• Pre-Review – Lead Service Line (LSL) Inventory Process

    A Lead Service Line (LSL) Inventory is required by the 2021 Lead and Copper Rule Revisions (LCRR). Water systems will need to identify the material of service lines in the distribution system – including both the publicly-owned and the privately-owned sections of each service line. Refer to 40 CFR 141.84(a) for full details of the LCRR LSL Inventory requirements.

  • Completing this optional questionnaire will allow Kentucky Division of Water (DOW) staff the opportunity to provide individual feedback and guidance about the LSL Inventory process to each water system that participates. Answer the questions most relevant to your situation. DOW will review your responses and provide suggestions and guidance.

    Use of this optional pre-review does not constitute approval of a water system’s LSL Inventory; it is only to be used for water systems to gain a better understanding about whether a water system is taking into account enough relevant information to complete the LSL Inventory.

  • Water system name:      PWSID:
    Contact person name: Contact email:      

  • Does the water system already have a list of each service line and its location?
  • Has the water system started a list of service line materials before now (for example, as part of an asset management plan or materials evaluation)?
  • Are there staff assigned to work on the LSL Inventory, including a coordinator?
  • Check each record the water system has available for use to develop the Service Line Inventory.
  • List or describe other resources you may use. Suggestions include: historic photos and plans, senior staff knowledge, road construction records, local ordinances, internal memos, annual reports, records of best management practices.

  • Prioritizing use of funds, resources, and time

    Because there are always limits to resources, DOW recommends prioritizing efforts carefully. While water systems are waiting on specific guidance from EPA and DOW, spend that time identifying and organizing records, defining which areas of the distribution system are most likely to have lead service lines, and getting a plan into action for recording service line materials during routine maintenance and repair activities.
  • Does the water system have a plan or process in place for identifying information about service line material during normal operations? Check all that apply.
  • Water systems will need to work with customers to a) identify the material of the customer-owned section of the service line, and b) eventually motivate customers to replace their lead service lines. Which of these resources and methods would you consider using to work with customers?
  • There are additional State Revolving Funds (SRF) available just for lead service line projects. Will you be applying for these loans?
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