The problem of lead in drinking water came into the spotlight with the crisis in Flint, Michigan, in 2016. It resurfaced late last year in Benton Harbor, Michigan, as residents complained loudly about persistently high lead levels in water from some home taps.

But concern about lead in drinking water goes back much farther. The hazards of lead have been known for decades. It is highly toxic, especially for young children, and is linked to problems such as central and peripheral nervous system damage, learning disabilities, shorter stature, impaired hearing, and impaired formation and function of blood cells

This is why, long ago, lead was removed from paint, gasoline and plumbing materials in contact with water. Still, legacy plumbing materials, including lead service lines in some communities, continue to release lead into drinking water.

Community water systems, the U.S. EPA, the American Water Works Association, and other entities have been working on the lead problem for a number of years, starting long before the crisis in Flint hit the news wires. They have made significant progress, but more work needs to be done, and the problem is not as simple as it may appear.

The Infrastructure Investment and Jobs Act signed by President Biden last November provides substantial funding to improve drinking water systems, and it includes $15 billion for replacement of lead service lines. Steve Via, director of federal relations for AWWA, talked about progress on lead abatement in an interview with Treatment Plant Operator.

For how long has lead in drinking water been a concern?

Via: We have been managing lead in water for many years. In 1986 there was a ban on new installations of lead piping. The first EPA Lead and Copper Rule was finalized in 1991; corrosion-control measures taken after that significantly reduced lead at customers’ taps. In the early 2000s, the focus shifted to maintaining reliable corrosion control while improving treatment for other contaminants of concern, such as disinfection byproducts. In 2012 an EPA report set the stage for an emphasis on replacement of all lead pipe between the water main and interior plumbing. In 2014 the Reduction of Lead in Drinking Water Act took effect, further reducing the potential for alloys like brass to release lead into drinking water. In 2015 a National Drinking Water Advisory Council Work Group Report recommended changes to the existing Lead and Copper Rule.

Who has been involved in working to reduce lead in drinking water?

Via: Water utilities have been working on it, as have AWWA, the Lead Service Line Replacement Collaborative, the EPA, state agencies, the National Rural Water Association, the Rural Community Assistance Partnership, and others. All are distributing information to help water systems move forward. But many states are not providing clear direction. An important area where clarity is needed is the definition of lead service lines.

In what ways has that definition changed?

Via: When we started the conversation around lead service lines, we focused on the portions of lines that were within utility ownership. Then we moved on to characterizing the entire service line, including the portion on the customer side. Because there are cases where galvanized pipe can absorb lead and subsequently release it, the definition was expanded to galvanized pipe where there is or may have been lead pipe upstream.  Some also recommend that lead connectors be included in lead service line inventories and figure in line replacement requirements.

What are the practical implications of these changes?

Via: A number of utilities that had a good handle on their lead service lines will find that universe expanded with the inclusion of galvanized pipe requiring replacement, and potentially lead connectors, depending on how the EPA finalizes the current revisions to the Lead and Copper Rule, and how the states proceed. The number of pipes that at are characterized as being of uncertain lead material is going to be larger. That has implications for public communication and the interactions that are required under the Lead and Copper Rule Revisions.

When do you expect the latest Lead and Copper Rule revisions to take effect?

Via: The revised rule provisions were to become effective on Dec. 16, 2021, and initial compliance dates begin on Oct. 16, 2024.

How does AWWA recommend that water systems proceed now to address lead in drinking water and to comply with the revised rule?

Via: Water systems that have not already done so should prepare their lead service line inventories regardless what the Lead and Copper Rule Revisions entail. Now would also be a good time, if they haven’t already done so, to make sure they understand their corrosion control practice fully and, if need be, further evaluate their practices and establish protocols to track performance. 

What is involved in corrosion control?

Via: Corrosion control is specific to each water system’s combination of source water quality, treatment, distribution system conditions, and installed plumbing materials. Many water systems rely on multiple water sources. Corrosion control often consists of modifying pH or alkalinity; water systems can employ orthophosphate as a corrosion inhibitor. It’s also necessary to maintain water quality in the distribution system, so systems need to consider water age and blending. Controlling corrosivity must take place while also managing disinfection and formation of disinfection byproducts. Systems also need to consider pipe materials in distribution systems in addition to lead and copper. The new rule requirements will mean that many more smaller systems in addition to larger systems will need to focus on corrosion control.

How will compliance procedures change under the revised Lead and Copper Rule? 

Via: Observed lead levels will be changed by under new sample locations and sampling protocol. The revisions include a revised set of sample site tiers that includes galvanized service lines preceded by lead pipe or a lead connector. These and other changes will increase the probability that system with lead service lines or galvanized lines preceded by lead will exceed either the lead action level or a new trigger level.

How would you describe the trigger and action levels?

Via: The Lead and Copper Rule historically had an action level where if the lead level in the 90th percentile of samples exceeded 15 micrograms per liter, a utility had to begin public education, begin service line replacement, re-evaluate corrosion control practices, and based on that study, possibly revise what they’re doing for corrosion control. The revised rule adds a trigger level of 10 micrograms per liter that, for larger systems in particular, forces re-evaluation of treatment and corrosion control. A lead action level notice will require a Tier 1 public notice to the affected community with 24 hours. The revised rule limits successful lead service line replacement to full-replacements, increases the speed with which lead service line replacement must be initiated, and extends the minimum duration over which lead service line replacement must be conducted.

Does the revised rule extend beyond residential drinking water?

Via: The revised rule includes a requirement for community water systems to conduct sampling for lead in child care facilities and elementary schools. Schools are large institutional structures with a lot of outlets and potential for water quality changes inside the building. The sampling is to help schools understand their plumbing and take steps to care for water quality in the building. The rule would require water systems to take a sample from each elementary school, and from licensed child-care facilities.

What is AWWA doing to further abatement of lead in drinking water?

Via: We have been active in promoting the federal infrastructure funding package. A broad coalition has been working on that, and we have been one of the players. We’ve been encouraging research to support corrosion control and lead service line identification. Also, partners including the Water Research Foundation have done a great job of producing materials to help water systems prepare for the Lead and Copper Rule revisions. One area where we’ve been working is to develop more robust corrosion control training offerings. Corrosion control, lead service line inventory, lead risk communication, and outreach to schools and child care facilities have all been a focus of our webinars, conferences and training modules.

What is the Lead Service Line Replacement Collaborative?

Via: It’s a broad coalition of stakeholders that includes associations representing water systems, state agencies, the public health community, community action organizations, and others. All are contributing to a website on how to move lead service line replacement forward on a community level. The collaborative hopes helps communities that want to proactively identify where lead service lines, build lead service line inventories, and replace those lines.

Are actions being taken at the state and local levels as well?

Via: AWWA has state sections that have been offering materials related to corrosion control and lead service line replacement. All have been providing content on the core elements of the Lead and Copper Rule Revisions that are is relevant to the states they serve, and are fostering conversations with water systems about next steps. They are also helping water systems stay on top of state-specific requirements and deadlines.

What makes abatement of lead in drinking water so challenging?

Via: If you look at a population-weighted level of lead in drinking at the tap, those numbers are quite low; we’re talking less than 2.74 µg/L. Now we’re asking ourselves: What is the next step? How can we do more with lead service line replacement? Because we’ve done so much already, those next steps are expensive, and they’re harder. Everyone agrees that we want to remove sources of lead from contact with water, like lead service lines but removing each one of them costs thousands of dollars.

Can the new infrastructure funding help in this area?

Via: Lead service line replacement is an expense for homeowners, either individually or as rate payers. It’s something water systems can most readily address when engaged in water main replacement or rehabilitation as part of an ongoing program. Unfortunately, many water systems are either prohibited from or find it very difficult under local and state policy to fund spend public money to improve private property. Replacing all lead service lines completely is the goal, but requires coordination and support of property owners. That’s where the infrastructure funding is going to come in handy. We hope the federal funds will help make it easier for communities to replace lead service lines completely and to do so more rapidly.