The Lead Service Line (LSL) inventory procedure is part of Glendale Water & Power’s (GWP’s) overall Asset Management Program and is a necessary component in maintaining compliance with the United States Environmental Protection Agency (USEPA) Lead and Copper Rule (LCR) in an effort to minimize the presence of lead and copper in drinking water.

GWP water staff conducted LSL inspections throughout Glendale beginning April 2024 in order to meet the initial requirements of the recently adopted LCR revisions. In the course of these inspections, GWP staff were required to open water meter boxes on the parkway of residential and commercial properties and take pictures and inventory of the customer-side service lines connected to the water meter.

Several revisions, entitled “Short-Term Revisions to the Lead and Copper Rule,” were made to the original LCR in 2000, 2004, and 2007. Senate Bill 1398 (2016) and Senate Bill 427 (2017) required all Community Water Systems (CWS) to compile an inventory of utility-owned service lines and identify material by July 1, 2018. Any unknowns in the initial inventory were required to be identified or scheduled for replacement by July 1, 2020. In January 2021, the USEPA issued long term revisions to the federal lead and copper rule (Lead and Copper Rule Revisions, LCRR) with the intent of providing better protection for children in schools and childcare facilities as well as the residents in communities throughout the country. These revisions followed the events in Flint, Michigan, and added a greater emphasis on the removal and replacement of LSLs.

As part of the revisions, the creation of an LSL inventory by community water systems (CWS) was required that included identification of not only the utility-owned portion of the service line, but also the customer-owned portion. This initial inventory is to be submitted by October 16, 2024. Further revisions are expected via the Lead and Copper Rule Improvements (LCRI) in October 2024. Click here for more information.

GWP Responsibilities:

GWP currently has 33,860 services in its system and has confirmed there were no lead services on the utility side of the system in the 2020 report. After reviewing available records, GWP was able to determine the number of post-1985 (when the lead ban in California became effective) customer side services, which reduced the total number of unknown customer-side service lines to 31,127.

In order to meet the initial requirements of the LCRR, GWP opted to physically inspect 1,299 of the total number of material-unknown service lines. This number is sufficient to provide a statistically representative 95% confidence level and is an accepted approach to extrapolating the material make-up of the total number of service lines. The services to be inspected were randomly selected based on the year they were built, with a larger percentage representing properties built during World War II. 

GWP will continue conducting inspections of service lines not included in the initial inventory until 100% of the system has been physically inspected.

LSL Inspection Results:

GWP has completed the initial lead service line inventory required by U.S. EPA’s Lead and Copper Rule Revisions. The deadline for the initial inventories is October 16, 2024.

Through completing a historical records review and field investigations, GWP has determined it has no lead or galvanized requiring replacement service lines in its distribution system. This includes any privately-owned or customer-owned service lines.

GWP reviewed all applicable sources of information, including

• All construction and plumbing codes, permits, and existing records or other documentation which indicates the service line materials;

• All water system records, including distribution system maps and drawings, historical records on each service connection, meter installation records, historical capital improvement or master plans, and standard operating procedures;

• All inspections and records of the distribution system that indicate service line material, including inspections conducted during the course of normal operations (e.g., checking service line materials when reading water meters or performing maintenance activities); and

• All previous service line or meter replacements were conducted.

In addition to reviewing the above sources of information, GWP used an alternative method to develop the inventory that was approved by the State Water Resources Control Board Division of Drinking Water on a case-by-case basis.

GWP used the interpolation method. The interpolation method is used when the water utility can divide their service area into uniform groups, such as neighborhoods or tracts. Each uniform group shares multiple common characteristics, such as time period built, location, or contractor. The service line materials for each group are assumed to be similar. Water utilities physically verified a percentage of the homes in that group to interpolate or determine the service line material for the remaining homes.

GWP created interpolation groups based on the time period in which each property with an unknown service line was built and verified around 5% per group. All service lines inspected were verified non-lead. The majority of inspected service lines were copper, around 7% were galvanized (not requiring replacement), and around 4% were plastic. No lead or galvanized requiring replacement service lines were identified. Properties built after 1985 were excluded from the interpolation groups because the use of lead solder and pipes was banned in California as of 1986. Properties with service lines 4” in diameter and larger were also excluded because lead was not used in larger sized pipes and fittings.

GWP continues to document service line material information obtained from normal operations, such as service line maintenance or water meter readings, after October 2024 and will update the initial inventory accordingly. 

Questions?

For any questions related to the LSL inventory please email GWPWaterQuality@GlendaleCA.gov or contact Micheal Earl, Water Quality Specialist at 818-548-2011. Once the inventory is submitted to the USEPA the results will be posted on this site.