5 Steps to Build Your LCRR-Required Service Line Inventory

Insight
5 Steps to Build Your LCRR-Required Service Line Inventory
Mark Zito Sandy Kutzing
Regardless of your system’s lead levels, under the EPA’s new Lead and Copper Rule Revisions (LCRR), all systems will be required to compile an inventory of service line materials. The time is now to identify all lead service lines (LSLs) and non-LSLs in your water distri­b­u­tion system—on both the utility and customer sides. 

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: 

LCR Inventory Screenshot of service line inventory in GIS-based database

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:

Digitally

  • Data mining
  • Predictive modeling/machine learning
  • Random sampling of unknowns to confirm assumptions

Interior

  • 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

Exterior

  • 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. 

Read more about Newark's successful LSL replacement program designed and implemented by CDM Smith.

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. 

 
Mark Zito Mark Zito
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.

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https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule
As of June 16, 2021, the EPA has extended the effective date of the Lead and Copper Rule Revisions to December 16, 2021 and the compliance date to October 16, 2024.
Read EPA's Release Opens in new window.
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Need help compiling your inventory data? 
Contact us today for guidance developing a plan to initiate and complete your inventory. 

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