Lead Service Inventory & Replacement
Welcome to the Lead Service Line Inventory and Replacement Project site!
This section covers the general context, scope, and intent of this project, contact information for project personnel, and educational information about the service line identification and replacement process.
A Brief History of Lead in Water Infrastructure and its Impacts
Lead has been utilized in water infrastructure for thousands of years, including by the Romans, due to its malleability, availability, and ease with being joined to other pipes. Even as far back as 2 BC, however, physicians were already documenting lead toxicity and poisoning; regardless, people continued to utilize lead in a variety of ways, including as a wine preservative and sweetener, paint additive, key element in metalwork and glasswork, etc. This led to numerous debates amongst chemists, physicians, engineers, and government officials about the impacts of lead exposure and whether it should be regulated.
For additional details and historical artifacts, please visit the digital National Library of Medicine
Despite such long-standing suspicions of the negative effects of lead exposure, including birth defects and developmental disabilities, the United States continued to allow its use in drinking water infrastructure until its ban by Congress in 1986; however, this ban only covered the installation of lead pipes and did not require the removal of existing lead infrastructure.
Originally published in 1991 and subsequently revised as recently as 2021, the Environmental Protection Agency (EPA)-mandated Lead and Copper Rule allows public water systems (PWSs) to better control lead and copper concentrations in water and identify where lead water service lines exist across the United States. Under this rule (specifically §141.84), every PWS is required to submit a verified water service line inventory. Figure 1 provides an estimate of suspected lead services lines across the nation per a survey performed by the Natural Resources Defense Council (NRDC):
Figure 1: Estimated Lead Services Lines per State (source: https://www.nrdc.org/stories/causes-and-effects-lead-water)
In an effort to continue making progress with prioritizing the public health and safety of Americans, the White House released a public briefing on December 16th, 2021, with the following statement:
“Today, the Biden-Harris Administration is releasing its Lead Pipe and Paint Action Plan. The plan represents a historic effort of unprecedented ambition that will deploy catalytic resources from the Bipartisan Infrastructure Law while leveraging every tool across federal, state, and local government to deliver clean drinking water, replace lead pipes, and remediate lead paint. The plan includes over 15 new actions from more than 10 federal agencies that ensure the federal government is marshalling every resource to make rapid progress towards replacing all lead pipes in the next decade.”
The EPA and Massachusetts Department of Environmental Protection (Mass DEP) are providing training sessions, guidance, and many other resources to help PWSs identify and eliminate lead in the distribution system.
Please note that any of the LRWU’s public lead service lines discovered during inspections post-1986, whether related to this particular project or not, have been and will continue to be replaced with pipes comprised of other EPA- and Mass DEP-approved materials.
Project Context and Purpose
The ultimate goal of this project is to develop an accurate inventory comprised of verified lead and galvanized water service lines (Phase I) for the purpose of providing it to the public and informing the LRWU of which services will need to be replaced (Phase II). The LRWU will continue to replace public lead service lines as discovered during normal operations; additionally, the LRWU maintains a robust corrosion control program using zinc orthophosphate to reduce lead concentration throughout the water system. This treatment process ensures that your water is well in compliance with relevant state and federal water quality regulations.
The EPA provides guidance to PWSs to reduce lead in drinking water by complying with federal and state regulations with the ultimate goal of complete lead removal from the distribution system; as displayed in Figure 2, this includes providing educational materials to the public, maintaining a useful lead and copper sampling program, keeping appropriate records, communicating with the public about this project, and remediating the presence of lead in water.
Figure 2: 3Ts for Reducing Lead in Drinking Water (source: https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water)
Phase I: Inventory Verification
During this phase, LRWU staff will continue to verify the LRWU’s records through review of readily available data and on-site inspections. The LRWU has already completed an initial comprehensive review of available water service records two (2) years ahead of Mass DEP’s schedule in an effort to expedite the process. The LRWU will commence on-site investigations on the private side of residences (i.e. the line leading up to the water meter) in Spring 2023.
The homeowner will be notified of the technician’s assessment within 30 days of confirmation of the water service line material (Table 1 shows the parameters upon which the technician will base his/her analysis). Once the inventory has been finalized, the LRWU will complete and upload a map on this website so that all water service line information collected for this project is publicly available.
Table 1: Types of Pipe (source: https://www.amwater.com/njaw/Water-Quality/Lead-and-Drinking-Water/pipe-material-information)
Phase II: Service Line Replacement
Once Phase I is complete, all services requiring replacement have been identified, and appropriate funding has been set aside, the LRWU will commence replacement. If you choose to replace your service line at your own expense, please notify the LRWU to ensure relevant records are properly updated.
Project Specifics, FAQs, and Educational Information
Why did I receive a notice asking to schedule an inspection?
You received a notice because the water service line serving your property was identified as potentially containing one (1) or more of the aforementioned materials. You reserve the right to be educated about your service line and to ask any questions regarding this information.
The LRWU separates the distribution system into two (2) separate classifications:
- Public: from the water main to the curb stop
- Private: from the curb stop to the cellar
Either or both segments on your property may contain one of the aforementioned materials. Public and/or private sides of your service line may be inspected during different times, and it may be determined that your service does not contain any of the initially suspected materials (i.e. your service may be listed as lead on record but was later replace with copper and never documented).
How often will this be done?
There are no plans at this time to redo the inventory at properties targeted by this project after its completion since the revised data collection methods should minimize the need for another citywide service line survey. When/if this inventory is redone in the future, you will be notified well in advance. Any feedback regarding the LRWU’s communication or outreach with respect to this or any project is welcomed and appreciated.
Should I be concerned about having lead in my water?
The LRWU’s lead service lines are internally coated with a zinc orthophosphate biofilm (which acts as a corrosion inhibitor) to prevent reaching or exceeding the maximum contaminant level (MCL) established by Mass DEP in the Lead and Copper Rule. Verifying service line material is just to provide up-to-date information for the LRWU’s records and does not serve as a response to a health and safety emergency or non-compliance with any regulations. Additionally, the LRWU regularly performs lead sampling across the distribution system to ensure the safety of the potable water supply and has demonstrated the efficacy of its corrosion control program (previous readings and additional information may be found in Consumer Confidence Reports: https://www.lowellma.gov/1088/Consumer-Confidence-Reports). UPDATE: All samples from the 2022 monitoring period (August-September 2022) were significantly under the lead MCL of 0.015 mg/L with a 90th percentile value of 0.002 mg/L
If you have lead-based plumbing in your home after the meter, the LRWU encourages you to contact a licensed plumber for an evaluation.
What is my role in this project?
One (1) or more of the LRWU’s technicians may need to inspect your service from the inside and/or outside of your residence to verify its material. The efficiency of this project relies on your cooperation to allow the technicians to properly investigate your service. The LRWU thanks you in advance for your participation and appreciates your time and understanding.
How much will it cost me to get an inspection done?
The inspection and any potential replacement, at the LRWU’s initiative, will be performed at no cost to you.
How will the verification of the materials be completed?
There are a few ways in which the LRWU will verify that services are comprised of a material requiring replacement:
- Visual verification: if the LRWU’s records indicate that your private line contains one of the materials, a technician will come by to inspect the piping leading up to your water meter;
- Sequential sampling: the LRWU may elect to take samples upstream and downstream of your service to determine what material(s) comprise your line; and/or
- Other methods approved by the Environmental Protection Agency and Massachusetts Department of Environmental Protection
Figures 3 and 4 provide a visual for the above-ground parts of the system that are of interest to the LRWU.
Figure 3 (L): Public vs. Private Service Line (Domestic and Irrigation) (source: Lowell Cross-Connection Control Program)
Figure 4 (R): Public vs. Private Side Service Line (source: Lowell Cross-Connection Control Program)
Where can I get more information about this project?
The notice distributed to PWSs may be found here:
More specific information about the Lead and Copper Rule and its revisions may be found here: https://www.epa.gov/dwreginfo/lead-and-copper-rule
More specific information about the water service line material verification directives may be found here:
The EPA’s response to the White House’s December 2021 statement may be found here:
PowerPoint presentation provided to Lowell City Council to inform public about progress through lead service identification and upcoming steps in the program:
How do I get a lead test for my water?
https://www.mass.gov/how-to/find-a-certified-laboratory-for-water-testing provides a list of certified labs; tests typically cost under $50.
You may also opt to contact the Mass DEP Drinking Water Program representative at (617) 292-5770 or firstname.lastname@example.org for additional information regarding finding a certified lab.
Who should I contact if I have questions?
The LRWU is pleased to provide any information related to this project between the hours of 7 am to 3 pm, Monday through Friday. For any questions you may have, please contact LRWU at (978) 674-4240 to be connected to one of our LSL staff members. Your feedback and mutual open communication are critical to the success of this project.
You may also contact the Mass DEP Drinking Water Program representative at (617) 292-5770 or email@example.com.