40 CFR §141.84 Every subsection, on every project — verified, not assumed

The most rigorous LCRI unknowns resolution a water system can commission.

LineProof assembles a documentation-complete baseline inventory — every statutory element, every required records search, the evidence file, the statistical sampling plan, and the replacement-plan impact — checked against the letter of 40 CFR Part 141 Subpart I before a specialist releases it.

Every subsection of 40 CFR §141.84Five statutory inventory elements, gate-checkedSDWIS · tap cards · permits · as-builts searchesSpecialist release on every project5-business-day SLA
Why projects fail

A single unresolved unknown can inflate your replacement obligation by millions.

Under the LCRI, every service line classified 'unknown' is presumed lead. That presumption triggers annual mailed notifications, drags your public inventory, and — most critically — counts toward the replacement-rate denominator that determines how many $5,000–$10,000+ line replacements your system must perform each year through 2037.

Most water systems run this by hand, from memory, once or twice a decade. The rule has not been read end-to-end since the last time it mattered. That is exactly where completeness gaps hide.

LineProof exists to close that gap with a single, exhaustive standard applied identically to every file.

23.5M
unknown service lines nationally — each one a presumed lead liability
The benchmark

Measured against the letter of the rule — subsection by subsection.

We do not summarize the law and hope. Every project is scored against a versioned rule pack tied to the exact text of 40 CFR Part 141 Subpart I. These are the provisions each project is held to.

40 CFR §141.84(b)(1)

Baseline inventory elements

Material classification for each service line (lead, galvanized requiring replacement, non-lead, unknown) — all present, or the project does not release.

40 CFR §141.84(b)(2)

Connector materials

Gooseneck, pigtail, and connector materials identified and documented at both water-main and meter ends.

40 CFR §141.84(b)(3)

Records-based evidence

Tap cards, plumbing permits, meter-installation records, and as-builts mined and cross-referenced against lead-ban dates.

40 CFR §141.84(b)(4)

Statistical sampling plan

State-accepted statistical methods (e.g., MassDEP, Kentucky, California DDW pre-approval pathways) applied to convert records evidence into documented non-lead determinations.

40 CFR §141.84(b)(5)

Public posting & notification

Address-level inventory posted to EPA's dashboard and annual notification letters drafted for each presumed-lead line.

40 CFR §141.84(c)

Replacement plan & schedule

Lead service line replacement plan with annual targets through 2037, sequenced on the calendar so nothing is missed.

How a project is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human specialist signs every release. That order is never reversed.

01

Unknowns Exposure Scan

Upload your system's SDWIS ID. We return a free completeness read: which statutory elements and records you already have, and which are missing.

02

Records mining & lien searches

As your authorized clerical agent, we OCR and classify decades of tap cards, plumbing permits, meter-installation records, and as-builts, building the evidence file.

03

Grounded classification

Material classifications are drafted from validated records and the 40 CFR §141.84 rule pack into field-locked templates — no legal opinions, no invented facts.

04

Deterministic completeness gates

Records evidence reconciles to the inventory to the line; the statistical sampling plan is verified; the search checklist is resolved; any failure blocks release.

05

Specialist release

A water-compliance specialist reviews the exception queue and signs the release. High-value or complex systems route to attorney review first.

06

Delivery

You receive the project: baseline inventory, evidence file, statistical sampling plan, replacement plan, annual notification drafts, and the compliance calendar — ready for the system to submit under its own name.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No project ships without a human signature.
5 days
Standard SLA
From complete intake to released project.
<1%
Critical-defect target
Tracked against a gold-standard project library.
4
Records-search sources
Tap cards · permits · as-builts · SDWIS, every applicable file.
Why LineProof

Built to be the most thorough option a water system has.

Documentation-complete, by design

The deliverable is completeness itself — every statutory element and records search accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A classification error cannot slip past a statutory requirement.

In its lane, on purpose

We prepare documentation and run records searches as your clerical agent. We never contact the public, give legal advice, or conduct the replacement work.

Engagement

Flat fee, per released project. No contingency, ever.

Simple, predictable, and aligned with a documentation standard — not a cut of any avoided replacement cost.

  • A free Unknowns Exposure Scan before you commit — see exactly what is missing.
  • One flat fee per released Baseline Compliance Package; disclosed pass-through records-search fees.
  • Optional fixed-fee attorney review for complex or high-value systems.
  • Optional Annual Notification Subscription for ongoing compliance through 2037.
FAQ

Questions, answered precisely.

Is LineProof a law firm?
No. LineProof, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or high-value systems.
Do you contact the public or perform replacements?
Never. LineProof is not a contractor and does not contact property owners or perform physical work. The water system remains the responsible party for all public notices and replacement activities.
What makes a project 'complete'?
Completeness is defined by the rule: the five §141.84(b) inventory elements present, records evidence resolved or exception-coded, statistical sampling plan validated, and replacement plan sequenced. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released project. The free Unknowns Exposure Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released project, plus disclosed pass-through records-search costs. No contingency and no percentage of any avoided replacement cost.

See what's missing before it costs you millions in replacement obligations.

Start with a free Unknowns Exposure Scan. Send your system's SDWIS ID and we'll return a completeness read against every subsection of 40 CFR §141.84.

Documentation-completeness service · not legal advice · the water system submits every filing.