7 Tips You Need to Know About Lead Service Line Inventories
By Susan Fenhaus, PE
Before joining Morrison-Maierle in 2022, I was the water utility engineer for a city in western Washington that serves a population of 60,000. When the EPA issued its Lead and Copper Rule Revision (LCRR), our staff decided to be proactive and start this process early.
To start this process, we reviewed the draft rule to understand the impacts of this project on our community. We decided to begin the service line inventory in 2021, well ahead of EPA’s 2024 deadline.
Having been through a service line inventory (not to mention learning about it from the perspective of a city utility), I have a few tips to help you get started. Here are some lessons learned to help you locate the information needed to meet this requirement.
1. Start Now
The EPA compliance date for the LCRR is October 16, 2024, which means your inventory must be completed in less than two years. It takes time to understand the LCRR requirements and what a utility needs to do to meet them.
Keep in mind that completing the inventory is just the first step. October 2024 is also the deadline for having a plan to replace all lead service lines in your system and a plan for sampling for lead and how you will educate the public about the health effects of lead in drinking water. These plans tie together and build upon each other, so getting started is important.
2. What Do You Already Know?
Good service records will make the inventory easier, but they are often incomplete or missing. Other sources to tap into are plans from development projects and street and utility improvements, which may provide installation dates and material types. Using historical aerial photos from the USGS site may provide a snapshot of the era, depending on location. For example, an image from the 1940s will show homes with either lead or galvanized services, and possibly, if they were dug up earlier, the pipes may have been swapped out for copper. Another place to look is on building and plumbing permits, as they will provide dates. Ask yourself what you have stored that can provide information.
3. Have a Good Map of the Water Distribution System
GIS is a great tool, but paper maps are also helpful. Use them to mark where the inventory is complete. Highlight and color code areas that likely have lead lines or need further investigation. In our inventory, we used a map to highlight the streets most likely to have lead services or lead gooseneck connections that would also require digging at the main to investigate. We used this map to coordinate work with the street department.
4. Inventory the Easy Stuff First
Streets and buildings that were developed after 1988 will all have non-lead services. In some instances, this could be a significant number of services in your community. Once you start with the easy-to-determine areas of your community, the service line inventory will not seem as overwhelming. Remember to take advantage of other information you know or can easily find out about your system. For example, water main replacements done in the 1990s and 2000s likely replaced the public side of the service at the same time with non-lead material. Target these areas, and you’re closer to a completed inventory.
5. Get Help from Your Customers
A single page, either included with utility bills or in a separate mailing, can inform your customers about the service line inventory and ask them for help. This type of communication will show them why you are asking for their assistance, what to look for, how to determine the material type, and how they can provide information to you and your staff.
We were surprised with how many of our customers were willing to help us, especially when we explained why we were asking for help, what to look for, and how they could help.
I noticed a great example of this in a recent issue of The Glasgow Courier. The Glasgow Public Works Department in Montana took a proactive approach to their LSL inventory and announced they would be mailing each water customer a service line test form with instructions on how to complete the test and report back. They explained that completing the test and returning the form would take 15 minutes. They also demonstrated that by participating in this process, the city might be able to receive funding from the federal government through the Infrastructure Investment and Jobs Act.
6. ‘Material Type Unknown’ is an Acceptable Answer, But …
EPA states that all unknown service lines must be treated as if they contain lead, according to the LCRR. This means more lines will be included in the replacement plan and require significantly more effort when notifying and educating the public. In Montana, DEQ provides thorough guidelines and specifications for notifying the public.
Annual notification is required to each customer with a known lead or unidentified service line, along with information about the health effects of lead and how customers can reduce their lead exposure. This notification will continue annually until the service material is identified or until the lead line is replaced.
If sampling exceeds the trigger limit of 10 ug/L, lead service line replacement will be required according to the plan established. The number of unknowns is included in the replacement plan. Narrowing the unknown category, if you can, is important to reduce the continued effort in the future.
7. IT Staff are Valuable Resources
Larger systems will have a significant amount of data to compile. Keep in mind that it takes time to manually enter information into your service line intake spreadsheet. Working with someone who understands GIS and asset management software can simplify the data entry process for blocks of information, such as a street or a new subdivision with identical service line information.
Developing your service line inventory can take a little detective work. The best thing you can do is start now and develop a plan of attack. If you and your staff divide the tasks and consistently devote time each month to completing a section of your community, your inventory will be done before October 2024.
If you need further assistance or have questions, please don’t hesitate to contact me for more information. My door is always open.