Title
Update on Lead and Copper Rule Revision
Description
This report provides the Transportation, Infrastructure and Planning Subcommittee an update on the impact of the Lead and Copper Rule Revision to the City of Phoenix Water Services Department.
THIS ITEM IS FOR INFORMATION AND DISCUSSION.
Report
Summary
The U.S. Environmental Protection Agency (EPA) established the Lead and Copper Rule (LCR) in 1991 to protect public health and reduce exposure to lead in drinking water. The most common source of lead in drinking water is lead leaching from household plumbing, including from certain brass fixtures, copper piping joined with lead-based solder, and lead service lines. When water stands for several hours in lead pipes or plumbing fixtures containing lead, the lead may dissolve into the water due to the corrosivity of the water. Lead particles can attach to the surface of galvanized material like galvanized steel and iron.
On Jan. 15, 2021, EPA finalized the first major update to the LCR in nearly 30 years, referred to as the Lead and Copper Rule Revisions (LCRR). The LCRR seeks to protect children and communities from the risks of lead exposure by better protecting children at schools and childcare facilities, getting the lead out of our nation’s drinking water, and empowering communities through information. Community water systems, such as the City of Phoenix, must develop a publicly accessible lead service line inventory and a formal plan for replacing the lead pipe infrastructure in their communities. The inventory must include a material classification for service lines for both the city and customer-owned portions. The LCRR also requires community water systems to monitor all elementary schools and childcare facilities within the first five years of the rule and upon request thereafter.
As part of the 1991 Rule the Water Service Department (WSD) is required to sample and monitor drinking water at customer taps. The City of Phoenix water system has been and currently is below the established action limits for lead. A large part of this success has been due to a department policy to eliminate and replace all known public lead service lines as a response to the rule.
Inventory and Replacement
As required by the new law, WSD is in the process of inventorying all water services lines, for both the public and private side, within the City’s water system to determine the material type of each service. The service line is the small pipe that connects the home or business to the City water main. The delineation between the City and the customer ownership is the water meter. Most services within the City’s water system are copper, galvanized steel, ductile iron, or plastic. At the time of this report, the WSD has identified 71% of the service lines within the system. At this time the WSD has not identified any lead services lines in the system. If any lead services are found, the lead service will immediately be replaced with copper, a new water meter will be installed, and educational material will be provided to the customer. The department is expecting that the services line investigation will be complete by Dec. 2023. Once the full inventory is completed, the results will be provided to the Arizona Department of Environmental Quality (ADEQ) who oversees the LCRR for Arizona.
The LCRR also requires water system providers to address galvanized steel service lines since lead particles can attach to the surface of galvanized material. The WSD expects to replace all galvanized services as part of compliance with LCRR. Based on the expected results from the inventory program, WSD plans to replace approximately 3500 galvanized service lines on the public side of the meter. In addition, WSD expects approximately 2500 services lines will need to be replaced on the customer side of the meter. For both the public and private service line replacement, WSD estimates the total cost to be approximately $40 million. WSD is currently evaluating funding options for customers to replace their private service lines.
Community Outreach
A large portion of the new rule is public outreach and communication. The LCRR requires community water systems to notify customers initially, upon completion of the lead service line inventory, and annually. Additionally, community water systems must notify customers during a disturbance to a known or potential service line containing lead and, in some cases, supply a water pitcher with filters. The LCRR also requires engagement with the schools and childcare facilities they serve by providing annual public educational materials according to EPA’s guidance for reducing lead in drinking water.
In Jan. 2017, the ADEQ initiated a six-month, statewide screening program for lead in the public school districts' drinking water. As a municipal public water provider, WSD supported the screening program and the benefit to Arizona’s children’s health. WSD provided sampling and analytical assistance. ADEQ and its partners collected 16,125 samples from 14,782 fixtures at all public schools, taking immediate corrective actions and retesting fixtures in buildings that tested higher than the screening level limit. This program confirmed that drinking water in public school districts is not a common source of lead in Arizona.
The LCRR requires that community water systems test for lead in drinking water in elementary schools and childcare facilities that they serve. The 1991 LCR had no federal requirement for community water systems to test for lead in drinking water in these buildings. However, children spend a significant part of their days at school or in a childcare facility. The faucets that provide water used for consumption, including drinking, cooking, preparing juice and infant formula, should be tested. As part of LCRR, WSD is required to test at elementary schools and childcare facilities over a five-year period (20% of the facilities each year). The facilities will receive annual outreach and have the opportunity to be tested for lead upon request. Secondary schools will also receive annual outreach and be given the opportunity to request testing. As part of the 2017 ADEQ school program, all identified lead issues in the City of Phoenix public school districts were addressed. WSD is currently establishing a list of schools and childcare facilities, developing sampling instructions, developing educational materials, and implementing procedures to track and report all activities to ADEQ.
WSD is developing a website to communicate information about LCRR with the public. The website will have information about the health effects of lead exposure along with links to information from EPA. The website will also have a mapping feature which will show the material type of each service line. Results from sampling at schools and childcare facilities will be shared on the website. WSD expects to have the website available in Jan. 2023.
Location
Council District(s): Citywide
Department
Responsible Department
This item is submitted by Deputy City Manager Karen Peters and the Water Services Department.