Tribal Water Systems in the Midwest

Receiving Lead Service Line Inventory Technical Assistance

EPA Region 7 is offering free lead service line (LSL) inventory technical assistance to eligible Tribal Community Water Systems (CWS) and Non-Transient, Non-Community Water Systems (NTNCWS).

The Oneida Total Integrated Enterprises and CH2M Joint Venture (OCH JV) is the vendor that was selected through a competitive process to provide this assistance. This technical assistance will be provided to participating tribal water systems at no charge.

Under the 2021 Federal Lead and Copper Rule Revisions (LCRR), all CWS and NTNCWS must submit an initial service line inventory by Oct. 16, 2024. Creating a service line inventory is the first step in developing a replacement plan for lead service lines and galvanized service lines requiring replacement within public water distribution systems.

What to Expect

• OCH JV will reach out to each eligible tribal water system to receive free LSL inventory technical assistance.
• Eligible public water systems should respond to OCH JV to let them know whether they intend to accept or decline the technical assistance.

Scope of Technical Assistance

The scope of technical assistance provided by OCH JV to eligible systems includes all the tasks listed below:

• Listing all distribution system service connections.
• Assigning unique locational identifiers for each service line.
• Reviewing existing records to determine service line material.
• Filling in all required fields of the EPA service line materials inventory spreadsheet.
• Developing an inventory report and submitting to the tribal water system and EPA.

Lead Service Line Inventories on Tribal Lands

Getting Started

Service line inventories are the foundation from which water systems 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.

On this page:

• Federal Service Line Inventory Requirements
• Service Line Inventory Guidance, Forms, Fact Sheets, and FAQs
• Service Line Inventory Technical Assistance
• Service Line Inventory Submittal
• Service Line Inventory Contacts

Federal Service Line Inventory Requirements

The Lead and Copper Rule Revisions (LCRR) require all Community Water Systems (CWS) and Non-Transient, Non-Community Water Systems (NTNCWS) to prepare and maintain an inventory of service line materials. Initial service line inventories for EPA Region 7 tribal water systems are required to be submitted to EPA Region 7 by Oct. 16, 2024.

Required and Recommended Inventory Elements

A service line inventory must include:

1. All service lines, regardless of the actual or intended use.
2. Service line material classification for the entire service line (from water main to inlet of the structure) (i.e., lead, galvanized requiring replacement [GRR], non-lead, or lead status unknown).
3. Material classifications for both the system-side and customer-side where ownership is split.
4. Location identifiers for lead and GRR service lines (e.g., street address).

EPA recommends that a service line inventory also:

• Include detailed location identifiers for all service lines.
• Add sub-classifications of service line materials.
• Include lead connectors where data is available.
• Track other drinking water infrastructure components potentially containing lead.
• Document additional service line characteristics.

Regulatory Information

• Lead and Copper Rule Revisions
• Proposed Lead and Copper Rule Improvements

Service Line Inventory Guidance, Forms, Fact Sheets, and FAQs

EPA has several webpage that include links to documents for developing and maintaining a lead service line inventory. (See Related Resources sidebar.) These key documents are also available at the links below and include EPA’s Service Line Inventory Guidance and Template, Small Entity Compliance Guide, Fact Sheet for Developing a Service Line Inventory, LCRR FAQs, and LCRR Implementation Fact Sheet. Please see the information below or visit the webpages in the sidebar to download the following documents:

Guidance for Developing a Service Line Inventory and Service Line Inventory Template

EPA’s Guidance for Developing and Maintaining a Service Line Inventory supports water systems with their efforts to develop initial service line inventories and provides primacy agencies with needed information for oversight and reporting. The guidance provides essential information to help water systems comply with the 2021 Lead and Copper Rule Revisions (LCRR) requirement to prepare and maintain an inventory of service line materials by Oct. 16, 2024. There is also an associated Inventory Template.

• Guidance for Developing and Maintaining a Service Line Inventory (pdf) (6.8 MB)
• Inventory Template (xlsx) (1.5 MB)

Small Entity Compliance Guide

EPA’s Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide supports water systems, particularly small water systems, in complying with the 2021 Lead and Copper Rule Revisions (LCRR) initial service line inventory requirements. EPA’s Small Entity Compliance Guide helps explain the initial inventory-related actions that small community and Non-Transient, Non-Community Water Systems (NTNCWS) are required to take under the LCRR.

• Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide (pdf) (1.5 MB)

Fact Sheet for Developing a Service Line Inventory

EPA’s Fact Sheet for Developing and Maintaining a Service Line Inventory can help water systems quickly identify the key 2021 LCRR initial service line inventory requirements, including inventory elements, planning, records review, investigations, public accessibility, and information for non-lead systems.

• Fact Sheet for Developing and Maintaining a Service Line Inventory (pdf) (1.2 MB)

LCRR FAQs for Water Systems

These Frequently Asked Questions (FAQs) address the provisions of the 2021 Lead and Copper Rule Revisions (LCRR) that EPA has proposed to retain, starting on the Oct. 16, 2024, compliance date. These requirements include the initial service line inventory, notification to persons served of known or potential lead service line, Tier 1 public notification of a lead action level exceedance, and associated reporting requirements.

• LCRR Frequently Asked Questions (pdf) (225 KB)

2021 LCRR Implementation Fact Sheet

EPA’s 2021 LCRR Implementation Fact Sheet describes the 2021 Lead and Copper Rule Revisions (LCRR) requirements that public water systems must comply with, starting on Oct. 16, 2024, as outlined in the Proposed Lead and Copper Rule Improvements (LCRI). These requirements include the initial service line inventory, notification to persons served of known or potential lead service line, Tier 1 public notification of a lead action level exceedance, and associated reporting requirements.

• LCRR Implementation Fact Sheet (pdf) (241 KB)

Service Line Inventory Technical Assistance

Water TA

EPA’s free Water Technical Assistance (WaterTA) supports communities to help them identify water challenges; develop plans; build technical, managerial, and financial capacity; and develop application materials to access water infrastructure funding.

To learn more about EPA WaterTA, including how to access assistance or sign up for ongoing updates, visit EPA's website.

EPA Region 7’s contact for Water TA is Lisa Montgomery. You can contact her at 913-551-7252 or [email protected].

Service Line Inventory Submittal

Water systems on tribal lands in EPA Region 7 can submit their lead service line inventory spreadsheet and associated service line inventory forms to EPA Region 7 via email at [email protected].

Service Line Inventory Contacts