LCRR Lead and Copper Rule Revision Part 2
DURATION 5 min read
The Lead and Copper Rule Revisions (or LCRR) went into effect December 16, 2021 with a compliance date of October 16, 2024. With this date fast approaching, it is important for all public water systems (PWS’s) to initiate the development of a comprehensive lead service line inventory. Previously, we discussed the background, definitions, and details of what a comprehensive lead service line inventory entails. https://quiddity.com/lcrr-lead-and-copper-rule-revision/ Now, we dive into how to begin the process for what may seem like an overwhelming task and hopefully provide some insight into ways to streamline the process.
Where to begin?
First step includes gathering and compiling all available documents to create the inventory with a focus on age of construction, material type, and location. Identify any “holes” or missing documentation which may exist. Additional time and effort may be required to research areas where little or no documentation is available; therefore, it is highly recommended to start this process sooner than later. To complete the inventory, the source(s) used to categorize PWS’s service lines must be documented and referenced. Ensuring reliable data is available to support the inventory submission is critical. Some examples of acceptable documents and sources include:
- Construction plans such as record drawings, final construction plan sets, preliminary plans, and specifications.
- Geographic Information System (or GIS) database information.
- Historical aerial imagery.
- Property data from local appraisal district(s) including timeline of building construction.
- Operator records such as water meter customer records, work orders, field operations documents (taps/repair records) and Customer Service Inspections (CSIs) reports.
- Field information from meter replacement or public waterline replacement programs.
The TCEQ template requires the preparer to formally certify the accuracy of the information used to prepare the inventory submission. It should also be noted that the inventory is a living document in which updates are required as changes are made. The inventory must also be made publicly accessible. (If a PWS serves a population of 50,000 or more, the inventory must be provided online.) The lead service line inventory is not a “one and done” process. Considering the importance of transparency and the availability of the information used to prepare the inventory, proper documentation of the sources used to validate and support the inventory classifications should be maintained. If possible, and depending on the size of the PWS, the creation and use of GIS may be appropriate and beneficial.
Now, what to do with all this information?
The TCEQ has provided the following additional guidance to assist in classifying service lines:
- Service lines installed after 1988 can be categorized as Non-Lead.
- Schools and childcare facilities (including in-home childcare) have more stringent requirements for classifying service lines. Service lines installed after 2014 can be categorized as Non-Lead.
Based on the 1988 and 2014 dates referenced above, a PWS can sort its services lines based on these time periods. All services lines can be assigned the non-lead classification where documentation confirms construction occurred after these cutoff dates. A great resource which can be used to establish these construction dates are the local appraisal districts. Most appraisal districts’ databases include a “built-on date” for most structures. By utilizing the post-1988 and post-2014 (for schools and childcare facilities) construction dates, the PWS can make a significant dent in classifying its service lines and reducing the number of unknowns in the PWS’s inventory.
Next, review all documentation available for the PWS’s service lines which were constructed prior to the cutoff dates referenced above. Start with reviewing all historical record drawing and specifications, including notes and field inspection photographs or reports, which may reference the service line material type. Talk with the PWS’s Operator to gather and establish what information has been obtained as part of on-going service line or meter replacement programs. Any documentation from general work orders or customer service inspections, which include a reference to the service line material type, can be used to classify the service line.
Starting now will provide the PWS with adequate time to identify any limitations in available historical documentation and minimize the number of “Unknowns” which may require additional effort. Further information will be provided in a follow-up article on what to do when you have limited historical documents and there is a number of “Unknowns” or “Galvanized Requiring Replacement”. If you have questions or are seeking further guidance, please reach out to our Water District Service Team members, Pam Madrigal, PE at Pmadrigal@quiddity.com, Chad Walker, PE at Cwalker@quiddity.com, or Wesley Lay, PE at Wlay@quiddity.com.