Dear Aqua Answers,
What’s the difference between a materials evaluation and a lead service line inventory?
Sincerely,
Mat Plumber
Dear Mat,
A materials evaluation is a survey of all lead, copper, galvanized, and cast iron and steel piping, service lines, and interior plumbing within a water system’s distribution system. Community water systems were first required to develop a materials evaluation nearly 40 years ago. Many water systems used the original materials evaluation to help identify sample pool sites when the 1991 Lead and Copper Rule was promulgated. However, over the years, these evaluations were mostly left to languish and were not maintained or at worst lost as water system personnel came and went. In 2016, the department requested the materials evaluations from systems to evaluate the appropriateness of their current lead and copper sample sites in terms of identifying lead service lines, lead pipes, and copper pipes with lead solder. The department worked with systems over several years to update their materials evaluations, which has yielded vast improvements in proper lead and copper sample site selection based on the current tiering levels of the Lead and Copper Rule.
The Lead and Copper Rule Revisions promulgated in 2021 requires systems to have a lead service line inventory when the rule takes effect, currently slated for the end of 2024. Water systems are required to identify the individual locations of each lead service line, galvanized pipe that is or was downstream of lead service line, non-lead service lines, and unknown service lines for both the publicly and privately owned sides. While much of this information was required for a materials evaluation, the department will expect water systems to take a second look and evaluate if they have their service lines properly identified on both the publicly and privately owned side of service lines.
It’s important that systems work hard on this inventory to develop a high confidence in their categorization of the service line material by 2024. Unknown service lines are treated as possible lead service lines and special notices will be required to be sent to these customers annually if they remain unknown. Ideally, a system has records of installed service line material or physically verifies the materials through pot-holing. Having records or physical verification of all service line materials is very unlikely for many water systems, however. When the rule becomes effective, the department will expect water systems to use a combination of installation and maintenance records, plumbing codes or permits, interviews with experienced system staff and homeowners, and selectively used physical verification when service line materials are unknown. This will allow water systems to make high confidence determinations on the material type to a swath of homes based on installation dates. The lead service line inventory must be updated at least annually as service line materials change and must be made available to the public with systems serving greater than 50,000 required to make them available online, such as a GIS map, unless there are no lead service lines, galvanized pipe downstream of previous lead service lines, or unknown service lines.
Now is the time for water systems to be proactive about their lead service line inventory. Systems should use this time to organize any available paper records and to implement service line identification procedures as part of routine distribution maintenance and repairs and meter reading and to document the findings with location identifying information. Please visit the department’s Lead and Copper Rule general website or Lead and Copper Rule FAQ for more information.
Happy hunting,
Aqua Answers
