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Oct. 26 — EPA wants to get the lead out. All of it.Replacing lead service lines in their entirety is among the regulatory options the Environmental Protection Agency is mulling as part of its upcoming revisions to the lead and copper rule.
A white paper released by the agency Oct. 26 said lead service line replacement is among the options being considered for addressing drinking water contaminated with lead leaching from old pipes and plumbing fixtures and outlined the related challenges and opportunities.
Cost and equity issues involved in paying for such an undertaking top the agency’s list of concerns along with complications arising from the shared ownership of lead service lines. Public water utilities are responsible for lead service lines from the water main to a property owner’s boundary. Beyond that, it is the homeowner’s responsibility.
The federal agency has been under pressure to propose revisions to the lead and copper rule earlier than the planned date of 2017, following the Flint, Mich., crisis that left the city of 100,000 exposed to high levels of lead in their drinking water. The contamination resulted when the state switched Flint’s drinking water source without adding the requisite corrosion controls, causing lead in the aging service lines to leach out into tap water.
The EPA estimates it could cost $2,500 to $8,000 to replace the full service line to a typical home, which includes the portion on public land and the part on the customer’s property. On a national level, EPA estimated the range at $16 billion to $80 billion.
The EPA said it developed many of the options based on recommendations from the agency’s National Drinking Water Advisory Council in late 2015, the Science Advisory Board in 2011, and the national experience in carrying out the requirements of the existing rule, the recent experience in Flint, Mich., Washington D.C., and other cities nationwide.
Lead was widely used in plumbing materials until Congress banned its use in 1986, according to the EPA. Yet 6.5 million to 10 million homes and millions of older buildings in thousands of communities nationwide still have lead pipes and plumbing.
In evaluating full line replacement, the EPA also must consider the pace of doing the work and the mechanism for implementing and enforcing project requirements. The agency also is evaluating whether to require drinking water utilities to identify the number and location of lead service lines in their system, as DC Water already is doing in Washington, D.C.
The EPA said it was aware that not all households within a given community can afford full service line replacements. At the same time, the agency pointed to Lansing, Mich., Madison, Wis., and Boston as examples of cities where innovative approaches have been used to achieve full lead service line replacements.
“EPA is looking at this experience in the context of developing proposed revisions to the lead copper rule,” the agency said.
The upcoming revisions to the 25-year old lead copper rule is expected to include both technology-driven and health-based elements that focus on proactive, preventative actions to avoid high lead levels and health risks, the EPA said.
The National Drinking Water Advisory Council advised the EPA to set a health-based, household action level that triggers a report to the consumer and to the applicable health agency for follow up. Under the existing rule, exceeding the technology-based federal action level of 15 parts per billion triggers a requirement that part of the lead pipes be replaced.
The agency is aware of the current rule’s shortcomings, “including a rule structure that for many systems only compels protective actions after public health threats have been identified,” the white paper said.
“EPA understands that there is no single answer or simple solution for reducing lead in drinking water,” said Joel Beauvais, EPA deputy assistant administrator for water, in an Oct. 26 blog.
“However, EPA is committed to ensuring that we use best available science, carry out the most robust analyses of regulatory options and are informed by stakeholder input as we update the rule to protect the American public from lead in drinking water,” he wrote.
The agency’s goal is to strengthen corrosion control treatment in drinking water systems to further reduce exposure to lead and copper and to identify additional actions that will equitably reduce the public’s exposure to lead and copper when corrosion control treatment alone is not effective.
To that end, the EPA said it will be guided by the following principles in pursuing its rulemaking, which include educating the public about the risks of lead exposure through drinking water, prioritizing protection for children and infants who are most vulnerable to lead exposure, clean and enforceable standards, and an integrated approach for reducing lead exposure from “drinking water, paint, dust, soil and other potential sources of exposure.”
The Association of Metropolitan Water Agencies, which represents publicly owned water utilities, described the white paper to Bloomberg BNA as a “distilled down, concise summary” of EPA’s thinking that is largely based on the drinking water council’s recommendations.
“They aren’t breaking ground here,” said Scott Biernat, director of AMWA regulatory affairs and scientific program development. The full replacement was a recommendation that came from the council’s report.
The council based its advice on the Science Advisory Board’s report in 2011 that in turn recommended against the EPA requiring partial or full lead service line replacements as the agency revised the 1991 rule. The scientists also expressed concern at the time about the short-term spikes in lead levels in tap water following both partial and full line replacement.
The EPA as part of its rulemaking is planning to study how to address short-term spikes in tap water following full line replacement and whether to prohibit or limit partial line replacements.
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