Tick tick tick – LCR inventory date is fast approaching

There’s still time to comply with the EPA’s new Lead & Copper Rule inventory requirement – but the clock is ticking and it’s getting louder every day. The EPA’s rule requires water systems to identify and make public the locations of lead, non-lead and unknown service lines through a lead service line inventory. The water system owner is responsible for collecting the information for every address they supply and entering the data on an inventory spreadsheet they must supply to their state regulatory agency. This inventory spreadsheet must be completed by Oct. 16, 2024. Here’s a step-by-step summary of how to create your lead service line inventory, courtesy of the Minnesota Department of Health:

Step 1: Gather your data.

You’ll need to determine the materials of the service line for both the publicly controlled and privately controlled portions of the service line, even if the line is completely privately owed. First, analyze what information you already have and identify what’s still unknown. After that, prioritize how you’ll reduce the number of unknowns. Information sources for that process may include:

  • Historical records, including distribution system maps and drawings (as-builts); building year and construction records CLIENT: PeopleService JOB NUMBER: DESCRIPTION: Lead and Copper blog DATE: May 31, 2024 with respect to the lead ban; tap/tie cards with connection year; and plumbing permits and permit amendments.
  • Customer-driven data, such as construction year and records, plans and drawings; previous service/repair reports; information from homeowner insurance; and a resident survey. PeopleService has created a survey that communities can send to their residents to help complete their initial inventory list.
  • Sampling, such as visual inspections; scratch and magnetic tests; and inspection of the pipe interior using a fiber-optic camera inserted inside the service line.

Step 2: Consolidate your data into an electronic database.

Public water systems should have the ability to make data accessible to the public and to the department of health in a consistent electronic format, such as a database or spreadsheet. The minimum fields required are:

  • Location identifier, such as address or GIS coordinates.
  • Material type of privately-owned side (lead, non-lead, galvanized in need of replacement, unknown).
  • Material type of publicly-owned side (lead, non-lead, galvanized in need of replacement, unknown).
  • Source of information used to determine material type (type of record, inspection, etc.).

Step 3: Prioritize and keep your inventory up to date.

Many systems will have unknowns in their initial inventory – which is fine. Once you know what you don’t know you can create a plan for determining the missing information.

  • At minimum, your inventory needs to be updated at the same frequency as your lead and copper sample schedule, at most on an annual basis. For systems on a three-year monitoring schedule, you may want to update the inventory annually or in real-time with projects and renovations to keep customers informed.
  • How to prioritize determining unknown services lines: based on factors including, but not limited to, the targeting of areas with known lead service lines, service lines that serve disadvantaged consumers and/or populations most sensitive to the effects of lead.

As always, check your state regulatory information for what is required and allowed. Below are links to online information for each state.

You also can contact our in-house expert, Jonathan McDonald (JMcDonald@peopleservice.com), with any general questions you might have about the Lead & Copper Rule inventory requirements. We’re always here to help.