City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Utilities
Meeting Date: November 4, 2024
Report #:2409-3507
TITLE
Informational Update: Completion of the Drinking Water Lead Service Line Inventory
RECOMMENDATION
No action, this is an informational update from the Utilities Department.
EXECUTIVE SUMMARY
This informational update to City Council summarizes the City’s ongoing efforts to comply with the Federal Lead and Copper Rule Revisions (LCRR) promulgated by the United States Environmental Protection Agency (USEPA) in 2021. The LCRR required the City to verify, before the deadline of October 16, 2024, that no public or private lead service lines (LSLs) exist in the City’s water system. Palo Alto completed the physical inventory inspection of the service lines and submitted the data from the service line inventory on the October 16, 2024, deadline. Staff did not find any lead service lines or galvanized service lines requiring replacement as part of the LSL inventory.
BACKGROUND
Staff provided an informational update to City Council on February 12, 20241. This staff report provides additional information regarding water service lines and presents the results of the City’s Lead Service Line (LSL) inventory investigation.
Water Service Lines and Lead Service Line Definition
The water pipe connecting the water main to the interior plumbing in a building is referred to as a water service line. The water service line may be owned wholly by the water system or customer, but typically the City owns the water service line between the main and the water meter and the portion between the meter and the building belongs to the property owner. The portion of the water service line referred to as a gooseneck, pigtail, or connector consists of a 1 City Council, February 12, 2024 Agenda Item 14, SR# 2312-2320 https://portal.laserfiche.com/Portal/DocView.aspx?id=70362&repo=r-704298fc&
short section of piping, typically not exceeding two feet, which can be bent and used for connections between rigid service piping. For purposes of the Lead and Copper Rule Revision (LCRR), lead goosenecks, pigtails, and connectors are not considered to be part of the LSL but are required to be replaced any time one is encountered during planned or unplanned water system infrastructure work pursuant to Title 40 Code of Federal Regulations (CFR) Part 141.84(c).
Federal Lead and Copper Rule and Revisions
In 1991, the United States Environmental Protection Agency (USEPA) published final regulatory revisions to the National Primary Drinking Water Regulations (NPDWR) for lead and copper under the authority of the Safe Drinking Water Act (SDWA). This regulation is known as the Lead and Copper Rule (40 CFR Part 141). Since 1991, the LCR has undergone various revisions.
In 2007, EPA revised the LCR to enhance implementation in the areas of monitoring, treatment, customer awareness, lead service line replacement, and enhanced public education requirements.
In January 2021, the USEPA published the Lead and Copper Rule Revisions to the National Primary Drinking Water Regulations and Implementation (40 CFR Parts 141 and 142). The LCRR improved the reliability of lead tap sampling results, strengthened corrosion control treatment requirements, expanded consumer awareness, and improved risk communication. Pursuant to the LCRR, all water systems must develop and submit, by October 16, 2024, an initial service line inventory of the entire system, including both the publicly and privately owned portions of the water service line up to the building penetration2. USEPA guidance recommends the lead service line inventory include the following3:
•Material Classification: Classify each service line or portion of the service line where ownership is split as lead, galvanized requiring replacement, non-lead, or lead status unknown.
•All service lines regardless of ownership status: Prepare an inventory that includes the system- and customer-owned portions of all service lines in the system’s distribution system.
•Information to identify material: Use previous materials evaluation, construction and plumbing codes/records, water system records, distribution system inspections and records, information obtained through normal operations, and state-specified information.
Because galvanized iron service lines that are or ever were downstream from an LSL can absorb lead and contribute to lead in drinking water, water services made from galvanized iron must 2 The original deadline established in the LCRR was January 16, 2024 (86 FR 4198) but was extended to October 16, 2024, in 86 FR 31939. The delay in the effective date is consistent with presidential directives issued on January 20, 2021, to the heads of federal agencies to review certain regulations, including the LCRR. 3 USEPA, 2022. Guidance for Developing and Maintaining a Service Line Inventory. United States Environmental Protection Agency. Office of Water (4606M). EPA 816-B-22-001. August 2022. be classified as a galvanized requiring replacement if the galvanized service is or ever was at any time downstream of an LSL or is currently downstream of a lead status unknown service line. If the water system is unable to demonstrate that the galvanized service line was never downstream of an LSL, it must presume there was an upstream LSL.
The current service line inventory results are required to be made available to the public and posted on the City’s website. If the City identifies any private LSLs, it must inform the resident within 30 days of completing the inventory and annually thereafter. Palo Alto previously inventoried all City-owned water piping (i.e., the water mains and service lines up to the water meter). Palo Alto does not have any known City-owned lead service lines in its system, but inventory of the private service lines had not been performed previously.
ANALYSIS
To meet the requirements of the LCRR, the Utilities Department reallocated personnel and retained additional temporary staffing to perform the physical inspection of 20,908 individual private services within the timeline set forth in the LCRR. Whenever possible, physical inspections were performed at two locations on each water service line – one near the meter and the other near the structure penetration. As of September 23, 2024, the City has completed inventorying all water service lines. No public or private lead service lines or galvanized requiring replacement service lines were identified as part of the lead service line inventory.
Working collaboratively with the City’s Information Technology department, the Utilities Department also developed and deployed a mobile data collection and visualization solution to allow the information collected during the LSL inventory to be available to the public through a public-facing map4. The map was updated on a weekly basis throughout the LSL inventory development process and is still available on the City’s website.
FISCAL/RESOURCE IMPACT
In order to meet the compliance deadline of October 2024, the Utilities Department had to reallocate staff performing maintenance work and hire additional temporary staffing to complete the sampling. No further expense for this portion of the LCRR compliance will be required.
STAKEHOLDER ENGAGEMENT
As part of the outreach for this project, the Utilities Department created an informational hand- out and sent a postcard to customers explaining that crews would be working at their meter 4 Public Map on City Website for Lead Service Line Inventory https://gis.cityofpaloalto.org/portal/apps/webappviewer/index.html?id=2ffc02f195564aee9f01e329d1bde4a6 box, it also provided a link to the City’s project web page, and let customers know that the City would notify them directly if any lead service lines were identified during the inventory.
ENVIRONMENTAL REVIEW
This informational update is not a project under the California Environmental Quality Act.
APPROVED BY:
Dean Batchelor Director of Utilities
Staff: Matt Zucca, Assistant Director, Utilities Water Gas Wastewater