How to Deal with Lead in Your City's Drinking Water
Get a grip on lead in drinking water by understanding the issues and what steps local governments can take to get ahead of it.
In a recent poll of EfficientGov readers, about half tested their municipality's drinking water for lead in the past year.
About one third believe they have never tested it, while the rest believe they have tested in the last five years.
During the month the poll was open, the Guardian named cities like Boston and Philadelphia for practices that hide lead. At least 33 U.S. cities are “preflushing,” claimed the Guardian, which distorts test results.
The [U.S. Environmental Protection Agency (EPA)] reiterated in February that these lead-reducing methods go against its guidance, and the Flint charges show they may now be criminal acts,” said journalists Oliver Milman and Jessica Glenza.
The U.S. water industry is not pleased with how the Guardian cast it, although its intent is to finger civic leadership in 33 U.S. cities and EPA for failing to police state agencies who oversee the reporting.
So, what really happened with the Lead and Copper Rule (LCR)?
And more importantly, what do municipal leaders need to know going forward?
In the early part of the 20th century, local governments installed lead service lines throughout the country, from big, old cities to new developments.
In 1991, the U.S. Environmental Protection Agency promulgated the LCR, requiring all suppliers of community water systems and non-transient, non-community water systems to comply.
The main purpose of the law is to ensure water suppliers control corrosion in sources, service lines and customer plumbing. With periodic testing, and by educating the public about risks and replacing lead service lines when lead levels regularly exceed the 15 ppb limit, lead and copper risks can be effectively controlled.
Then, Flint happened. The Michigan city went off Detroit’s water system and started supplying homes and businesses with water from the Flint River. It didn’t take long for corrosive river water to start appearing in regular tests, in buildings, in homes, in schools and in people. Unfortunately, it took a little too much time to educate the public. A frenzy of finger pointing began over numerous LCR breaches.
In the aftermath of the crisis, EPA revised LCR in a February 29, 2016 memorandum* based on its Flint Task Force recommendations. For the first time, EPA recommends that a testing practice called pre-stagnation flushing no longer be used.
Couple this with the cost. As WIRED magazine said in its January story, Here’s How Hard it Will Be to Unpoison Flint’s Water:
The basic challenge: dig up several thousand miles of poisonous pipe buried as deep as dead bodies.”
Of course, drinking water lead service lines running through streets and connecting homes are common. They are expensive to replace—between $3,000 and $5,000 for each service connection, by some estimates.
Since 2007, lead service lines that tested below the action level, and were thus not required to be replaced under LCR, still have to be tested. If corrosion control is in place, and lead levels stay below the action level, the lead service lines have often stayed in the ground.
That may be changing as public awareness is heightened and money starts flowing to the problem.
What is pre-stagnation flushing and what factors increase lead levels?
The general consensus in the water industry is that the Guardian article accused it of maliciously distorting LCR—the authors did not explain the purpose of the pre-stagnation flushing practice, and why it was done prior to this year.
According to Ria Convery, spokesperson for the Massachusetts Water Resources Authority (MWRA), the regional wholesale drinking water supplier to Boston and many other municipalities in the region, the practice of pre-stagnation flushing creates an apples-to-apples comparison from one test to the next, one house to another, one neighborhood to another, and so forth. Prior to February 29, 2016, pre-stagnation flushing before the LCR-required, six-hour stagnation time was an acceptable practice.
They wanted to have the water sitting in the lead service line for the same amount of time,” she told EfficientGov.
According to the Guardian story, however, EPA warned back in 2008 that “pre-flushing goes against the ‘intent’ of the regulations.”
Not quite so, Convery pointed out.
Closer inspection of the Guardian article's source documents reveal the argument is in part based on a letter that actually implicates just one utility for its pre-flushing timeframe.
In Boston, the Boston Water & Sewer Commission (BWSC), which manages the household lead testing, previously asked homeowners to run their taps six hours before the homeowners collected their samples.
The Guardian’s EPA reference document from September 2008 “warning” is actually a letter from EPA to a Washington, D.C. community activist in response to how the District of Columbia Water and Sewer Authority (DC WASA) handled its homeowner lead testing protocol. It’s not a memorandum warning all U.S. water utilities of anything related to LCR.
DC WASA asked the selected district homeowners to run their faucets 10 minutes before they took their Spring 2008 samples.
The problem with what DC WASA did was that “the regulations require the water to stagnate for a minimum of six hours prior to collection of the sample,” EPA said in the 2008 letter.
There are many factors that cause elevated levels to appear in drinking water, from the natural source all the way to the tap. Responsibility falls to public and private inputs to the sources, as well as public and citizen pipe owners.
Luckily for DC WASA, samples collected in March of 2009, which did not utilize the 10-minute pre-flush, showed no material change when compared with January through March 2008 samples that were taken after a 10-minute pre-flush, as DC WASA reported to its board of directors on April 28, 2009.
Convery said she does not expect lead levels in Boston’s next household sampling tests happening in September—without pre-stagnation flushing—will change much from sampling done before EPA eliminated the practice.
That’s because Boston started its corrosion control program back in 1992 and by 2000, the system—some parts more than 100 years old—were more regularly below the action level, she said.
Some years, there are no samples above the drinking water lead action level. In other years, there may be one or two samples, said Convery. For the most part, BWSC and other utility managers try to keep the same homeowner samples sites, although they do change from time to time.
In 2015, there were two samples that exceeded the action level, but the March 2016 samples at those sites did not exceed the action level, said Convery.
What pre-stagnation flushing six hours prior gave water managers was a benchmark to compare the samples year over year.
Lead levels sometimes change for many reasons. In some cases, when a city replaces its lead lateral to a home, the homeowner can decline to pay to change its end. When the city’s new section is fused to the homeowner’s old section, corrosion control in that lateral is lost for a period of time.
Science shows lead levels can go up after a partial replacement,” said Convery.
DC WASA recommends using filtered water for drinking and cooking for at least six months after lead service line replacement. For pregnant women and children under six, it’s up to a year.
There are also plumbing fittings that homeowners purchase and install. Brass and other fittings did not have to be lead free until the Safe Drinking Water Act was amended in 2014, Convery noted.
What steps can municipal leaders take to get ahead of lead in drinking water?
- Better understand your drinking water distribution system, and communicate where lead service lines are located.
While all municipalities may not test their drinking water distribution systems, the water authority managing the distribution is required to. Open communication between water authorities and municipal leaders can offer communities greater insight and better control over their lead risks.
Once you have that information, you can share it with the public.
DC WASA did last month. Its interactive map lets district residents search by address to see if their service lines contain lead. It helped to combat a news story and a tweet about lead content in city water that was reportedly based on records from more than 10 years ago.
- Find ways to pay for additional lead testing and lead service line replacement.
There’s the state revolving fund, but that has a 2 percent interest rate. Everyone, from state officials to Congress, is finding money.
For example, MWRA developed a Local Water Assistance Program for its 50 member communities. There is $100 million that can be borrowed interest-free. According to the MWRA, it should be enough to cover the estimated 26,000 – 28,000 service lines left in its total service area.
Cities like Boston are offering homeowners $2,000 grants and then 48 months to pay off the rest, for their portions, said Convery.
The town of Framingham, Mass., one of the largest MWRA members, won’t need it, however. In 2004, Framingham’s tests started showing elevated lead levels. EPA required a lead service line replacement program, and the town completed it in 2016 using a portion of its operating budget to help homeowners figure out the costs of their portions.
The town funded the replacement of the town-owned portion within its operating budget. For the privately owned portion, the town contracted with an excavation company that provided estimates for each service, which were shared with the property owner for them to agree to and pay. This took some of the work off of the property owners, but didn’t place the financial burden on the town of Framingham,” Blake Lukis, director of water and wastewater for town of Framingham, told EfficientGov.
- Help homeowners and others understand lead risks.
Review a summary of LCR’s public education requirements in EPA’s LCR Quick Reference Guide so you can make sure utilities are following through.
There are public education resources on the American Water Works website. There is also basic information about lead in drinking water on EPA’s website.
Help plumbers and homeowners follow the 2014 guidelines for Lead Free Certification Marks when upgrading or repairing plumbing.
*Editor's Note July 27, 2016: EPA is considering long-term revisions to LCR, but they have yet to be promulgated. More information about the working group and meeting summaries are available on EPA's website.