Utilities will be required to complete a comprehensive service material inventory and make it publicly available by the LCRR compliance deadline October 16, 2024. Any unknown service line will be considered lead until identified otherwise and annual notification will need to be provided to residents with lead or unknown service lines about the dangers of lead in drinking water. Additionally, not having updated records could potentially limit access to federal and state funding for LSL replacement programs —including the proposed $45B in infrastructure funding from President Biden’s American Jobs Plan proposal.
If your system does not have any LSLs, please scroll to the last paragraph for guidance on preparing a written statement.
Below are five steps to building and managing your inventory:
Step 1: Gathering all the records
The first step to compiling an inventory is to collect all the records—both digital and paper to add to a single database. The inventory should include both utility and privately owned sides of the service line as required by the LCRR. Common sources for data include:
- GIS database
- CMMS database work orders
- Paper records and property data
- Assessors database
- Meter replacement programs
- Tap cards and tie cards
- Construction and plumbing codes, permits, and existing records for customer side
- Water main replacement programs
Since data is coming from a series of sources, methods like document scanning and advanced object character recognition can be employed to streamline compilation and extract key information like installation date and service line materials from records.
Step 2: Combining and digitizing records
Once you have all your digital files and scanned paper records compiled or as you are compiling them—the next step is to figure out where to host them. For systems serving over 50,000 customers—these records will need to be digitally available to the public. Systems serving under 50,000 customers will need to have these records publicly available on request but are not required to host them digitally. Having inventories readily available online promotes good customer relations and transparency.
Using a GIS-based platform like ESRI or CDM Smith’s web program management tools like this one from Newark’s program will not only help make the data publicly available, but also help communicate more effectively with customers by providing site-specific information. In the database we recommend including, at minimum, fields for customer account, address, diameter, utility side installation date, utility side material, private side installation date or building construction date, private side material (interior and exterior underground which can be different), goosenecks, utility and private side material source, and replacement information such as contractor, date and new materials. A web-based database will also allow you to set up internal dashboards to track inventory progress and other program efforts like replacement goals, sampling progress, and communication notification efforts.
Step 3: Verifying unknown service line materials
Having too many unknowns in your inventory can make it difficult to prioritize next steps, can impede your system’s ability to receive funding, and can cause you to send unnecessary notifications about lead in drinking water to customers. Before the compliance date of the LCRR, it is critical for water systems to classify as many unknown service lines as possible, both on the utility-owned side and on the privately-owned side. Visit this article for guidance on what counts as a lead service line or unknown.
To better classify unknowns, verification best practices include:
- Data mining
- Predictive modeling/machine learning
- Random sampling of unknowns to confirm assumptions
- Door to door inspections by field staff
- Homeowner surveys and photos
- Meter inspections
- Inspections during compliance sampling
- Contractor inspections
- Scratch and magnet tests
- Water quality sampling
- New tools in development such as CCTV inspection or electrical resistance testing
- Test pits/potholing
- During water main replacement events
- New tools in development such as using sound waves or magnetic fields
Assumptions for unknowns can be made based on information known about the system and information collected through this process. Assumptions can be made based on installation dates, home construction dates and service line size if that information is available. The 1986 EPA Lead Ban can be used as a cutoff date or a date sooner if it is known when the utility stopped using lead and lead goosenecks for service lines. Developers, plumbers and local ordinances would need to be consulted to determine when lead was no longer in use on the private side of the line.
Machine learning can provide a more sophisticated analysis of which areas are likely to be similar in construction. In addition to directly predicting material type, machine learning can be used to predict which houses will provide the most additional certainty to the data if their actual service line material is verified. This analysis can also be used to help to group the unknown materials into unknown lead and unknown not lead and remove non-LSLs from the count.
Step 4: Planning for replacement
The LCRR requires having an LSL Replacement Plan by October 16, 2024 with strategies for determining "lead status unknown" service lines, replacement prioritization strategies, and replacement goal rates among other things. Based on assumptions above, unknowns can be categorized into three groups for verification: high lead probability, medium lead probability, and low lead probability. These categories can help prioritize replacements to send contractors to areas with the greatest probability of lead, reduce uncertainty and save program costs.
Coordinating and funding private side replacements is one of the most difficult aspects of Lead Service Line Replacement plans. Only full LSL replacements—both customer-owned and utility-owned portions—count toward the replacement target. It is important to identify the materials on the customer-owned side to help with communication, prioritizing replacements and determine funding needs.
Step 5: Managing and updating the inventory
If there are LSLs in your system, the service material inventory will need to be updated annually. Since the inventory doesn’t stop at the 2024 compliance date and will be used to build LSL replacement plans, maintaining the inventory is a continuous process. With machine learning and other software, the process of updating the inventory with new information and distribution system changes can be automated to increase accuracy and efficiency.
Having an updated inventory keeps both the public and utility informed on where LSLs are located and promote replacement. The updated inventory will also help to reduce the number of unknowns being counted as LSLs and reduce the number of annual notifications a utilities needs to send to customers with unknown service lines.
What if your system does not have lead service lines?
If your water system does not have any LSLs, you will still need to demonstrate the absence of LSLs. This requires compiling proof with an inventory of non-lead materials or a written statement of verification from your plumbing department.
Based on the requirements of 40 CFR 141.84 (a)(3), (5) and (6), a utility will need to review available information and documentation for a system and compare with the state’s requirements related to certification for not having LSLs.
Compiling and organizing data is a tedious process, but in the long run, it saves more money, time, and resources than physically verifying unknown service lines.