LCRR Inventory Project / Self-Identification

Please be advised that an instruction mailer will be going out to Sudbury Water District customers regarding an upcoming water service line review. The District is conducting this review to stay in compliance with the Environmental Protection Agency’s (EPA) recent Lead and Copper Rule Revisions. We will be collecting data on the age of homes, water mains, and service lines in this water service inventory project. The mail notice will include detailed instructions for self-reporting information to assist the District in this effort. It will also include information for scheduling a service line identification appointment. Thank you for your participation.

Mass Lead Service Line Identification

Lead can cause serious health problems, especially for pregnant women and young children. Please read the brochure below closely to see what you can do to reduce lead in your drinking water. Lead is a health concern and is commonly found in the environment; most commonly in lead based paint. Lead can also be found in water, though at much lower levels.

 

Dear Customer:

The District is currently conducting a review of water service line materials in the District’s distribution system. A service line is the pipe that brings water from the water main in the street into a building, and generally consists of two parts; the “public” side, which runs from the water main to the curb stop (shutoff valve near the sidewalk or property line) and the “private” side, which runs from the curb stop into the building. In our public water supply system, the District is responsible for the “public” portion of the service line, while the property owner is typically responsible for the “private” portion, generally separated by the curb stop. In accordance with the Environmental Protection Agency’s (EPA) recent Lead and Copper Rule Revisions requirements, we are currently reviewing available records, including the age of your home and the water mains that serve it, and are consulting with current and former staff to conduct a comprehensive water service inventory to report to EPA.

During this process, we determined that we have incomplete information on the materials used for the “private” portion of the service line at most addresses within the District. This is typical of many water systems due to incomplete record information and documentation of materials that may date back 75 years or more. Because of this, we are providing you with the following information and the opportunity to assist the District in this important initiative and self-identify the private side material of your water service or request an appointment for District staff or approved consultants of the District to do so.

Step 1: IDENTIFICATION

 There are more than 6,200 unique service lines connected onto the District’s public water supply, and records indicate that most of them are made of copper. A small percentage may be made of plastic, galvanized steel, iron, or lead. To identify your service line material yourself, please take the following steps.

  1. Find your water meter, which is typically located in the basement.
  2. Look for the pipe that comes through the outside wall of your home and connects to your water meter.
  3. Evaluate the color of this pipe. Does it appear to be plastic or metal? (See photos below)
  4. If the pipe appears to be metal and you cannot determine the material by color alone, place a strong magnet on the pipe.
    1. If the magnet sticks, your pipe is likely galvanized steel or iron.
    2. If the magnet does not stick, your pipe is likely copper or lead.
      1. Copper pipe is identifiable from lead by its color but may have normal buildup on the outside of the pipe so a closer visual inspection may be necessary to see the copper color that is similar to a penny.
  • Note: Please DO NOT attempt to scratch your service line for identification purposes. Depending on the material, this may damage the pipe and result in a leak.

Step 2: TAKE A PICTURE OF YOUR SERVICE LINE AND UPLOAD

The Massachusetts Department of Environmental Protection (MassDEP) has created a web-based application for consumers to submit information on their service line material to their public water supplier. You can access the Mass Lead Service Line Identification (MA-LSLI) Web App by scanning the QR code to the left or visiting the following link – https://app.smartsheet.com/b/form/f9ee39b7972f443ca63e8b936cd7f92b. The app may be accessed on any mobile device, tablet or computer with internet access and does not require you to download anything.

All you need to do is take a photo of your service line, upload it to the app’s website and answer a few basic questions. Be sure to select Sudbury as the City/Town and Sudbury Water District (PWS ID: 3288000) as Your Water Supplier to ensure your submission is received.

 

WHAT WILL WE DO WHEN WE GET YOUR SUBMISSION?

Once we receive your submission, we will review the information and photo provided to confirm your service line material. If we are unable to confirm the material from the information provided, we will contact you to schedule an appointment for on-site inspection by a representative of District staff member.

ALTERNATIVE: SCHEDULE A SERVICE LINE IDENTIFICATION APPOINTMENT

If you are having difficulty identifying your service line material or navigating MassDEP’s web app, you can schedule a service line identification appointment with a District staff member instead. To do so, please send an email to customerservice@sudburywater.com with “Lead Service Line ID Appointment” in the subject line and include your name and address in the body of the email. You can also call our office at: (978)-443-6602 on Monday-Thursday from 8:00am – 3:00pm, or Friday from 8:00am – 12:00pm.

We look forward to your interest and participation in this important water system inventory project!

 Respectfully,

Vincent J. Roy, Executive Director, Sudbury Water District

 

From MassDEP

December 4th, 2023

IMPORTANT INFORMATION

LEAD AND COPPER RULE REVISIONS NOTICE

SERVICE LINE INVENTORY COMPLIANCE SURVEY

 

Dear Community and Non-Transient Non-Community Public Water Suppliers,

On March 16th, 2021, the Federal Environmental Protection Agency (EPA) promulgated the Lead and Copper Rule Revisions (LCRR) which will require all Community (COM) and Non-transient Non-Community (NTNC) public water systems (PWS) to submit a service line inventory (SLI) by the compliance date of October 16th, 2024.

The inventory must include all service lines connected to the PWS distribution system regardless of ownership status, and regardless of the current use (potable and non-potable). Please be aware that systems that do not have any lead service lines are still required to submit the SLI by October 16, 2024. For more information about the SLI requirements see https://www.mass.gov/info-details/lead-and-copper-rule-revisions.

The Massachusetts Department of Environmental Protection (MassDEP) is committed to continuing efforts to address lead service lines and exposure to lead in drinking water and to work with PWS to meet the MassDEP public health protection goal of removing all lead service lines in five years.  Therefore, the Drinking Water Program is encouraging PWS to submit their draft SLI by April 1, 2024. This would give PWS time to complete and submit the inventories and receive MassDEP’s review and technical assistance, if needed, before the PWS regulatory deadline.

For any MA water systems subject to the LCRR which anticipate being unable to achieve full compliance with the LCRR SLI requirement by the October 16, 2024 deadline, MassDEP has developed a compliance plan option. Interested systems can work with us ahead of the deadline to enter into a compliance plan prior to the required deadline.

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ACTION REQUESTED – COMPLETE AND SUBMIT LCRR COMPLIANCE SURVEY

By December 15th, 2023, to help you to comply or plan for compliance with the LCRR SLI deadline, please complete and submit the following survey which contains questions pertaining to your PWS expected submission date of your system’s SLI. Surveys must be submitted by email to the MassDEP Drinking Water Program at program.director-dwp@mass.gov.

Access the Survey Here: https://www.mass.gov/forms/lead-and-copper-rule-revisions-service-line-inventory-compliance-plan-survey-form

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What if your PWS knows that it will not be able to complete and submit to MassDEP a LCRR SLI by October 16, 2024?

PWS POTENTIAL VIOLATIONS AND COMPLIANCE PLANNING

Even if you enter into a compliance plan with MassDEP, if your SLI is not submitted by October 16th, 2024, it will be a violation of the USEPA LCRR regulations, and your PWS will be in non-compliance with the federal LCRR implemented by the USEPA.  However, a compliance plan could be considered by USEPA in any enforcement decision regarding the violation.  Therefore, we are advising all PWS that may not be ready for submission of their LCRR SLI by the compliance date to enter into a compliance plan with MassDEP by signing an Administrative Consent Order (ACO) for the submittal of the SLI. Entering into a compliance plan with MassDEP prior to the implementation date of the LCRR will allow the PWS to work on a schedule for compliance that is acceptable to both MassDEP and the PWS while the PWS take actions to address the expected violation. If you are interested in entering into a compliance plan with MassDEP please indicate your interest in the above-mentioned survey.

AVAILABLE RESOURCES

MassDEP recognizes that developing a SLI may be challenging tasks for PWS and therefore has developed various funding and assistance opportunities to aid with submission of a SLI in a timely manner, before the deadline of October 16th, 2024. These opportunities include:

  • Lead Service Line Inventory and Replacement Plan Grant Program

The Massachusetts Clean Water Trust, in collaboration with MassDEP, are making State Revolving Funds (SRF) available to support a lead SLI and replacement plan grant program.   MassDEP is accepting grant applications, on a rolling basis, while funding it available. Eligible activities for these planning programs include:

  • Completing a comprehensive SLI for both public and private portions of the service line that will be made publicly available.
  • Preparing a Lead Service Line replacement program for the PWS that complies with the LCRR.
  • The application for this program can be found on MassDEP’s website under the section titled “Loan and Grant Applications for Lead Service Line Replacement.” This section also includes the SRF Lead Service Line Replacement Financial Assistance application for a 0% interest rate loan for the replacement of lead services lines for both public and private proportion.

To apply, complete the survey available at:https://www.mass.gov/lists/state-revolving-fund-applications-forms#loan-and-grant-applications-for-lead-service-line-replacement-  OR https://tinyurl.com/SRF-Applications

  • Assistance for Small Community Water Systems and Non-Transient Non-Community Systems – Lead Service Line Planning Program

This program is available for Public Water Systems serving a population of less than 10,000.  MassDEP will use set-aside funding from the DWSRF Lead Service Line Replacement Grant to contract with a qualified technical assistance provider to complete eligible planning projects working with the PWS.

To apply, just complete the survey available at: https://www.mass.gov/forms/massdep-service-line-inventory-and-lead-service-line-replacement-plan-technical-assistance-survey OR https://tinyurl.com/Small-System-Survey

  • Massachusetts Free Pilot Program for School and Early Education and Care Facilities (EECF) Testing Ahead of LCRR

As you may be aware, beginning in October 2024, all community water systems must offer to test and conduct sampling in at least 20% of the elementary schools and 20% early education and care facilities per year in their service area for lead and ensure that all facilities are initially offered testing within 5 years. To assist water systems, MassDEP has launched a FREE testing pilot program for systems that apply and are selected.

For more information about this Pilot Program, and to apply, you can contact program.director-dwp@mass.gov. with the subject: PWS Pilot program for Lead in Schools.

 LEAD AND COPPER RULE IMPROVEMENTS (LCRI) SLI REQUIRMENTS THAT MAY IMPACT YOUR SLI.

The proposed LCRI has been announced by EPA on November 30th, 2023. For information on the proposed LCRI, see EPA’s webpage here: Proposed Lead and Copper Rule Improvements | US EPA. This proposed regulation has provided new information that may affect your service line inventory and methods for verifying service lines. Please pay attention to the following LCRI proposals:

  • Connector Requirements

The proposed LCRI will require PWS to develop a baseline inventory, due 3 years after the promulgation of the final LCRI, that will include identification of service lines materials AND identification of connectors, such as pigtails and goosenecks. The connectors information is NOT required under the current initial LCRR SLI due October 16th, 2024, even though it is MassDEP’s current practice to encourage PWSs to include identification of connectors materials, when known, in their SLI. Having this upcoming change in mind, MassDEP strongly recommends that PWS track connector materials with their current inventory, to reduce or eliminate the workload of having to re-create their LCRI inventory in the future.

  • Verification Methods

The LCRI is proposing a requirement for all systems to validate the accuracy of non-lead service lines that have not been verified via a records review or visual inspection of at least two points along the service line. Under the proposed requirements, to confirm their status as non-lead, PWS will need to validate the accuracy of their service line materials by performing a two-point inspection of the service line on a percentage of non-lead service lines randomly selected from a validation pool. This validation will need to be completed no later than 7 years after the LCRI compliance date, or at an earlier date required by MassDEP. For more information on the validation requirements, see here: FACT SHEET (epa.gov).

  • Location Identifiers

The proposed LCRI will require systems to include a street address with each service line and connector.

Thank you for your continued work to provide safe drinking water and protect the public health. Please remember to complete and return your survey by the December 15th at https://www.mass.gov/forms/lead-and-copper-rule-revisions-service-line-inventory-compliance-plan-survey-form.

FOR MORE INFORMATION