Replacing Lead Service Lines in a Historic New England City

This means that most residents are at risk for health inequities based on demographic criteria, including race, income, and primary spoken language. Like many historic cities and towns with aging infrastructure, Fall River has undertaken a massive effort to inventory and replace any known lead service lines throughout its water distribution system. While this effort will help the city comply with Lead and Copper Rule Revisions (LCRR) requirements, the expedited schedule of the work has been driven by a Massachusetts Department of Environmental Protection (MassDEP) Notice of Noncompliance issued in March 2022 and Administrative Consent Order (ACO).

Historically, lead was commonly used to connect water mains to individual properties because of its strength, which prevented leaks, and malleability, which made the pipe easy to shape. At the time, the ill effects of lead exposure were not known as they are today. In 1986, the Safe Drinking Water Act was amended to prohibit the use of pipes, solder, or flux that were not “lead free,” which was defined at the time as solder and flux with no more than 0.2 percent lead and pipes with no more than 8 percent lead. As research and understanding of the health risks evolved, regulatory measures dropped lead content to 0 percent.

While the water leaving Fall River’s treatment facility is lead free, the chemistry of the drinking water as it travels through the distribution system can cause corrosion over time. The corrosion then causes the lead from any existing lead-containing materials to leach into the drinking water as it is delivered to the end user. During routine monitoring between July and September 2021, Fall River Water Division staff identified more than 10 percent of samples exceeded the Environmental Protection Agency (EPA) action level of 15 parts per billion triggering immediate action to address this public health matter. Monitoring since 2021 has been in compliance with state and federal regulations.

Creating a Lead Service Line Inventory

The Water Division’s 230-mile distribution system has 21,555 metered connections. Utility staff must identify all LSLs for replacement. This process is complicated by the fact that most residential connections are not documented in city records because the pipe connecting from the water main to the property has historically been the owner’s responsibility. When the city launched an interactive website in the spring of 2024, there were approximately 10,000 unknown connections.

Identifying the service line material requires in-home inspections, which poses a major hurdle and requires property owner cooperation. The Fall River Water Service Line Inventory dashboard was designed using ArcGIS to map all the service lines in the city. This interactive dashboard helps property owners search their address or use the MassDEP’s tool to self-report the service line material. The map is also connected to Fall River’s asset management system, which allows it to be updated in real time as unknown service lines are identified as needing replacement or safe to remain in use.

The website also includes resources for property owners and residents regarding how to reduce lead exposure if an LSL is identified, who to contact with questions, and what to expect during the LSL replacement process. Woodard & Curran supported the city’s development of this website, as well as the public outreach campaign to prepare the community for this project work. With a diverse population of residents, the website is also equipped with translation services to allow users to switch the content to their language of choice.

Lead Service Line Replacement Efforts

Woodard & Curran supported the development of a Draft Lead Service Line Replacement Plan to help Fall River effectively replace LSLs. The plan included criteria to prioritize the program rollout, such as coordination with the city’s existing street reclamation program and planned utility work, EJ block groups and associated criteria, and population age. Because there was uncertainty around when the $10 million WIIN grant funds would become available, Woodard & Curran supported the city’s pursuit of an additional $4.15 million in funding from the DWSRF for the calendar year 2023 LSL Replacement Program to expedite the city’s inventory, planning, and replacement efforts. Fall River also leveraged American Rescue Plan Act (ARPA) funding to supplement costs for the 2023 program. According to the Massachusetts Clean Water Trust 2022 IUP Loan Forgiveness Project Descriptions is receiving 59.8 percent principal forgiveness on the $4.15 million loan for the work conducted in 2023.

With the extensive work necessary to comply with the city’s ACO and the federal LCRR requirements, the city is continuing to work with Woodard & Curran on planning and design for work to occur in 2024, which will be funded by the WIIN Grant and include two contracts expected to be awarded in February and June of this year.