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Replacing Lead Water Service Lines in Massachusetts Emily Wexler, Joshua Taylor, Matthew Tate, Katelyn Wittkowski, Katherine Calandriello, Zachary Popp, Julia Nassar, Darden PilkintonAbstractBecause lead’s toxicity causes significant injury and associated costs it is a critical public issue. It has long been known that lead poisoning is of special concern to children, but recent information shows it also harms adults, and that its damage is extensive and expensive. Some Massachusetts municipalities are taking action or have taken action to address lead service lines, which can be a significant source of preventable exposure to lead. Two of only six municipalities we found in the U.S. to have completed lead service line replacements are in Massachusetts, and the state has provided funding to assist communities with lead in schools. Despite this, in many municipalities in the state there remains the issue of lead exposure, in particular from lead service lines in residences. There is also reason to conclude that the federal standards for lead content in water are not sufficient to maintain public health. We interviewed the water departments we were able to identify that had successfully replaced all the lead service lines in their community, to glean information about how municipalities may efficiently address the problem, and then we contacted all municipalities in Massachusetts to ask what they are doing about water pipes made of lead serving homes. The results of that survey are incomplete, but they provide indication that concerted statewide action is necessary to assist municipalities in preventing exposure in residences to lead in the water they drink. IntroductionWe found only twelve states in the U.S. that have policies that support community lead service line replacement programs; although Massachusetts is not one of the twelve, some of its communities have undertaken initiatives of their own to address the problem. Two of the five communities that have been recognized by the Environmental Defense Fund (EDF) for having fully completed lead service line replacement programs are in Massachusetts: Framingham and Springfield.There are federal regulations for the amount of allowable lead in drinking water, but many experts consider these inadequate to protect public health. This is especially true when the lowest achievable amount of lead is theoretically zero, with proper steps taken in infrastructure management by municipalities. These projects may seem initially of such a scale that they are impossible for most communities, but with some guidance, they are achievable. The costs of lead being allowed to persist in water exceed the savings from refraining from launching replacement programs.This report compiles information from both successful programs in the U.S. and from municipalities in Massachusetts about lead service line replacement, and commonalities between strategies used.MethodologyOur research involved three phases:Analyzing existing data about lead concentration in drinking water in Massachusetts.Analyzing completed programs that have succeeded in fully removing lead service lines across the nation.Analyzing the status of lead service lines in Massachusetts across all municipalities.Phase 1 Involved using data from the Massachusetts Department of Environmental Protection (MassDEP), which conducted a study in late 2017 of drinking water across schools in Massachusetts. Since it was a part of a voluntary initiative to eliminate lead from schools’ drinking water, there were some limitations to this data; only about half of municipalities had any schools tested. This information was cross referenced with income data for municipalities to discern where lead exposure was the worst. Schools and childcare facilities that exceeded regulation for lead in the water were used as indicator variables for communities likely to have exposure problems generally. The data showed that lead pollution in schools did not indicate a strong correlation with income, countering conventional ideas that lead poisoning is primarily a problem of poorer areas of the state. The data showed a problem of lead exposure across Massachusetts. It may be assumed that if lead is showing up in schools, that it is also a problem in residences. Children may also be considered as facing more risk in their own homes, as well as their parents and other adults, because it may be expected that there would be higher rates of water consumption at home, and there may be no effort to test for lead or manage the problem. It was also learned that lead may exist in school water even after a full scale replacement of lead service lines, as was found in Springfield. This happens due to fixtures in schools still containing lead, or faulty water heaters, or other site issues that are not affected by a replacement of the service line.Phase 2 Each of the five municipalities the EDF had identified as having completed LSL replacement programs was contacted with the hope of speaking with an executive or engineer related to the replacement project. The five cities contacted were: Sioux Falls, SD; Madison, WI; Lansing, MI; Springfield, MA and Framingham, MA. Each of these projects were completed on different time scales in different area sizes of areas, and with different funding plans. The diversity of the details of the programs proved advantageous in some respects and detrimental in others. Part of the interviewing process included asking for recommendations to other municipalities considering launching a project, so having a diversity of conditions made those answers more helpful. In some cases, such as the case of Springfield, the timescale of the project proved detrimental, as it was launched in 1992, so by Fall of 2018 when interviews were attempted, there was no one involved in the design of the project still working with the department.Some of the questions to the engineers and executives included: “Why did your community undertake the endeavor of replacing lead service lines” to try to determine motivation for projects; “How did you estimate and handle the time and cost it would take to replace the lines, and how accurate were those estimates” to determine different methods of budgeting such large scale projects; “How did you engage the public, and was there any pushback against the project” to understand different tactics of gaining public support. Future surveys of communities that have undertaken to address the problem should consider asking more detailed questions, such as the specific manner of replacement, which one water department pointed out was important. If pipes are pulled or dug out of the ground can make a significant difference in costs. How pipes are identified, how or whether homeowners are charged, how the work is budgeted or paid for are all critical issues needing further examination. However, our survey indicated that cities can address the issue of lead service lines without extraordinary costs, countering the conventional expectation that the problem is simply too expensive to manage.Phase 3 After completing the interviews and preliminary research, a survey was designed for the state of Massachusetts, to send out to all municipalities with questions about their plans concerning lead service line replacement, including whether the city (or town) had created an inventory of lead service lines.ResultsPhase 1: MassDEP’s survey included information about the distribution of income and schools with lead above action levels: While the high outliers, communities with more than ten schools with lead content above action level, are on the lower end of the income spectrum, (mostly at or below $50,000 average annual income), the general results are fairly uniform. For the towns surveyed, across all incomes, there is a fairly uniform distribution of towns with between zero and five schools with lead above action levels, of schools surveyed. Just over half of municipalities participated in the survey, so it is justified to conclude that while the problem of lead in school water affects municipalities of lower incomes more than higher incomes, it is a problem that affects all municipalities in Massachusetts. Every community needs to address lead in water.In addition, troubling uncertainties remain. Data on the proportion of participating schools in a given municipality was not present, so exposures in many may remain unexamined, and data from many communities was simply absent. Although Massachusetts has set up a trust fund set up for Massachusetts schools through MassDEP to pay for this testing, the voluntary nature of the program does not provide sufficient information to know that the health of Massachusetts residents is being protected.Phase 2:Sioux Falls, SD:Excerpts from the interview with Greg Anderson, the water superintendent for the city of Sioux Falls. Our questions are in italics.One of the difficult aspects to deal with in creating a program like this is cost, and different cities have used different approaches to financing the program. We saw in the (Sioux Falls) newsletter a mentioned rate increase, is that related to the lead service line replacement program? If so, how long do you estimate it will take for that to pay off the program, and if not, how did the utility budget the money for this program?The water rates did not include any cost of the service line removal initiative. With the exception of fuel, equipment wear and tear, brass and copper pipe the only additional cost was the rental of a mini excavator. We budget for one every few years so some years we rent one and some years we don’t. The maintenance team we have either removing lead lines or other maintenance tasks. We managed to perform all work necessary even with the lead line removal initiative. Everyone just performed more work.I calculated costs: labor, equipment, fuel, paving costs and parts,. Surveyed costs from contractors. We didn’t bid out the work and a consultant was not hired. This is what we do, maintenance. The cost saving were engineering costs, and the difference between what a contractor charges versus our expenses. Our cost per service line was nearly 35% on contractor costs.”Prior to and after 2016 how were you estimating the number of lead service lines? Was there a record of contracts, or home testing, etc.? We were also only able to find how many lines were replaced after the program was launched in 2016, do you know how many were replaced prior?I didn’t know how many were replaced prior to the 2016 initiative. That would depend on the area of town involved with the water main replacement program. That didn’t really matter, it was important to remove what was remaining. I hired part time staff, used existing staff, and engineering staff to find every electronic and paper file known to complete a thorough audit of all known service lines and plotting all services with lead. This lasted for most of 2015. From the data collected I developed a four quadrant map of the city with all known lead service lines.Next step was to perform an actual audit of the properties identified from the audit. Part time help knocked on doors, color paper handouts were left with the customers that didn’t want us to enter the home. Phone calls were placed. I believe we contacted each home with a lead service line. We had support with every customer. No one refused.We worked in each quadrant, first area of focus were important customers such as schools and churches. We wanted the work completed during the time of week or month with the least negative impact to the customers.Coordination with our street department. They follow behind us to patch every dig site.We rented a mini-excavator, used our backhoes, and tandems. All parts and supplies were removed from our existing inventories. (copper and brass) (no-lead brass)”Another difficulty communities face in launching these programs is the reaction of residents to the program. Was there any financial aid to residents to replace their lead pipes, and in general how did people react to the program? Can you send us any materials you might have used to engage them about lead? One of the problems we have faced is that some communities here have faced pushback against replacement, with residents saying that they do not think lead in their water is a very big issue. As such, how you distributed information, both about lead itself and about how residents can deal with lead, is very valuable.We didn’t have any push back from the public, there were two customers that still had lead from the curbstop to the meter. One paid for the work without complaint, the other could not pay for the work. I asked what she could pay each month and she said 20 dollars. I said deal and without interest. We paid for one service line from the curbstop to the meter (contractor installed). Our billing team indicates this owner pays the agreed upon amount each month. She is actually paying more than the 20 dollars.I’m a water professional all the time, not just when there is money. I don’t allow lead to stay in use once we find out. We can make a deal somehow. The safety of drinking water is not just part time it is all the time.I have a great team, I took the proposal to them, they worked out the details and gave me the buy-in that was needed to complete the work. The lead service line removal is just maintenance, that is what we do. We just made the time to complete the work.Four team member, two service lines per day, 10 hour work days. Four day per week. I believe we averaged the 8 per week. Utility locates were called in prior to the block where they were going to work. Notice was provide to customers, sometimes we brought in water or reschedule for a different area if the homeowner had something planned. Cooperation with the public. I don’t remember receiving a single negative call for the entire time we removed the lead service line.”Finally, if you were making recommendations to other municipalities, is there anything you would call the key to your success in this program?Support the maintenance team, provide the tools they need, set reasonable goals and expectations. Stay out of their way. Trust them, it takes freedom to succeed.Mr. Anderson’s program had a few common elements with the other successful programs surveyed in his development of a clear and achievable plan, and the drive to stick to that regimented plan. This is imperative due to the time scale of many of these replacement projects, which can last for up to a decade. They require a high level of organization. He also mentioned a coordination with maintenance projects and programs, which shone through other water departments surveyed as important to the success of the project. In this case it was a budgetary measure, of taking advantage of staffing and rental provisions in order to finance the replacement of the lines. Very much in evidence is also Mr. Anderson’s vision for the purpose of the project and his focus on public health; that he would work and coordinate with residents on paying for replacement and on timing of replacements to be the least bothersome to residents. That level of care and vision for the health of his city seems integral to his success, and also a commonality with the few other cities in the country to have completed the same kind of project.Lansing, Michigan: Excerpts taken and paraphrased from a phone interview with Joe Eastman, Project Engineer, Water and Steam Distribution.Why did your community undertake this endeavor?There had recently been a replacement in D.C. at the behest of Congress and the EPA, but it was a partial replacement. Partial replacements have issues associated with them, and Lansing wanted to undertake a similar project, but instead target full replacements. Partial replacements cause a disturbance in the system, which then causes lead levels in the water to increase, which then fall slowly.Did you test private residences for lead content?Lansing did not test residences for lead content, rather if there was no way to determine whether piping was lead, it was replaced by default to ensure that it was safe.How were the cost of the program and the time it would take to complete the program estimated?The department initially estimated 15 years, but was ordered by city hall to instead complete the project in 10 years. During the recession work slowed, and instead the project was completed in 12 years. The cost estimates were variable, but kept lower than estimated because the department took advantage of existing sewer maintenance programs. They would take advantage of where the company had already scheduled work to be done in an area, meaning much of the digging was either done or the equipment was at least already rented, and perform replacements there. Otherwise, the project was financed by a grant, a slight rates increase, and by cutting the improvement budget year to year.Were certain sites prioritized over others?The program prioritized schools and elderly care facilities, but people could request to be pulled ahead, the idea being to target the most vulnerable people first.How did you engage the public about this replacement?The public mostly accepted the program, and was engaged throughout the process. The department coordinated with residents to find when convenient times would be for the replacement. If the resident had some sort of event planned, the replacement was rescheduled, this ensured public support. As well, town hall meetings were held, though their format was variable. Initially, the water department held open town hall meetings about the topic, but found that the conversation quickly meandered from questions about the replacement. They instead advocate doing a station based town hall. Having a town hall meeting where the water department has 6 or however many stations based around frequently asked questions, and has staff and materials present to answer questions. This helped keep the conversation focused around the topic. They also did mass mailings of residents to inform them of the project and why it needed to be done.What advice would you give to other communities?Even if the plan isn’t perfect, launch it anyway, and consider having the water department seize the lines up to the meter.Mr. Eastman also provided a package of materials used to engage the public and steps necessary to launch a replacement plan modeled after the one used in Lansing. The common elements seem to be having a regimented plan and a coordination with existing maintenance programs. Mr. Eastman was the most explicit about the importance of engaging the public and the specific methods they used to do so, highlighting the importance of taking public input on the project and having public support and understanding of the real risks of lead exposure.Madison, WI: The water department of Madison,Wisconsin, headed by Joe Grande, provided a chemical study that convinced them to pursue full replacement of lead service lines, rather than corrosion control. It outlines how the chemical treatments the EPA recommends should not be assumed to be effective. They can, according to the report, actually increase lead levels in drinking water due to corrosion. The study recommends full replacement of lead service lines. Madison also had a unique method of financing their project: the city leased the spaces on top of water towers to telephone companies to build towers. That money was allotted for lead service line replacements.Phase 340 towns responded to the survey sent to them, representing about 11% of Massachusetts municipalities. Of those to respond, the vast majority claimed that their residents are not served by public water. We received 13 responses with information concerning actions to address the issue of residents served by public water. Though a small sampling, these responses provided valuable information about lead service line replacement.The Belmont water division provides an annual mailer to residents about lead in water. The division also has a water main replacement program due to age, and when non-copper service lines are discovered during this process, they are upgraded to copper. This is in line with the advice of the successful communities to coordinate with existing maintenance projects.Harvard provides annual information as well, and claims to have replaced all lines.Harwich water department responded that there are no full lead service lines in its community, but there are some lead goosenecks in the piping. They do not target them directly, instead targeting older metal piping in general. This frames the issue as one of infrastructure and age. Those replacements are budgeted year to year, making the replacements a routine aspect of the department, rather than a project. This is a way to understand the issue that prevents the misconception that lead line replacement is an “extra” cost, not an integral part of drinking water delivery systems.Hingham is a member of the Lead Service Line Replacement Collaboration, and responded that creating a lead service line inventory is an important step to replacement.Mendon is currently in the process of creating a lead service line inventory, to allow for formal inspection of the problem.Natick claims to have removed all lead service lines.Plainville replaces lead service lines as they are discovered through routine maintenance practices.Plymouth conducts partial service line replacements, where the piping is replaced up until the property line.Lee has no lead lines, but replaces lead goosenecks as they are discovered.Lenox outlines an issue where even without lead service lines one of its schools had issues with lead in its water. The department indicated that this issue was caused by a fault in a hot water heater, which was then replaced. This highlights the importance of attention being paid to fixtures in addition to replacements of lines.Westborough claims to have replaced its lead service lines in the 1980s during routine upgrades.DiscussionEaston, Falmouth, Harwich and Hingham mentioned pH or corrosion in their responses about lead control in water. Given the study commissioned by the Madison, Wisconsin water department, these control methods may not be fully effective. They should be reevaluated and coordinated with actual on site testing for places serviced by water for which those methods are used.Plymouth mentioned partially replacing lead service lines in its community, which is not recommended, as it can increase lead concentration temporarily in the water. Fully service line replacements are more effective.There was also an issue in the study in that many of the communities claimed that their residents are serviced by well water. The municipality may not be directly responsible for the quality of their water, but may consider the interest it has in protecting the public health of citizens within its jurisdiction. The piping used by those residents could still be lead. If there is no public ownership of these lines, however, there may be a difficulty in using public monies to address the problem. This is an issue that is likely best addressed at the state level. Any future survey should attempt to understand the extent and seriousness of lead exposure from private drinking water sources. A requirement for testing data to be submitted to a central, publicly available source could help, while also providing a means for prospective tenants or purchasers to have access to data is material to their health or decision to purchase or rent (analogous to lead paint disclosure requirements and public lead registries and blood lead level information). Most communities claimed to provide information about lead in water to their residents. The survey did not ask what language these materials are offered in, which is important in many communities. Future surveys should correct for this oversight and the state could take action to review the information provided to ensure that it is fully informative and has preventive value. For example, some advice for testing includes the suggestion that an accurate reading of typical lead levels is obtained after flushing. But some people use the first draft (for example, to make their coffee after the water has been sitting in the pipes all night, or of greater concern, to fill a baby bottle first thing in the morning). Information should include adequate warnings concerning the use of water that has not been flushed, and testing before flushing will provide a better indicator of the presence of lead in the water delivery system.ConclusionThe problem of lead in water is widespread throughout Massachusetts and the nation. The solution to this problem is full scale replacement of lead service lines. Many consider this solution to be prohibitively expensive, but communities that have implemented it have not found that to be the case.There are a variety of tactics to achieve that goal, and a variety of financing options. Those tactics have commonalities both practically and administratively. Practically, a strong coordination with existing maintenance programs proved beneficial to the program. On an administrative level, coordination with communities and a focus around public health allowed for success. The issue itself is one of infrastructure. Lead is a dated material. The lines that incorporate it are aging, and their replacement is inevitable as they degrade, the same as any other material. Though these projects may seem grand in scale, when examined they really are not. Lansing budgeted $40,000,000 for its project. Disregarding any other financing options, imposing that full cost on customers to the department would have correlated to a water bill increase of approximately $6 per month. In actuality, the cost was much lower.There are a host of funding options for communities to use in launching their programs, and communities should budget for the expense over time, spreading the cost and spending efficiently by coordinating with existing, ongoing planned work. As time progresses, if grants for projects and recognition decreases, yet the recognition of the cost of lead poisoning increases, communities can justify action by understanding replacement as part of drinking water system maintenance. By joining the issue of public health protection to the issue of decaying existing piping, the benefit of efficient management of public concerns may become more apparent.Supplements and AcknowledgmentBackground materials and raw data files are too large to append to this report and are on the website bu.edu/rccp as supplements to this report.Supplement One is the MassDEP’s survey of lead in schools.Supplement Two compares average community income to lead levels in MA schools.Supplement Three contains materials used by Michigan water officials.Supplement Four is the Corrosion Study that convinced officials to prefer line replacement.Supplement Five is a compilation of the responses we received from our survey of MA municipalities.Supplement Six is the 2015 Report of the Lead and Copper Rule Working Group To the National Drinking Water Advisory Council that recommends full replacement.We wish to acknowledge the fact that we are aware of other communities and public officials taking responsible action, who do not appear in this report, and the fact that our research does not provide a full picture of the response to this issue. We wish to thank these public officials and the citizens of communities who have contributed their voluntary efforts to the issue of safe drinking water. We particularly wish to acknowledge a debt to the work of clean water activists, most especially Clean Water Action, and Maureo Fernandez of that organization, who provided substantial assistance and advice to the team in this work. We also wish to thank BU’s Earth and Environment Department for providing us the opportunity to do this project. ................
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