A lead service line inventory that is already on file is not finished work. It is the baseline you update when the ground tells you something new. A repair, a meter swap, a main replacement, a customer-side find, or a material you finally verify all change the record. The primacy agency expects the file it holds to match the street.

This page is that update. The first filing, and what you owed to start the record, live on other pages: LCRI lead service line inventory: what to file and when, lead service line inventory requirements, and what small systems owe by November 2027. Do not treat those pages as the update-after-filing job, and do not treat this page as a new first-filing deadline. Confirm the current LCRI timing, and the resubmittal the state wants, with your primacy agency. This isn't legal advice.

What "current" means once the file exists

The inventory classifies every service line connected to the system as lead, galvanized requiring replacement (GRR), non-lead, or unknown. Connectors belong in that record. "Current" means the classification on each service matches the last thing you actually saw or verified, and the version the state has is that version, not last year's spreadsheet.

Unknown is not a parking spot. Until you verify the material, the line travels with lead and GRR for planning and notice purposes. A current file shrinks that unknown column one verified line at a time, and it moves a line out of lead or GRR the day you replace it, not the day you plan to. Put the PWSID on every export. If you need the identifier, use PWSID lookup. Community and non-transient non-community systems both keep this file.

New finds during repairs and ordinary field work

Most updates are not a special inventory project. They happen because someone already has the street open.

  • Service-line repair or leak work. The crew sees the material on the system side, the customer side, or both. Write what they saw, which side, the address, and the date, before the ditch is backfilled.
  • Meter replacement or setter work. The pit is often the only place you can see both sides without a full excavation. A copper setter with an unknown run to the main is not a classified line. Record what was visible and what was still hidden.
  • Main replacement or service transfer. Unknown services get identified in batches here. Transfer each service into the inventory before you close the job file.
  • Customer report, plumber find, or old records. Ask for a photo, the address, and which side. Verify it against your own file before you change a classification. Log the document, not just the new label.

The habit is one field slip per address: date, crew, what was seen, which side, photo, and the new classification. If the crew is not sure, leave it unknown. A guessed "non-lead" is how a current file becomes a wrong file.

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Replacements have to move the row the same week

When you replace a lead or GRR line, or a connector, the inventory has to show the new material. A replacement that exists only in a capital-project folder is not an inventory update.

  • Record the date the new line went into service, the material on each side, who did the work, and whether any lead or GRR remains on the customer side.
  • If you replaced only the system-owned portion, the customer-owned portion keeps its own classification. Partial replacement is a split row, not a full non-lead.
  • If a galvanized line is no longer downstream of lead, ask the state whether it still counts as GRR. Do not reclassify GRR to non-lead on a hunch.
  • Keep the work order and a photo with the inventory export. You will need both when the state asks how a lead count dropped.

Replacement planning and the LCRI replacement clock live on the first-filing pages. This page is the record change after the work is in the ground. Confirm the current replacement timing with the state. Do not invent a new federal deadline here.

Material changes that are not a replacement

Three common changes do not involve a new pipe and still have to hit the file:

  • Unknown to classified. Inspection, a records review the state accepts, or a customer-side verification turns unknown into lead, GRR, or non-lead. Date the method. If the state has a verification protocol, use it.
  • Lead or GRR confirmed on a line you had as non-lead. Correct it the day you know. A polite inventory that hides a find is a wrong inventory. Tell the primacy contact if their last accepted file now understates lead.
  • Connector added or reclassified. Goosenecks, pigtails, and other connectors that were left out of an older file belong in the current one. Add them when you find them. Do not wait for a later baseline conversation to mention a lead connector you already saw.

Each change should leave a version you can reconstruct: the old label, the new label, the reason, and the date. A spreadsheet that only keeps the latest label, with no history, is hard to defend in a sanitary survey.

What you resubmit to the state

The first-filing pages cover when the inventory is due and what the November 2027 package includes. This page does not add a new federal due date. Ask your primacy agency what it wants after the file already exists:

  • The format it accepts (the state's template, a portal upload, or a letter plus a table).
  • Whether it wants a full replacement file or only the rows that changed.
  • How soon after a find, a replacement, or a material change it wants the new version.
  • Whether a public-facing inventory has to update on the same day as the state file.

Send the PWSID, the version date, a short change log (how many lines moved from unknown to classified, how many lead or GRR were replaced, how many connectors were added), and the file. Keep the sent copy. States vary. Wyoming systems resubmit to EPA Region 8. The District of Columbia and tribal systems resubmit to the EPA region with primacy. If the state has not named a resubmittal clock, do not invent one. Ask, then follow the answer you get in writing.

The Consumer Confidence Report will need an inventory-status line under the Revised CCR Rule. That line is a pointer to this file, not the filing. See What is a CCR. Public education after a lead action-level exceedance, and the consumer notice after tap sampling, are different notices on different clocks. They are not inventory updates. See lead action level exceedance public education and lead consumer notice after tap sampling.

A working field habit

  • Print the current inventory (or take a filtered export) on every repair and replacement job. The crew should know what the file already claims for that address.
  • Fill the field slip before backfill. Photo the pipe, the curb stop, and the house number.
  • Enter the change the same week. Do not batch finds until "inventory season."
  • Send the primacy contact any version they have asked for. Do not guess a federal date. Keep the public copy in sync with the state copy. See water system record retention.

FAQ

We filed in 2024. Can we leave the file alone until the next LCRI package?

No. The 2024 initial inventory was the starting file. Finds, replacements, and material changes after that date belong in the current record. The later baseline package is a different filing. Confirm what the state wants between those filings. Do not treat a future package date as permission to run a stale street file.

Do I send the state a new inventory every time we repair one service?

Ask the state. Some primacy agencies want a full refresh on a set cycle. Some will take changed rows after a batch of work. This page does not invent that cycle. Record the change the week of the work either way, so the next submittal is not a reconstruction from memory.

Check my system at /find-my-system.

Orevant provides compliance information tools. This page isn't legal advice. Confirm current LCRI inventory-update timing and the resubmittal your primacy agency wants.