Lead In Drinking Water: Chemistry, Policy, New York City Case Study – Hydroviv

Lead In Drinking Water: Chemistry, Policy, New York City Case Study

Lead In Drinking Water: Chemistry, Policy, New York City Case Study
*  Updated in July 2016 to include the most recent water quality reports.
With the spotlight on the ongoing lead crisis underway in Flint, Hydroviv has been getting a lot of questions about lead in drinking water.  In various discussions, it has become clear that most people don't understand how lead is regulated in municipal tap water.  Most people are surprised by the number of samples collected, and that most cities don't collect samples every year.  The goal of this article is to explain the rule that regulates municipal water providers, and to present a case study based on a water quality assessment that we conducted for a customer.

How Does Lead Enter Municipal Tap Water?

Lead contaminates tap water differently than most pollutants, because lead comes from plumbing, not the water supply.  For example, some buildings in older neighborhoods have lead-containing service pipes that connect water mains to the residential plumbing (see image below), and plumbing installed before 1986 often used lead-containing solder to join copper pipes.  If corrosion control measures fail (what happened in Flint, MI), lead can leach from the pipes into the tap water.   This problem is compounded when water sits stagnant for several hours before use (e.g. overnight or while resident is at work), because lead concentrations rise as corrosive water remains sits in the pipes.

Diagram Showing Underground Components of Residential Plumbing

Diagram Showing Lead Service Pipes In Washington DC, Chicago, New York City
Image From: https://www.dcwater.com/waterquality/household_water_quality.pdf

How Does EPA Regulate Lead In Drinking Water?

The Lead and Copper Rule was originally established by EPA in 1991 to protect the public from toxic levels of lead and copper that leaches from pipes.  Because the route of contamination is unique, The Lead and Copper Rule is fundamentally different from other drinking water regulations in two main ways:

Differences in Sampling Methodology:  Most water quality tests are performed on samples collected from locations under direct control of the municipality (water mains, service access points), while samples collected as part of The Lead and Copper Rule come from the resident’s tap.  By sampling at the tap, water flows through the underground service line and residential plumbing, and can pick up lead along the way if it's present.  Furthermore, the Lead and Copper Rule requires that samples are collected after the water has been sitting stagnant in the pipes for at least 6 hours, which gives time for lead to accumulate in the pipes.  This sampling method recreates common water usage scenarios (when residents are sleeping and/or at work), and attempts to hold municipalities responsible for providing water that doesn't draw lead from pipes.  This is a very good thing, because many people (particularly renters) don’t know a lot about their building’s plumbing or underground pipes.

While the lead and copper rule does a good thing by requiring samples to be collected at the tap, the rule has large "blind spots" when it comes to sampling practices.  For example, the rule does not require municipalities to collect large numbers of samples to be tested for lead, or even require that samples be collected each year.  This holds true, even for large cities like Atlanta, which last collected samples for lead analysis in 2012, and at that time it only collected and analyzed 51 samples citywide.  Other large cities, such as Dallas and Houston did not disclose the number of samples that were collected and subsequently tested for lead.

Differences in Violation Criteria:   For most pollutants, EPA establishes a risk-based Maximum Contaminant Level (MCL), and a violation is triggered if the concentration of the pollutant exceeds the MCL.   EPA has not set an MCL for lead, though it has set a Maximum Contaminant Level Goal (MCLG) of 0 ppb.  Unlike the MCL, the MCLG is a non-enforceable public health target where there is no known or expected risk to human health.

EPA uses a different set of criteria when determining violations under the Lead and Copper Rule.  Instead of using risk-based MCL thresholds,
 EPA uses a different term (Action Level) for the threshold, which is 15 ppb for lead.  It's important to point out that EPA acknowledges that there is no safe level for lead... so the 15 ppb threshold is somewhat arbitrary.  Using the Action Level threshold methodology, a municipality is in violation of the Lead and Copper Rule only if 10% or more of the samples have more than 15 ppb lead present.  To restate that in a slightly different way:  up to 10% of the samples can have lead concentrations higher than 15 ppb and still be in compliance, even if some samples have extremely high lead levels.   

Simply put, the Lead and Copper Rule is a system that is designed to detect system-wide process upsets, not to detect contamination events on short-term time scales.  

Case Study:  New York City Tap Water

New York City is widely recognized in the water industry as the “Gold Standard” for urban tap water  The source water is well-protected, the pipelines used to transport the water from the source are impressive feats of engineering, and the city spends a lot of money on municipal infrastructure.  However, in the case of lead, these things don't matter if lead is able to leach from residential plumbing.

This is particularly important in New York City for two main reasons:  
  • There are a lot of older buildings in New York City, which are most likely to have lead-containing service pipes and residential plumbing  
  • A large proportion of New York City residents are renters, and have little or no information about the age/composition of their building’s plumbing

Compiled Lead Test Results New York City Tap Water
​(EPA Action Level = 15 ppb)
New York City Tapwater Lead Table

Data are compiled from publicly available water quality reports provided by New York City: http://www.nyc.gov/html/dep/html/drinking_water/wsstate.shtml)
During this time frame, 2010 was the only year that New York City was in violation of The Lead and Copper Rule, despite the fact that a meaningful number of samples tested positive high each year.   In addition to this, it's important to point out that the maximum lead level measured in some years is several hundred times higher than the 15 ppb action level, and did not trigger a violation.

Because the reported lead concentrations were all over the map, Hydroviv advises our customers in NYC to take advantage of the free lead testing program available to all NYC residents.  Under this program, people can request a free kit to test for lead in their drinking water by calling New York City’s 24-hour helpline at 311 or visiting www.nyc.gov/apps/311

To minimize lead exposure from drinking water, New York City  (as well as other municipalities) recommends that you allow your water to run for 2 minutes (or longer if you live in a large building) before collecting water for consumption.   Doing so allows the stagnant water that is in residential pipes to flush and be refilled with fresh water coming off the main.  


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