In 1991, the Environmental Protection Agency (EPA) established the Lead and Copper Rule (LCR) to control the presence of lead and copper in drinking water. In 2021, the EPA released an addendum to the LCR called the Lead and Copper Rule Revisions (LCRR), establishing new requirements for protecting people from lead and copper contamination in drinking water.
There are a variety of requirements outlined in the LCRR that water systems must be compliant with by October 16, 2024. One of these requirements is for water systems to develop and submit a Lead Service Line Inventory for both the public-owned utility water service lines and the private-owned customer water service lines. Water systems must identify and label each public and private water service line as lead, galvanized requiring replacement, lead status unknown, or non-lead. Water systems are required to inform any customers with service lines identified as lead, galvanized requiring replacement, or lead status unknown annually of the service line status until it’s replaced.
The Public Works department maintains approximately 82,000 service lines in the City’s water system. In 2021, Public Works began identifying service line and yard line material based on existing records. Per TCEQ/EPA guidance, any water service lines with an install date after July 1, 1988 are assumed non-lead. Anything built before this date required further investigation of service line material by reviewing as-built documentation, building inspection historical data, and historical service line replacement tasks in Cartegraph and Cassworks work order systems. Currently, the material for water service lines is 92% verified for the public-side (from the water main to the water meter) and 50% verified for the private-side (from the water meter to the customer home/building).
Since March 2022, Public Works staff have only been able to field verify material for 11,000 service lines using "in-house" staff. The inspections are completed during routine repairs on water meters and service lines. The Public Works Department would like to verify the material of all service lines ahead of the October 16, 2024 inventory deadline so that no service lines are listed as "unknown", which would require notification for the potential of lead to each resident or business served by an "unknown" material location. Performing the field investigation now for the service lines with unknown material is the most cost effective and prudent approach to meet the LCRR requirements of inventorying all public and private water service lines. Public Works staff is seeking to establish a Professional Services Agreement with Ameresco, Inc. for field verification of the remaining sites to identify the material of all service lines in the water system before the Lead Service Line inventory deadline. Ameresco, Inc. has completed similar work for the City of Mesquite, City of Conroe, and the City of the Woodlands.
Public Works staff is requesting to contract with Ameresco, Inc. for field-verification of service line material on each side of the water meter to meet compliance with the LCRR. The contract is for the field investigation of approximately 42,000 service lines with an anticipated timeframe of 6 – 8 months. The estimated expenditure for the City is $2,800,000 for FY 2023-24 with anticipated contract completion in September 2024.
If this contract is not awarded by City Council, the City will not complete field verification of all water service lines by the LCRR deadline. This will result in a public facing map indicating that lead could be present in over 50% of private-side water service lines and will require city staff to annually notify these customers that they could be served by lead service lines.
The funding for this expenditure is coming from the Water Fund (36).
The City is exempt from the competitive bid process for this purchase as allowed by Texas Local Government Code Chapter 252 Subchapter B Section 252.022(a)(4). (City of Plano Internal Contract No. 2024-0147-X)