Lead Service Line Inventory Submittal and Public Notification Requirements Reminder:
Your Community’s Lead Service Line Inventory (LSLI) is due for submission to the Indiana Department of Environmental Management (IDEM) by October 16, 2024. Pursuant to the Lead and Copper Rule Revision (LCRR), all Community Water Systems and Non-Transient Non-Community Water Systems must complete initial Lead Service Line Inventories by this date. This inventory must include ALL service lines connected to the distribution system, including those not in use. The inventory for Community Water Systems must also include information on both the system and customer-owned portions where ownership is split.
Service lines must be classified as “Is Lead”, “Galvanized Requiring Replacement (GRR)”, “Non-Lead”, or “Unknown”. A classification of “Non-Lead” must be supported by evidence-based records, methods, or survey techniques.
Inventories are required to be submitted to IDEM through the PWS Portal and you MUST click the “Submit Inventory” button as shown below.
IDEM_PWS Portal Guidance_v1.3 (120water.com)
After the LSLI for your community is completed, customers at locations served by lines under the classification of “Is Lead”, “Unknown”, or “Galvanized Requiring Replacement (GRR)” must be notified within 30 days of the finalized submission. These initial notifications must be done by November 15, 2024. This notification will need to continue to be sent to your affected customers annually. This notification sent to the customer must include:
- Statement that the service line material is Lead, GRR, or Unknown
- Information on the health effects of lead (40 CFR 141.85(a)(1)(ii))
- Steps to minimize exposure in drinking water
- Additional information about replacement, financing, and if further identification is required depending on the material classification of the service line
Click on the link below for access to templates to aid in complying with your Public Notification Requirements.
Notification Templates for Known or Potential LSLs
Inventories must be made available to the public within 30 days (prior to, or on, November 15, 2024) of inventory submission. Utilities serving populations of more than 50,000 must make the inventories available via their website. Community Water Systems must include language in their Consumer Confidence Report (CCR) explaining how customers can access the inventory.
After you have completed these notifications, you will need to certify that these notifications were completed. You can email this form or fill out the certification form within PWS Portal to confirm that the notifications were completed. The certification form in PWS Portal will be a new feature on the State Reporting page coming soon. Click Here To Download the Form.
After the initial inventory is completed, there is a 3-year period to determine if “Unknown” service lines are classified as “Lead” as part of the final version of EPA’s Lead Copper Rule Improvements that is anticipated to be issued in the next few weeks. This anticipated rule also requires that communities plan and initiate Lead Service Line Replacements within the noted 3-year period and will have 10 years to fully replace all lead lines. The inventories will become living documents routinely updated as additional information is received and replacements occur.
If IDEM does not receive an initial inventory by the October 16th, 2024 deadline, a violation will be issued, and this violation must be included in the Consumer Confidence Report (CCR).
For more information, contact Brady Dryer or Rachel Runge, PE.
