Managing Lead Compliance

glass of water

Efficiently Managing Lead Testing and Data Collection Is Becoming More Prevalent for Water Utilities as LCR Mandates Evolve

Professionals across the U.S. water sector would likely admit that while it was a catastrophic event, the water crisis in Flint, Michigan, stemming from 2014, pushed the topic of water infrastructure into the national spotlight.

Unfortunately for water utilities, the story was not a good one. The crisis cast negativity and doubt about the ability of public water systems to provide safe drinking water to the public. It also raised many questions about the risks posed by lead service lines that deliver potable water to homes, as well as the practices of utilities to make sure customers’ drinking water is lead-free (even though Flint was about more than service lines).

According to the U.S. Environmental Protection Agency (EPA), lead can enter drinking water when service pipes that contain lead corrode, especially where the water has high acidity or low mineral content that corrodes pipes and fixtures. The most common problem is with plumbing materials that contain brass or chrome-plated brass faucets and fixtures with lead solder, from which significant amounts of lead can enter into the water.

According to the Centers for Disease Control and Prevention (CDC), exposure to lead and copper can cause health problems ranging from stomach distress to brain damage, and those risks are especially higher for pregnant women and young children. Although most lead exposure occurs from ingesting lead paint, dust or lead-contaminated soil, EPA estimates that 10 to 20 percent may come from drinking water.

EPA’s Lead and Copper Rule (LCR) has regulated lead and copper in drinking water since 1991. Although the LCR has undergone various revisions throughout this time it continues to mandate lead and copper in drinking water fixtures.

Industry-wide Initiatives

In the aftermath of the Flint crisis, several recent initiatives across the industry to eradicate – or at the very least educate – about lead in drinking water have come to the forefront. The American Water Works Association (AWWA) has been a strong proponent of LCR revisions that would require more accurate utility inventory of customer lead service lines and greater transparency with customers about lead pipe and fixtures.

“Communities have taken positive steps for more than two decades to reduce lead exposure from water and other sources,” AWWA CEO David LaFrance has said. “But there is clearly much more to be done. The Flint crisis lays bare a simple fact — as long as there are lead pipes in the ground or lead plumbing in homes, some risk remains.”

AWWA’s Board of Directors voted unanimously in March 2016 to support recommendations from the National Drinking Water Advisory Council (NDWAC) for the complete removal of lead service lines. An AWWA study published a month later estimated that more than six million lead service lines remain in the United States, with ownership of individual pipes often split between the utility and customer. AWWA has said that number suggests progress in lead service line removal over the past 20 years but also indicated that an estimated $30 billion challenge remains (when the LCR was instituted in 1991, EPA estimated there were 10.2 million lead service lines nationwide).

“The primary mission of community water systems is to protect the health of the people they serve,” LaFrance added. “Revisions to the [Lead and Copper Rule] should advance strong customer protections today while we work for a future where lead is no longer in contact with the water we drink.”

In 2017, the Lead Service Line Replacement Collaborative was launched, announcing a joint effort to accelerate full removal of the lead pipes across the United States. The Lead Service Line Replacement Collaborative is composed of 26 national public health, water utility, environmental, labor, consumer, housing and state and local governmental organizations. The focus of the Collaborative is to encourage communities around the country to develop and begin implementing plans for full replacement of lead service lines. The group has also released an online toolkit to help communities voluntarily develop and implement lead service line removal programs.

LCR Compliance & Sampling

In 2014, the NDWAC Lead and Copper Rule Working Group was convened to provide advice to EPA in addressing five issues related to LCR compliance: sample site selection criteria; lead sampling protocols; public education for copper; measures to ensure optimal corrosion control treatment; and lead service line replacement.

In response to the noted industry initiatives around lead, many utilities have responded by improving transparency with customers about possible lead pipe materials in their neighborhoods. But for water systems, public outreach on lead risk and mitigation is only part of the challenge. Ultimately, managing everything that goes into complying with Lead and Copper Rule regulations presents additional challenges and calls for a streamlined process.

120WaterAudit, founded in 2016, is one company working to help utilities bring better continuity and organization to LCR compliance. A cloud software and testing kit provider, 120WaterAudit works with government agencies and public water systems to implement drinking water compliance programs.

As Megan Glover, co-founder and CEO, explains, new regulations and the Flint water crisis, in addition to aging infrastructure across the United States, have spurred many lead compliance programs at public entities, namely water systems and school districts.

“There are new capital infrastructure programs and compliance programs that public water systems and school districts are having to execute and the government agencies are having to regulate,” she says.

Specifically, 120WaterAudit helps clients execute the following programs: Lead and Copper Rule mandates, lead service line inventory and replacement programs, lead sampling in schools and consumer request. The company got its start in late 2016 when it began working with the Pittsburgh Water & Sewer Authority (PWSA), which had instituted a consumer request program for lead sampling that was four months behind schedule.

120WaterAudit developed an EPA-approved consumer lead testing kit that could be used for compliance. PWSA partnered with 120WaterAudit to help streamline the process of conducting lead sampling, incorporating the company’s unique, simplified testing kit for residential customers.

Sampling kits are shipped to households in the utility services area with a return label inside. Customers then fill a beaker with water and drop it back in the mail, after which it is sent to a lab for testing. Results are then sent back to customers using 120WaterAudit’s proprietary software provided to the utility.

“Given this consumer product that we already build with a logistics back-end, we were able to implement the technology, provide testing kits and take [PWSA’s] four-month turnaround time down to 14 days for collecting lead samples,” says Glover.

Glover, who has a background in marketing for business-to-business cloud-based software, says she was moved by the events in Flint, which inspired her to start looking into Safe Drinking Water Act regulations and the ways in which everyday people can go about getting their water tested for lead.

By having a consumer request kit, utilities are also able to update location information of customers to streamline the process for the future.

With 120WaterAudit’s software, kits and managed services, utilities can manage and execute water quality programs that scale, save operational resources and assist managers improve public health outcomes through the management of these point of use programs.

As part of 120WaterAudit’s work with public water systems, the company helps utilities provide customers with point-of-use solutions including testing kits and filters, simplifying the process of acquiring samples from customers.

Based on discussions with multiple utilities, Glover says water quality managers at utilities have rarely had to interact “past the meter” like they are now.

“They’ve never been tasked with managing the [lead testing] data that they actually need to execute these programs,” she says. “Some of their data is managed on paper in file folders, some of their data is held hostage in their consumer information system, some of their location data is held hostage in their GIS.” 120WaterAudit aims to centralize utility data that water quality managers need to complete a testing program.

“We’re taking an antiquated process, which is costly, and not only saving [the utility] money, but we’re helping them scale the process of managing lead compliance,” Glover adds.

One of the key aspects of the testing program with PWSA is that lead tests were offered to ensure any customer in the service area had access to information about their water’s lead content. The data collected helped Pittsburgh refresh their Lead and Copper Rule sites and make informed decisions as they embarked on their Lead Service Line replacement project.

“We’ve learned that the results of compliance testing are highly variable,” says PWSA Executive Director Robert Weimar. “While we’re pleased that the latest results are trending downward, PWSA will not rest until we improve our water treatment using orthophosphate and replace the lead lines in our system. We know what needs to be done, and we’re moving full speed ahead to deliver for our customers.”

Pittsburgh’s consumer request program for lead sampling is ongoing, and 120WaterAudit is also working with the utility to help manage its lead service line replacement program, which requires water distributed through service lines to be tested before and after replacement.

120WaterAudit also provides utilities with its in-house proprietary lead program management software, which helps to centralize data related to lead programs, integrate customer information and other systems of record, manage program workflows, save time and improve communications for lead programs.

Lead testing practices also tend to vary across utilities.

The Cleveland Plain Dealer recently published a story examining Cleveland Water’s lead and copper testing process. The report revealed that Cleveland Water relies on samples collected in many cases by city and water department employees at their homes. The Plain Dealer article notes that the practice is not prohibited by regulators, but suggests that because tests are coming consistently from the same locations (the locations of employee residences), there is a lack of testing occurring in various neighborhoods, including low-income communities.

According to The Plain Dealer, Cleveland Water defended its process, as Scott Moegling, water quality manager, noted that consistency in the samples tested measures the effectiveness of water treatment methods. Utility officials also said the lack of testing in high lead-poisoning neighborhoods isn’t intentional, but rather a result of not having volunteers from those areas helping with the sampling, for which there are strict standards.

School Districts

The issue of lead in drinking water at school districts has received increased media attention since Flint.

As of September, 57 out of 86 schools tested in the Detroit Public Schools Community District have been found to have elevated levels of lead or copper in the drinking water, according to the Detroit Free Press. Those results came on the heels of the district shutting off water across 106 school buildings.

In Indiana, more than 900 public schools have had their water fixtures tested recently for lead levels under a state-funded program. In August, the Indiana Finance Authority said 57,000 water samples were collected from 915 school buildings to identify fixtures with lead levels exceeding the EPA’s action level of 15 parts per billion. Roughly 60 percent of those schools tested had at least one fixture with lead levels exceeding the limit, according to the Associated Press.

Within the first four weeks of launching 120WaterAudit, Glover says her and her team were contacted by school districts looking for a similar lead testing kit to help comply with impending regulations that would mandate school lead testing. Similar to what it offers utilities, the company can partner with school districts to offer lead program management software, point of use solutions including kits and filters, certified laboratory contracts within the state, environmental consulting contracts in the state, as well as managed services and technical assistance.

The importance of managing lead compliance as part of broader industry initiatives to eradicate lead service lines has drawn the attention of both the industry and the public, and going forward, it will be interesting to see what kind of expansion takes place in the United States with rehabilitation and/or replacement programs.

According to AWWA, it will still take utilities time to complete inventory and prioritize lead service line replacement, along with identifying funding mechanisms to assist in payment for the work. The association added that many customers will likely face affordability challenges in replacing lines on their property. For now, there seems to be positive momentum with companies such as 120WaterAudit entering the market offering solutions to help utilities optimize the enormous inventory and prioritization challenges that exist in addressing lead in drinking water.

Andrew Farr is the associate editor of Water Finance & Management, published by Benjamin Media. He has covered the water sector in North America for six years and also covers the North American trenchless construction industry for sister publications Trenchless Technology and NASTT’s Trenchless Today.

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