Westerville Water-Line Letters Raise Questions Despite Low Lead Test Results

Westerville’s latest compliance testing found lead levels well below the federal rules, even as a limited number of residents received letters stating that their private water service lines need further investigation.
The letters do not mean lead was detected in a home’s water. According to the city’s website, residents receive notices when Westerville cannot determine with certainty what their private water-service connection is made of or when the connection has been identified as galvanized steel.
Water Utility Manager Adam McDowell said the concern is not the water leaving the treatment plant or moving through the city’s mains. Lead could enter the water after it reaches an older private service line, household plumbing, or fixtures.
Westerville’s review was not prompted by a failed water test, and the city has no known lead service lines on the city-owned side of the system. Federal rules nevertheless require the city to verify the material of each service-line connection.
When records or inspections cannot establish that a line is not lead-based, the city must continue its investigation and notify the affected resident.
“You either have to know for sure that it’s not lead or you have to treat it like it is,” McDowell said.
For some residents, the warning letter was the first indication that a section of the pipe carrying water into their homes had not been identified. Its references to possible lead exposure, state oversight, and federal requirements also left some recipients uncertain about whether the city had found a problem with their water.
One resident posted online that she received the city’s letter at her apartment and later learned the property owner did not appear to know about the notice or understand its significance. Her experience highlights a practical problem with the process: The person drinking the water may not own the pipe or control access for an inspection or replacement.
McDowell said the city uses corrosion-control treatment to reduce the chance that lead from private service lines, plumbing or fixtures will leach into the water.
“There’s no lead here in the plant,” McDowell said. “There’s no lead when it comes to your house. The question is what happens in your house.”
From early maps to a detailed inventory


Westerville’s effort to identify service-line materials has become more detailed as federal requirements have tightened. After the Flint water crisis drew national attention to the dangers of lead service lines, Westerville created a 2017 map identifying properties for possible review based on records available at the time. A 2022 update refined that survey using more accurate information.
The city’s current geographic information system map reflects the next stage of that work: compliance with the EPA’s Lead and Copper Rule Revisions (LCRR) and the newer Lead and Copper Rule Improvements (LCRI).
Earlier maps showed properties or areas that required further review. McDowell said a highlighted property did not necessarily have a confirmed lead service line; it meant the city could not rule one out.

The current map is more precise. It shows individual water-service connections and separately classifies the city-owned and privately owned portions of each line. Categories include non-lead, unknown, and galvanized requiring replacement. An accompanying map graphic shows the number and location of connections in each category.
The distinction between the public and private portions matters because a resident may receive a letter even when the city-owned side is classified as non-lead. If the privately owned side remains unknown, federal rules still require notification and follow-up.
McDowell said the city’s initial review intentionally cast a wide net. If a home was built during a period when lead service lines might have been used, and the city could not prove the line was made of another material, the property remained on the suspect list.
“The first one was a very high-level, high passover,” he said. “What fits the bill that may have been lead? And if we can’t prove it isn’t, boom, those are all maybe.”
Responses from residents have helped narrow the list. Some residents inspected the pipe where it enters the home, scratched its surface to help identify the material, photographed it, and submitted the information to the city. When that information confirmed the line was copper, plastic, or another non-lead material, the property could be removed from the unknown category.
Other lines may require a more intrusive inspection. McDowell said unresolved cases could require potholing, in which crews dig down to expose the service line and determine what it is made of.
Testing found low lead levels
Westerville tested 32 locations during its most recent sampling round, including 30 Tier 1 sites, the sampling locations considered most relevant under the federal lead and copper program.
The city’s 90th-percentile result was 1.04 parts per billion, compared with the current federal action level of 15 parts per billion. The highest result was 3.4 parts per billion, and only four of the 32 samples were above 1 part per billion, McDowell said.
The results help distinguish between two issues that are easily confused. The letters concern the identification of service-line materials; they were not prompted by Westerville exceeding the federal lead action level.
Federal rules require water systems to document the material of every service-line connection, even when routine sampling results remain below that level.
Galvanized steel lines are not the same as lead lines, but some must still be replaced under federal rules. Galvanized pipes can collect lead particles released from upstream lead plumbing and later release those particles into the water, particularly when the system is disturbed.
Because of that risk, certain galvanized lines must be classified as “galvanized requiring replacement” unless the city can establish that they were never located downstream from lead. McDowell said that makes galvanized lines part of the broader replacement effort even when the pipe itself is not made of lead.
“Galvanized pipe traps any lead in the system,” he said.
Federal requirements expand in 2027
The current letters are part of the initial phase of the EPA’s Lead and Copper Rule Revisions, which require water systems to inventory service lines and to notify customers when lines are lead, galvanized, or unknown, or when replacement is required.
The next major deadline under the Lead and Copper Rule Improvements arrives in 2027. By then, water systems must prepare a more complete baseline inventory and a service-line replacement plan. Westerville’s capital improvement program lists the service-line inventory as due in 2027, with replacement work scheduled from 2027 through 2037.
That schedule reflects the broader federal goal of removing lead and replacing galvanized service lines over roughly a decade. Unknown lines must also be resolved, either by confirming they are non-lead or by placing them in the replacement process. The 2027 requirements also call for expanded public information about testing, reducing exposure, and planning replacements.
Schools and child-care facilities next
The 2027 requirements extend beyond residential properties. Water systems will be required to offer lead testing at elementary schools and licensed child-care facilities they serve.
McDowell said the work will fall largely on the city and could add about 200 tests over a five-year cycle. Depending on how the final list is developed, the requirement could include public schools, child-care centers, and licensed child-care operations in private homes.
The school and child-care testing requirement underscores the broader scope of the federal program. The current residential letters are one public-facing phase of a longer effort to identify service-line materials and reduce potential lead exposure.
Residents with questions about their property, inspection options, or water testing should contact the Westerville Water Department.
For now, McDowell said, Westerville’s testing remains well below federal action levels, and the city has no known lead service lines on the city-owned side of the system. But federal rules require more than low test results. They require the city to document the material of each service-line connection, which is why notices, mapping, and inspections will continue into 2027 and beyond.
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