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:
PWS name
PWSID:
PWSID
Contact person name:
contact name
Contact email:
email
Does the water system already have a list of each service line and its location?
Yes - a list in paper format
Yes - an electronic table of each service line and the address (Excel or other)
Yes - a geodatabase (ArcGIS or other)
Yes - a third-party company manages our database of customers/service lines
No
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)?
Yes - paper format
Yes - electronic format
No
Are there staff assigned to work on the LSL Inventory, including a coordinator?
Yes - we have a coordinator
Yes - we have a coordinator and staff/team for LSL inventory
Yes - we have hired a consultant to assist
Not yet
Other (describe below)
Check each record the water system has available for use to develop the Service Line Inventory.
Materials evaluation required by earlier regulations
Records of construction/installation dates
Tap cards or other utility records listing material of each service line
Construction or plumbing permit documents
Building plumbing records
Distribution system map
Distribution system inspection records
Meter installation records
Inspection records
PVA
Aerial photos
Tax records
Water sample analyses
Board of Realtors records
Purchase orders
Customer submitted photo
Customer verification - sample analysis
Customer survey
Field inspection (excavation, CCTV, visual inspection at meter pit, etc.)
Other (describe below)
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.
Provide a short description of the overall plan of action.
How will challenges be addressed, such as missing records, limited staff time, limited funds, etc.?
Provide a short description of how the data will be organized: Spreadsheet, ArcGIS Online, other method? Explain challenges or assistance needed for this process.
Division of Water will be providing templates for Excel and ArcGIS Online, to assist water systems in organizing data and submitting to DOW.
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 meter reading
Water meter repair or replacement (e.g., place on work order to record SL material)
Service line repair or replacement
Water main repair or replacement
Backflow prevention device inspection
Other
If 'Other' chosen above, describe here:
Will a lead service line replacement plan be developed or enacted along with the inventory? If so, describe here:
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?
Mailing information (via postcard, bill insert, etc.)
Online survey(s)
Mail-in survey
Phone calls
ArcGIS Online survey
Door-to-door visits
Incentive programs (financial or other)
Please provide details about how you plan to work with customers.
You may also consider what communication tools/methods will be used.
There are additional State Revolving Funds (SRF) available just for lead service line projects. Will you be applying for these loans?
Yes
No
Not sure yet
If applying, what would the funds be used for? (For example, new software, hiring a contractor or additional staff, excavating equipment, etc.)
Use this space to submit any questions about LSL Inventories to DOW staff.
Optional: Upload narrative, standard operating procedure' or other document for DOW review.
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