San Antonio Water System officials told the Municipal Utilities Committee that they are assembling a citywide inventory of water service-line materials and testing noninvasive technologies as part of "Project Lead," the utility's program to comply with revised federal lead-and-copper rules.

The update, delivered by Kirsten Eller, potable water quality supervisor at SAWS, explained the inventory categories, inspection approaches and customer protections under the Environmental Protection Agency's Lead and Copper Rule revisions (LCRR) and the subsequent Lead and Copper Rule Improvements (LCRI).

The inventory covers the full service line from the water main to the building connection. "In San Antonio, we have split ownership of that service line," Eller said. "From the main to the meter is SAWS' property. Once it passes that meter, it's actually a property owner's." She said the inventory must include four categories: non-lead (copper or plastic), lead, "galvanized requiring replacement," and unknown.

Why it matters: The EPA's recent rule changes require public water systems to document all service-line materials and, over time, remove lines that pose a lead risk. SAWS officials said the work affects residents across the utility's system and will take years of inspection and data collection.

Key facts from SAWS' presentation
- Total service lines: 642,000 across SAWS territory (inside and outside city limits).
- Share unknown: About 60% of service lines are currently listed as unknown material.
- Confirmed historic replacements: SAWS records show over 800 lead lines were removed in the 1980s and 1990s.
- Customer interest: 11,000 customers have signed up to have their service-line material investigated.
- Compliance timeline: LCRR compliance actions began in October 2024; SAWS said the LCRI compliance period runs through 2027 and officials cited 2037 as an extended target for removing lead from systems.

How SAWS will fill the inventory: SAWS described a three-part approach: historical records review (tap slips, as-builts and work orders), physical inspections (meter box inspections and hydrovac "potholing" near the meter), and approved emerging technologies. "We have 11,000 customers signed up with interest in investigating their service line," Eller said, but added that number is a small fraction of the roughly 380,000 service lines SAWS estimates will need investigation based on construction dates prior to 1989.

Emerging technologies and pilots: SAWS has tested multiple technologies with EPA involvement. One device that "snakes" through pipes and measures electrical decay was not suitable for San Antonio because it cannot pass pressure-reducing valves, officials said. SAWS is piloting a different metal-detection device and described itself as the only U.S. public water system testing that particular technology with the vendor.

If a line is confirmed lead or deemed "galvanized requiring replacement," SAWS said it will coordinate next steps with the customer. "Right now, SAWS will offer to replace that pipe at the customer cost," Eller said, adding the utility is "evaluating funding options." She emphasized that the program is not mandatory: "If they refuse, that's perfectly fine. If they want an inspection but they don't want to do a replacement, that's also completely fine. There's not going to be a penalty against them. We're not going to shut off water. We're not going to initiate fines."

Customer protections and school/childcare sampling: SAWS said schools and childcare centers are eligible for sampling under the rule: elementary schools get five samples, childcare centers two, and sampling offers must be made so that 20% of eligible sites are sampled each year over five years. SAWS noted it will supply information on filters and use of filters as an interim protective measure.

Notification and public map: SAWS sent required customer notifications beginning in mid-October 2024. Officials acknowledged some customers found the federally required language alarming and said they adjusted the letter's presentation after discussions with the Texas Commission on Environmental Quality (TCEQ). SAWS maintains a public service-line map (saws.org/led) that shows properties coded as unknown (green), non-lead (blue), galvanized requiring replacement (yellow) and confirmed lead (red); the utility said the map will be updated quarterly.

Costs and funding: SAWS said it has not yet designed a billing or assistance program because the utility has found few confirmed lead lines to date and lacks data on the total replacement need. As one example of homeowner cost, an attending council member cited a reported homeowner replacement for about 50 feet of service line that cost roughly $4,500. SAWS officials said they are exploring funding options and acknowledged the difficulty of designing a subsidy without better data.

Questions from council members focused on timelines, prioritization of older neighborhoods, protections for lower-income residents, and property impacts from excavation. Council members asked SAWS to provide clear customer-facing materials (infographics) and to prioritize outreach to higher-risk areas. SAWS said it would start by targeting higher-risk zones and customers who have already requested inspections.

What the committee heard about legal and compliance limits: Edward Guzman, general counsel for SAWS, told members the utility faces no civil liability if a homeowner refuses an inspection. SAWS staff also described regulatory requirements that will require annual notifications to customers who decline inspections and an obligation to re-engage new occupants if a property changes hands.

Next steps: SAWS said it will continue records review, expand pilot testing of emerging technologies, perform physical inspections (meter boxes and hydrovac potholing) and update its public inventory quarterly. The utility plans to begin replacement work and broader implementation under the federal timetable for removal obligations; any large-scale replacement program and related customer assistance remain under development pending more complete inventory results.

Ending: Committee members commended SAWS on testing new technologies and urged the utility to prioritize assistance options for fixed-income and vulnerable residents if replacements are required.