Lead Service Line Inventory Requirement for Public Water Systems

Background

Existing laws require public water systems (PWS) to take specified actions to test for and remediate certain contaminants in drinking water, including lead and copper. Existing law prohibits the use of any pipe, pipe or plumbing fitting or fixture, solder, or flux that is not "lead free" in the installation or repair of any public water system or any plumbing in a facility providing water for human consumption, except as specified. Section 116885 of the California Health and Safety Code, Lead Service Lines in Public Water Systems, added to the Health and Safety Code by Senate Bill 1398 (2016) and amended by Senate Bill 427 (2017), requires all community water systems (CWS) to compile an inventory of known partial or total lead user service lines in use in its distribution system by July 1, 2018. The inventory must include all user service lines that are active and those that are reasonably expected to become active in the future. Also, Section 116885 requires that CWS identify areas that may have lead user service lines in use, and/or identify any areas within the CWS distribution system that the CWS cannot identify the material that is being used for the service line. CWS will be 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. "User service line" means the pipe, tubing, and fittings connecting a water main to an individual water meter or service connection.

HSC Section 116885 requires CWS, after completing the inventory, to provide a timeline for replacement of known lead user service lines in the distribution system to the State Water Resources Control Board (State Board) by July 1, 2020. In addition, by July 1, 2020, CWS with areas that may have lead user service lines in use in its distribution system must either determine the existence or absence of lead user service lines in these areas and provide that information to the State Board, or provide a timeline for replacement of the user service lines whose content cannot be determined. The State Board must approve the replacement timeline.

For more information, please see our Frequently Asked Questions (FAQ) document (link below).

For more information, click on the links below.

What is My Community Water System Required to do?

HSC Section 116885 requires all CWS to compile an inventory of known partial or total lead user service lines in use in its distribution system. The inventory must include all user service lines that are active and those that are reasonably expected to become active in the future. Also, Section 116885 requires the CWS identify areas that may have lead user service lines in use, and/or identify any areas within the CWS distribution system that the CWS cannot identify the material that is being used for the service line. CWS will be required to propose a schedule to replace all the known lead user service lines and user service lines constructed of unknown material.

Who is required to comply with HSC Section 116885?

All CWS are required to compile an inventory. 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 should I be doing now?

All CWS need to begin compiling an inventory of user service lines and identify areas of known lead user service lines and areas that may have lead user service lines (user service lines whose content cannot be determined). Resources to assist CWS compile an inventory are listed below.

All CWS will need to provide DDW a certified inventory form explaining how the inventory was determined and the results. DDW will utilize the 2017 electronic annual report (eAR) to gather this information. DDW has added the Lead Service Line Replacement (LSLR) Section into the 2017 eAR. After completing the LSLR Section, the CWS will be able to print a copy of the inventory form, have the water system representative sign the form, attesting under penalty of perjury that to the best of their knowledge the submitted information is a correct and thorough inventory of their service line, and then scan and upload the certified inventory form to the eAR Portal. If the CWS indicates the existence of areas with lead user service lines, unknown material user service lines or lead goosenecks associated with user service lines, a map(s) will need to be uploaded for those areas. Maps need to be in a GIS layer, google earth .kml/.kmz file, or PDF format.

For CWS that report lead user service lines, unknown material areas or lead goosenecks, DDW is in the process of developing a web portal to receive user service line replacement timeline documents. Once the web portal is ready, DDW will notify the CWS. The FAQ will also be updated.

Resources/Supplemental Material