No Yes Non-Lead - Copper Yes 2015 2 Service line repair or replacement record No


Galvanized 1950 - 1955 2 Installation record (e.g., tap card) Yes Customer self-identification 1/15/2020
Galvanized Requiring Replacement No Don't Know Backflow preventer Single Family Residence No Unknown No



Example 8 123 System Ave., City, State, Zip Code Building B No No Non-Lead - Copper Don't know 2015 2 Service line repair or replacement record No


Unknown - Material Unknown 1940's 2
No


Unknown No Yes
Single Family Residence No Unknown No



Sheet 9: Public Accessibility Doc.





Public Accessibility Documentation
PWS Name: Sunny View Water System
PWSID: XX0000001
Enter Date Last Updated:





Purpose of this worksheet: For systems to provide documentation to states on how they met the public accessibility requirements of the LCRR.




1. Select the location identifiers that you use for your service line inventory. Check all that apply.
Address


Street


Block


Intersection


Landmark


GPS Coordinates


Other


If "Other", please describe:


2. Does every service line have a location identifier? Select "Yes" or "No"
If "No", explain. Remember that location identifiers are required for service lines that are lead and galvanized requiring replacement.


3. How are you making your inventory publicly accessible? Check all that apply. Remember that if your system serves > 50,000 people, you must provide the inventory online.
Interactive online map


Static online map


Online spreadsheet


Printed service line map


Printed tabular data


Information on water utility mailings or newsletter


Hard copy information available in water system office


Other


If "Other", please describe:























































































































































































































































































































































Sheet 10: State Checklist








State Checklist for Initial Inventory Submittal

PWS Name: Sunny View Water System

PWSID: XX0000001

Enter Date Last Updated:








Purpose of this worksheet: For states to determine and document if water systems met all of the January 15, 2021 Lead and Copper Rule (LCRR) requirements for their Initial Inventory including timely submission, required elements, use of information sources, public accessibility, and public notification of service line materials.







Part 1: Person Completing This Checklist

Name: Title:






Telephone: Email:












Part 2: Review for Timely Submission

1. Was the initial inventory submitted by the deadline of October 16, 2024? Select "Yes" or "No"

Consider post-mark or date sent via email or reported into a state data system.







Part 3: Review for Required Elements

1. Does the inventory include all service lines connected to the distribution system? Select "Yes" or "No"

Consider if the total number of service lines in the Inventory Summary worksheet, Part 3, matches sanitary survey and monitoring data in the state’s database (e.g., SDWIS/State) based on population served, number of service connections (including those for non-potable use), number of accounts, census data, or other information.


2. Does the inventory include portions owned by the water system and the customer? Select "Yes" or "No"

Check the service line ownership type selected in the Inventory Summary worksheet, Part 1, Question 2a. If the system selected "Ownership is Split" check that their inventory includes information for both the system-owned and customer-owned portions.

3. Did the system classify all service lines as either Lead, Galvanized Requiring Replacement (GRR), Non-Lead, or Lead Status Unknown? Select "Yes" or "No"

Consider if the system completed each row of the inventory summary table in the Inventory Summary worksheet, Part 3.
Some rows may be zero.


4. In the space below, provide additional comments/documentation related to required elements of the system's initial inventory.










Part 4: Review for Information Sources

1. Did the system use the following historical records to prepare their initial inventory: previous materials evaluation, construction and plumbing codes/records, water system records, distribution system inspections and records. Select "Yes" or "No"

Consider if the system identified historical records in each row of the Inventory Methods worksheet, Part 1, Rows 1 through 4.
Consider if the system completed Row 5 if additional records are required in your state.


2. Is the system collecting service line material information during normal operations?
Select "Yes" or "No"

Consider if the system checked one or more normal operations activities in the Inventory Methods worksheet, Part 2.
Consider asking the systems to submit updated or new standard operating procedures documenting service line material information collection.


3. Has the system conducted investigations to verify service line material? Select "Yes" or "No"

This is not required by the LCRR but recommended by EPA to verify historical records and gather information where records do not exist to reduce the number of unknowns in the system as quickly as possible. Consider:
• If the system checked one or more of the investigative methods on the Inventory Methods worksheet, Part 3.
• If in their inventory, the system indicated that the materials classification was based on investigations.
• The number of unknowns - EPA strongly discourages systems from submitting inventories with all unknowns. If all service line materials are lead status unknown, consider asking the water system to conduct investigations.


4. In the space below, provide additional comments related to information sources used to develop the system's initial inventory.










Part 5: Review for Public Accessibility

1. Does the inventory include locational identifiers for each service line that is lead or galvanized requiring replacement? Select "Yes" or "No"

Consider checking the inventory for location identifiers and reviewing the system's answers in the Public Accessibility Doc. worksheet, Questions 1 and 2.

2. Did the system make its inventory publicly accessible? Select "Yes" or "No"

Consider reviewing the method by which the water system is making its inventory publicly accessible as identified in the Public Accessibility Doc. worksheet, Question 3. Check that systems serving more than 50,000 people have posted their service line inventories online.

3. In the space below, provide additional comments/documentation related to public accessibility of the system's initial inventory.










Part 6: Review of Customer Notification of Service Line Material

1. Does the water system's inventory consist of all Non-Lead Service lines? Select "Yes" or "No"
If No, complete questions 2 through 5. If Yes, stop here.

2. Did the water system deliver the notification to people served by a lead service line (LSL), GRR, or lead status unknown service line within 30 days of completing the initial inventory? Select "Yes" or "No"

3. Did the water system demonstrate that they delivered the notification and provide a copy of the notification to the state by July 1 for the previous calendar year? Select "Yes" or "No"

4. Did the notification include the required content?

a. For confirmed LSLs, does the notification include: Select "Yes", "No", or "N/A"
· A statement that the service line material is lead,
· Information on lead health effects including mandatory health effects language of §141.85(a)(ii),
· Steps to minimize exposure to lead in drinking water,
· Opportunities for service line replacement,
· Available financing programs, and
· A statement that the system must replace its portion if the property owners notify the system that
they are replacing their portion?




b. For GRRs, does the notification include: Select "Yes", "No", or "N/A"
· A statement that the service line material is GRR,
· Information on lead health effects including mandatory health effects language of §141.85(a)(ii),
· Steps to minimize exposure to lead in drinking water, and
· Opportunities for service line replacement?




c. For Unknowns, does the notification include: Select "Yes", "No", or "N/A"
· A statement that the service line material is lead status unknown,
· Information on lead health effects including mandatory health effects language of §141.85(a)(ii),
· Steps to minimize exposure to lead in drinking water, and
· Opportunities to verify the service line material?




5. In the space below, provide additional comments/documentation related to customer notification for people served by an LSL, GRR, or lead status unknown service line.



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