On June 28, 2023, EPA released two new resources that support water systems with the Lead and Copper Rule Revisions (LCRR) service line inventory requirements. All community water systems (CWSs) and non-transient non-community water systems (NTNCWSs) must submit an initial inventory to their state or primacy agency by October 16, 2024. These new resources complement existing EPA guidance and can be used by water systems to understand service line inventory requirements better. As your LCRR experts, we reviewed and summarized the two new resources below. 

Resource #1: The Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide (Small Systems Guide) is designed to support water systems, particularly small water systems, in complying with the LCRR initial inventory requirements. The Small Systems Guide helps explain the inventory-related actions that small community and non-transient non-community water systems must take under the LCRR. 

The Small Systems Guide and the Guidance for Developing and Maintaining a Service Line Inventory (Full Guidance) published by EPA in August 2022 are both based on the LCRR, effective December 16, 2021. Currently, the LCRR has remained the same, so the Small Systems Guide does not contain new requirements based on a regulatory change. The EPA intends to publish a proposal to revise the LCRR and take final action on the proposal by October 16, 2024. However, the EPA does not expect to propose changes to the initial service line inventory requirements.

The Small Systems Guide contains regulatory requirements and recommendations; it is important to understand what is required versus what is recommended. This information is summarized in Exhibit 1 on page 2. In addition, each State may have passed laws or regulations for service line inventories that are more stringent than federal requirements. At 120Water, we developed a website to track state-specific service line inventory requirements. The website contains downloadable service line inventory guides summarizing state-specific inventory resources and requirements.  

What is a small system, and do service line inventory requirements differ based on the size of the system?  

The LCRR allows flexibility for some requirements for systems serving varying levels of customers (e.g., 50,000, 10,000, or 3,300). Most of the LCRR flexibility applies to systems serving 10,000 or fewer people, which is the general threshold for defining small systems in the LCRR. However, the only service line inventory requirement that varies based on system size is that systems serving >50,000 persons must provide access to their inventories online (e.g., website). All other requirements are the same regardless of system size, and the inventory is still due on October 16, 2024. However, some state due dates (Illinois, New Jersey, Michigan, and Alaska) differ, so consult your State for specific inventory deadlines.  

What is the difference between the Small Systems Guide, just published on June 28, 2023, and the Full Guidance, published on August 4, 2022? 

Since the regulation has remained the same, there are no new requirements in the Small Systems Guide. However, the information in the Small Systems Guide is presented in a FAQ format that focuses on inventory issues that are the most important for small systems. New graphics for understanding master meter scenarios (Ex. 3 on pg. 7) or NTNCWS configurations (Ex. 4 on pg. 8) have been added. A hypothetical example of a completed inventory using the EPA template (C-1) is provided. The Small Systems Guide (50 pages) is more concise than the Full Guidance (164 pages). 

Is there a different template for small systems? 

There is still only one inventory template that EPA released in August 2022. However, most states are releasing their own template, and some states have different templates based on system size. You should consult your State to understand State specific template requirements. State-specific inventory templates can be accessed in the resources section at the bottom of each state-specific guide on the 120Water website. 

How should I use the new small systems guide? 

The Small Systems Guide is designed for small systems and NTNCWS. However, since all systems must develop a service line inventory, this guide can be a resource for any system developing an inventory. The Small Systems Guide could be combined with the more detailed Full Guidance. 

What systems will benefit most from this new small systems guide?

• Small towns
• Rural water districts
• Tribal waters systems
• Manufactured housing parks
• Homeowners associations
• Small private water systems
• Factories, schools, and religious institutions that have their own water supplies 

Resource #2: The Fact Sheet for Developing and Maintaining a Service Line Inventory (Fact Sheet) is a concise eight-page overview of EPA’s requirements and recommendations for developing an initial inventory. 

The Fact Sheet is organized into six sections: 

Section 1: Required inventory elements and definitions
Section 2: Inventory planning
Section 3: Records review
Section 4: Service line investigations
Section 5: Sharing inventory information with the public
Section 6: Information for systems with only non-lead service lines

How should I use the new Fact Sheet? 

The Fact Sheet provides a very high-level overview of the inventory requirements. The Small Systems Guide and the Full Guidance contain more detailed information on service line inventories. Water systems can use all three resources to better understand the requirements and recommendations of service line inventories.

About 120Water

120Water is the comprehensive solution used by state agencies, water utilities, and facilities across the country to manage critical lead and drinking water programs. Comprised of secure cloud-based software, services and products, 120Water’s solution provides tailored workflows for complying with lead and water quality programs to protect public health. Visit 120Water.com/lcrr-assistance to schedule a time to connect with our team.

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