EPA releases lead service line inventory guidance
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EPA’s Guidance for Developing and Maintaining a Service Line Inventory is now available, and EPA will host a webinar on the guidance August 10. The registration link is available here. Lead service line inventories must be prepared by all water systems subject to the Lead and Copper Rule, and submittals are due to primacy agencies no later than Oct. 16, 2024.
EPA describes this guidance saying, "This document is not a regulation itself, nor does it change or substitute for those provisions and regulations.” EPA also emphasizes that states may set additional expectations with which systems must comply. EPA left open the possibility that the upcoming Improvements rulemaking could change inventory "updating” requirements.
The guidance includes several themes, among them (1) preparing an initial inventory based on a weight-of-evidence approach reflecting the best available information, (2) establishing procedures to update service line material characterization, and (3) updating the inventory through ongoing operations and proactive efforts.
At several points in the guidance EPA urges systems to reduce the number of service lines characterized as "lead status unknown” prior to initial inventory submittal. In the inventory, if either the customer-owned or public portion of the service line is considered unknown, the service line should be identified as "lead status unknown” in the inventory.
Note: EPA included a list of state-specific implementation dates for the 1986 Safe Drinking Water Act Lead Ban in Appendix D. The guidance recognizes uses of predictive modeling as a tool in inventory preparation.
