For Water Subcommittee Meeting October 23, 2024
TO: Honorable Water Subcommittee Members
APPROVAL: John Rossi, Interim Utilities Director
FROM: Nicole Hemmans, Senior Administrative Analyst
...Title
Staff requests that the Water Subcommittee provide feedback on the Lead Copper Rule Regulation (LCRR) and Lead Service Lines (LSL) Inventory update. (ACTION)
RECOMMENDATION
Staff recommends that the Water Subcommittee provide feedback on the Lead Copper Rule Regulation (LCRR) and Lead Service Lines (LSL) Inventory update.
...Body
BACKGROUND
The Water Subcommittee received presentations from staff on September 27, 2023 & February 28, 2024, about the United States Environmental Protection Agency’s (U.S. EPA) Lead and Copper Rule Revisions (LCRR) and Lead Service Lines (LSL) Inventory. On March 12, 2024, the City Council/Rialto Utility Authority Board authorized a contract with 120Water, Inc. to meet the City’s compliance with the Federal Environmental Protection Agency’s Lead and Copper Rule Revisions.
ANALYSIS/DISCUSSION
The Lead and Copper Rule Revision (LCRR) requires the Public Water System (PWS) to develop an inventory to identify the materials of service lines connected to the public water distribution system. The PWS must also review sources of information to identify service line materials for the initial inventory. The water system may use sources of information if approved by the State such as any identification method to assess service lines materials.
The identification method used for the verification strategy is a statistical approach. The statistical approach allowed for completing a service line inventory with a 95% level of statistical confidence (with ±5% margin of error and 50% sample proportion).
The statistical method includes the following steps:
Step 1: Identification of All Service Lines of Unknown Material
Step 2: Identification of the Number of Service Lines to be Physically Inspected
Rialto, CA has more than 1,500 unknown service lines, so the Stratified Random Sampling method was appropriate. Using the Stratified Random Sampling method, the PWS must physically verify an amount of the total number of unknowns maintaining a minimum of 95 percent level of statistical confidence.
The Stratified Random Sampling method considers the following:
• Buildings built between 1950 and 1986, very little to no lead was used on private property.
• Buildings built between 1900 and 1950, splitting the system up by decades depending on how many buildings fit in each decade would be important.
• Buildings built prior to 1900, lead is likely to be found.
Table 4 presents the minimum and proposed number of unknown service lines to be physically verified by decades. Rialto has taken a 95% confidence level for each stratified category, or a 20% calculation if there were fewer than 1,500 service lines in a stratified category. Since the category <1900 only had 7 service lines, the City plans to verify them all.
Step 3: Random Selection of Service Lines for Physical Inspection
From the number of unknown service lines identified in Step 1 and the proposed number from Step 2, 120Water randomly selected service lines to be physically inspected as determined in Step 2. The selection was uniformly random and not based on any specific criteria, which could introduce bias.
The generation of the uniformly random set of service lines for inspection was created using a Microsoft Excel spreadsheet utilizing the RAND function. The RAND function in Excel is one of the functions specially designed for generating random numbers.
Step 4: Physical Inspection of the Service Lines
The type of service line verification method that will be use is:
✔ Public Side: Visual Inspection at the Meter Pit
✔ Private Side: Visual Inspection at the Meter Pit
At least one point of verification will be conducted for the portion of the unknown service line. The verification method includes meter box inspection. If one or more of the original randomly selected sites cannot be verified, the next available location from the random number generation will be used. For example, if a system has 2,000 unknowns and has to verify 322 SLs but is only able to verify 312 SLs, then the next 10 SLs will be taken from the original random number list (e.g., 323 to 333).
Step 5: Record of the Physical Inspection Process
120Water will use a Microsoft Excel spreadsheet to enter the service line category and materials observed at each point and reflect that data in the 120Water platform. The four service line category types shown are lead, non-lead, galvanized requiring replacement, and unknown. 120Water uses subclassification categories (e.g., copper, plastic) to capture the various material types for Rialto’s records.
Step 6: Results Input of Unknown Service Lines into the Inventory
For unknown service lines that will be inspected for the statistical sampling, 120Water will record the water system material identification method (physical inspection - meter box inspection). For unknown service lines not needing to be inspected, 120Water will record the material identification method as “statistical” and service line material as “non-lead”.
Step 7: Retention of Identification Records
The City of Rialto will retain all the documentation of all service line identification efforts and will be available to the Division of Drinking Water (DDW) if requested.
The Lead Service Lines (LSL) Inventory was due to the Department of Drinking Water on October 16, 2024. The City of Rialto’s inventory was submitted to DDW on October 15, 2024. A copy of the LSL Inventory submitted is included as Attachment 1.
NEXT STEPS:
1) Required Notifications sent within 30 days after DDW approval of initial inventory submission.
Once DDW has accepted the City’s LSL Inventory, Water systems must notify persons served by the water system at the service connection with lead, galvanized requiring replacement (GRR), or lead status unknown service lines. Water systems servicing more than 50,000 people, must also provide accessibility of the LSL Inventory online for residents to access. Lastly, notifications must be sent out annually until only non-lead service lines remain. Sample of DDW Required Notification Letter included as Attachment 2.
120Water has provided a quote of $23,236 to cover the required notification efforts for this year’s inventory totaling 10,175 unknowns. This amount is within the spending authorization of the Utilities Director to approve. The 120Water Quote is included as Attachment 3.
2) Field Testing of 807 residential service lines will begin the 1st week of November, and the completion date is estimated to be 8-12 weeks from the start date, considering the holiday season is approaching. Notification letters will go out to the 807 residents to inform them of the field tests being performed. This notification is not a requirement for DDW, but rather a supplement for our residents. If residents are interested in testing their service line independently, test kits will be available for purchase at City Hall.
ENVIRONMENTAL IMPACT
This request is not a “Project” as defined by the California Environmental Quality Act (CEQA). Pursuant to Section 15378(a), a “Project” means the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment. According to Section 15378(b), a Project does not include: (5) Organizational or administrative activities of governments that will not result in direct or indirect physical changes in the environment.
GENERAL PLAN CONSISTENCY
This action is consistent with Guiding Principle 3 in the General Plan:
Our City government will lead by example, and will operate in an open, transparent, and responsive manner that meets the needs of the citizens and is a good place to do business.
LEGAL REVIEW
The City Attorney’s Office has reviewed the staff report.
FINANCIAL IMPACT
Operating Budget Impact:
The total cost to fulfill the requirement of notifying Water System users of the Lead Service Line Inventory is $23,236, which is within the Utilities Director's authority to approve. Funding is available in the FY25 Budget Fund 680 - Acct No. 56807960-52011.
Capital Improvement Budget Impact: No impact.