1. Lead Service Line Replacement: Regulatory Perspective
06/18/2019
Justin Burke
Manager - Compliance Assurance Section
Division of Drinking and Ground Waters
Ohio EPA

2. LSL – Regulatory Perspective
LSL refresher/primer
LSL Challenges
Regulations related to LSLs
State and Federal assistance efforts
Summary

3. Lead Service Lines (LSLs)
Pipes and connections from main to the house
Lead could comprise the majority of the service line historically, copper and plastic are used now
Main -> “corp” stop -> gooseneck/pigtail -> service line pipe -> curbstop -> service line pipe -> water meter -> shutoff valve
“Public Side” vs “Private Side”

4. Lead Service Lines (LSLs)
Corrosion Control
Adjusting the water chemistry
Addition of an inhibitor
LSLs vs Fixtures

5. Lead Service Lines

6. LSL Challenges Administrative, Engineering, and Remediation
The balance of public health, priorities and costs

7. LSL Challenges Ownership of the LSL Costs Service disruptions
Legal authority to require private owners to replace the “private side” of the service line
Increase in lead concentrations in partial LSL replacements
Liability of construction
Costs
$2,000 - $10K for an LSLR
Estimate of $30B for nationwide
Service disruptions
Inconvenience
Temporary increase in lead concentrations

8. LSL Challenges Prioritization/Resources Will
Notification, corrosion control, data collection
Will
Political, Utility, Consumers
Greater Cincinnati Water Works and other large public water systems have successful LSL replacement programs
Local level efforts appear effective, but still require significant resources and political backing
Large public water systems have programs in place to replace LSLs when found on main repair/replacement projects
Small, medium systems struggle with costs, data

9. Regulation & LSLs
Focus compliance monitoring at locations that contain lead
Service Lines
Internal piping and materials that would have used lead components
By rule, public water systems can be required to replace LSLs when corrosion control is proven ineffective
Require public water systems to offer, at the expense of the owner, replacement of private side if system is replacing public side

10. Regulation & LSLs
Ohio House Bill 512 (Ohio Revised Code ) effective on September 9, 2016
Emphasized requirements for notification to consumers
Mapping requirements
New mapping rules in 2020/2021?
Did not address LSL replacement
Updated Lead and Copper Rules
Providing filters during disruption/partial

11. Lead Drinking Water Assistance
Lead Plumbing Fixture Replacement Assistance Grants (HB )
Administered by Ohio Facilities Construction Commission
$12M state funds ($15K per school for investigation and material costs for replacement)
Voluntary
2 rounds of grant awards

12. Lead Assistance

13. Lead Assistance

14. WINN Act & LSLs
Federal Water Infrastructure Improvements for the Nation (WINN) Act
Lead Testing in School and Child Care Program Drinking Water Grant
$43.7M nationally, $1.361M allotted for Ohio
No money for remediation, only investigation
Voluntary

15. WINN Act & LSLs
Federal Water Infrastructure Improvements for the Nation (WINN) Act (cont)
Ohio Department of Health (ODH) is state lead
Working with Ohio Jobs & Family Services to identify in-home daycares
Ohio EPA, ODH identifying funding resources for remediation (not funded by WINN grant)
Focus on disadvantaged communities

16. Summary
Significant funding and resource challenges for statewide LSL replacement program
State and Federal assistance programs focus on children
Regulatory programs focus on corrosion control and notification
Directives through legislation have focused on consumer notification rather than source removal (HB512, HB390)

17. Summary
Voluntary programs like GCWW’s LSL replacement program are successful, and could be used as blueprints for other public water systems
Statewide LSL removal requirements would likely need to come with funding alternatives and direction/authority to prioritize lead in drinking water for the public water system and regulatory agencies, as well as address private property considerations