RLCR: Lead Service Line (LSL): Inventory and Replacement Plan

Posted by Tori Morgan on Friday, December 3, 2021

Once you understand what the Revised Lead and Copper Rule (RLCR) means for your specific water system, the next important step is to create a service line inventory, identifying Lead Service Lines (LSLs). After that, a LSL replacement plan will be needed if you’ve identified any LSLs, unknown areas, etc.

Let’s start by answering two basic questions about the inventory:

What formats are acceptable for the LSL inventory?

The inventory may be a list, table, or map with location identifiers. Keep in mind, once the inventory is finished, it will need to be made publicly available, and will need to be updated periodically.

What Needs to be included in the LSL inventory?

All service lines in the system need to be included in the inventory, including utility and customer-owned portions. Information needed for the Inventory includes materials used up to the meter in the house. Any lead solder in the interior home plumbing is not part of the inventory. Additionally, each line must:

  • Have a unique identifier
  • Specify materials (ie: lead, galvanized requiring replacement, non-lead, lead status unknown, etc.)
    • Galvanized pipe will require replacement if has ever been downstream of a LSL.

Creating your Inventory:

Start with the Information You Already Have Available:

Gather up your water system records (distribution maps, drawings, installation, and maintenance records), plumbing codes or permits, and tax records.

Review information from any past water meter replacement programs; review pre/post photos or documents if available to help determine the material used; review customer information sheets; check applicable contractor records for any lead lines noted during the replacement process; this information will be a great start to know where the focus needs to be on the inventory and possible lead service lines.

Review any historical water line service records to help narrow the search for lead line services; often these documents will contain the information necessary to rule out lead components, greatly reducing the scope and effort needed to complete your inventory.

Identify Unknowns and Target Areas:

  • Focus on homes built in the 1940's and prior as these homes are most likely to have “high potential” lead components
  • The Utility is not responsible for the costs associated with the private line replacement due to lead; however, many utilities are seeking grants/funding which covers both the private and public portion and need to determine best measures to ensure private line replacement is conducted as needed
  • Narrow down the list of service lines with unknown components/materials; once that is done you could consider a customer survey to gather additional information; however, the information received may still pose more questions than answers, so you may still need to evaluate through on-site checks
  • If needed and feasible use a camera or a "soft-dig" to determine material on either side of the curb stop

Creating a Replacement Plan:

All systems with any Lead Service Lines (LSLs), galvanized requiring replacement, or lead status unknown service lines must develop a full Lead Service Line Replacement (LSLR) plan that includes:

  • Strategy for determining the composition of lead status unknown service lines in its inventory
  • Procedure to conduct full LSLRs
  • Strategy for notifying customers prior to full or partial LSLRs
  • Recommended LSLR goal rate in event of trigger level exceedance (small systems are exempt) approved by the State
  • Procedures for customers to flush service line and premise plumbing
  • LSLR prioritization strategy
  • Funding strategy considering ways to accommodate customers that are unable to pay to replace the portion they own
  • Submit to the State by the proposed compliance date, which is currently October 16, 2024.

The RLCR is multi-faceted regulatory update, which will impact every water system differently. See our additional RLCR blogs.

I am happy to discuss your system and help you answer any questions you may have! Feel free to contact me via the links below!

Tori Morgan, LO Photo

Tori Morgan, LO

compliance coordinator

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Categories: Municipal Infrastructure

Tagged: Revised Lead & Copper Rule (RLCR)

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