In mid-2021, when the U.S. Environmental Protection Agency (USEPA) announced the Lead and Copper Rule Revisions deadline, October 16, 2024 seemed a long way away. There are now 12 months left to accomplish the considerable requirements that all water systems must complete.
AE2S has been working with water systems to help them with LCRR compliance. Throughout our projects, we have identified eight steps to take to get started on the path to successfully completing the requirements. Start now to ensure your water system has adequate time to complete the process before the deadline.
Step 1: Get on the Funding List
The LCRR may have the highest cost for compliance of any previous drinking water rule. The Federal government allocated funding to each of the States to help fund LCRR compliance. However, each State’s funding program is unique and the deadlines to apply for funding vary. It is prudent to submit a request for funding as soon as possible due to the number of requests for funding being greater than the amount of available grant funding. To estimate your system’s potential cost to create a lead service line inventory, consider the following variables:
- Personnel Time: How many labor hours will be required of the water system’s staff to complete the LCRR process?
- Equipment Costs: Do you have access to a vac-truck to complete potholing to spot check service lines? Is there other equipment that will be needed to complete the inventory?
- Consulting Fees: Will the water system staff tackle the LCRR requirements on top of their standard duties? If that is not feasible, contracting with a consultant who can serve as an extension of staff may be a more efficient way to complete the inventory.
- Communication Costs: The LCRR requires an inventory of both the water system and the customers’ portions of the service lines. This means water systems need to budget time and funds to communicate with customers about testing service lines. Depending on the size of the service area, bill stuffers, mailers, emails, calls, or texts may be utilized to reach customers and provide instructions. If the system serves more than 50,000 people, a lead service line map needs to be developed and posted online.
Step 2: Create a List of Every Service Line
Every water service line must be accounted for in the LCRR inventory. To begin the inventory process, the location of every line in the system needs to be identified. When that is complete, the list of service line locations should be compared to the billing database to ensure everything matches up. AE2S recommends creating a spreadsheet with one row for each service line. Another option is to update the water system’s GIS database to include a node for each service line.Finally, whether service lines do or do not have private componentsshould be noted in the location records.
Step 3: Create a Method for Collecting Field Information
The information necessary to complete the inventory can be logged during routine water system operations. In fact, systems are required to collect information during normal operations, which includes the following scenarios:
- Normal repair and replacement actions on mains, service lines, and meters
- Backflow inspections
- Meter reads
- Customer call outs
- Sampling stops
- Valve box inspections
Step 4: Collect and Review Historical Records
The official, accurate documentation of service line materials is the primary goal of the USEPA with the LCRR inventory. Memory, hearsay, and guesses are not admissible for the inventory. Historical records are a great source of information that can help complete the inventory process. Examples of historical records include:
- Distribution maps and record drawings
- Historical construction and plumbing codes
- Maintenance records
- Historical documentation such as tap cards
- Capital improvements and master plans
- Meter installation records
- Standard operating procedures
- Operations and maintenance manuals
- Inspection records
- Permit files
Step 5: Determine the Construction Date of Service Lines
Since the USEPA’s original Lead and Copper Rule went into effect in 1991, it can generally be assumed buildings constructed after 1991 will not have lead pipes. Portions of the service area built before 1991 will need to be inventoried completely. GIS imagery from 1990 can be compared with modern imagery to identify the areas developed after the Lead and Copper ban was implemented. The construction dates do not have to be exact, but the year is pertinent. Some of the documentation that is helpful for determining when construction occurred include:
- Development records
- County records
- Tax records
Step 6: Collect Private Line Information
Now it is time to get your customers involved. AE2S recommends starting the public education piece of the LCRR inventory early on by educating customers about the parts of the water system, the importance of identifying lead pipes, and explaining the LCRR process. Customers should also receive a heads-up that they will be asked to help the water system identify lead pipes within their properties. If the water system provides enough information for people to understand why and how they are being asked to help, they should be more likely to test their pipes and submit the results.
AE2S developed a short online survey that walks customers through the process of a scratch test using a key or coin and a magnet. As the customer completes the simple test and answers questions within the survey, the test results are linked to the address of the property.
Step 7: Evaluate Gaps for Investigation
USEPA has said it will not accept “unknowns” on the inventory, so it will be important to determine what information is missing from the inventory. If the gaps in data are greater than is reasonably feasible to complete, AE2S recommends taking a targeted approach. Two considerations for targeting are:
- Likelihood: Disadvantaged areas and areas with children should be a high priority to complete lead service line testing.
- Environmental justice: Be cognizant of environmental justice requirements when considering which areas to prioritize.
If the water system is large, predictive modeling can help fill in the gaps in data.
Step 8: Validate and Investigate
The LCRR inventory process is almost complete. The final step before submitting the results to USEPA is to validate your data and investigate what you do not know.
There are several methods that can validate or investigate, and any or all of them may be utilized depending on the situation.
- Visual inspection during normal operations – least disruptive to customers.
- Water quality samples can only confirm lead, but not rule it out.
- Potholing requires a vac-truck.
- Excavation is the most disruptive option.
Although the LCRR deadline is now only one year away, do not panic. Instead, get the process started now. If you have questions about the LCRR or inventory process, contact Nate Weisenburger, AE2S Drinking Water Practice Leader.