In August 2022, the Environmental Protection Agency (EPA) released guidance and a sample template to support utilities and states with their Service Line Inventory (SLI) efforts. The EPA deadline for the SLI submission is October 16, 2024. Many states have already released specific guidance, resources, and templates to ensure that water systems understand the SLI requirements in their state. 

Read below for some examples of how some state approaches to SLI requirements differ from EPA guidance.

Missouri – Verification Requirements for Historical Records

The Missouri Department of Natural Resources has issued SLI templates and a FAQ document. 

Missouri is recommending that water systems start their SLI process by evaluating the EPA required list of paper/digital records to identify service line materials. The accuracy of historical records can vary for each water system. In order to increase confidence in historical records, Missouri is requiring 10% visual verification, at randomly selected locations, for each type of paper/digital record (e.g. tap cards, build date, etc.). For example, if a Missouri water system had 1,000 tap cards and wanted to use the SL material classification listed on the tap cards for their inventory the system must first confirm that 100 (or 10%) of the materials listed on the tap card match the material identified through visual field verification at random locations. Until the 10% field verification process is confirmed, service line materials originating from historical records would be classified as “lead status unknown”. For the 10% random site inspections a 95% accuracy threshold is acceptable.

Pennsylvania – Gooseneck Definition

The Pennsylvania Department of Environmental Protection has released their SLI template and other resources.  The EPA guidance contains specific information on how lead goosenecks/pigtails/connectors (GPCs) are defined. 

1. EPA has determined that lead GPCs are not considered to be a part of the service line and if the only lead piping serving a home is a lead GPC then the service line would not be considered a lead service line. Pennsylvania is following this interpretation.
2. The EPA guidance also states that lead GPCs are not considered upstream sources of lead for the Galvanized Requiring Replacement (GRR) classification. Pennsylvania DOES consider lead GPCs to be an upstream source of lead for classifying GRR and  water systems must be able to demonstrate that a galvanized service line is not or never was downstream of a lead service line or lead GPC. Otherwise it must be considered GRR. 

Delaware – Lead Status Unknown

The Delaware Office of Drinking Water has provided a SLI guidance document. EPA defines “Lead Status Unknown” as a service line where there is no documented evidence supporting material classification. The lead status unknown classification can be used for a section of the service line (e.g. customer or system owned) as well as a classification for the entire service line. EPA has disincentivized submitting initial inventories that contain a high percentage of entire service lines classified as lead status unknown by requiring additional notifications and requirements for those lines. However, EPA does not explicitly prohibit systems from submitting inventories to states with all of the service lines classified as lead status unknown. Delaware has provided additional clarification on this topic and will not accept an initial inventory that contains more than 25% of service lines that are classified as lead status unknown.

120Water is currently developing a web-based interactive map that will provide state specific SLI resources in an easily accessible format. Enter your information HERE to receive an email once this map is available. 

Jonathan Cuppett, Director of Water Quality Compliance

120Water

×

120Water