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Who is required to submit service line inventories? |
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All Community and Non-Transient Non Community Water Systems are required to submit a lead service line inventory under the Lead and Copper Rule Revision (LCRR) per
40 CFR 141.84.
LCRR requires water systems to prepare and maintain an inventory of service line materials.
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| 2. |
Is there an official service line inventory template? |
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Yes! All systems submitting lead service line inventories are required to use DEQ’s Official Service Line Inventory for Idaho Public Drinking Water Systems Template.
There are 3 different sized templates. Choose the template that aligns best with the size of your system.
Access the templates here.
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| 3. |
When is my service line inventory due? |
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Initial inventories are required to be submitted to state primacy agencies by October 16, 2024.
After initial inventories are submitted, inventories should be submitted before January 30th of the year after your lead monitoring schedule ends.
If you have any questions about when your next inventory is due. contact your compliance officer.
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| 4. |
What happens if my system’s service line inventory is submitted late? |
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If the service line inventory is submitted late, then violations will be forthcoming. As soon as the inventory is submitted, the system will return to compliance.
If you have any questions, contact your Compliance Officer.
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| 5. |
What if I accidentally submitted the wrong file? |
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The compliance officer will carefully review your submitted document and, if necessary, reject it.
In the event of rejection, you will be provided with an opportunity to resubmit your inventory through the same process.
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| 6. |
What are the contents of a service line inventory? |
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Open DEQ’s official service line inventory template.
Complete the fields in the ‘Summary Information’ tab and ‘Inventory sheet’ tab. To access detailed instructions, click on the 'Instructions' tab.
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| 7. |
What service lines should be included in the inventory? |
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All service lines, regardless of the actual or intended use are required to be included in the inventory. |
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| 8. |
What are the types of service lines? |
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Each service line must be classified using one of the four options listed below. Material classifications are required for both the system- and customer-side where ownership is split.
Lead: A portion of the pipe that is made of lead, which connects the water main to the building inlet.
Galvanized Requiring Replacement (GRR): A galvanized service line that is or ever was downstream of an LSL or is currently downstream of an unknown service line.
Non-Lead: The service line is determined not to be lead or GRR through an evidence-based record, method, or technique.
Unknown: The service line material is not known to be a lead, GRR, or non-lead, such as where there is no documented evidence supporting material classification. It is recommended that you track additional information in your inventory, such as pipe diameter and installation date, source of material information, actual material of nonlead lines, and other lead sources (e.g., lead goosenecks and solder).
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| 9. |
How do I develop a Service Line Inventory? |
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Start with a records review
You must review the following to prepare your initial inventory:
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Previous materials evaluation.
Specifically, you must review the materials evaluation you performed to identify lead and galvanized iron or steel under the original Lead and Copper Rule.
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All construction and plumbing codes, permits, and existing records or other documentation that indicates the service line materials used to connect
structures to the distribution system.
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All water system records, including distribution system maps and drawings, historical records on each service connection, meter installation records,
historical capital improvement or master plans, and standard operating procedures.
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All inspections and records of the distribution system that indicate the material composition of the service connections that connect a structure
to the distribution system.
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Any resource, information, or investigation method provided by or required by the state or primacy agency to develop your initial inventory.
Records reviewed previously need not be reviewed again.
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| 10. |
Am I required to share my inventory with the public? |
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If you are a community water system, you must include instructions on how to access the inventory in your Consumer Confidence Report.
If you serve more than 50,000 people, you must provide your inventory online.
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| 11. |
What if I discover a lead service line, galvanized requiring replacement, or lead status unknown service line after I submit my initial inventory? |
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Even when all service lines have been classified as non-lead, a lead or GRR service line may subsequently be found. If this happens, you must: |
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Notify DEQ within 30 days, and |
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Prepare an updated inventory on a schedule established by DEQ. |
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| 12. |
Additional Guidance |
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