The Benefit of Historical Records for a Lead Service Line Inventory

The Revised Lead and Copper Rule Revisions (LCRR) that went into effect on December 16, 2021, aims to better protect children and communities from the risks of lead exposure by removing lead from our nation’s drinking water systems and empowering communities with information through increased public outreach. One of the first areas of compliance is quickly approaching. As of October 16, 2024, an initial lead service line inventory is required.

The lead service line inventory aims to document all materials throughout the entire service line, from the water main to the building inlet, regardless of ownership. This can present challenges for systems in which ownership is split between the water system and the customer at the water meter. There are several potential data sources that can be used to identify service line material and historical records can reduce or eliminate the need to mobilize a team for field verification.

This article will discuss how proper organization and a thorough review of available water service connection records at the beginning of the inventory process can save time, money, and stress.

Innovative Inventory Research

Water permits, service requests, connection permits; the term applied to a request for water service has differed over time and geography, but the records associated with these service requests can be a wealth of knowledge to municipalities and water utilities. The documents have taken many forms over the years but generally provide basic information like the applicant, property location, date, pipe diameters, installer and most importantly our current focus, pipe material. This attribute makes these records particularly beneficial because it can mean the difference between a “non-lead” determination and an “unknown” on your lead service line inventory that will require further field investigation. These records can also be beneficial when galvanized lines are present within the system. To avoid a “galvanized in need of replacement” status the entity must be able to prove that the galvanized material was never downstream of a lead pipe. Water service connection records can provide that confirmation.

While water service connection records can save time and money by eliminating or reducing the need for field investigations, the records review itself can be time-consuming. It is important to consider the use of other data sources that contain information that can help screen out properties. The Safe Drinking Water Act incorporated a ban on the use of lead pipe that went into effect on June 19, 1986, but allowed states two years to incorporate the ban into State law and regulations. It is important to note the actual date of the state implementation of the lead ban as this can be used as an initial screening tool for portions of the system. State and local building and development codes have been published at intervals and contain prohibitions of or requirements for the use of specific pipe material during property development. Many municipalities and systems enacted lead bans much earlier than 1986 so a review of local codes and regulations can dramatically reduce the number of water service connection records that must be reviewed. This can be done by cross-referencing the dates of adoption of laws, codes and regulations regarding lead bans with the construction dates available in development plans and online property records. The result is a more focused review of only those water service connection records that can provide more detail about the pipe material on properties that would otherwise require field verification.

Records Vary by Time Period and Location

Water service connection records, like all historical records, vary widely based on time period and local preferences. The format, information requested and level of detail in the applicant’s response can make some records useful while others provide little to no information. Collection completeness and organization can have a significant impact on the level of effort required to efficiently review the records. Water service connection records were historically handwritten and can be difficult to decipher. Organizing them by time period can help the reviewer(s) recognize patterns in handwriting from the various applicants. If possible, organization by street and/or geographic location can assist in the identification of patterns in service line material and construction details for portions of the system.

Another key consideration is the replacement of pipe material in and around the property over the years. Property transactions and repairs necessitate the completion and submission of new records so many properties may have multiple records available. Each record should be scrutinized as it can indicate a change in pipe material for all or a portion of the service line. In this case, even those properties originally associated with a lead service line can be listed as non-lead on the final inventory if a review of the historical records indicates that the line has been replaced with a lead-free option.

Accuracy is Important

It is important to remember that a property’s address may have changed over time. Street name and address numbering changes are not uncommon and should be noted to ensure that the records being reviewed are indeed associated with the historical location rather than a more recent change in the property description. Hand-drawn maps should be heavily scrutinized and cross-referenced with current and historical maps whenever possible as they often contain incorrect compass directions and/or conflicting street name or location information.

In addition to gathering the information required for the lead service line inventory, the records can also be a wealth of knowledge for other aspects of your asset management system as older records can contain surprisingly detailed information. For example, diameter and material information related to the water main the service was tied to. Whether you are starting from scratch or already have a robust asset management system, reviewing water service connection records can have many benefits.

GBA’s Municipal Services and Water Environment Groups bring a team of experienced utility management and engineering professionals together to provide your utility with the services needed to achieve Revised Lead and Copper Rule Compliance. For additional details, click here.

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