Public Water System Compliance with Revised Lead and Copper Rule, Lead Poisoning Prevention Act

PWSs have developed an inventory to identify the materials of and classify all public and private side service lines connected to the public water distribution system. PWSs must have submitted their initial inventories to RIDOH by October 16, 2024. The online map compiles the inventories of all PWSs in the state.

RIDOH has prepared an inventory template that incorporates Rhode Island's requirements in addition to EPA's requirements, available at the link below. PWSs may submit inventories using the RIDOH inventory template [RIDOH Inventory Template] or by using online portal owned by RIDOH’s contractor 120Water. Every PWS that must comply with inventory requirements has access to a 120Water account. Visit their help center or contact RIDOH for more information.

Once inventories are completed, PWSs will need to develop lead service line replacement plans.

About classifying galvanized service lines

It is important to note that Rhode Island and EPA differ on how galvanized service lines should be classified. Rhode Island’s LPPA is stricter than EPA’s LCRR in how it classifies galvanized service lines as lead lines and omits the “galvanized requiring replacement” classification. RIDOH encourages systems to classify its service lines according to both the LCRR and LPPA requirements and to identify the specific material (e.g., copper, plastic, galvanized iron, etc.) of all components of the service lines. Doing so will help the PWS if and when seeking DWSRF funding for replacement of its service lines.

Because the Rhode Island LPPA’s classification requirements are stricter than EPA’s LCRR requirements, PWSs are required to classify service lines according to Rhode Island’s classification standards. If a PWS seeks funding from certain federal pots of money, the PWS will also need to classify its service lines following EPA’s specific classification requirements as further detailed below. RIDOH has created an inventory template that includes two columns for classifying service lines: (1) a "RI Service Line Material Classification" column, and (2) an "EPA Service Line Classification" column. RIDOH encourages PWSs to use this template.

Under the LPPA, PWSs must classify their service lines into one of three categories: lead, non-lead, or lead status unknown. In Rhode Island all galvanized service lines must be classified as lead service lines, with two exceptions. The PWS can classify a galvanized service line as “non-lead” if it can demonstrate that any part of the line is not and was never downstream of a lead service line and is not currently downstream of an unknown service line (i.e., that the galvanized line is not “galvanized requiring replacement”); or it can classify a galvanized service line as “lead status unknown” if applicable.

In contrast, under the LCRR, systems must classify their service lines into one of four categories: lead, galvanized requiring replacement, non-lead, or lead status unknown. Though "galvanized requiring replacement" is not a required classification in Rhode Island, knowing whether a service line is "galvanized requiring replacement" is necessary if a system seeks funding for the replacement of galvanized service lines or components under certain DWSRF sources. Under the LCRR, a galvanized service line must be classified as "galvanized requiring replacement" if it is or was at any time downstream of a lead service line or is currently downstream of a lead status unknown service line. By contrast, under Rhode Island’s LPPA, such a line would be classified as “lead.”

Service Line Inventory Guidance and Resources

Guidance documentation (by PWS size) prepared by EPA are available at the links below. Please note that these federal materials are based on the requirements of the LCRR and do not address Rhode Island-specific requirements. More information about inventories will continue to be distributed directly to PWSs and added to this webpage as it becomes available.

• EPA Guidance for Developing and Maintaining a Service Line Inventory
• EPA Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide – for small PWS

On this webpage you can find information about technical assistance and funding opportunities as well as service line types, ownership, and verification.

Customer Notice of Lead Service Line Discovery or Disturbance

PWSs must send written notification to property owners and the tenants of a building within 30 days of identifying or disturbing a public or private side lead service line or lead status unknown service line that supplies drinking water to their building or dwelling. To reach both the property owner and any tenants of the building, the PWS must send the notification to the billing address (to inform the property owner) of the building, as well as all mailing addresses at the building (to reach every unit at the address). PWSs must also send a similar notification at the time of water service initiation, such as when a property changes ownership or tenancy, at properties with lead or unknown service lines.

To certify that the customer notices have been distributed, sign into the PWS’s 120Water account. Upload a copy of the notice template or letter and use the dropdowns to select how many lead or unknown lines were discovered. Check off the applicable items and submit the form to complete. Submitting the 120Water web form certifies to RIDOH that notices were sent and fulfills a requirement of the LCRR. 

To comply with the LPPA, PWSs must send customer notice when any new lead or unknown service lines are discovered. PWSs must send a copy of the notices to RIDOH to certify that they were distributed to consumers.

PWSs are strongly encouraged to use the template notifications RIDOH developed, which include all of the elements required by LPPA. You may also choose to include the appropriate flushing guidance flier (Daily Water Pipe Care to Reduce Lead Exposure, Intensive Flushing Method Following Lead Pipe Replacements) along with the notice. If the PWS’s community speaks a language other than English or Spanish, the PWS should seek translation services to provide the notice in the appropriate language(s).

• Lead Line Discovery Notice English Spanish
• Lead Line Disturbance Notice English Spanish

At this time, RIDOH is not requiring systems that previously detected lead service lines or lead status unknown service lines prior to the LPPA’s effective date of June 24, 2023, to send notifications. However, PWSs should be aware that the LCRR requires a similar notification to consumers within 30 days of completion of the required inventory and a repeat notice annually. More information about requirements will continue to be distributed directly to PWSs and added to this webpage as it becomes available.

Filters

PWSs that have identified a public or private lead service line or lead status unknown service line must provide to the consumer, upon request, a filter pitcher or point-of-use device certified by an American National Standards Institute accredited certifier to reduce lead, instructions to use the filter, and six months of filter replacement cartridges.

Filters that are certified to comply with ANSI Standard 53 for the removal of lead will meet the certification requirement. Before distributing any filters to consumers, PWSs must get approval from RIDOH for the type of filter the PWS intends to provide. PWSs may send an email attaching the filter’s specifications, including the appropriate certification, to RIDOH at DOH.RIDWQ@health.ri.gov with “Service Line Filters” in the subject line.

 

Private Side Service Line Inspection

PWSs that have detected a lead service line or lead status unknown service line must inspect the private side service lines, at no cost to the property owner, to determine if lead, galvanized iron, or steel is present.  If lead is detected in a private side service line, the lead service line must be replaced. If funding for replacement projects is available, all lead service lines must be replaced over the next 10 years.

It may be helpful to notify customers before private side service line inspections occur. RIDOH has created a sample letter that PWSs can use to notify their consumers of the inventory and the potential need for the PWSs to enter buildings to complete service line inspections. Bracketed text indicates areas where PWSs should enter their information and the details of how they plan to proceed with the inventory inspections. Distribute a copy of the Daily Water Pipe Care factsheet with the letter. The use of this letter is voluntary.

• Inventory Sample Letter English  Spanish
• Daily Water Pipe Care to Reduce Lead Exposure

Lead Service Line Replacement

PWSs that have identified lead service lines or lead status unknown service lines must develop and submit lead service replacement plans to RIDOH in accordance with the LCRR and LPPA. More guidance on the required deadline and contents of the replacement plans will be made available on this webpage.

Consumer Notice Requirements

If a property owner refuses to allow an inspection or replacement of private side service lines, PWS must notify all occupants of the address. PWSs must also notify RIDOH by sending a completed refusal form to RIDOH attesting that two attempts were made and that notice was distributed to all occupants of the address. RIDOH prepared template notifications for occupants in English and Spanish with all required elements of the LPPA. PWSs are strongly encouraged to use the templates which are linked below. If the PWS’s community speaks a language other than English or Spanish, the PWS should seek translation services to provide the notice in the appropriate language(s).

• Inspection Refusal Notice for Occupants English   Spanish
• Replacement Refusal Notice for Occupants English   Spanish
• Refusal Form (complete and return to RIDOH)

All addresses where service line inspections or replacements were refused are shown here. If a service line inspection or replacement takes place where it was previously refused, notify DOH.RIDWQ@health.ri.gov with the subject “Service Line Refusal Update” so that the list of addresses can be maintained.  

Lead Service Line Disturbance Filter Requirements

When a PWS disturbs a private lead service line or lead status unknown service line to replace the line or a component of the service line, the PWS must provide to the consumer a filter pitcher or point-of-use device, instructions, and six months of filter replacement cartridges (unless a pitcher or point-of-use device was requested when the consumer was notified of a lead or unknown service line discovery). When a PWS disturbs a service line by performing a water shutoff and on, the PWS must send notice of the disturbance to consumers but is not required to provide or offer a filter pitcher.

Before distributing any filters to consumers, PWSs must get approval from RIDOH for the type of filter the PWS intends to provide. PWSs may send an email attaching the filter’s specifications, including the appropriate certification, to RIDOH at DOH.RIDWQ@health.ri.gov with “Service Line Inventory Filters” in the subject line.

PWSs must submit updated inventories to RIDOH annually to show adjusted service line counts due to verified service line types and lead line replacements. PWSs that have demonstrated the absence of lead service lines will not be required to provide updated inventories, unless lead or lead status unknown service lines are discovered after the initial inventory.

PWSs must also submit an annual report with information about their service line inventories and replacement statuses to the Governor, the President of the Rhode Island State Senate, the Speaker of the Rhode Island House of Representatives, the Director of RIDOH, and the Executive Director of the Rhode Island Infrastructure Bank. Starting in 2024, the annual report will be due within 90 days of the end of each fiscal year (June 30). 

RIDOH is contracting with 120Water to provide technical assistance to PWSs. 120Water has expertise in LCRR compliance and specialized experience in service line inventory and lead service line replacement plan development. 120Water can assist PWSs with maintaining their inventories, reporting, and developing their lead service line replacement plan at no cost to the PWSs. You can request technical assistance through the website or by emailing support@120Water.com. Sign up online to access the inventory portal for more information and to watch recorded trainings.

The information sheets linked below can be used as inserts to consumer notice about lead service line discoveries, disturbances, or inspection or replacement refusals.

• Daily Water Pipe Care to Reduce Lead Exposure
• Cleaning Faucet Aerators
• Intensive Flushing Method Following Lead Pipe Replacements

Under the LPPA, lead service lines must be replaced by July 2033. The LPPA also states that private side service lines must be replaced at no cost to the customer provided project funding is available. Eligible PWSs will be able to apply for funding through the Drinking Water State Revolving Fund (DWSRF) for service line inventory development. Funding is also available for lead service line replacement through the DWSRF. 

In order to receive funding through the DWSRF for a project, PWSs must apply to have the project added to the RIDOH Project Priority List (PPL). In February of each year, RIDOH sends a letter to PWSs eligible for the PPL. For PPL applications and more information about DWSRF, you can visit the DWSRF webpage or contact the Center for Drinking Water Quality by emailing DOH.RIDWQ@health.ri.gov (please put “DWSRF” in the subject line) or calling 401-222-6867. 

PWSs that serve a population of less than 10,000 people should consider the DWSRF as a funding source even for relatively small projects. If it is determined that the PWS is economically disadvantaged, then subsidies such as lower interest rates, zero interest rates, and/or additional forgiveness may be available. 

Another possible source of funding is the Water Infrastructure Improvements for the Nation (WIIN) Act’s Small, Underserved, and Disadvantaged Communities grant. For grant details, please visit the EPA’s grant webpage.

If you have questions about any of the matters on this webpage, please refer to the letter distributed in January 2024. For additional information, contact the Center for Drinking Water Quality by emailing DOH.RIDWQ@health.ri.gov (please put “Service Line Inventory” in the subject line) or calling 401-222-6867.

Use the following definitions to describe service lines in the service line inventory and replacement planning:

• Lead service lines are broadly defined as any part of a public or private service line that is made of, lined with, or contains materials consisting of lead, and importantly, includes service lines with galvanized steel or iron.
• Galvanized refers to iron or steel piping that has been dipped in zinc to prevent corrosion or rusting.
• Galvanized requiring replacement refers to galvanized service lines that are or were at any time downstream of a lead service line or are currently downstream of a lead status unknown service line. For more information see About classifying galvanized service lines under the Initial Service Line Inventory tab above.
• Non-lead refers to service lines that are determined through an evidence-based record, method, or technique not to be lead or galvanized requiring replacement.
• Lead status unknown refers to the designation given to service lines where the service line material is not known to be lead, galvanized requiring replacement, or a non-lead service line. A service line must be classified as lead status unknown if there is no documented evidence supporting material classification or if a non-lead determination cannot be made. Under the LPPA, service lines that are “lead status unknown” will be considered lead service lines.

Service line ownership is often split between the PWS or municipality and the owner of the building that receives the water. A service line is comprised of several parts, which may be made of different materials, between the distribution main and building plumbing. Service lines are usually divided in two segments, the segment owned by the PWS (often referred to as the public side), and the segment owned by the customer (often referred to as the private side).

See the image below for an example of the service line components. Service line parts include:

• Connector from a distribution main. This could be or include a lead “gooseneck” or “pigtail” and is less than 2 feet in length.
• Public side portion of the line
• Curb stop and/or shutoff valve
• Private side portion of the line
• Connector into the building. This may include a lead pipe segment.
• Water meter

PWS may use partial inventories or other records to inform their inventory. For locations where the material of service lines is not known, PWS can incorporate verifying the service line into day-to-day operations, such as completing visual service line inspections alongside planned meter work.  The following methods can be used to determine the materials of the service lines.

• Any information already known about the material of service lines such as PWS, construction, and plumbing codes records.
• Historical building records and other data available from American Water Works Association or other research groups.
• Visual inspection during planned maintenance such as backflow prevention inspections or meter, service line, or main repairs or replacements.
• Material identification by customer in the service area. Customer identification may be made through comments, complaints, and other input that PWS receives through solicitation such as a survey form.
• Other procedures and resources that are available to the PWS, if approved by RIDOH.