The Lead and Copper Rule Revisions (or LCRR) went into effect on December 16, 2021, with a compliance date of October 16, 2024. With this date fast approaching, it is vital that all public water systems (PWSs) initiate the development of a comprehensive lead service line inventory. Previously, we discussed details of what a comprehensive lead service line inventory entails (LCRR Lead and Copper Rule Revisions Part 1 – Quiddity) and the first steps for completing a lead service line inventory (LCRR Lead and Copper Rule Revisions Part 2 – Quiddity). Now, our focus is pipe material designation and field investigations.

Pipe Material Classification

After compiling the information needed to begin inventory and determining the construction date for each service line, the pipe material classification for both service lines should be completed. Field investigations will be required for any service line with a pipe material that cannot be verified by existing records. These investigations allow the PWS to confirm the pipe material of each water service line for commercial and multi-family customers constructed prior to 1989 for which records do not exist. Service lines for schools and daycares constructed prior to 2014 with an “Unknown” classification must also be field verified.

Field Investigation and Verification

For service lines serving single-family residential developments, the public water system (“PWS”) may want to consider developing a field investigation strategy to minimize the number of field investigations. Since each single-family residential section was likely constructed by the same builder and service lines within a section are often the same pipe materials, field verification of every single-family residential service line may not be necessary. If the PWS prefers to visually inspect each service line or field investigations to determine if multiple pipe materials were used to construct service lines, field verification may be necessary.

TCEQ recently provided guidance for completing service line field verifications. PWSs could focus the field investigation efforts to the inside of each water meter box. If the service line material on either the public or private side of the water meter cannot be determined by visual inspection, potholing on either side of the water meter box may be necessary. Any required potholing should be limited to the public rights-of-way or easements unless explicit permission is given by the property owner.

Water service line pipe material can usually be determined simply from visual inspection. However, depending on the age of the service line, the pipe material could be lead, copper, galvanized steel, plastic, or another pipe material. In addition to a visual inspection, a magnet test, a scratch test, or a lead test kit may be necessary to determine the material. For example, helping differentiate a galvanized steel pipe from a lead pipe.

Once field investigations are completed, results and any other pertinent information obtained should be compiled for each investigation and transferred to a service line database or directly into TCEQ’s lead service line inventory table. This table has both required and optional information to be submitted to TCEQ about each service line. Each PWS should decide what information it plans to provide prior to submittal. Results from field investigations may also be transferred directly to the PWS’s Geographic Information System (GIS), if applicable.

What’s Next?

Upcoming in the LCRR Lead and Copper Rule Revision Part 4 article, you can expect guidance on summarizing field investigation results, completing the TCEQ lead service line inventory table, transferring data to a GIS, and preparing publicly available documentation for a PWS. If you have any questions about the LCRR or require additional guidance, please feel free to reach out to our Water District Service Team members: Pam Madrigal, PE (Pmadrigal@quiddity.com), Wesley Lay, PE (Wlay@quiddity.com), or Chad Walker, PE (Cwalker@quiddity.com).