Options are being established for presentation to the Graham City Council to comply with the Texas Commission on Environmental Quality regarding a lead service line inventory.
TCEQ required the city of Graham to send notice to residents last week regarding noncompliance with a lead service line inventory requirement in place from the U.S. Environmental Protection Agency.
City Manager Eric Garretty spoke with the city council Thursday, June 26 and updated them on what happened with the notice.
“(Public Works Director) Randall (Dawson) and his team are required to… do lead and copper testing of the water every three years, as required, at 20 different locations in the city, and we report the individual test results of all 20 of those locations every year,” Garretty said, “…In this testing, in Randall’s recent memory, we have never detected any lead or copper residual in our water and our test results show it.”
The city did not comply with the October 2024 deadline to submit an initial lead service line inventory and will be starting an inventory with an estimated completion date of Oct. 1, 2025.
“What’s being required by the Environmental Protection Agency, with the Texas Commission on Environmental Quality acting as their agent in Texas, is they have ordered a full inventory of all the connections in our water system… (of) around 4,700 connections,” Garretty said.
The city manager said the city would have to dig up water lines on the customer side of the meter and verify if the line is lead or another type of material.
“In some cases, they’re requiring that if we discover a particular type, we can’t just look in the meter box or dig out a pothole on the customer side. They’re requiring us to uncover the entire line all the way to the customer’s residence to determine if there’s any lead solder joints along a metal line,” Garretty said.
Garretty said there is federal money available through the state for the lead and service line program. The city manager said he spoke with consulting engineers who looked at a similar community with half the amount of water connections and the inventory cost was $230,000.
“That means it could cost us half a million dollars just to do the inventory. If we uncover anything that needs to be replaced, the program provides that the city may, at the city’s expense, replace the customer side of the line,” Garretty said.
If the city decides to move forward with the grant process, they would have to submit an application in March and could be notified of the award in May.
Garretty said the EPA is stating the city can approach a customer and ask if they will voluntarily give them the ability to dig up the line. If they refuse, then the city can be granted an easement to complete that work.
“We’d have to get an easement for their service line. Having the easement would then allow us to dig up the line,” he said. “If they won’t give us an easement, what the EPA is saying is that the council take action to legally condemn an easement and get it anyway. So this just gets more complicated as we go along.”
Council Member Jack Little asked if a customer could report their own line for the inventory.
“When I talked to the engineer yesterday, …their requirement is that an official of the water system has to verify so the answer to your question is, no. You may know, but it doesn’t count because it has to be done by an official of the water system,” Garretty said.
The city manager suggested one option of using the engineering firm Jacob & Martin to help advise the city on options.
“(They have specialized) in this since this program came out. They can provide us with some initial guidance on what to do and give us a professional opinion on what it is, what they think we’re looking at, …and give us an opinion of probable cost if we decide to contract it out,” Garretty said.
Another option would be to perform the inventory in-house with the city but there are limited positions in the water department and the city estimates it could take six months to a year to complete.
“When Randall and his team have gone around the city and found anything that doesn’t meet that code, that line’s been replaced, usually, with poly,” Garretty said. “We’ve got a map of the system. …The map of the distribution system is not 100% correct. We’re correcting that with this comprehensive plan we’re coming up with.”
