2024 Service Line Inventory Program

To comply with the federal Environmental Protection Agency (EPA) Revised Lead and Copper Rule, public water systems are required to complete an inventory of both the public and private portions of water service lines. Detailed information regarding the Lead and Copper Rule Revisions (LCRR) and service line inventory requirements can be found on the Washington State Department of Health Office of Drinking Water page here: https://doh.wa.gov/community-and-environment/drinking-water/contaminants/lead/lead-and-copper-rule-revisions and the EPA’s Ground and Drinking Water section here: https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule

Clallam PUD (CPUD) has elected to utilize an approved statistical approach to complete the required service line inventory. This approach requires CPUD personnel to physically verify the service line materials of at least 20% (based on the size of CPUD water systems) of the service lines that cannot be categorized via construction records, size or installation date. The 20% requiring physical verification must be randomly selected from the pool of uncategorized or unknown service lines identified within each water system. From May to through October of 2024, CPUD water personnel will be onsite to verify service line material of both the CPUD owned service lines between the water main and the water meter and customer owned service lines immediately downstream of the water meter at the randomly selected service locations. At some locations physical verification may be possible from within the water meter box. At other locations, verification may require a small excavation on either side of the water meter box.

FAQ:

Does CPUD have lead service lines in its water system?

CPUD does not have any records indicating that personnel have encountered lead service lines within CPUD operated water systems during water main replacements, service repairs or replacements or any other work in which service lines have been exposed. Additionally, CPUD has not identified any records that suggest that lead pipe was ever specified in any construction documents for CPUD constructed water systems. CPUD staff does not expect any lead service lines to be identified during the 2024 Service Line Inventory.

What happens if my service is randomly selected?

WA DOH guidance requires a minimum of one verification point for each side (utility-owned and customer-owned) of the service line. Depending on the age and type of water service construction, this may be possible to complete from within the water meter box and excavation will not need to take place. If this is the case, CPUD personnel will record the service line materials and to be added to the inventory. If excavation is needed, CPUD personnel will mark the area around the water meter box in white paint and call 811 for a locate ticket at least two business days prior to starting work. CPUD personnel may leave a doorhanger at your residence if your water meter is located in an area where water personnel might want you to have advance notice of the excavation.

When were lead service lines banned?

Lead Pipe Background in Washington*
*from DOH Lead Service Line Inventory Guidance 331-711

In 1986, Congress amended the Safe Drinking Water Act (SDWA) to prohibit the use of pipes, solder or flux that are not “lead free” in public water systems or plumbing in facilities providing water for human consumption. At the time, lead free was defined as solder and flux with no more than 0.2 percent lead and pipes with no more than 8.0 percent lead. In 1996, congress further amended the SDWA to prohibit the use of pipe and plumbing fittings and fixtures that are not lead free in the installation and repair of any public water system or plumbing in a facility providing water for human consumption. The 1996 amendments also required lead-free plumbing fittings and fixtures (endpoint devices) to comply with a lead leaching standard. Service lines for homes constructed after 1986 in Washington should be made of materials other than lead. Water systems developing their lead service line inventories may designate homes built after 1986 as not having a lead service line. There may be a local ordinance or code that provides an earlier date that you may use to classify non-lead materials.

Can I see the results?

Water systems must make their service line inventories publicly accessible. CPUD will add Service Line Inventories to this page when they have been completed and submitted to DOH/EPA.

WA DOH guidance on the statistical approach:

https://doh.wa.gov/sites/default/files/2023-05/331-723.pdf