Inventory gap check
Example Rural Water District
PWSID XX0000000 (fictional) · Example State (fictional) · Sample prepared October 2026
Samplefictional data
- System type
- Community water system
- People served
- 1,180
- Service connections
- 486
- Water source
- Groundwater
1. Where your inventory stands
Sample data56.4%of service lines still unknown
Your state's published summary of your 2024 initial inventory lists 274 of 486 lines as lead status unknown. Together with 8 galvanized requiring replacement lines, that is 282 lines that need yearly customer notices and a replacement plan.
| Category | Lines | Share |
|---|---|---|
| Lead | 0 | 0.0% |
| Galvanized requiring replacement | 8 | 1.6% |
| Non-lead | 204 | 42.0% |
| Lead status unknown | 274 | 56.4% |
| Total | 486 | 100.0% |
2. What comes next, with dates
Sample data- Now, every year Customer notices to 282 addressesRequired under the 2021 rule since 2024 for every lead, galvanized requiring replacement and unknown line. Not in public record
- Nov. 1, 2027 Baseline inventory to the stateAll 486 lines, both sides where ownership is split, plus a connector entry for each. Needed
- Nov. 1, 2027 Service line replacement planRequired because you have galvanized requiring replacement and unknown lines. Needed
- 30 days after the baseline Notices based on the baseline inventoryTo every address still lead, galvanized requiring replacement or unknown. Needed
- Jan. 30, 2029 First yearly update to the stateUpdated inventory and plan, then every January 30. Later
- Dec. 31, 2034 Spot check of non-lead linesLook at the pipe at two points on a random sample of lines marked non-lead. Lines with records showing installation after June 19, 1988 are left out. If all 204 stay in the pool, that is about 41 lines. Later
- 2037 Replacement deadlineReplace the 8 galvanized lines under your control, plus any unknown lines found to be lead or galvanized. Every unknown line identified. Later
Rule text: 40 CFR 141.84, 40 CFR 141.85(e), 40 CFR 141.90(e)
3. What looks missing
Sample data- No connector data. The 2024 inventory lists service lines only. The baseline needs a connector entry for each line: lead, non-lead, unknown, or no connector present.
- 274 unknown lines. This drives your notices, your plan and your future field work. Many may be settled from records you likely already hold (see section 4).
- One material per line. The state summary shows a single material for each line. Where the district and the customer each own part of a line, the baseline needs both sides.
- No public copy found. We did not find the inventory on the district's website. Systems your size do not have to post it online, but it must be publicly accessible.
- No replacement plan yet. Not due until November 1, 2027, but required because of your galvanized and unknown lines.
4. Cheapest ways to settle the 274 unknowns
Sample dataA first sort, based on public parcel build years and the kinds of records districts like yours usually hold. We confirm it against your actual records in the kit.
| Group and likely way to settle it | Lines |
|---|---|
| Built after 1988Build or tap dates after June 19, 1988, if your state accepts them as evidence. Office time only. | 141 |
| Meter change-out records2019 meter project work orders that note pipe material at the meter. Office time only. | 62 |
| No record, easy accessA look in the meter pit or curb box during a routine read. | 48 |
| No record, hard accessA customer photo where your state accepts it, or potholing as a last resort. | 23 |