Lead Service Line Inventory Information
Hello Don Elias - CA3110034 - CHRISTIAN VALLEY PARK CSD
You’re receiving this email because the California Division of Drinking Water (DDW) has not received either a lead service line inventory or an inventory workplan from your water system. This email contains a lot of information, in 6 sections:
1. Lead Service Line Inventory (LSLI) Reminder – 99 days until the 10/16/2024 deadline to submit the inventory.
2. Training sessions via Zoom
3. LSLI Virtual Office Hours – Meet staff and ask questions
4. Do I need to submit an inventory workplan?
5. LSLI Submission Web Portal & Inventory Submission
6. What to include in a workplan (only if you need to submit one)
You can always contact DDW’s LCRR unit at ddw-LSLReports@waterboards.ca.gov if you have any questions about the LCRR or review Water System Resources. We are here to help you.
1. Lead Service Line Inventory Reminder
The US EPA’s Lead and Copper Rule Revisions (LCRR) requires all California community (CWS) and non-transient non-community (NTNC) water systems to develop and submit a service line material inventory to the Division of Drinking Water (DDW) by October 16, 2024. The US EPA will be issuing enforcement action to water systems that do not submit an inventory by this date.
The inventory must include all service lines connecting the water main to the building inlet, regardless of ownership status and intended use. See DDW Inventory Methods (Slides 5-7) for the types of service lines to include.
Each service line must be categorized as one of the following:
· Lead
· Non-lead (specify actual material when possible – copper, plastic, etc.)
· Galvanized requiring replacement (GRR)
· Lead status unknown (unknown)
We highly recommend using the DDW Inventory Template to build your inventory and ensure your data transfer to the submission portal without errors. Please refer to the LSLI Template Instructions and Video for additional instructions.
2. Training Sessions via Zoom
We will be conducting 3 training sessions to summarize what water systems need to do, how to build your inventories, and how to enter the data into the DDW template and portal. Q&A if time allows. If interested, register for one or more session by using the links below. The same information will be presented at each, so you do not need to attend all 3 unless you want to.
July 23, 2024 from 9am-10am
July 30, 2024 from 9am-10am
August 6, 2024 from 9am-10am
3. LSLI Office Hours with the LCRR Unit
We have recurring virtual office hours weekly on Wednesday from 9am - 10am and Thursday from 2pm - 3pm where you can meet with LCRR Unit staff and ask questions about the LSLI—from workplans and verification methods to using the DDW template and submission portal. We encourage you to join these if you have specific questions.
· Space is limited to 20. If a session is full, please choose a different session. Other water system representatives may be present in the same session.
· If no participants attend within the first 15 minutes of the start time, the session will be closed early.
4. Do I need to submit an inventory workplan?
Maybe. The LCRR requires water systems to conduct a historical records review to identify service line materials. In addition, California allows for service lines installed after the CA lead ban (1/1/1986) and greater than 4 inches in diameter to be classified as non-lead.
If there are still service lines with unknown material after the previous step, and a physical field verification will be performed on ALL unknowns, you do NOT need to submit an inventory workplan. Proceed with building your inventory and submit to the DDW LSLI Web Portal.
However, an inventory workplan IS REQUIRED for systems using ANY alternative verification method to identify remaining service lines with unknown materials:
· Interpolation
· Statistical Verification, Predictive Models/Machine Learning
· Water Quality Sampling (requires a demo study)
· Interviews (to support statistical methods, not to be used alone)
· Other/Emerging Methods (requires a pilot study)
To submit a workplan or request more information, please send any information, attachments, or inquiries to ddw-lslreports@waterboards.ca.gov with your water system number in the subject line. A list of what is typically included in an inventory workplan is #5 at the bottom of this email.
5. California’s LSLI Submission Web Portal & Inventory Submission
Water systems can submit completed inventories online using the LSLI Submission Web Portal. We recommend designating one person from your system to register a WBKey account and submit the inventory. Please see our comprehensive Guidance Document for instructions on creating an account, transferring data, and using the portal.
Preparing your inventory for submission:
· We highly recommend using the DDW Inventory Template to format your data so your records will copy and paste cleanly into the submission portal.
· If you are using your own spreadsheet, make sure the column headers, column order, and cell entries match the EXACT formatting as this example spreadsheet. Any additional columns cannot be submitted.
Before submitting your inventory:
· Confirm your workplan has been approved if an alternative verification method was used.
· Complete your entire inventory and verify as many unknowns as possible.
· A service line material must be entered on both the System-Owned AND Customer-Owned side for the entire line to be categorized correctly. If the entire service line only has one owner, please repeat the information on both sides.
· Inventories for multiple water systems may be submitted under one account, but please submit ONE inventory PER water system to avoid incorrect or duplicate records.
After submitting your inventory:
· Inventories cannot be edited once submitted. If you need to change or add information, DO NOT create a new submission—Please contact ddw-lslreports@waterboards.ca.gov with your water system number in the subject line, and we will re-open your submission for editing.
· The LCRR Unit reviews submissions in the general order received. After our review, we will contact you with revision comments or notify you of approval via email.
· Please continue to update your inventory file with any new information you acquire after the submission deadline. You can use this file to submit updated inventories to DDW.
What if I don’t finish my inventory before October 16, 2024?
· You should submit what you have done. Any service lines with unknown material should be submitted as “unknown” in the inventory.
· The water system will be required to send public notification within 30 days of inventory submission to customers with lead, galvanized requiring replacement (GRR), or UNKNOWN service line material. Notification template on DDW LCR website.
6. What to include in an inventory workplan (only if applicable).
There is no template for inventory work plans, but they typically include the following as applicable:
- The LCRR requires historical records and other information to be reviewed, and describe how they were used to reduce the number of unknown service lines
- The alternative method(s) the system proposes to use for the remaining unknowns (interpolation, statistical verification, predictive modeling, etc.)
- Number of customer-side service lines that will be physically verified and how the minimum number was calculated
- If using stratified random sampling, show the strata or groups by decade/lead risk and the number to verify per group. We encourage systems to create a separate bin targeting the WWII-era (1940's).
- If using interpolation, include how the groups were determined and the percentage of verifications per interpolation tract/development
- A hybrid approach combining both interpolation and statistical analysis is permitted
- Historical lead use
- The number of two-point verifications needed when the service line material cannot be determined at the meter box or tails were used
- Next steps the system will take if lead is found
- Physical investigation methods (i.e., scratch tests, lead test kits, customer surveys, etc.)
- Tables, figures, or maps (optional)
Submit completed work plans to ddw-lslreports@waterboards.ca.gov with your water system number in the subject line.
If you have any questions, you can always email ddw-lslreports@waterboards.ca.gov. Please include your water system number in the subject line for all communication.
Thank you,
DDW LCRR Unit