What is the compliance date for the revised rule?
The compliance date for the revised rule is October 16, 2024.
What do I need to do for the LSL inventory and when does it need to be completed?
PWSs will need to identify all service line materials as lead, galvanized iron requiring replacement, non-lead, or unknown service line. Unknown service lines will be treated as LSLs and will need to be replaced or identified in the future.
The inventory asks if lead goosenecks, pigtails, or service line connectors are present at a service connection, and possible answers are: yes, no, don’t know. If a PWS has a record of any lead connectors on record, it is recommended the PWS add it to the inventory. PWSs will also be required to replace any lead connectors they encounter while removing and replacing LSLs.
The inventory must be completed and submitted to the state by October 16, 2024. PWSs will need to make the inventory information publicly accessible.
Once my PWS has an LSL inventory, do I have to sample all sites with LSLs? Or will the number of sample points still be the same for my PWS?
The number of sample points will remain the same, in that a system’s number of required samples will still depend on the system’s monitoring schedule, sample results, and system size in terms of population. Systems will need to redefine their lead and copper sample site list to prioritize homes that are served by lead service lines.
Where do I submit my LSLI?
You can send your completed LSLI spreadsheet to email@example.com.
LCRR requires that an evidence-based record, method, or technique be used in determining whether a service line is, or is not, lead or galvanized requiring replacement. What is an evidence-based record, method, or technique?
An evidence-based record, method, or technique provides documentation that supports the classification of service line materials. For this initial inventory, LCRR requires water systems to make use of any relevant records available to the water system, including certain records specified in LCRR. LCRR also requires water systems to make use of information from system operations or any lead service line replacements
For the initial inventory, LCRR does not require water systems to use investigative methods, such as visual inspections or excavation, although some systems may want to use them. Use of investigative methods other than simple visual inspection would need prior approval from DEQ.
Where there are conflicts in records and field information, EPA recommends using a classification of “unknown” until the conflicts can be resolved.
Are inactive service lines required to be on the inventory?
Yes, systems must include all service lines, including inactive service lines or service lines with non-potable applications such as fire suppression or those designated for emergency.
Can we safely assume that anything built after 1987 does not have LSLs?
Service lines constructed after the 1986 Safe Drinking Water Act Lead Ban became effective are unlikely to be lead service lines. In Oklahoma, the Lead Ban requirements were adopted in 1987, and local governments may have adopted their own laws on a different date. Thus, water systems should check with their local government to determine the appropriate date.
What is required when a lead service line is found during routine investigations?
When a water system finds a lead service line during a routine investigation, LCCR requires the water system to update the inventory.
LCRR also requires the water system to inform all persons at that service connection within 30 days of completion of the lead service line inventory and repeat the notification on an annual basis until the entire service connection is no longer a lead. For new customers, water systems must also provide the notice at the time service is initiated. LCRR specifies what must be included in the content of the notice.
What are the expectations for NTNC systems that do not have a customer side and system side of the service line?
An NTNC system may have a direct connection from a well to a single building and not have a system side and customer side of the service line. EPA asks this type of public water supply to report the material from the well to the building inlet for their inventory. This type of public water supply will need to complete both halves of DEQ’s inventory template (system side and customer side), and in general, the information entered on both sides will be identical.
Are public water supplies required to use the template provided by DEQ for the lead service line inventory, or can they create their own?
Drinking water systems are required to use the template provided by DEQ, unless prior permission is granted by DEQ to utilize an alternate method.
How often are inventory updates required to be submitted to DEQ?
LCRR requires water systems to provide updated inventories to the primacy agency annually or triennially based on lead tap sampling frequency, but not more frequently than annually.
How can I pay for development of the lead service line inventory?
DEQ can help by providing financial assistance in two ways:
- A loan forgiveness program for communities that have the resources to manage a contract, or
- DEQ’s contractor for those small communities that lack the manpower and/or do not find it financially feasible to enter into their own contract.
How can I pay for replacement of lead service lines located on the private side?
DEQ is aware that paying for replacement of the private side of a service line will be challenging. DEQ/DWSRF will work with communities to look at those situations on a case-by-case basis and determine the appropriate approach, such as a rebate program, for example.
Who should public water supplies contact if they have questions about the inventory?
If you have questions about the inventory, you can contact your DEQ Public Water Supply District Engineer or your DEQ Public Water Supply Compliance Coordinator.