Lead Service Line Inventory Requirement for Public Water Systems
Under California Health and Safety code, Section 116885, added by Senate Bill 1398 (2016) and amended by Senate Bill 427 (2017), all community water systems (CWS) must compile an inventory of known lead user service lines in its distribution system by July 1, 2018. The inventory is to include all user service lines that are active and those that are reasonably expected to become active in the future. In addition, the inventory has to include any areas for which the CWS cannot determine the content of the service line. CWS are further required to propose a schedule to replace all the known lead user service lines and user service lines constructed of unknown material by July 1, 2020.
California Code of Regulations, Title 22, Section 64551.60 defines “User service line," as “the pipe, tubing, and fittings connecting a water main to an individual water meter or service connection but does not include the service line from the meter to individual homes.” The inventory, therefore, only needs to contain information on the pipe owned by the water system from the main water line to the meter, and information about the water lateral, which is the homeowner’s responsibility (see diagram on page 3), might not be included.
Removal of lead service lines is important because, as was experienced in Flint, Michigan, changes in a water system’s source of water could cause a reaction with lead pipes and fittings, causing lead to be leached into drinking water.
For more information, please see our Frequently Asked Questions (FAQ) document (link in the Resources/Supplemental Material section).
What is My Community Water System Required to do?
The State Water Resources Control Board’s Division of Drinking Water (DDW) utilized the 2017, 2018 and the 2019 electronic annual reports (EARs) submitted by the CWS to gather the user service line inventory information. All CWS have provided DDW the information required by section 116885, along with a certified form explaining the results and detailing how the survey of the distribution system was conducted and how the inventory was compiled. CWS that identified lead user service lines, or user service lines containing unknown materials are now required to submit to DDW a schedule, by July 1, 2020, to replace the service lines that contain lead or unknown material.
Who is required to comply with HSC Section 116885?
All CWS must comply. The definition of a CWS “means a public water system that serves at least 15 service connections used by yearlong residents or regularly serves at least 25 yearlong residents of the area served by the system." A CWS should have a domestic water supply permit issued by the Division of Drinking Water (DDW) or one of our Local Primacy Agency (LPA) partners.
What Are the Next Steps?
CWS Prepare Inventory and Timeline for Replacement of Distribution Lines
CWS have until July 1, 2020 to verify materials used in their distribution system user service lines and submit a timeline for replacement of any service lines containing lead or unknown materials. The timeline needs to include the spreadsheet (Link below) and a letter or short report signed by a representative of the water system describing how the timeline for replacement was developed. The State Board expects the identified user service lines to be replaced as soon as possible and depending on the number of lines to be replaced, should not take longer than 10 years. To avoid having to replace lines that are of unknown materials, CWS may continue investigating and report the findings to DDW in the 2019 EAR.
For a copy of the inventory and timeline submitted by your CWS, please use the map below.
HSC 116885 requires:
(2) By July 1, 2020, a community water system that has identified areas that may have lead user service lines in use in its distribution system as provided for in subdivision (a) shall do both of the following:
(A) Provide to the state board its determination as to whether there are any lead user service lines in use in those areas of its distribution system and provide a timeline to the state board for replacement of those lead user service lines that the community water system has identified.
(B) Provide its findings as to whether there are any areas for which it cannot determine the content of the user service lines and a timeline to the state board for replacement of the user service lines whose content cannot be determined.
By July 1, 2020, any identified lead user service lines and any user service lines where the content of the material of the user service line cannot be determined, the community water system shall provide a timeline to the local district office for replacement. Additional information is available on the 2020 FAQs.
Customer Replacement of Service Lines
DDW encourages CWS to notify customers if it identifies water laterals, which run from the water meter to the home and are the homeowner’s responsibility, are also constructed of lead or an unknown material. However, a homeowner can also find out more about the construction of the water lateral that services its home by finding out about what the water system’s portion of the user line that serves its home is constructed of. It is much less likely that a water lateral will be constructed of lead if the user line is not or ever was constructed of lead. To identify if any lead user service lines exist in the customer’s service area, click on the map below and find your water system or contact your water system directly. In addition, if you are concerned about lead pipes or fittings on your water lateral, you are encouraged to contact your water system for assistance or a hire a plumbing expert to have a portion of your water lateral checked for lead (see diagram below). DDW has added a Frequently Asked Questions for Customers in the Resources/Supplemental Material section below.
Service Line Inventory (SLI) Status Map
The Service Line Inventory (SLI) Status map displays the SLI status based on the data collected in the 2018 Electronic Annual Report (EAR) The online map allows the public to click on a specific service area to open a pop-up window that provides inventory data about the makeup of the user service lines, which include pipes and fittings within their service area. (Note that service lines do not include the water laterals, which are the responsibility of the homeowner, but include the pipe, tubing, and fittings that connect a water main to an individual water meter or service connection.). The map is divided into four categories: Lead in the system; no lead in system; unknown service lines or material; and incomplete information.
Please note, a user can download a spreadsheet of all the information from a link on the left side of the map. To view the SLI Status map, please click on the links below:
- Frequently Asked Questions 2020
- Replacement Timeline Spreadsheet Template
- Lead Service Line Replacement Certification Form
- Frequently Asked Questions about Lead Service Lines in Public Water Systems
- Frequently Asked Questions for Customers
- LSL Data Collection
- DDW will be collecting LSL data from water systems using the Electronic Annual Report (eAR) web portal.
- Resource material to assist water system with developing a user service line inventory:
- Service Line Inventory Guide
- Senate Bill 1398
- Senate Bill 427