v>EPA Developing and Maintaining
United States a Service Line Inventory:
Environmental Protection
A9ency Small Entity Compliance
Guide
-------
Office of Water (4606M)
EPA Document No. 815-B-23-005
June 2023
-------
NOTICE
This guide was prepared pursuant to section 212 of the Small Business Regulatory
Enforcement Fairness Act of 1996 ("SBREFA"), Pub. L. 104-121 as amended by Pub. L.
Number 110-28. THIS DOCUMENT IS NOT INTENDED, NOR CAN IT BE RELIED UPON, TO
CREATE ANY RIGHTS ENFORCABLE BY ANY PARTY IN LITIGATION WITH THE UNITED
STATES. The statements in this document are intended solely as a guide to aid you in
complying with the initial service line inventory requirements of the Lead and Copper
Rule Revisions (LCRR). EPA may decide to revise this guide without public notice to reflect
changes in EPA's approach to implementing the LCRR or to clarify and update text. To
determine if EPA has revised thisguide and/orto obtain copies, contact EPA'sSmall
Business Ombudsman Office at (800) 368-5888 or (202) 566-2822 (Washington DC
metropolitan calling area) or contact EPA's Office of Ground Water and Drinking Water
Safe Drinking Water Hotline at (800) 426-4791 (e-mail: safewater@epa.gov). or visit the
following EPA LCRR website: https://www.epa.gov/ground-water-and-drinking-
water/revised-lead-and-copper-rule. The full text of the rule can be found at 40 CFR Part
141 and 40 CFR Part 142 as well as in the Federal Register (86 FR 4198) and at docket EPA-
HQ-OW-2017-0300 at https://www.regulations.gov.
Disclaimer: The guidance within this document can be used to comply with the requirements
underthe LCRR that are in effect at the time of document publication. As described in the
Environmental Protection Agency's (EPA's) Federal Register notice of December 17, 2021
("Notification of conclusion of review"), EPA intends to publish a proposal to revise the LCRR and
take final action on the proposal by October 16, 2024, but EPA does not expect to propose
changes to the requirements for information to be submitted in the initial service line inventory.
However, the rulemaking could include changes to the requirements for inventory updates
(USEPA, 2021a). The statutory provisions and EPA regulations described in this document contain
legally binding requirements. This document is not a regulation itself, nor does it change or
substitute for those provisions and regulations. Thus, it does not impose legally binding
requirements on EPA, states, or the regulated community. This document does not confer legal
rights or impose legal obligations upon any member of the public. Although EPA has made every
effort to ensure the accuracy of the discussion in this document, the legally binding requirements
applicable to public water systems are determined by statutes and regulations. In the event of a
conflict between the discussion in this document and any applicable statute or regulation, this
document would not be controlling. The recommendations provided here may not apply to a
particular situation based upon the circumstances. Because they are recommendations, and not
legally binding requirements, public water systems retain the discretion to follow the
recommendations or adopt approaches that differ from those described in this document.
Mention of trade names or commercial products does not constitute endorsement or
recommendation fortheir use.
Developing and Maintaining i
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Table of Contents
Table of Contents ii
Table of Exhibits iii
Acronyms iv
Glossary v
1. Introduction 1
2. Who Should Use This Guide? 1
3. How Do I Use This Guide? 1
4. What Are the Benefits of a Comprehensive and Accurate Inventory? 3
5. What Are the Initial Inventory Requirements of the LCRR? 3
6. How Do Service Line Inventory Requirements Relate to Other Federal, State, and Local
Requirements? 5
7. Which Service Lines Must I Include in My Initial Service Line Inventory? 5
8. What Information Must Be Included in My Initial Inventory? 9
Required Service Line Material Classifications 9
Classifying the Entire Service Line When Ownership Is Split 11
Location Identifiers in Your Publicly Available Inventory 12
9. IsThere Additional Information I Should Considerfor My Inventory? 12
10. How Do I Develop My Service Line Inventory? 14
ToolsThat Can Help You Develop and Maintain Your Inventory 15
Recommendations for Developing the Service Line Inventory 16
11. What If I Only Have Non-Lead Service Lines? 19
Recommendations for Determining That All Service Lines Are Non-Lead 20
Finding an LSL or GRR After Submitting Your Initial Inventory 20
12. What Information Must I Report to My State and When? 21
13. What Information Must I Provide to the Public? 21
Public Accessibility 21
What Information to Include 21
How to Make the Data Publicly Available 22
Recommendations for Public Input and Updates 24
Consumer Confidence Report Inventory Requirements 24
Service Line Notification Requirements and Recommendations 24
Appendix A: Additional Useful Resources A-l
Developing and Maintaining ii June 2023
a Service Line Inventory: Small Entity Compliance Guide
-------
Appendix B : Blank Template Forms B-l
Append ixC : Completed Inventory Template Forms for a Hypothetical System C-l
Table of Exhibits
Exhibit 1: Guide Organization 2
Exhibit 2: LCRR Inventory Requirements 3
Exhibit 3: Example of a Community Water System with a Master Meter and Multiple Service Lines
(Plan View) 7
Exhibit 4: Examples of a Non-transient Non-community Water System (NTNCWS) Service
Configurations (Profile View) 8
Exhibit 5: Example of Service Line Ownership Distinction Between the Water System and
Customer 9
Exhibit 6: Required Inventory Materials Classifications 10
Exhibit 7: Classifying Service Line Materials When Ownership Is Split 11
Exhibit 8: Organization of EPA Inventory Template: Water System Worksheets 15
Exhibit 9: Excerpt of Instructions from EPA's Inventory Template 16
Exhibit 10: Service Material Screening Process Based on Records 18
Exhibit 11: Greater Cincinnati Water Works Service Line Information Map 23
Exhibit 12: Service Line Notification Requirements 25
Developing and Maintaining iii
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Acronyms
Hg/L
Micrograms per liter
CCR
Consumer Confidence Report
CFR
Code of Federal Regulations
CWS
Community Water System
EPA
United States Environmental Protection Agency
GRR
Galvanized Requiring Replacement
LCR
Lead and Copper Rule
LCRI
Lead and Copper Rule Improvements
LCRR
Lead and Copper Rule Revisions
LSL
Lead Service Line
LSLR
Lead Service Line Replacement
NTNCWS
Non-Transient Non-Community Water System
PWS
Public Water System
SOP
Standard Operating Procedure
Developing and Maintaining iv
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Glossary
Term
Definition1
Curb stop
An exterior valve located at or near the property line that is used to turn on and
off water service to the building.2
Community water
system
A public water system that serves at least 15 service connections used by year-
round residents or regularly serves at least 25 year-round residents (40 CFR
§141.2).
Full lead service line
replacement
Replacement of a lead service line (as well as galvanized service lines requiring
replacement) that results in the entire length of the service line, regardless of
service line ownership, meeting the Safe Drinking Water Act (SDWA) Section
1417 definition of lead free3applicable at the time of the replacement. See 40
CFR §141.2 for the full regulatory definition.
Galvanized requiring
replacement
A galvanized service line that is or was at any time downstream of a lead service
line or is currently downstream of a lead status unknown service line. If the
water system is unable to demonstrate that the galvanized service line was
never downstream of a lead service line, it must presume there was an upstream
lead service line (40 CFR §141.84(a)(4)(ii)).
Galvanized service
line
Iron or steel piping that has been dipped in zinc to prevent corrosion and rusting
(40 CFR §141.2).
Gooseneck, pigtail, or
connector
A short section of piping, typically not exceeding two feet, which can be bent
and used for connections between rigid service piping. For purposes of Subpart 1,
lead goosenecks, pigtails, and connectors are not considered to be part of the
lead service line but may be required to be replaced pursuant to §141.84(c)4 (40
CFR §141.2).
Lead service line
A portion of pipe that is made of lead, which connects the water main to the
building inlet. A lead service line may be owned by the water system, owned by
the property owner, or both. For the purposes of Subpart 1, a galvanized service
line is considered a lead service line if it ever was or is currently downstream of
any lead service line or service line of unknown material. If the only lead piping
serving the home is a lead gooseneck, pigtail, or connector, and it is not a
galvanized service line that is considered a lead service line, the service line is
not a lead service line (40 CFR §141.2).
Lead status unknown
service line
A service line where the material is not known to be lead, galvanized requiring
replacement, or a non-lead service line, such as where there is no documented
evidence supporting material classification. It is not necessary to physically verify
the material composition (e.g., copper or plastic) of a service line for its lead
status to be identified (e.g., records demonstrating the service line was installed
after a municipal, state, or federal lead ban3) (40 CFR §141.2).
Non-lead
A service line that is determined through an evidence-based record, method, or
technique not to be lead or galvanized requiring replacement (40 CFR §
141.84(a)(4)(iii)).
Developing and Maintaining v
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Term
Definition1
Non-transient non-
community water
system
A public water system that is not a community water system and regularly serves
at least 25 of the same persons over 6 months per year (40 CFR §141.2).
Service line
The pipe connecting the water main to the interior plumbing in a building.2 The
service line may be owned wholly by the water system or customer, or in some
cases, ownership may be split between the water system and the customer.
State
State means the agency of the State or Tribal government that has jurisdiction
over public water systems. During any period when a State orTribal government
does not have primary enforcement responsibility pursuant to Section 1413 of
the Act, the term "State" means the Regional Administrator, U.S. Environmental
Protection Agency (40 CFR §141.2).
Water main
A pipe that conveys water to a connector or customer's service line. In
residential areas, it is usually located underground.2
Water meter
An instrument, mechanical or electronic, used for recording the quantity of
water passing through a particular pipeline or outlet.2
Notes:
1 Definitions without a regulatory citation are recommended definitions for use in this guide.
2 Source: Seventh Drinking Water Infrastructure Needs Survey and Assessment: Lead Service Line
Inventory for America's Water Infrastructure Act - State Survey Instruction. January 2021.
3 In 1986, Congress amended the Safe Drinking Water Act (SDWA), prohibiting the use of pipes, solder, or
flux that were not "lead free" in public water systems or plumbing in facilities providing water for human
consumption. At the time, "lead free" was defined as solder and flux with no more than 0.2 percent lead
and pipes with no more than 8 percent. In 2011, Congress passed the Reduction of Lead in Drinking Water
Act (RLDWA) that amended Section 1417 of SDWA and updated the definition for "lead free" as a
weighted average of not more than 0.25 percent lead calculated across the wetted surfaces of a pipe, pipe
fitting, plumbing fitting, and fixture and not containing more than 0.2 percent lead for solder and flux. On
September 1, 2020, EPA published the final regulation "Use of Lead Free Pipes, Fittings, Fixtures, Solder,
and Flux for Drinking Water" to make conforming changes to existing regulations based on the RLDWA.
https://www.federalregister.gov/documents/2020/09/01/2020-16869/use-of-lead-free-pipes-fittings-
fixtures-solder-and-flux-for-drinking-water.
4Section 141.84(c) of the January 15, 2021 Lead and Copper Rule Revisions (LCRR) specifies the operating
procedures for replacing lead goosenecks, pigtails, or connectors. The LCRR is under revision and all rule
provisions except for the initial inventory requirements may be subject to change.
Developing and Maintaining vi
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
1. Introduction
This document is published by the U.S. Environmental Protection Agency (EPA) as our official
compliance guide for small entities, as required by the Small Business Regulatory Enforcement
Fairness Act of 1996. Before you begin using the guide, you should know that the information in
this guide was compiled and based on the Lead and Copper Rule Revisions, effective on
December 16, 2021 (referred to as the "LCRR" throughout this document). EPA is continually
improving and upgrading its rules, policies, compliance programs, and outreach efforts. You can
determine whether EPA has revised or supplemented the information in this guide by consulting
EPA's LCRR website at: https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-
copper-rule.
2. Who Should Use This Guide?
This guide is designed for owners and operators of small community water systems (CWSs) and
non-transient non-community water systems (NTNCWSs). All CWSs and NTNCWSs must develop
and maintain an inventory of each service line in their distribution system to comply with the
LCRR. Water systems must submit their initial inventories to their State1 by October 16, 2024.
Systems that might find this guide useful include those that operate the following:
• Small towns; • Homeowners associations;
• Rural water districts; • Small private water systems; and
• Tribal waters systems; • Factories, schools, and religious institutions
• Manufactured housing parks; that have their own water supplies.
3. How Do I Use This Guide?
Exhibit 1 shows how this guide is organized, including where you can find rule requirements and
recommendations.
1 EPA authorizes states, territories, and Indian tribes to assume primary enforcement responsibility to implement
SDWA's Public Water System Supervision Program, for public water systems to States, territories, and Indian tribes if
they meet special requirements. To date, 54 states and territories and one tribe have primacy. Wyoming, Washington
D.C., and all Indian Tribes except the Navajo Nation do not have primacy. Where no state, territory, or Indian Tribe
has primacy, the relevant EPA regional office implements the program. Throughout this guidance, the terms "State"
or "States" are used to refer to all types of primacy agencies including U.S. territories, Indian tribes, and EPA Regions.
Developing and Maintaining 1
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Exhibit 1: Guide Organization
Section
Number
Contents
Requirements
Recommendations
4
The benefits of a comprehensive and accurate
inventory.
X
5
Summary of the complete initial inventory
requirements of the LCRR.
X
6
How the initial inventory requirements relate to
other federal, state, and local requirements.
X
7
Which service lines must be included in your initial
inventory
X
8
What information must be included in your initial
inventory.
X
9
Other information you could consider including in
your inventory.
X
10
How to develop your initial inventory.
X
X
11
What to do if you only have non-lead service lines.
X
X
12
What information you must provide to your State
and when.
X
13
What information you must provide to your
V
V
customers and the public.
A
A
Section 5 of this guide provides relevant citations to the LCRR. Note that the full rule language is
available for download from the Federal Register at https://www.ecfr.gov/current/title-
40/chapter-l/subchapter-D/part-141/subpart-l. Hyperlinks will take you to relevant sections of
the EPA's "Guidance for Developing and Maintaining a Service Line Inventory" (hereafter referred
to as the "full guidance"), from which this guide was developed. This guide includes a template
for water systems, States, and tribes to use or adapt to create their own inventory. This template
is available online at https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-
copper-rule.
This guide also contains three appendices:
• AppendixA provides web links to additional resources that you might find helpful.
• Appendix B includes blank forms from EPA's inventory template.
• Appendix C provides a completed example of the inventory template forms for a
hypothetical system.
Developing and Maintaining 2
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
4. What Are the Benefits of a Comprehensive and Accurate Inventory?
Service line inventories are the foundation from which systems can take action to address a
significant source of lead in drinking water - lead service lines (LSLs). Establishing an inventory of
service line materials and identifying the location of LSLs is a
key step in getting them replaced and protecting public
health. A comprehensive and accurate inventory allows you
to publicly track progress on LSL identification and
replacement, engaging the community and enhancing
transparency. In addition to benefits related to lead service
line replacement (LSLR) and public health protection, a
comprehensive and accurate inventory can help all systems
by supporting asset management programs and customer communications.
5. What Are the Initial Inventory Requirements of the LCRR?
The initial inventory requirements underthe LCRR are summarized in Exhibit 2. The remainderof
this guide will coverthese requirements in more detail.
EPA is currently developing a revision to the LCRR, called the Lead and Copper Rule Improvements
(LCRI). All LCRR requirements aside from the initial inventory are subject to change under the LCRI.
Exhibit 2: LCRR Inventory Requirements
Inventory Requirement
40 CFR Citation
Inventory Specifications
Material Classification: Classify each service line or portion of the service line where
ownership is split as lead, galvanized requiring replacement (GRR), non-lead, or lead
status unknown.
§141.84(a)(4)
All Service Lines and Ownership: Prepare an inventory that includes the system- and
customer-owned portions of all service lines in the system's distribution system.
§141.84(a), (a)(2)
Information to Identify Material: Use previous materials evaluation, construction and
plumbing codes/records, water system records, distribution system inspections and
records, information obtained through normal operations, and State-specified
information.
§141.84(a)(3)
Given the many benefits of LSLR,
EPA encourages systems to begin
LSLR as soon as possible,
regardless of the stage of
inventory development.
Developing and Maintaining 3
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Inventory Requirement
40 CFR Citation
Deadlines for Submission
Initial Inventory: Submit an initial inventory by October 16, 2024.
§141.80(a)(3)1
Updates to State: Submit updated inventories to your State annually or triennially
based on lead tap sampling frequency, but not more frequently than annually.
Water systems that have demonstrated the absence of lead service lines (LSLs) by
October 16, 2024, are not required to provide an update. However, if these systems
subsequently find any LSLs or GRR service lines, they have 30 days to notify the State
and prepare an updated inventory on a schedule established by the State.
§141.90(e)(3),
§141.90(e)(3)(ii)
Public Accessibility and Consumer Confidence Report
Public Accessibility: Make the inventory publicly available and include a location
identifier for LSLs and GRR service lines. Water systems serving more than 50,000
people must provide inventories online.
§141.84(a)(8)
Consumer Confidence Report (applies to CWSs only): Include a statement that a
service line inventory has been prepared (including inventories consisting only of
a statement that there are no LSLs) and instructions on how to access it.
Service Line Consumer Notification
Provide notification to persons served by the water system at the service connection
with a lead, GRR, or lead status unknown service line. If the water system serves
communities with a large proportion of non-English speaking consumers, as
determined by the State, public education materials must be in appropriate languages
or contain a telephone number or address where persons served may contact the
water system to obtain a translated copy of the materials or to request assistance in
the appropriate language.
Timing: Notification within 30 days after completion of the initial inventory and
repeated annually until only non-lead remains. For new customers added after the
initial inventory, water systems must also provide this notice at the time of service
initiation.
Content: Statement about service line material, lead health effects, and steps to
minimize lead exposure in drinking water. If the service line is:
• Confirmed LSL, must include opportunities to replace the LSL, any available
financing programs, and statement that the system must replace its portion if
property owners notify the system they are replacing their portion.
• GRR, must also include opportunities for service line replacement.
• Lead status unknown, must also include opportunities to verify the material of the
service line.
Delivery: By mail or by another method approved by the State.
Reporting to States: Demonstrate that the water system delivered the notification and
provide a copy of the notification and information materials to its State annually by
July 1 for the previous calendar year.
§141.153(d)(4)(xi)
§141.85(a)(l)(ii),
§141.85(e) &
§141.90(f)(4)
Developing and Maintaining 4
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Notes:
June 16, 2021, EPA published a rule to extend the compliance date from January 16, 2024, to October
16, 2024 (40 CFR §141.90(e)(l)). Federal Register 86(114): 31939. June 16, 2021. Washington, D.C.:
Government Printing Office.
6. How Do Service Line Inventory Requirements Relate to Other Federal, State,
and Local Requirements?
Your State may have passed laws or regulations for service line inventories that are more
stringent than federal requirements. This guide identifies a few examples where the State may
have more stringent requirements. For the most accurate and up-to-date requirements, you
should reach out to your State.
In addition, there are existing Lead and Copper Rule (LCR) requirements that rely on service line
inventory information. The following requirements under the LCR are in effect until October 16,
2024:
• Inventory-Related Requirements in the Event of Action Level Exceedance. Under the
LCR (40 CFR §141.84(b)), systems subject to LSLR requirements2 must replace annually
at least seven percent of the initial number of LSLs that are in place at the time the
replacement program begins. Water systems must identify the initial number of LSLs in
their distribution system under this requirement. EPA recommends that systems use
information gathered for the initial inventory under the LCRR to help identify the
required initial numberof LSLs for replacement underthe LCR.
• How the Inventory Relates to the Tap Monitoring Requirements. Required lead and
coppertap monitoring underthe LCR is based on a tiering system for prioritizing
sample sites (40 CFR §141.86(a)). Single family homes with LSLs are in the highest tier
(i.e., Tier 1), meaning systems should prioritize these locations for lead and coppertap
monitoring. Systems may gather more information on the location of LSLs under their
initial inventory efforts.
7. Which Service Lines Must I Include in My Initial Service Line Inventory?
Your initial service line inventory must include:
• All service lines connecting the water main to the interior plumbing in a building,
regardless of ownership status. This includes service lines owned entirely by the
2 Under the LCR, systems that exceeded the lead action level of 15 micrograms per liter (ng/L) based on their 90th
percentile sample result after installing corrosion control and/or source water treatment (whichever sampling
occurred later) were required to replace seven percent of their LSLs annually until they no longer exceeded the lead
action level for two consecutive 6-month monitoring periods (40 CFR §141.84(a)).
Developing and Maintaining 5
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
customer as well as both the system-owned and customer-owned portions where
ownership is split.
• All service lines connecting the water main to the interior plumbing in a building,
regardless of the actual or intended use. These include, for example, service lines:
o With non-potable applications such as fire suppression or those designated for
emergency.
o Connected to vacant or abandoned buildings, even if they are unoccupied and
water service is turned off.
EPA requires that these service lines be included because they could be repurposed in
the future for a potable or non-emergency use.
• Service lines connecting multiple units or buildings on a property.
• Service lines connecting a well to a single building such as in cases where the system
meets the definition of a CWS or NTNCWS but does not have an extensive distribution
system.
EPA recommends that systems include in their inventory any pipes that are not connected to
buildings that have the potential to be lead. See Exhibit 3 and Exhibit 4 for examples of service
line configurations for CWSs and NTNCWSs, respectively.
Developing and Maintaining 6
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Exhibit 3: Example of a Community Water System with a Master Meter and Multiple Service Lines
(Plan View)
Building 1
KEY
C=Customer-owned
S=System-owned
SL=Service Line
Customer-owned
Service line=
System-owned
Service line=
Meter
Developing and Maintaining 7
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Exhibit 4: Examples of a Non-transient Non-community Water System (NTNCWS) Service
Configurations (Profile View)
Example 1: NTNCWS with
well pumped directly to a
building
Water
Well
S-SL1
Bill
HI I
»J" I
"
Example 2: NTNCWS
with well connected to a
pressure tank to a building
Water
Well
1
Hospital
S-SL1
Example 3: NTNCWS
with well connected to a
building connected to
another building
Water
Well \
Concession
Stand
S-SL1
S-SL2
KEY
NTNCWS=Non-transient
non-community water system
S=System-owned
SL=Service Line
System-owned
Service line=
Meter
Pressure
Tank
Well
Developing and Maintaining 8
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
8. What Information Must Be Included in My Initial Inventory?
Required Service Line Material Classifications
Underthe LCRR, you must use one of the following material classifications for your service lines:
• Lead;
• Galvanized requiring replacement (GRR);
• Non-lead (or the actual material, such as copper or plastic); or
• Lead status unknown service lines (or unknown).
You must include separate material classifications for the water system-owned and customer-
owned portions where ownership is split (see example of split ownership in Exhibit 5).
Exhibit 5: Example of Service Line Ownership Distinction Between the Water System and Customer
Property
Water Meter
Boundary
Premise
Plumbing
Sidewalk
Street
Alternate
Water
Meter
Location
System-owned
Service Line
Customer-owned
Service Line
* i' . . "V,l '
; - • w
Note that lead goosenecks, pigtails, or connectors are not considered part of the service line
underthe LCRR, These are defined as "a short section of piping, typically not exceeding two feet,
which can be bent and used for connections between rigid service piping" (40 CFR §141.2).
Section 141.84(c) of the LCRR specifies the requirements for when lead goosenecks, pigtails, or
connectors must be replaced.
Developing and Maintaining 9
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Your State may require you to include lead goosenecks, pigtails, and connectors in
your initial inventory. Please contact your State to determine if they have additional
requirements beyond those of the LCRR.
Exhibit 6 provides additional information to help you make material classifications.
Exhibit 6: Required Inventory Materials Classifications
Material
Classification
Use This Classification If:
Lead
The service line is made of lead (40 CFR §141.84(a)(4)(i)).
Keep in Mind:
• The LCRR updates the definition of a lead service line (LSL) as "a portion of pipe
that is made of lead, which connects the water main to the building inlet" (40 CFR
§141.2).
• If the only lead pipe serving the building is a lead gooseneck, pigtail, or connector,
the service line is not considered an LSL under the initial inventory requirements
of the LCRR. EPA recommends that the system track the material of all
components that potentially contain lead, including connectors.
Galvanized
Requiring
Replacement
(GRR)
The galvanized service line is or ever was at anytime downstream of an LSL or is
currently downstream of a lead status unknown service line. If your water system is
unable to demonstrate that the galvanized service line was never downstream of an LSL,
you must presume there was an upstream LSL (40 CFR §141.84(a)(4)(ii)).
Keep in Mind:
• Galvanized service lines that are or ever were downstream from an LSL can adsorb
lead and contribute to lead in drinking water.
• An example of a GRR service line is when the customer-owned portion from the
meter to the building is galvanized, and the system-owned portion from the water
main to the meter was previously lead but has been replaced. The customer-
owned portion of the service line would be GRR.
• Under the initial inventory requirements of the LCRR, a galvanized service line that
was never downstream of an LSL but is downstream or previously downstream of
a lead gooseneck, pigtail, or connector is not considered GRR. However, systems
should check with their States if they have more stringent requirements.
Developing and Maintaining 10
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Material
Classification
Use This Classification If:
Non-Lead
The service line is determined through an evidence-based record, method, or technique
that it is not lead or GRR (40 CFR §141.84(a)(4)(iii)).
Keep in Mind:
• You can classify your service line as non-lead if you can demonstrate that a
galvanized service line was never downstream of an LSL.
• You may classify the actual material of the service line (e.g., galvanized, plastic, or
copper) as an alternative to classifying it as non-lead.
• The term "non-lead" refers to the service line material only and does not include
other potential lead sources present in solder, connectors, and other plumbing
materials.
Lead Status
Unknown
The service line material is not known to be a lead, GRR, or non-LSL, such as where there
is no documented evidence supporting material classification (40 CFR §141.84(a)(4)(iv)).
Keep in Mind:
• You have the option to use the terminology of "unknown" instead of "lead status
unknown" service line.
• You may elect to provide more information regarding your unknown lines as long
as your inventory clearly distinguishes unknown service lines from those where
the material has been determined through records or inspections.
Classifying the Entire Service Line When Ownership Is Split
In addition to separate material classifications for the water system-owned and customer-owned
portions when ownership is split, a single classification per service line is needed to support
various LCRR requirements, such as LSLR and tap sampling. Exhibit 7 provides guidelines to help
you classify the entire service line for various system-owned and customer-owned material
combinations.
Exhibit 7: Classifying Service Line Materials When Ownership Is Split
System-Owned Portion
Customer-Owned Portion
Classification for Entire Service
Line
Lead
Lead
Lead
Lead
Galvanized Requiring
Replacement
Lead
Lead
Non-lead
Lead
Lead
Lead Status Unknown
Lead
Developing and Maintaining 11
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
System-Owned Portion
Customer-Owned Portion
Classification for Entire Service
Line
Non-lead
Lead
Lead
Non-lead and never previously
lead
Non-lead, specifically galvanized
pipe material
Non-lead
Non-lead
Non-lead, material other than
galvanized
Non-lead
Non-lead
Lead Status Unknown
Lead Status Unknown
Non-lead, but system is
unable to demonstrate it was
not previously Lead
Galvanized Requiring
Replacement
Galvanized Requiring Replacement
Lead Status Unknown
Lead
Lead
Lead Status Unknown
Galvanized Requiring
Replacement
Galvanized Requiring Replacement
Lead Status Unknown
Non-lead
Lead Status Unknown
Lead Status Unknown
Lead Status Unknown
Lead Status Unknown
Location Identifiers in Your Publicly Available Inventory
You must include a location identifier for any lead or GRR service line in your publicly available
inventory. The location identifier can be a street address, intersection, or landmark.
You have flexibility to determine which location identifier best meets the needs of your
community. If the street address is not used, you must use a meaningful location identifier. The
location identifier could be, for example, a block, intersection, landmark, Global Positioning
System (GPS) coordinates, emergency 911 address for systems in rural areas, or an alternate
indicator (such as water meter location). Regardless of which identifier you choose, it must not be
so overly broad (e.g., census tract or zip code) that the public could not adequately track general
LSL locations or where the system is making progress in replacing LSLs.
9. Is There Additional Information I Should Consider for My Inventory?
This section identifies additional information that could be helpful to include in your inventory.
These are recommendations only and are not required under the LCRR. Check with your State for
any additional requirements. EPA recommends water systems consider:
1) Further subclassifying service lines or portions of the service line to improve asset
management, help target LSLR efforts, and provide greater transparency to your customers:
• LSL likelihood for unknown service lines: For example, if an individual service line
material is unknown but was installed when lead was not commonly used in the
Developing and Maintaining 12
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
system prior to the lead ban, based on interview with experience system staff and
plumbers, the system could consider subclassifying the service line as "Unknown-
Unlikely Lead" or a similar designation.
• Additional information for GRR: For example, you could document if the galvanized
pipe: 1) is known to be currently downstream of an LSL, 2) was previously downstream
of an LSL, or 3) does not have information to indicate it was never downstream of an
LSL.
• Lead-lined galvanized pipes: EPA is aware of the existence of lead-lined galvanized
service lines. These lines would be subject to the same LCRR requirements as other
LSLs in the inventory. These service lines may be difficult to identify because their
exterior is not lead. EPA recommends you consider any available information that
indicates where (if ever) lead-lined galvanized pipes were used along with approaches,
such as water quality sampling for lead, to identify them.
• Actual material for non-lead service lines: EPA recommends that you classify the
actual material of the service line (e.g., galvanized, plastic, or copper) as an alternative
to classifying it as non-lead. Including these classifications can improve system asset
management.
2) Including information on other lead-containing infrastructure in your inventory, such as:
• Goosenecks, pigtails, and connectors.
• Lead solder in service line or premise plumbing.
• Fittings and equipment connected to the service line such as curb stops and meters
that may be made of older brass that pre-date the effective date for the Reduction of
Lead in Drinking Water Act (January 4, 2014).
3) Documenting where service line ownership or responsibility is split between the customer
and the system.
4) Including additional information forthe public, such as:
• A location identifierforall service lines (e.g., including unknown and non-lead).
• Consider using the street address as the location identifier for all service lines.
• Additional location descriptors if multiple service lines serve different buildings with
the same listed address (e.g., hospital or university campus) to allow each service line
to be uniquely identified.
5) Including additional service line characteristics, such as:
• The source(s) of information used to identify the service line material: Tracking this
information can help you asses the accuracy of historical records and service line
investigation methods.
Developing and Maintaining 13 June 2023
a Service Line Inventory: Small Entity Compliance Guide
-------
• Pipe diameter: Pipe diameter can be an important factor in determining service
material classification because LSLs are often two inches or smaller in diameter.
• Installation or replacement date: The date of service line construction or replacement
can be an important factor in screening for potential LSLs since LSLs were banned at
the federal level in 1986 and even earlier by some states and communities. Where
precise dates are not available, the year (e.g., 1985) or estimated date range (1950-
1960) of installation or replacement can be used.
10. How Do I Develop My Service Line Inventory?
Under the LCRR, EPA requires that water systems review
certain types of information to develop their initial
inventory. Specifically, water system must review the
following:
• Information on lead and galvanized iron or steel
that was identified prior to the LCR under 40 CFR
§ 141.42(d).3
• 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.
• 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.
• 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.
In addition, water systems must use any resource, information, or investigation method provided
by or required by the State to develop their initial inventory.
Looking for ways to fund the
development of your inventory? See
EPA's LSLR funding page at
https://www.epa.gov/ground-water-
and-drinking-water/funding-lead-
service-line-replacement
3 Note that the LCR required systems to review information gathered under 40 CFR § 141.42(d) to identify targeted
sample sites. This and other information reviewed for the LCR requirements may be helpful in identifying service line
material.
Developing and Maintaining 14
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Tools That Can Help You Develop and Maintain Your Inventory
EPA developed a spreadsheet template, available online at https://www.epa.gov/ground-water-
and-drinking-water/revised-lead-and-copper-rule. as an optional tool to help water systems
develop and maintain their service line inventory. The template contains five worksheets for
water systems as shown in Exhibit 8.
Exhibit 8: Organization of EPA Inventory Template: Water System Worksheets
Worksheet Name
Description
PWS Information
For systems to document basic system information.
Inventory Methods
For systems to document the methods and resources they used to develop
and update their inventory.
Inventory Summary
For systems to provide a summary of their service line inventory, including
information on ownership, inventory format, and the number of service lines
for each of the four required materials classifications. Systems can enter the
totals into this worksheet or automatically generate totals based on
information in the Detailed Inventory worksheet.
Detailed Inventory
Provides a customizable format water systems can use to track materials for
each service line in their distribution system. Each row equals one service line
connecting the water main to the customer's plumbing. Separate columns
track location information, the system-owned portion, the customer-owned
portion, other possible sources of lead, information for assigning a tap sample
tiering classification, and information for lead service line replacement (LSLR).
Systems can customize the worksheet by adding or deleting columns.
Public Accessibility Doc.
For systems to provide documentation to states on how they met the public
accessibility requirements of the LCRR.
The template also contains color-coded instruction worksheets in yellow. Exhibit 9 provides an
excerpt of the instructions.
Developing and Maintaining 15
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Exhibit 9: Excerpt of Instructions from EPA's Inventory Template
System Template Instructions
Purpose of this worksheet: To provide detailed instructions for each worksheet for systems that
elect to use this template.
Getting Started
1. Save a copy of this workbook to your hard drive or network drive. Consider adding your
system PWSID or other system identifier to the filename (e.g., Inventory
TemplateXXOOOOOOO) and indicating in the filename if this is the "initial" inventory or
"updatel", "update2", etc.
2. Complete the PWS Information, Inventory Methods, Inventory Summary, and Public
Accessibility Documentation worksheets by following the instructions below.
3. If you decide to use the Detailed Inventory worksheet in this workbook to organize
information on service line material, follow the instructions below. Alternatively, you can use
a different format for your inventory such as a list, custom spreadsheet, database, or map.
You will be asked to describe the inventory format on the Inventory Summary worksheet.
The inventory template is designed for you to save a copy to your computer, enter your
information electronically, and submit the entire file to your State. Blank forms from the
inventory template that could be filled out by hand (except for the detailed inventory) are in
Appendix B. Appendix C provides an example of the completed forms and an excerpt from a
detailed inventory for a hypothetical system. Remember that EPA does not require you to use this
template for your inventory. You should check with your State for any format requirements.
Recommendations for Developing the Service Line Inventory
1) EPA recommends that systems start with planning steps, including:
• Identify staff and resources: The level of effort for the initial inventory depends on the
size of your system, the availability of historical records, the format and condition of
those records, the extent of LSL investigations, and methods required and/or
approved by your State. Interviews with your experienced system staff and plumbers
can be used to focus the inventory effort and verify utility practices.
• Select an inventory format: Possible formats include lists, spreadsheets, databases,
and maps. EPA does not require a specific inventory format, but you should check with
your State. The format should be flexible enough to accommodate updates, be easily
transmittable to the State, include location identifiers, and be in a format that can be
Developing and Maintaining 16
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
made publicly accessible. You can use part or all of EPA's inventory template for your
initial inventory; see the description of the template provided above in "ToolsThat
Can Help You Develop and Maintain Your Inventory."
• Develop procedures for collecting service line information: Inventory activities should
be considered as something that can be worked into the day-to-day activities of your
system rather than treated as an independent effort. Opportunities for information
collection include meter reading, meter repair service line repair, service line and/or
main repair or replacement, and backflow prevention inspections. You should consider
developing standard operating procedures (SOPs) or modifying existing SOPs to
document how your staff and contractors can collect information and use it to update
your inventory. EPA recommends that systems begin tracking service line materials as
they are encountered during normal operations before the LCRR requirement takes
effect on October 16, 2024.
2) EPA recommends that systems consider using one of
the following approaches to historical records review.
• Initial screening process (see Exhibit 10 below):
Beginning with all service lines in your system,
you can screen out non-lead service lines based
on the date of the lead ban and construction
records (i.e., service lines constructed after your
local lead ban became effective are unlikely to
be an LSL). You can further reduce your data set
by classifying non-lead lines based on size, such
as a maximum diameter of lead pipe that was
installed (typically two inches).4 The remaining dataset represents the service lines
that could potentially be lead or GRR.
Most Lead Service Lines Are Old!
LSLs were primarily installed from
the late 1800s to the 1940s
(Hensley et al., 2021). Some
communities, however, continued
to install them through the 1980s
until they were banned at the
federal level.
4 Preparing a Lead Service Line Inventory - LSLR Collaborative (lslr-collaborative.org).
Developing and Maintaining 17
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Exhibit 10: Service Material Screening Process Based on Records
1
r
i
r
r
Source: Liggett; J. 2021. Revised Lead and Copper Rule Inventory Requirements [Webinar], AWWA Virtual Summit:
Lead & Water Quality, April 7-8, 2021.
• Asking key questions: The LSLR Collaborative developed a flowchart with key
questions to ask when starting the inventory process and points to available resources.
It is available online at https://www.lslr-collaborative.org/preparing-an-inventory-
where-do-we-start.html.
• Weight of evidence: A weight of evidence approach can be useful if you have multiple
sources of information for identifying service line material. Corroboration of historical
records by another method makes a strong case for any service line classification.
However, some water systems have reported finding conflicting records. If you have
conflicts, EPA recommends a conservative approach whereby you assign the material
as unknown (or lead, where one or more data sources indicate that lead is present)
until the conflicts can be resolved.
3) EPA recommends that systems consider conducting service line investigations to reduce the
number of unknowns as quickly as possible, EPA recommendations for service line
investigations are as follows:
• Determine the extent of service line investigations based on the completeness of
historical records, your confidence in the accuracy of historical records, potential
opportunities for coordination with crews already in the field doing other work,
previous investigation efforts, and number of service lines of unknown material.
Developing and Maintaining 18 June 2023
a Service Line Inventory: Small Entity Compliance Guide
-------
• Prioritize service line investigation: There are many
ways to prioritize locations for service line
investigations, examples include prioritizing based on
vulnerable or environmental justice populations, areas
with the most unknowns, service lines that are most
likely lead, and areas where LSLR is already occurring.
• Select investigation methods: Examples of
investigation methods include visual identification of
service line material by customer, mechanical or
vacuum excavation, and water quality sampling. Note
that State approval is needed to use select investigation
methods for service line material classification.
Additional information on investigation methods is available in Chapter 5 of EPA's full
inventory guidance.
EPA recommends water systems develop procedures for inventorying service lines of vacant or
abandoned buildings. For example, systems could consider:
• Prioritizing occupied homes for service material investigation or replacement to
achieve a greater lead exposure reduction from their overall program, provided that
the water is turned off at the vacant or unoccupied structure.
• Investigating these structures' service lines if they are doing maintenance or
construction work in the area.
• Identifying service material before service is restored, or not reconnecting LSLs on
previously vacant homes or buildings (or new construction built after demolition).
• Using the transfer of property as an opportunity for service line identification or LSLR.
11. What If I Only Have Non-Lead Service Lines?
The requirements for developing an initial inventory are the same for systems with all non-lead
service lines as they are for those with LSLs, GRRs, and/or service lines of unknown material. You
must prepare an initial inventory of service lines in your distribution system and submit it to your
State by October 16, 2024. Your inventory must include the system- and customer-owned portion
of all service lines, and service lines should be classified as non-lead orthe specific non-lead
material. You must review previous materials
evaluations, construction and plumbing codes/records,
water system records, distribution system inspections
and records, information gathered during normal
operations, and State-specified information to prepare
your initial inventory.
PROTECT YOUR TAP
a quick check for lead
EPA has developed a step-by-step
guide to help people identify LSLs
in their homes, available online at
https://www.epa.gov/ground-
water-and-drinking-
wate r/protect-yo u r-ta p-q u ick-
check-lead
Remember that records already
reviewed for service line material
information under previous
inventory efforts need not be
reviewed again.
Developing and Maintaining 19
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Although requirements are the same for developing the initial inventory, you have additional
options for sharing information with the public. You can make the initial inventory publicly
available OR provide a written statement that your system has no LSLs, GRRs, or lead status
unknown service lines along with a statement describing the methods you used to make the
determination.
Recommendations for Determining That All Service Lines Are Non-Lead
Underthe LCRR, you can classify a service line as non-lead by determining through an evidence-
based record, method, or technique that it is not lead or GRR. You should also check with your
State for any additional applicable requirement.
There are several ways to determine whether all service lines are non-lead. You may be able to
use municipal codes and construction dates to show that all service lines were constructed after
lead was banned in the system (i.e., the system never had LSLs). Or you may be able to positively
identify non-lead materials (e.g., copper or PVC) for all service lines through historical records,
field investigations, or both. You may be able to use a combination of evidence-based records,
methods, or techniques; for example, when a portion of your distribution system was constructed
after the lead ban, and the remainder is verified as non-lead based on historical records and
service line investigations.
EPA recommends that you document the evidence-based records, methods, and techniques that
you used to determine that all service lines are non-lead to help with customer communications,
transparency, and State review.
Finding an LSL or GRR After Submitting Your Initial Inventory
EPA recognizes that even when all service lines have been classified as non-lead, an LSL or GRR
may subsequently be found. If this happens, you must:
• Notify your State within 30 days.
• Prepare an updated inventory on a schedule established by your State.
Although not required, EPA recommends that, if your inventory has only non-lead service lines
and an LSL or GRR is found, you replace the LSL or GRR as soon as possible and investigate when
it was installed and who installed it. You should consider whether the discovery was an isolated
event or a potential indicator of additional LSLs/GRRs in your system. If the latter, EPA
recommends that you work with your State to determine which service lines should be
reclassified as unknown and develop a plan for field investigations.
Developing and Maintaining 20
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
12. What Information Must I Report to My State and When?
You must submit your initial service line inventory to your State by October 16, 2024. The initial
inventory must include the system- and customer-owned portions of all service lines in the
system's distribution system and each service line or portion of the service line must be classified
as lead, GRR, non-lead (orthe actual material), or lead status unknown.
The LCRR does not require a specific format for the inventory; however, States may have
additional requirements or recommendations regarding inventory format. See Section 10 for
recommendations for inventory format.
13. What Information Must I Provide to the Public?
The public information requirements of the LCRR are intended to help customers understand the
sources of lead in their drinking water, so that they can take steps to reduce their exposure.
These requirements include: 1) public accessibility of the service line inventory, 2) revised
Consumer Confidence Report (CCR) requirements, and 3) service line material notification.
Public Accessibility
What Information to Include
You must make the initial inventory publicly accessible. It must include at a minimum, a location
identifier for each LSL and GRR. If you serve more than 50,000 people, you must provide your
inventory online. The exception is if your system has all non-lead service lines. In this situation,
you have the option to provide (1) a written statement that your system has no LSLs, GRRs, or
unknowns and (2) a general description of the methods you used to make this determination.
EPA encourages you to consider providing additional information in your publicly available
inventory (see the recommendations below). However, you should weigh the benefits of
providing additional detail with the drawback of compromising a user's ability to find the most
relevant information. You could consider indicating what other inventory information is available
on request or including links to additional information if your inventory is available online.
Developing and Maintaining 21
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Recommended Additional Information to Include in Your Publicly Accessible Inventory
1) Location identifier for a//service lines (not just LSLs and GRRs) and detailed location identifier
information as previously described.
2) Actual material for non-lead service lines.
3) Additional Information about the inventory such as:
• The total number of LSLs, GRRs, unknowns, and non-leads.
• A schedule for investigating unknowns.
• Instructions for the public on how to read and interpret the inventory.
• The date of the last inventory update.
• System contact information for questions or more information.
4) Clear disclaimer language to help you communicate any uncertainty inherent in your inventory, such as
the varying reliabilities of some data sources.
5) Information to help minimize exposure to lead including:
• The water system's actions to reduce lead.
• How customers can test their water for lead, (e.g., a system's lead testing program or a list of
certified laboratories that can provide testing services).
• Steps that consumers served by LSLs can take to protect themselves.
• Statements that other lead sources may exist in drinking water plumbing or the building.
How to Make the Data Publicly Available
Under the LCRR, you must make your initial inventory publicly accessible, such as on the system's
website, by mail, or in-person at your water system's office. If you serve 50,000 or fewer people,
you are not required to publish your inventory online. EPA encourages all systems to provide
online inventory access to reduce the time and cost associated with individual requests for
inventory information.
A web-based map is an effective means for communicating service line inventory information to
the public. Interested parties can view your service line materials anywhere there is internet
access. The primary advantages of this format are user accessibility, data transparency, and your
ability to regularly update the data. Exhibit 11 shows an example service line map created by
Greater Cincinnati Water Works (GCWW). Best practices for map development include thoughtful
selection of colors and symbology, displaying only the information that is most useful to the
consumer, defining terminology and acronyms, and providing the text in multiple languages.
Developing and Maintaining 22
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Exhibit 11: Greater Cincinnati Water Works Service Line information Map
Greater Cincinnati Water Works Service i ine Information
Pybte £<4* | fc-iYdW S>d«
NO»WsADj£AD
3felAQ>
i£&D_NQMl£A3
If you are not using a web-based map application but want to share your inventory electronically,
there are many options. If your system has a website, a new webpage or subsection could be
added for hosting service line inventory documents and updates. If your system does not have a
website, providing your inventory online could be as simple as uploading a list, spreadsheet, or a
simple map to a free filesharing service or publicly viewable social media account forthe system.
You can also check if your State, or county can host your inventory.
If your circumstances do not a I low for web-based sharing, EPA recommends that you develop a
plan for effectively distributing your inventory. Potential options for providing information
without the use of electronic data sharing include:
• Printed service line maps;
• Printed tables of data;
• Information in your water system's mailings or newsletters; and
• Information available at your water system's office.
Developing and Maintaining 23
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
NTNCWSs could consider using email, posting the information in frequented locations (e.g.,
breakroom or notice board), or include the information in a newsletter.
Recommendations for Public Input and Updates
Community involvement in the inventory process can lead to a more accurate inventory and
more LSLR participation. You could ask for public feedback on existing material classifications or
additional information where service line material is unknown. Public feedback can take many
forms. For example, you can provide contact information on your website for individuals to
submit corrections and updates via email or phone. Another example is a user submission form
where customers identify the service line material and provide a photo.
Consumer Confidence Report Inventory Requirements
If your system is a CWS, you must include in your annual CCR, starting with reports delivered in
2025, a statement that you have prepared a service line inventory and instructions on how to
access it. If all of your service lines are classified in the inventory as non-lead, you can instead
provide a statement that you have no LSLs or GRRs with the description of methods used to make
that determination. EPA may potentially revise these requirements underthe Lead and Copper
Rule Improvements (LCRI). Regardless of the final LCRI requirements, EPA recommends that you
provide inventory-related information in your CCR.
Service Line Notification Requirements and Recommendations
If you have lead, GRR, or lead status unknown services lines, you must provide notification to
people served by these lines within 30 days after completing the initial inventory. For new
customers, added after the initial inventory is complete, you must provide the notice at the time
of service initiation. The notification must be repeated annually until the entire service line is no
longer a lead, GRR, or lead status unknown service line. Delivery must be by mail or another
State-approved method.
If you serve communities with a large proportion of non-
English speaking consumers, as determined by the State,
you must provide public education materials in the
appropriate language(s) or provide contact information
where people can request a translated copy or
translation assistance.
Exhibit 12 shows what must be included in the notice based on service line material.
You must demonstrate that you
delivered the notification and
provide a copy of the notification
and information materials to your
State annually by July 1 for the
previous calendar year.
Developing and Maintaining 24
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Exhibit 12: Service Line Notification Requirements
For LSLs, the notice must include:
For GRR service lines, the
notice must include:
For lead status unknown service
lines, the notice must include:
•
A statement that the service
• A statement that the service
• A statement that the service
line material is lead
line material is GRR
line material is lead status
•
Mandatory health effects
• Mandatory health effects
unknown
language
language
• Mandatory health effects
•
Steps that consumers can take
• Steps that consumers can
language
to reduce exposure to lead in
take to reduce exposure to
• Steps that consumers can
drinking water
lead in drinking water
take to reduce exposure to
•
Opportunities for LSL
• Opportunities for service
lead in drinking water
replacement opportunities
line replacement
• Opportunities to verify the
•
Information about any
material of the service line
available financing
•
A statement that the water
system must replace its portion
if the property owners notify
the system they are replacing
their portion
The mandatory health effects language is specified in §141.85(a)(ii) of the LCRR.
Recommendations For Your Notifications
1) Use simple, plain language and short sentences that can be easily understood by the members of
the public. Avoid long paragraphs or legalistic language.
2) Design notices to convey the urgency of the information, differentiate the notice from other mail
that a household receives, and draw consumers' attention to key information. For example, use:
• Colored envelopes, large-sized envelopes, or text on the external envelope to make the notice
stand out compared to other mail.
• Bold design practices to draw consumers' attention to key information, including large, bold,
underlined, or colored font, bullet points or numbered points, or boxes around key information.
3) Make the notice action-oriented, emphasizing the key steps consumers can take and providing
specific instruction on how to do so. You should consult your local health department on resources
that consumers can be directed to, including water filters and blood lead level testing.
Developing and Maintaining 25
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Appendix A: Additional Useful Resources
EPA Resources
• January 15, 2021 Lead and Copper Rule Revisions: https://www.ecfr.gov/current/title-
40/chapter-l/subchapter-D/part-141/subpart-l.
• Inventory Development Materials: https://www.epa.gov/ground-water-and-drinking-
water/ revised-lead-and-copper-rule.
o Guidance for Developing and Maintaining a Service Line Inventory,
o Inventory Template.
o Webinar- Getting the Lead Out: Guidance for Developing Service Line Inventories
and Funding Information on the Bipartisan Infrastructure Law. August 10, 2022.
o Fact Sheet for Developing and Maintaining a Service Line Inventory. June 2023.
• Protect YourTap: A Quick Check for Lead: This online step-by-step guide to help
people identify lead pipes, called lead service lines, in their homes. It also provides tips
on actions to reduce lead exposure in drinking water, information on certified
laboratories for water testing, and resources to learn more.
https://www.epa.gov/ground-water-and-drinking-water/protect-your-tap-quick-
check-lead.
• Funding for Lead Service Line Replacement: https://www.epa.gov/ground-water-and-
drinking-water/funding-lead-service-line-replacement.
• Lead and Copper Rule Revisions (LCRR) Data Entry Instructions (DEI). This document
provides the required LCRR initial inventory and violation data that must be reported
to the Safe Drinking Water Information System (SDWIS).
https://usepa.servicenowservices.com/sdwisprogram?id=kb article view&sysparm ar
ticle=KB0015473&sys kb id=bdlcc2201b67d9140a81202de54bcbae&spa=l.
LSLR Collaborative Website
• This website contains information to facilitate full lead service line replacement:
https://www.lslr-collaborative.org/.
Examples of Customer Service Line Material Identification Instructions:
• DC Water: https://www.dcwater.com/sites/default/files/Lead-
Testing/DCWPipeMaterialldentificationGuide 2021.pdf.
• Newark. NJ: https://www.newarkleadserviceline.com/check-your-line.
• Philadelphia Water System:
https://www.phila.gov/media/20211208161245/HowToCheckYourServiceLineForLead-
21.12.07.pdf.
Developing and Maintaining A-l June 2023
a Service Line Inventory: Small Entity Compliance Guide
-------
• Rockport, IL: https://rockfordil.gov/citv-departments/public-works/water-
d ivision/lead-a nd-drin king-water/.
Example of Information Sent to Customer Prior to System's Inspecting Customer's Service Line
Material from Menasha Utilities. Wisconsin
• Postcard developed by Menasha Utilities to schedule an appointment with customers
to confirm the type of water service from the water main to the home. See Appendix C
of the full guidance (https://www.epa.gov/ground-water-and-drinking-water/revised-
lead-and-copper-rule).
• Information when appointment is scheduled:
https://www.menashautilities.com/sites/menashautilities.com/files/Water%20Service
%20Verifications%20webpage%20content%202019.pdf.
Developing and Maintaining A-2
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Appendix B: Blank Template Forms
See EPA's website at:
https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule for a
downloadable, spreadsheet version of the template, which contains the forms below as well as
additional sheets for inventory tracking.
Developing and Maintaining B-l
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
PWS Information
Purpose of this worksheet: For water systems to document basic system information.
Facility Information
Water System Name:
PWSID:
Population Served
(number of people):
Number of Service
Connections:
PWS Type:
~CWS ~ NTNCWS
If you are a CWS, do multi-family residences comprise at least 20% of
the structures you serve?
Indicate "Yes" or "No"
Mailing Address
Street or P.O. Box:
City or Town:
State:
Zip Code:
System Contact Person
Name:
Title:
Telephone:
Email:
Person Who Prepared Inventory (if different from above)
Name:
Title/Affiliation:
Telephone:
Email:
Developing and Maintaining B-2
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Inventory Methodology
PWS Name:
PWSID:
Enter Date Last Updated:
Purpose of this worksheet: For water systems to document the methods and resources they used to develop and
update their inventory.
Part 1: Historical Records Review
Type of Record
Describe the Records Reviewed for Your Inventory and Indicate
Your Level of Confidence (e.g., Low, Medium, or High)
1. Previous Materials Evaluation
Example: Locations of Tier 1 lead tap sampling
locations that are served by a lead service
line.
2. Construction Records and Plumbing Codes
Examples: Local ordinance adopting an
international plumbing code. Permits for
replacing lead service lines.
3. Water System Records
Examples: Capital improvement plans.
Standard operating procedures. Engineering
standards.
4. Distribution System Inspections and
Records
Examples: Distribution system maps. Tap
cards. Service line repair/replacement
records. Inspection records. Meter installation
records.
5. Additional Records Required by Your State
6. Other Records
Developing and Maintaining B-3
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Inventory Methodology (Continued)
Part 2: Identifying Service Line Material During Normal Operations
1. During which normal operating activities are you collecting information on service line material? Check all
~ Water meter reading ~ Water main repair or replacement
~ Water meter repair or replacement ~ Backflow prevention device
~ Service line repair or ~ Other
replacement
If "Other", please explain:
2. Did you develop or revise standard operating procedures to collect service line Indicate "Yes" or
material information "No"
If "Yes", please describe:
Part 3: Service Line Investigations
1. Identify the service line investigation methods your system used to prepare the inventory (check all that
apply). If a water system chooses an investigation method not specified by the state under 40 CFR
§141.84(a)(3)(iv), state approval is required. Note that investigations are not required by the LCRR but can be
used by systems to assess accuracy of historical records and gather information when service line material is
unknown.
~ Visual Inspection at the Meter Pit
~ Customer Self-Identification
~ CCTV Inspection at Curb Box - External
~ CCTV Inspection at Curb Box - Internal
~ Water Quality Sampling - Targeted
~ Water Quality Sampling - Flushed
~ Water Quality sampling - Sequential
If "Other", please explain:
~ Water Quality Sampling-Other
~ Mechanical Excavation
~ Vacuum Excavation
~ Predictive Modeling
~ Other
2. If "Predictive Modeling", please briefly describe the model and inputs used:
3. How did you prioritize locations for service line materials investigations? For example, did you consider
environmental justice and/or sensitive populations, did you use predictive modeling, and/or did you target
areas with high number of unknowns?
Developing and Maintaining B-4
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Inventory Summary
PWS Name:
PWSID:
Enter Date Last Updated:
Purpose of this worksheet: For water systems to provide a summary of their service line inventory, including information
on ownership, inventory format, and the number of service lines for each of the four required materials classifications.
Part 1. General Information
1. Is this the Initial Inventory or an Inventory Update?
2a. Who owns the service lines in your system?
2b. Is there documentation that defines service line ownership in your system, such as a local ordinance? If yes, please
describe below and explain where ownership is split (e.g., property line, curb stop).
3a. Describe when lead service lines were generally installed in your system.
3b. When were lead service lines banned in your system? Reference the state or local ordinance that banned the use of
lead in your system.
4. Do you have lead goosenecks, pigtails or connectors in your system? Indicate "Yes", "No", or "Don't Know"
5. What is your overall level of confidence in the inventory (i.e., "Low", "Medium", or "High.") Please explain your
rationale below.
Part 2. Inventory Format
Describe your inventory format in the space provided below (e.g., the Detailed Inventory worksheet, custom
spreadsheet, GIS map). Provide the filename and/or web address if applicable. Note that the state may require you to
submit your detailed inventory of each service line in your distribution system.
Developing and Maintaining B-5
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Inventory Summary (Continued)
Part 3. Inventory Summary Table1
Enter the number of service lines in the aqua-colored cells. Remember this is the classification for the entire service line.
Service Line Material
Classification
Definition
Total Number of Service Lines
(REQUIRED to be reported
under the LCRR)
Lead
Any portion of the service line is known to be made of
lead.2
Galvanized Requiring
Replacement (GRR)
The service line is not made of lead, but a portion is
galvanized and the system is unable to demonstrate that
the galvanized line was never downstream of a lead service
line.
Non-Lead
All portions of the service line are known NOT to be lead or
GRR through an evidence-based record, method, or
technique.
Lead Status Unknown
The service line material is not known to be lead or GRR.
For the entire service line or a portion of it (in cases of split
ownership), there is not enough evidence to support
material classification.
TOTAL
Notes
1 This summary table is for reporting material for the entire service line connecting the water main to the customer's plumbing. See
Section 2.1 for additional guidance on assigning a materials classification to the entire service line when ownership is split.
Remember that systems must track the system-owned and customer-owned portions separately in their inventory.
2 A lead-lined galvanized service line is consistent with the definition of an LSL under the LCRR ("a portion of pipe that is made of
lead, which connects the water main to the building inlet") (40 CFR §141.2) and must therefore be classified in the inventory as an
LSL. Do NOT, however, count non-lead service lines with a lead gooseneck or pigtail as lead service lines unless required by your
state.
Developing and Maintaining B-6
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Public Accessibility Documentation
PWS Name:
PWSID:
Enter Date Last Updated:
Purpose of this worksheet: For systems to provide documentation to states on how they met the public
accessibility requirements of the LCRR.
1. Select the location identifiers that you use for your service line inventory. Check all that apply.
~ Address
~ Street
~ Block
~ Intersection
~ Landmark
~ GPS Coordinates
~ Other
If "Other", please describe:
2. Does every service line have a location identifier? Indicate "Yes" or "No"
If "No", explain. Remember that location identifiers are required for service lines that are lead and galvanized
requiring replacement.
3. How are you making your inventory publicly accessible? Check all that apply. Remember that if your system
serves > 50,000 people, you must provide the inventory online.
~ Interactive online map
~ Static online map
~ Online spreadsheet
~ Printed service line map
~ Printed tabular data
~ Information on water utility mailings or newsletter
Q Hard copy information available in water system office
~ Other
If "Other", please describe:
Developing and Maintaining B-7
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Appendix C: Completed Inventory Template Forms for a Hypothetical System
This appendix contains an example of completed inventory template forms for a hypothetical water
system in Virginia, called "the Applewood System." This system is using a modified version of the
detailed inventory worksheet to track the material for each service line in Excel. An excerpt of
Applewood System's inventory is included at the end of this appendix.
Developing and Maintaining C-l
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
PWS Information for Hypothetical System
Purpose of this worksheet: For water systems to document basic system information.
Facility Information
Water System Name:
ApplewooeJ Welter System
PWSID:
Population Served
(number of people):
Number of Service
Connections:
PWS Type:
VA0000000
7,223
2,748
0CWS ~ NTNCWS
If you are a CWS, do multi-family residences comprise at least 20% of
the structures you serve?
No
Mailing Address
Street or P.O. Box:
200 Soutk Main. St.
City or Town:
State:
Zip Code:
Applewoocd
VA
r
00000
System Contact Person
Name:
Title:
3oel Howard
Water Treatment Plant Superintendent
Telephone:
Email:
(240)001-0001
j.koware<app I ewooc( wtp.org
Person Who Prepared Inventory (if different from above)
Name:
Title/Affiliation:
Telephone:
Email:
Developing and Maintaining C-2
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Inventory Methodology for Hypothetical System
PWS Name: Applewood Water System
PWSID: VA0000000
Enter Date Last Updated: 03/01/23
Purpose of this worksheet: For water systems to document the methods and resources they used to develop and
update their inventory.
Part 1: Historical Records Review
Type of Record
Describe the Records Reviewed for Your Inventory and Indicate Your
Level of Confidence (e.g., Low, Medium, or High)
1. Previous Materials Evaluation
Example: Locations of Tier 1 lead tap sampling
locations that are served by a lead service line.
Applewood Summary of Materials Survey Results Updated in
2011 {HigK), used to identify our LCR tap monitoring
locations; 2002 Applewood Evaluation Skort Form for Small
and Medium Public Water Systems (High.).
2. Construction Records and Plumbing Codes
Examples: Local ordinance adopting an
international plumbing code. Permits for
replacing lead service lines.
1973 - 2000 Virginia Uniform Statewide Building Codes
(High.); 1975-1999 Building Officials and Code
Administrators' (BOCA's) National Building Codes (Plumbing
Codes) (High); 2003 - 2018 Virginia Construction Code
(High); 2015 Virginia Plumbing Code, Chapter 6, Section 605
Materials, Ooints and Connections (High) ; 2013 Applewood
Plumbing Permit Application (Medium).
3. Water System Records
Examples: Capital improvement plans. Standard
operating procedures. Engineering standards.
Standard Operating Procedures for Applewood Water System
dated from 1960 to 2015 (High); Applewood revised Standard
Operating Procedures - Lead Line Replacement - Remodeling
dated in 1998 (High)
4. Distribution System Inspections and Records
Examples: Distribution system maps. Tap cards.
Service line repair/replacement records.
Inspection records. Meter installation records.
Applewood Water System Service Reports (Tap Cards) dated
from 1916 to 2022 (Medium); Applewood As-Built Drawings
for the distribution system from 1916 to 1990 (High).
5. Additional Records Required by Your State
N/A
6. Other Records
Interviews with local plumbers in the city of Applewood
(medium).
Developing and Maintaining C-3 June 2023
a Service Line Inventory: Small Entity Compliance Guide
-------
Inventory Methodology for Hypothetical System
(Continued)
Part 2: Identifying Service Line Material During Normal Operations
1. During which normal operating activities are you collecting information on service line material? Check all that
apply.
~ Water meter reading 0 Water main repair or replacement
0 Water meter repair or replacement ~ Backflow prevention device inspection
0 Service line repair or replacement ~ Other
If "Other", please explain:
2. Did you develop or revise standard operating procedures to collect service line material Yes
information during normal operation?
If "Yes", please describe:
In August of 2022, tke Applewood Standard Operating Procedures were updated to require maintenance
crews to record service line materials during water meter, water main, and service line repair and
replacement projects. Tkis information is reported to tke water system manager and used to update
tke service line inventory.
Part 3: Service Line Investigations
1. Identify the service line investigation methods your system used to prepare the inventory (check all that apply). If a
water system chooses an investigation method not specified by the state under 40 CFR §141.84(a)(3)(iv), state
approval is required. Note that investigations are not required by the LCRR but can be used by systems to assess
accuracy of historical records and gather information when service line material is unknown.
0 Visual Inspection at the Meter Pit
0 Customer Self-Identification
~ CCTV Inspection at Curb Box - External
~ CCTV Inspection at Curb Box - Internal
~ Water Quality Sampling - Targeted
0 Water Quality Sampling - Flushed
~ Water Quality sampling - Sequential
If "Other", please explain:
~ Water Quality Sampling - Other
0 Mechanical Excavation
~ Vacuum Excavation
~ Predictive Modeling
~ Other
2. If "Predictive Modeling", please briefly describe the model and inputs used:
3. How did you prioritize locations for service line materials investigations? For example, did you consider
environmental justice and/or sensitive populations, did you use predictive modeling, and/or did you target areas with
high number of unknowns?
We targeted older areas of tke distribution system wkere we didn't know tke customer-owned portion.
We also requested a list of licensed family day komes from Virginia Department of Education and
prioritized tkose for investigation.
Developing and Maintaining C-4
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Inventory Summary for Hypothetical System
PWS Name: Applewood Water System
PWSID: VA0000000
Enter Date Last Updated: 03/01/23
Purpose of this worksheet: For water systems to provide a summary of their service line inventory, including information
on ownership, inventory format, and the number of service lines for each of the four required materials classifications.
Part 1. General Information
1. Is this the Initial Inventory or an Inventory Update?
Initial Inventory
2a. Who owns the service lines in your system?
Ownerskip is split, meaning tkat tke system owns a portion. and tke customer owns a portion.
2b. Is there documentation that defines service line ownership in your system, such as a local ordinance? If yes, please
describe below and explain where ownership is split (e.g., property line, curb stop).
City of Applewood Municipal Code 12-1-15: Tke City skall be responsible for city owned water mains lying
witkin City rigkts-of-way. Tke property owner skall be responsible for tke repair and maintenance of
tkeir water service line from tke meter to tkeir building.
3a. Describe when lead service lines were generally installed in your system.
Tke first pkase of tke Applewood distribution system was constructed in 1916, and tkere were two major
expansions in 1946 and 1990. As Virginia referred to tke BOCA plumbing codes and lead was banned for
water distribution in tke 1981 BOCA plumbing code, tkere was a possibility tkat service lines built
between 1916 and 1981 were made of lead.
3b. When were lead service lines banned in your system? Reference the state or local ordinance that banned the use of
lead in your system.
1981. Virginia referred to tke BOCA plumbing codes and starting in 1981, Lead as a material for water
distribution was banned in tke BOCA plumbing code. Also, Maryland and Virginia banned tke use of lead
solder in plumbing on August 9, 1986.
4. Do you have lead goosenecks, pigtails or connectors in your system? No
5. What is your overall level of confidence in the inventory (i.e., "Low", "Medium", or "High")? Please explain your
rationale below.
Medium. Altkougk all tke information above can be located in kistorical records, tke exact years wken
lead service lines were installed and wkere tke lead service lines are located are still not confidently
confirmed, because some tap cards are too old to be readable. Also service line replacement records were
not kept in a consistent way until tke 1980's.
Developing and Maintaining C-5 June 2023
a Service Line Inventory: Small Entity Compliance Guide
-------
Inventory Summary for Hypothetical System (Continued)
Part 3. Inventory Summary Table 1
Enter the number of service lines in the aqua-colored cells. Remember this is the classification for the entire service line.
Service Line Material
Classification
Definition
Total Number of Service Lines
(REQUIRED to be reported
under the LCRR)
Lead
Any portion of the service line is known to be made of
lead.2
745
Galvanized Requiring
Replacement (GRR)
The service line is not made of lead, but a portion is
galvanized and the system is unable to demonstrate that
the galvanized line was never downstream of a lead service
line.
26
Non-Lead
All portions of the service line are known NOT to be lead or
GRR through an evidence-based record, method, or
technique.
1,501
Lead Status Unknown
The service line material is not known to be lead or GRR.
For the entire service line or a portion of it (in cases of split
ownership), there is not enough evidence to support
material classification.
476
TOTAL
2,748
Notes
1 This summary table is for reporting material for the entire service line connecting the water main to the customer's plumbing. See
Section 2.1 for additional guidance on assigning a materials classification to the entire service line when ownership is split.
Remember that systems must track the system-owned and customer-owned portions separately in their inventory.
2 A lead-lined galvanized service line is consistent with the definition of an LSL under the LCRR ("a portion of pipe that is made of
lead, which connects the water main to the building inlet") (40 CFR §141.2) and must therefore be classified in the inventory as an
LSL. Do NOT, however, count non-lead service lines with a lead gooseneck or pigtail as lead service lines unless required by your
state.
Developing and Maintaining C-6
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Public Accessibility Documentation for Hypothetical
System
PWS Name: Applewood Water System
PWSID: VA0000000
Enter Date Last Updated:
03/01/23
Purpose of this worksheet: For systems to provide documentation to states on how they met the public
accessibility requirements of the LCRR.
1. Select the location identifiers that you use for your service line inventory. Check all that apply.
0 Address
0 Street
D Block
D Intersection
D Landmark
D GPS Coordinates
~ Other
If "Other", please describe:
2. Does every service line have a location identifier? Yes
If "No", explain. Remember that location identifiers are required for service lines that are lead and galvanized
requiring replacement.
3. How are you making your inventory publicly accessible? Check all that apply. Remember that if your system
serves > 50,000 people, you must provide the inventory online.
D Interactive online map
D Static online map
0 Online spreadsheet
D Printed service line map
0 Printed tabular data
0 Information on water utility mailings or newsletter
Q Hard copy information available in water system office
~ Other
If "Other", please describe:
Developing and Maintaining C-7
a Service Line Inventory: Small Entity Compliance Guide
June 2023
-------
Excerpt from the Detailed Inventory for the Hypothetical System
100
31 Applewood Drive,
Applewood VA 00000
Non-Lead - Plastic
Yes
1997
2
Installation
date after lead
Yes
Visual inspection
at the meter pit
11/1/2022
Non-Lead - Plastic
1997
2
Installation
date after
lead ban
No
Non-Lead
101
66 Main Street, Applewood
VA 00000
Non-Lead - Plastic
No
Fall 1980
2
Installation
record (e.g.,
tap card)
Yes
Mechanical
excavation at one
location
10/10/2022
Galvanized
Fa/11980
2
Installation
record (e. g.,
tap card)
Yes
Mechanical
excavation at one
location
10/10/2022
Non-Lead
102
167 Birch Drive, Applewood
VA 00000
Non-Lead -
Copper
Don't know
1985
11/2
Service line
replacement
No
Galvanized
1922
11/2
Installation
record (e. g.,
tap card)
No
Galvanized
Requiring
Replacement
103
15 Oak Ave, Applewood VA
00000
Unknown - Likely
1940's
2
No
Galvanized
1940's
2
Yes
Customer self-
identification
2/2/2023
Galvanized
Requiring
Replacement
104
The Children's Place, 127
Oak Ave, Applewood VA
00000
Unknown -
Material
Unknown
1950-1960
3/4
No
Unknown - Material
Unknown
1950-1960
3/4
No
Unknown
105
33 First Ave, Applewood VA
00000
Lead-lined
galvanized
1955
2
Installation
record (e.g.,
tap card)
Yes
Water quality
sampling
10/26/2022
Lead-lined
galvanized
1955
2
Installation
record (e. g.,
tap card)
Yes
Water quality
sampling
10/26/2022
Lead
106
93 Maple Drive, Applewood
VA 00000
Non-Lead -
Copper
Yes
2015
2
Service line
replacement
No
Galvanized
1950 -1955
2
Installation
record (e. g.,
tap card)
Yes
Customer self-
identification
2/26/2023
Galvanized
Requiring
Replacement
107
99 Main Street, Applewood
VA 00000
Non-Lead -
Copper
Don't know
2015
2
Service line
replacement
No
Unknown - Material
Unknown
1940's
2
No
Unknown
Note: Although not shown here, this hypothetical system is also using the detailed inventory worksheet to track where the service connection is to a school or day care,
other sources of lead, which service connection addresses are also LCR compliance monitoring locations, and lead and GRR service lines that have been replaced and
when.
Developing and Maintaining
a Service Line Inventory: Small Entity Compliance Guide
C-8
June 2023
------- |