Lead Service Line Inventory Project

Project Summary (Project No. A2214)

On December 16, 2021, after a public comment period, the U.S. Environmental Protection Agency (EPA) announced new revisions to the Lead and Copper Rule (LCR), the first significant changes in over 30 years. The EPA’s new rule, referred to as the Lead and Copper Rule Improvements (LCRI), aims to strengthen the LCR to better protect children and communities from the risks of lead exposure. The EPA identified priority improvements for the LCRI:  1) proactive and equitable lead service line replacement (LSLR); 2) strengthening compliance tap sampling to better identify communities most at risk of lead in drinking water and to compel reduction actions; and 3) reducing the complexity of the regulation through improvement of the action and trigger level construct.

The Lake Whatcom Water and Sewer District operates three Group A water systems (water systems with 15 or more service connections) regulated by the Washington State Department of Health: 1) South Shore Water System (DOH Identification No. 95910); 2) Eagleridge Water System (DOH Identification No. 08118); and 3) Agate Heights Water System (DOH Identification No. 52957). The South Shore system serves the Geneva and Sudden Valley communities, while the Eagleridge and Agate Heights systems predominantly serve those neighborhoods located on the north shore of Lake Whatcom.

The District’s three Group A water systems are required to comply with the LCRI by October 16, 2024. The District intends to meet the compliance tap sampling requirements through its routine water quality monitoring program. Compliance with the LSLR provisions, however, requires greater effort to create an inventory of District water system connections that identifies any lead service lines requiring replacement prior to the 2024 deadline. A service line is the pipeline between the public water main and the customer’s structure (home, apartment, business, etc.). In many cases, including the District, service line ownership is split meaning that the system (District) owns a portion and the customer owns a portion of the service line, as shown in the image to the right.

To complete a service line inventory of each of the three water systems, the District has identified the tasks summarized below. Inventories specific to each system will be completed using an EPA-supplied service line inventory template.


Task 1—Historical Records Review

The District will review all available records to define the material used for both District- and customer-owned portions of as many service lines as possible. Records may include:

  • Construction records and plumbing codes (e.g., Whatcom County Assessor building construction records)
  • Water system records (e.g., as-built records, engineering standards, etc.)
  • Inspection records (e.g., tap cards, service line repair/replacement records, etc.)

Completion of this task will allow for reduction of the number of service lines requiring physical inspection to define the material composition. For example, if the Whatcom County Assessor’s Office records indicate that a home was constructed after the 1986 federal ban of lead service lines, then its associated service line may be categorized as non-lead and no further investigation is required.

Task 2—Identify Service Line Material During Normal Operations

The District has adopted a standard operating procedure for repairs to water mains and/or service lines that District staff conduct to record the material and diameter of any service line encountered in the District’s asset management system. This will allow for confirmation of any service lines previously categorized through the historical records review process, as well as definition of material for any service lines that records were not identified for. Each water service line inventory will be updated, as necessary, up to and after the October 2024 compliance deadline.

Task 3—Service Line Investigations

For those service lines whose material remains categorized as unknown through Tasks 1 and 2, the District will conduct additional categorization efforts, such as visual inspection of the service line entering each side of the water meter box, excavate to the service line at specific locations, and/or use predictive modelling to identify potential lead service lines. Any physical investigation of customer-owned service lines will not be completed without prior approval of the property owner. Investigation findings will be added to the inventory as information becomes available.

Task 4—Inventory and Lead Service Line Replacement Plan Submittal

Prior to the October 16, 2024 LCRI deadline, inventories of each of the District’s three water systems will be completed and submitted to DOH. Should any of the systems be found to have lead service lines, a plan for replacement of those lines will also be prepared and submitted to DOH.

Project Schedule

Task 1—Historical Records Review—Agate Heights and Eagleridge systems completed December 2022; South Shore system anticipated June 2023 completion

Task 2—Identify Service Line Material During Normal Operation—ongoing

Task 3—Service Line Investigations—July 2023 through July 2024

Task 4—Inventory and Lead Service Line Replacement Plan Submittal—October 16, 2024

Project Cost

The District plans to complete all work in-house to limit costs.

Project Contact

Justin Clary
General Manager

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