Town of Rich Creek LSL Scope of Services_12.11.23 (2).pdf

December 18, 2023 Lead Service Line Methodology

Town of Rich Creek

PROJECT UNDERSTANDING

The Town must develop an inventory that identifies the materials of all potable water service lines and submit it to the Virginia Department of Health (VDH) Office of Drinking Water (ODW) by October 16, 2024.

This inventory must be developed for every service line connected to the distribution system, regardless of ownership or current use status, and each service line must be identified by a specific address associated with the line.

The pipe materials classifications for this inventory are lead, galvanized requiring replacement (GRR), unknown, and non-lead. If any portion of a line is lead pipe or lead-lined galvanized pipe, it is considered a lead service line (LSL). If the only lead portion of the pipe is a lead gooseneck, pigtail, or connector, the service line is not considered a lead service line, although the EPA recommends that the Town track these components as well. Galvanized pipes must be analyzed to determined whether they are or ever were downstream of a lead service line and if so, are considered galvanized requiring replacement. If there are no records that can prove the galvanized line was never downstream of an LSL, it must also be considered GRR.

Galvanized pipes that were ever downstream from an LSL may have adsorbed lead and contributed to lead in the drinking water supply. Pipes can also be classified as non-lead if demonstrated through evidence-based record or a technique that determines the actual material (galvanized that was never downstream of a LSL, copper, or plastic). Finally, a pipe may be classified as unknown if there is no documented evidence that supports a material classification.

Pipe materials must be classified for both the Town owned and customer owned portions of each service line. Each portion will be classified as lead, galvanized requiring replacement (GRR), unknown, or non-lead.

Once each portion is classified individually, the overall service line can be classified according to a hierarchy of materials. If any portion of the line is lead, the entire service line must be classified as lead, which requires replacement. For example, if the Town owned portion of the service line is lead, but the customer owned portion is non-lead (plastic), the entire service line must be classified as lead. Table 1 shows this classification hierarchy that will be used to build the Town’s lead service line inventory.

Table 1 – Classification of Service Line Material Based on Town/Customer Ownership

Town-owned Portion Customer-Owned Portion Classification for Entire

Service Line Lead Lead Lead

Lead Galvanized requiring replacement

Lead

Lead Non-lead Lead

Lead Lead status unknown Lead

Non-lead Lead Lead

Non-lead and never previously lead

Non-lead, specifically galvanized pipe material

Non-lead

Non-lead Non-lead, material other than galvanized

Non-lead

Non-lead Lead status unknown Lead status unknown

Non-lead, but system unable to demonstrate it was not previously lead

Galvanized requiring replacement

Galvanized requiring replacement

Lead status unknown Lead Lead

Lead status unknown Galvanized requiring replacement

Galvanized requiring replacement

Lead status unknown Non-lead Lead status unknown

Lead status unknown Lead status unknown Lead status unknown

SCOPE OF SERVICES

Phase 1 – Kickoff

The selected consultant will host a kickoff meeting with the Town and VDH to familiarize Town staff with the lead service line inventory requirements and the project timeline and deliverables. The project team will identify and discuss the existing data sources and systems that will be accessed by the consultant for investigation in order to compile the preliminary lead service line inventory.

Phase 2 – Base Mapping and Data Preparation

The consultant team will work with the Town to develop a base mapping and database platform that will house all data that is collected. This platform will include GIS, ArcGIS, and a Fulcrum field data collection tool to create data points with address identifier for each service line in the Town. This platform will be the main data management tool throughout the duration of the project.

Phase 3 – Lead Service Line Identification

Throughout the course of the service line inventory development phase, the consultant team will be utilizing and recommending a variety of verification methods based on the characteristics the various services areas in Town. Our verification methods are separated into three categories:

1. Records Review – This includes any records that can verify service line material type through non-destructive methods and without involving individual property owners. Records that will be utilized include but are not limited to the following:

a. Build Permits – This method will verify data of structure construction. Structures that were built after 1988 will be inventoried as service lines with non-lead.

b. Water System As-built Mapping – Distribution system as-builts that verify pipe material will be utilized to inventory both the municipal and private service lines.

c. Distribution Maintenance and Work Order Reports – Municipal records that document installation, replacement, or repair of municipal service lines will be utilized to inventory municipal service lines.

2. Visual Inspection – This includes multiple methods that all involve visual verification. Methods for this category include but are not limited to the following:

a. Meter Setters – Documented inspection of the pipe material pipe that enters a water meter from the municipal or private side will be utilized to inventory service lines. Photos will be taken to document and verify. The Fulcrum Application will be utilized for this method.

b. In-House Piping – Inspection of the piping inside of a structure footing will be utilized to inventory service lines on the private side. Photos and/or lead swab or surface testing (with photo of results) will be taken to document and verify.

c. Excavation – Potholing on either side of the meter will be utilized to verify service line material type. Photos will be taken to verify and document.

3. Sampling – This includes sampling on the private side of the meter. The methods planned for this category include but are not limited to the following:

a. Private sampling - Utilizes kits that are provided to the property owner with instructions on how to properly take the sample and provide documentation to meet VDH requirements.

These kits may include lead swab or surface test kits and water lead testing kits.

b. Consultant Water Sampling – This would include coordination with property owners to collect sampling that can verify service line material type. These kits may include lead swab or surface test kits and water lead testing kits.

Predictive modeling, and emerging methods may also be considered at some point in the future. We will coordinate with ODW in advance of using these methods as ODW approval is required prior to accepting the results from these methods. The full list of VDH approved inventory verification methods are as follows:

Phase 4 – Consultant Software Import and Evaluation

At the conclusion of each inventory identification method evaluation, the consultant will import the inventory data into their software platform. The platform will create a database containing inventory mapping that includes service line identification for each and every data point in the platform. The ArcGIS / GIS and VDH LSL spreadsheet databases will be updated, and reports will be prepared for presentation to the Town for review and comment. The consultant team will collaborate with the Town to determine if additional investigation is needed with the current method or if a new method should be engaged based on the results and the various connection types within the Town service area. This process will be repeated until all methods that do not require customer interaction have been utilized. At the conclusion of this effort, the the consultant team will collaborate with the Town to determine how to proceed which could include but is not limited to the following:

1. Providing surveys to customers with instructions on how to provide documentation related to their service line. This could include a request to take a photo of their service line, performing a scratch test, or collecting a sample following proper protocol.

2. Excavation on both sides of the meter to determine pipe material. Utilization of this method will only occur if the Town determines that this activity justified and necessary. This method should be utilized as a last resort.

Phase 5 – Preliminary Lead Service Line Inventory

The consultant team will utilize the data collected in phases 2 - 4 to develop an inventory that will be organized and compiled to VDH standards using the spreadsheet template required by VDH. The preliminary, full system inventory findings will be presented to the Town with a summary of the number of service lines the project team was able to definitely categorize as well as the geographic areas that will require additional investigation. After Town review, the consultant will submit the inventory to VDH ODW. As part of this phase, the the consultant team will propose the methodology for customizing the 120Water platform to meet the Town’s specific needs, which may include custom data fields, location and service line identifiers, and prioritizations.

Phase 6 – Software Training

The consultant team will coordinate a training meeting with the Town’s intended user(s) on the software platform using the Town’s inventory data. During this training session, the consultant team and the Town will discuss the Town’s current data systems and processes and provide guidance on using the software platform for long-term LSL management.

Phase 7 - Customer Notifications

After the initial inventory is finalized and submitted, customers served by LSLs, GRRs, or unknown pipes must be notified within 30 days. This notification is required to include the classification of the service line (LSL, GRR, or unknown), the health effects of lead, and the steps available to minimize lead exposure in drinking water. Depending on the classification of the service line involved in each individual notification, the notice must also include information about opportunities to replace LSLs or GRRs or information about opportunities to verify the material of the line if it is unknown.

The consultant software can be used to customize customer notifications and education in line with Town expectations and satisfying all VDH and EPA requirements. Communications can be automatically generated within the software for a single location or the entire distribution system. The software will also show a history of all communications and activities with customers by location for easy tracking and recordkeeping.

Phase 8 - Notification and Sampling at Schools and Day Care Centers

The consultant will compile a list of all schools and day care centers that are served by the Town water distribution system, as required by the EPA under the Lead and Copper Rule Revisions. All schools and childcare facilities that were constructed before September 4, 2018, must be notified of the health effects of lead and of the requirement by VDH and the EPA to sample the potable water. Concurrent with customer notifications, the consultant and 120Water will notify schools and day care centers of the testing requirement and schedule sampling. The testing will follow EPA protocol for sampling lead in the water supply and 120Water will incorporate the sampling results and dates into the 120Water software platform and ArcGIS environment as necessary. This recordation and testing will satisfy all VDH requirements.

Secondary schools, which serve students in 7th grade and above are not required to undergo lead testing unless requested by the school. However, the consultant recommends that these schools be tested as well for full transparency.

Phase 9 – Lead Service Line Replacement Program

The consultant team will work with the Town to develop a lead service line replacement plan that includes timing, public outreach, funding, and implementation scheduling. The plan will be developed to target areas with the highest concentration of LSL inventory. The plan will be developed in accordance with 40 CFR §

141.84 b, and will include the following at a minimum:

1. Prioritization strategy that will include, but is not limited to disadvantaged consumers, known lead service lines and sensitive populations.

2. Development of LSL replacement implementation plan that includes:

a. Detailed process of customer notification protocol in compliance with 40 CFR 141.84 (b) (3)).

b. Development of construction specifications (in compliance with ANSI/AWWA C810-17

Replacement and Flushing of Lead Service Lines).

c. Development of pre-approved contractor list for performance of the work.

d. LSL replacement inspection verification protocol.

e. Development of program to roll out customer education related to service line and property maintenance responsibilities in the future.

3. LSL disposal plan.

4. Emergency repair plan.

5. Development of a LSL replacement financing plan.

6. Development of Lead Risk Mitigation procedures.

7. Development of a Lead Service Line Replacement Goal Rate in compliance with 40 CFR 141.84 (b) (4).

Phase 10 – Additional Investigation Methods, Notifications, and Program Management

At the conclusion of the initial LSL mapping effort, utilizing the methods explained in Phase 3, all remaining unknown service lines will be evaluated to determine an appropriate method to complete the inventory to the extent that is practicable. This could include excavation, in-house inspection, additional sampling, etc.

The Town will have control of the budget associated with this phase and will determine how to proceed related to activity and associated costs.