Overview

Entech assisted the Borough of Fleetwood (Fleetwood) to complete a Service Line (SL) Inventory of their public water system. The SL Inventory is part of EPA’s Lead and Copper Rule Revisions (LCRR). Public Water Systems are required to locate and verify the materials of service lines on both the water system side and the customer side. All water systems were required to comply with the initial phase by October 2024.

The first step in the process was gaining an understanding of Fleetwood’s water system assets and assessing the level of effort that would be required to meet the requirements. Achieving this goal is greatly dependent on the availability of water system records. This effort also requires property-owner involvement.

Entech divided the overall effort into two phases. Phase 1 focused on available historical documentation (tap cards, project details, as-built plans, ordinances or Borough-specific guidelines, etc.) to identify and document service line materials. After exhausting all available historical documentation, Phase 2 efforts explore additional methods of service line material identification, such as potholing, Swordfish technology, water sampling, and statistical analysis.

Entech began the process by developing a database for storing information gathered, which mirrored the PA DEP service line inventory spreadsheet. Methods for acquiring data included water system billing information, review of historical records, collection of water meter and water main replacement project data, and community outreach.

Through the document review phase, several key documents and combinations of historical records were useful in verifying non-lead.

Entech and Fleetwood were able to use details from project manuals and a homeowner letter distributed to all associated customers. The homeowner letter notified customers that if lead or galvanized pipe was discovered on the customer-owned side of the service line, it would be the responsibility of the homeowner to replace it before reconnection could occur. Since all of the Borough’s service lines are operational, PA DEP allowed the use of this pairing of documents to provide evidence of non-lead on both sides of the service line.

In an attempt to reach property-owners, Fleetwood Middle School students participated in developing an online survey that was distributed to the community, asking them to determine the material of the service line where it enters their home or business. It included instructional videos, illustrations, and a simple form that could be filled out. They were also asked to upload photographs. All data gathered was added to the database.

Finally, a long-term employee of the Authority was able to provide invaluable first-hand knowledge of decades of water main and associated service line replacement projects where no physical records existed. PA DEP accepted an Affidavit from the employee as validation of “non-lead” service lines.

Continual contact with PA DEP was essential in developing the database and confirming what types of documentation were appropriate to prove that service lines were lead-free.

Following the data gathering stage, Fleetwood engaged Entech to continue with the Phase 2 evaluation, which includes continuing to investigate remaining service lines of unknown material through additional verification methods beyond historical records.