The U.S. Environmental Protection Agency (EPA) estimates there are still 9.2 million lead lines connecting homes to water systems nationwide. According to the American Water Works Association, the average cost to fully replace a single lead service line can be more than $10,000 and AWWA has said the cost industrywide could easily exceed $90 billion.
But 100 percent removal of lead service lines is the goal the water industry has set forth. This goal was further echoed by the federal government in November 2023 when EPA released its proposed Lead and Copper Rule Improvements (LCRI). The LCRI would amend the 2021 Lead and Copper Rule Revisions and establish a mandate for U.S. water systems to replace all lead service lines within 10 years, among other provisions.
The 2021 Lead and Copper Rule Revisions still carry a compliance deadline of Oct. 16, 2024, for utilities to develop inventory of service lines including private (customer) side materials and develop systemwide removal plans. With the proposed LCRI, the EPA under the Biden administration aims to accelerate the timeline of lead service line removal.
In Northeast Ohio, the City of Cleveland Division of Water (Cleveland Water) serves the City of Cleveland and surrounding communities. It is the tenth largest public water system in the United States, the largest in the State of Ohio and the largest system to source its water from Lake Erie. Cleveland Water treats and delivers water to more than 1.4 million people and thousands of businesses in the area.
The system has about 5,375 miles of water main and about 440,000 total active service connections. Cleveland Water last used lead in its system in 1953, so any service connections installed prior to 1954 could contain it. Cleveland Water estimates it has about 178,000 possible lead service connections, with 142,000 of those having city-owned lead, more than 10,000 with customer-owned lead and about 4,000 with downstream galvanized steel requiring replacement.
Although these numbers rank Cleveland among the highest concentration of lead service lines in the nation, Cleveland Water has a favorable record of delivering safe drinking water. The department uses orthophosphate in the treatment process as a corrosion control measure for mains and service lines. It also controls pH levels to help maintain the orthophosphate, contributing to effective corrosion control. As a result, lead levels detected in Cleveland’s drinking water have been below the federal requirement of 15 parts per billion (ppb) since that requirement was introduced in 1997, and consistently below 5 ppb since 2009 (note EPA’s proposed Lead and Copper Rule Improvements released in November 2023 would reduce the federal threshold to 10 ppb).
Inventory
Even with its success in controlling lead levels, Cleveland Water has launched an ambitious lead service line replacement (LSLR) program managed entirely in-house.
“We’ve always maintained that our water is safe, yet nevertheless, the sentiment nationwide is that it’s time for the lead to go,” says longtime Cleveland Water Commissioner Alex Margevicius, who has worked for the department for more than 35 years.
Developing a service line material inventory can present several challenges for water utilities, not the least of which is inaccurate record keeping. In Cleveland Water’s case, records documenting service line replacements between 1954 and 1986 were either missing or incomplete, complicating the task. The customer side presents more challenges, and the department is combing through years of replacement records, as well as building and housing development records to help determine the locations of lead.
The department has also done some in-house detective work to locate lead. In one recent situation, using past records from a pipe cleaning and lining program, a GIS staff member discovered about 750 city-owned connections originally thought to be lead, actually were not. They were removed from the department’s GIS inventory as possible lead connections. The department estimates the move saved about $1.5 million.
“Paying attention to any paper record that you have can save you a lot of money,” says Brenda Culler, lead program manager at Cleveland Water.
Curb box cover style also helps determine the presence of lead. Cleveland Water has a number of triangle-shaped curb box covers that were still used into the late 1950s and early 1960s. Cleveland Water knows that about 90 percent of those curb covers were used at locations with a lead connection.
In addition, Cleveland Water leverages its contractors, who are on the lookout for previously completed connection replacements that may have been undocumented. The department also has a history of using city-owned service connection materials consistently on a given street. If one investigation reveals lead, it is likely the other service connections along the main are also lead.
For Cleveland Water, the only way to truly verify if lead is present in a service connection is through hydro excavation or potholing, making investigative efforts prior to field validation so critical. The department estimates the cost of hydro excavation or potholing to verify lead is about $2,200 per connection including tree lawn and curb box restoration.
Prioritization
Cleveland Water is using funds from the Bipartisan Infrastructure Law for its LSLR program, which requires prioritization of disadvantaged communities. In Cleveland, 13 of 78 communities in Cleveland Water’s service area meet the definition of disadvantaged communities. Those 13 communities have roughly 80 percent of the city’s lead service lines.
Cleveland Water uses census tracts to divide the amount of money it has for replacements. Based on census tract, communities with the highest concentrations of lead are getting the most lead removed in the first year of its full-scale lead line replacement program. Anytime it is verified that a customer has lead on their side of the connection, the city will prioritize replacing those connections.
The department is also replacing lead service lines beyond its disadvantaged communities. Since 2018, anytime Cleveland Water or one of its contractors disturbs a city-owned service line, the department will offer to replace the customer-side service line for free if it is lead. Since 2022, the same now goes for customer-side galvanized steel found downstream of city-owned lead, which Cleveland Water will replace free of charge.
“We want to be able to take out lead service lines on the customer side with available funding no matter where they are in our system,” says Culler.
Cleveland Water also prioritizes replacing “piggyback” connections in which houses on opposite sides of the street both have lead connections. In this situation, two lead connections can be replaced with one street excavation. Culler says the street excavation needs to be done properly in order to accomplish this, but since Cleveland Water has many lead connections on both sides, it makes sense to tackle these connections at once, which saves on restoration costs for having to excavate a street only once.
Replacement
In 2021, Cleveland Water launched a pilot program to remove lead service lines from state-licensed childcare providers that was funded with $2.5 million in state and federal grants. The city replaced lead service lines at more than 450 daycare centers in the area.
The first replacement as part of Cleveland Water’s full-scale program was completed in August 2023. Of the estimated 142,000 city-owned lead connections, Cleveland Water aims to replace about 4,000 lead lines via the LSLR program and an additional 2,000 that will be tackled with water main replacement and repair work, bringing the total to about 6,000 replacements per year. Even at this aggressive pace, the work is expected to extend out 25 years.
Margevicius says that timeline could be sped up if EPA’s LCRI proposal to mandate lead service line replacement within 10 years goes into effect. Margevicius adds, however, that it will likely be some time before the clock starts ticking on the 10-year timeline of the LCRI.
Some utilities are anticipating the LCRI effective date could come sometime in 2027, putting the deadline at 2037.
“Nevertheless, it’s an extremely accelerated time schedule for any legacy system that has a lot of lead to deal with,” he says. “That kind of schedule could require 2-3 times the rate of what we’re doing now to be able to meet that. In some respects, this is a defining issue for the short term.”
All lead service lines in Cleveland Water’s service area are 1 in. inside diameter (ID) or smaller, with most being 5/8 in. ID and some as small as ½ in. ID. All new lines will be made of copper.
The city doesn’t mandate a particular replacement method, but Cleveland Water and its contractors are proponents for trenchless methods. “The less invasive, the better, because that means less restoration – and we have to pay for restoration,” says Culler. “We don’t dictate to our contractors how they do the work, but all of our contractors are using either pipe pulling to pull the copper through where the lead line was with a cable, or they’re using pneumatic moling.”
Some installations are being completed via directional boring in which case the old lead lines are typically abandoned. As a last resort, crews will open cut a street to replace a lead service line when obstructions such as flow fill or other utilities prevent the use of a pneumatic mole to pull the new copper service through.
Culler says no matter the replacement technique, the goal for Cleveland Water on LSL replacements is to not disturb other underground infrastructure, which can result in more costs to the department or contractor, avoid disturbance to the customer and limit time that a street is excavated.
Challenges & Outlook
Cleveland Water has experienced supply chain issues lingering from the COVID-19 pandemic including for brass products, corporation valves and curb stop valves. Margevicius says he is concerned that the proposed LCRI may add more strain.
“If this country is going to ramp up to get rid of 9 million connections in about 10 years, it’s going to put a tremendous stain on the ability to procure all of that,” he says, adding that contractor capacity is another major concern that could worsen.
Margevicius, however, credits his department’s proactive approach to tackling lead and the importance of naming a dedicated point person in Culler to give the program the attention it needs.
“I am very proud that we have birthed this program strictly with in-house staff,” he says. “From what I can see, we’re one of the more aggressive cities to have pursued BIL money and have gotten shovels in the ground to remove lead voluntarily, while not under any sort of mandate, ahead of a lot of other places.”
Andrew Farr is managing editor of Water Finance & Management, published by Benjamin Media in Richfield, Ohio. He has covered the water sector in North America for 12 years. An alternate version of this article first appeared in the January issue of Trenchless Technology a sister publication to WF&M.
