3 Things to Consider When Creating a Lead Service Line Inventory

By Brendan O’Brien, Bill Marriott & Nick Bouthilette

Across the United States, public water systems are facing a big question: is there lead in our water lines? This is a concern especially in older cities where most of the water infrastructure pre-dates the federal lead pipe ban implemented in 1986.

Under the U.S. EPA’s Lead and Copper Rule Revisions (LCRR), public water systems have until October 16, 2024, to complete an initial inventory of all residential, commercial and industrial connections (2-in. diameter and smaller) within their service area. In addition, under the EPA’s recently proposed Lead and Copper Rule Improvements (LCRI), all lead service lines will need to be replaced within 10 years (or sooner) of the LCRI promulgation date, depending on the state.

With these requirements and verifications looming, there’s a sense of urgency to initiate or expedite the completion of service line inventories. As many of those working on this can already attest, this can be a daunting process, with significant financial and logistical considerations.

Stantec has worked with many public water systems to develop service line inventories and have leveraged our experience working with old water records, in-the-field service identification methods and innovative technologies. We have helped these same organizations adjust to the dynamic nature of the tasks and regulatory changes.

For those water systems that may just be starting their service line inventories, here are three things to consider when creating a service line inventory.

1. Plan Your Funding

The question of how to pay for service line inventories no doubt weighs heavily on those that deliver water. These inventories are costly but necessary to remain compliant with EPA regulations.

The key to success: Financial and capital planning combined with an efficient approach to prioritize the lowest cost per service line identification method (when possible). Without a good plan in place, identifying funding for service line inventory development will be challenging and many dollars can be wasted tracking down or digitizing information that is not useful.

Under the Bipartisan Infrastructure Law (BIL), the Federal government has allocated a total of $26.7 billion: $15 billion in dedicated funding through Drinking Water State Revolving Fund (DWSRF) programs, and $11.7 billion in DWSRF base appropriations that can be used for lead service line replacements. These are intended to help public water systems across the country provide the services necessary to comply with the LCRR – including service line inventory development. These funds are expected to be available through each state’s primacy agency, and the application process and financial terms vary. It is important that system managers engage with local regulators to better understand the terms and timelines of funding availability as this will increase their chances of success.

Some states have used their BIL funds to implement technical assistance programs to support the effort. For example, the West Virginia Department of Environmental Protection and Minnesota Department of Health have established statewide programs to assist public water systems with their inventories. These are a great aid to small, rural water providers with limited resources to complete this work. In Massachusetts, we have assisted public water systems of all sizes in applying for, securing, and delivering over $1 million in service line inventory work through a Massachusetts Department of Environmental Protection (MassDEP) grant program administered by the Massachusetts Clean Water Trust.

Funding research, regulatory engagement and action on a financial planning level are all key in taking the first steps to developing a service line inventory. Without a thoughtful financial plan upfront and communication lines open among regulators, funding agencies and constituents, the cost of an LCRR compliance program can increase significantly.

2. Do You Have System Records?

Another major component of developing a comprehensive inventory is to determine what kind of records are available related to water services and the infrastructure they supply. Many public water systems have no records available, and that’s okay. Others have complete records or a large volume of records in different formats and various stages of organization and digitization. It’s important to understand each case to establish real costs and expectations for the next steps in building the service line inventory.

The burden of reviewing records may prove to be too much for those with limited staff. While consultants can help, it’s important to review records in advance of initiating a contract, if possible. If a public water system is proactive with their records, they will be in a better position to begin their service line inventory. Even if comprehensive records are not available, every relevant input reduces the need for more costly methods of service line material identification.

The goal of the records review, i.e. data discovery, is to begin the working inventory and establish a baseline that will guide subsequent activities. These may include targeted field verifications and predictive modeling, if allowed by the state’s regulators. This efficient approach can significantly reduce the cost per service line material identification.

Transparency is paramount so that the goals of the LCRR can be accomplished through a joint effort between a public water system and its customers.

3. Inform the Public

It is imperative that public water system customers are informed and engaged relative to the goals of the LCRR. This includes informing the public of the hazards of elevated lead in drinking water, explaining why these inventories are now required, letting customers know how they can help, and where they can go to receive further assistance.

Residents are key stakeholders and benefit from knowing if lead may be present in their service line. Public support for these projects, as most utilities and water systems know, is vital. Additionally, verification, testing or exploration for service lines may occur at or near someone’s home or school. They should be aware of the “what, when, and how” of this process ahead of any potential disruption. Transparency is paramount so that the goals of the LCRR can be accomplished through a joint effort between a public water system and its customers.

Public outreach can include a variety of materials, from door hangers on homes and businesses to an informational card or social media campaign. It can also be useful to engage with local media to help inform the public about service line inventories, the danger of lead and how it might affect them or their loved ones.

Customer outreach and crowdsourcing initiatives typically resonate well. One such example is the Town of Maynard, Massachusetts, where customers have been asked to assist with preparation of their service line inventory. A mailing from the town was sent to all water customers with information from MassDEP including instructions on self-identifying their service lines. This has helped build trust and transparency with residents while empowering them to learn more about the program and providing critical, inexpensive feedback that has helped populate the service line inventory.

What’s Next?

If they haven’t started already, public water systems across the U.S. should be aggressively developing their initial service inventory by mid-October of 2024 to remain in compliance with the EPA. A significant effort to plan for and replace service lines and resolve inventory unknowns is likely to follow.

With strategic planning, each public water system will be in the best position to limit the potential resource and financial burden — and will have the customer support to boot.

Brendan O’Brien, P.E., is a project manager for water for Stantec. He has 10 years of engineering experience in water, wastewater, and stormwater distribution and conveyance system design and construction. He leads Stantec’s Lead and Copper Rule Revisions (LCRR) Growth Initiative team and manages several LCRR inventory projects.

Bill Marriott, P.E., is a senior project manager for Stantec. He has more than 27 years of engineering experience in the study and design of water and wastewater treatment systems, pump stations and pipelines. He has extensive experience in treatment process alternatives and alternative project delivery methods.

Nick Bouthilette is a senior associate and civil engineer for water with Stantec. He represents the New England territory and beyond with more than 19 years’ experience in drinking water conveyance. He provides oversight and technical support on a range of projects from LCRR-related compliance to large scale water distribution programs.

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