EPA's Lead and Copper Rule for Clarksville Gas & Water

WHAT IS THE EPA'S LEAD AND COPPER RULE?

40 CFR Part 141 Subpart I

In 1991, EPA published a regulation to control lead and copper in drinking water. This regulation is known as the Lead and Copper Rule (also referred to as the LCR). Since 1991 the LCR has undergone various revisions.

The treatment technique for the rule requires systems to monitor drinking water at customer taps. If lead concentrations exceed an action level of 15 ppb or copper concentrations exceed an action level of 1.3 ppm in more than 10% of customer taps sampled, the system must undertake a number of additional actions to control corrosion.

If the action level for lead is exceeded, the system must also inform the public about steps they should take to protect their health and may have to replace lead service lines under their control.

LEAD AND GALVANIZED WATER SERVICE LINE REPLACEMENT PROGRAM

We have enhanced our current program to remove lead and galvanized service lines in our water system in accordance with the Environmental Protection Agency’s (EPA) Lead and Copper Rule, 40 CFR Part 141 Subpart I.

Please scroll through the following storyboard for what the Clarksville Water System is doing (and has already done) to reduce or eliminate lead levels in its drinking water?

Preventing Lead in Drinking Water

Exposure to lead in drinking water can cause serious health effects in all age groups. Infants and children can have decreases in IQ and attention span. Lead exposure can lead to new learning and behavior problems or exacerbate existing learning and behavior problems. The children of women who are exposed to lead before or during pregnancy can have increased risk of these adverse health effects. Adults can have increased risks of heart disease, high blood pressure, kidney, or nervous system problems.

Clarksville Gas and Water views public health as a core part of our mission. We consistently provide safe, reliable water services that meet or exceed all state and federal standards for public health, including compliance with the Lead and Copper Rule (LCR) and its subsequent revisions (LCRR).

Definitions 

  1. Gooseneck – a pipe curved like a goose’s neck made of a malleable material such as lead. Goosenecks were once used to connect the tap at the water main to a water service line.
  2. Solder – a low-melting alloy, especially one based on lead and tin or (for higher temperatures) on brass or silver, used for joining less fusible metals (i.e. water plumbing pipes joined with solder).
  3. Swing Joint – a pipe joint designed with a series of two to five 90-degree elbows and nipples so that the parts joined are movable and can be rotated relative to the other. Many swing joints are made of galvanized materials. 
  4. Plumbing Fixture – an exchangeable device which can be connected to a plumbing system to deliver water (i.e. water faucet, hose bib, etc.).
  5. Water Main – a main line in a water system.
  6. Water Meter – an instrument for recording the quantity of water passing through a particular outlet.
  7. Water Service Line – Generally, a small diameter water line that is connected to a water main and runs to a meter box then continues to a house or other building. Water service lines are comprised of many types of materials including lead, galvanized steel, copper, polyvinyl chloride (PVC), high-density polyethylene (HDPE), cross-linked polyethylene (PEX), etc. The city or utility-owned water service line is the portion that runs from the water main into the meter box. The city or utility assumes all responsibility of the city or utility-owned portion of the water service line. The customer or privately-owned service line is the portion that runs from the meter box to the foundation of a house or building and connects to the customer’s private plumbing system.

History of Water Service Line Materials

Clarksville, TN, like many older cities in the United States, utilized lead in its original water system service line materials. In the first half of the 20th Century, lead and iron were the primary material options for drinking water conveyance piping. Iron was utilized for water main pipes and lead, being less expensive and more durable and malleable than iron, was used in most water service line applications. Lead-related health problems were not fully understood during the times it was utilized in making water conveyance piping.

The original Clarksville Water System, which was located primarily in the old downtown area and surrounding neighborhoods, was comprised of cast iron water mains and lead service lines. Lead was regularly utilized from the inception of the water system until galvanized steel superseded lead in the water line service material market.

Galvanized steel involves the application of molten zinc to pre-formed steel pipes to provide a corrosion resistant coating. Zinc, the “corrosion-resistant” coating used in galvanized production, contained lead, which was a common impurity. In the growing Clarksville Water System, galvanized steel was primarily utilized on the city or utility-owned portion of the water service from around the end of World War II until the early 1960’s when copper (primarily “Type K”) was used instead of galvanized steel for new water services. Home builders and contractors continued to use galvanized steel for service lines and plumbing (later primarily using copper, PVC, HDPE, and PEX). The City of Clarksville also utilized galvanized steel for small diameter water mains in its system.

NOTE: Plumbing fixtures and the solder/flux used to join copper pipe historically contained high levels of lead. In 1986, Congress banned the use of lead solder containing greater than 0.2% lead and restricted the lead content of faucets, pipes and other plumbing materials to 8%. Tennessee adopted this ban in 1988. Since then, the Safe Drinking Water Act has reduced the maximum allowable lead content to be a weighted average of 0.25% calculated across the wetted surfaces of pipes, pipe fittings, plumbing fittings, and fixtures. Solder and flux remains “lead-free” at 0.2% or less lead content.

Health Risks of Lead Ingestion

The following information is borrowed from the Agency for Toxic Substances and Disease Registry (ATSDR) and the Center for Disease Control (CDC). This and other information about the risks of lead exposure can be found at ATSDR.CDC.gov and CDC.gov, respectively.

There are a number of routes that dangerous levels of lead can be introduced into the human body. It does not matter if a person breathes-in, swallows, or absorbs lead particles, the health effects are the same; however, the body absorbs higher levels of lead when it is breathed-in. Once inside the body, lead is absorbed and stored in our bones, blood and other tissues ATSDR.CDC.gov.

Lead exposure in the general population (including children) occurs primarily through ingestion. Lead paint is the major source of higher lead level exposures in children in the United States [ATSDR 2010, AAP 1993]. As higher lead content paint deteriorates, peels, chips, crumbles, or is removed, house dust and surrounding soil may become contaminated. Lead then enters the body through normal hand-to-mouth activity. Food and drinking water are other sources that lead may be ingested. ATSDR.CDC.gov.

Lead inhalation occurs mainly in industrial or work environments. Additives in leaded gasoline at one time contributed to lead inhalation for the general population ATSDR.CDC.gov.

Some health effects from acute and/or chronic overexposure to lead include:

  •  Abdominal pain
  • Constipated
  • Tired
  • Headachy
  • Irritable/Depressed
  • Loss of appetite
  • Memory loss
  • Nausea
  • Pain or tingling in the hands and/or feet

People with prolonged exposure to lead may also be at risk for high blood pressure, heart disease, kidney disease, and reduced fertility. [CDC.gov]

If you are concerned with lead ingestion, you may consult your doctor or the Montgomery County Health Department for blood testing or assistance.

Montgomery County Health Department

330 Pageant Lane

Clarksville, TN 37040

(931) 648-5747

https://mcgtn.org/health

How Lead gets into Drinking Water:

The following information is borrowed from the Environmental Protection Agency (EPA). EPA is the federal agency that regulates lead amounts in drinking water. This and other information about the risks of lead exposure from drinking water can be found at epa.gov.

It is important to clarify that lead is not in drinking water when it leaves the water treatment plant. Lead can enter drinking water when plumbing materials that contain lead corrode, especially where the water has high acidity or low mineral content that corrodes pipes and fixtures. The most common sources of lead in drinking water are lead pipes, faucets, and fixtures. In homes with lead pipes that connect the home to the water main, also known as lead service lines (LSLs), these pipes are typically the most significant source of lead in the water. [EPA.gov/ground-water-and-drinking-water/basic-information-about-lead-drinking-water] Note: the term LSL includes galvanized steel due to the possible lead content in the zinc coating and the ability of galvanized steel to absorb lead from previous or current lead pipes upstream of the galvanized pipe.

Regulations to Minimize or Eliminate Lead Levels in Drinking Water

Water Systems are either directly or indirectly (for states with primacy like Tennessee) regulated by EPA’s Safe Drinking Water Act (SDWA). The SDWA is complex, but is valuable to ensure the public consuming drinking water from a municipal, privatized or semi-privatized utility water system is safe to consume and use. Part of the SDWA contains the 1991 Lead and Copper Rule (LCR) and the 2021 Lead and Copper Rule Revision (LCRR). To see information regarding the history of the LCR and see new regulatory information regarding the implementation/compliance of the LCRR, go to epa.gov/dwreginfo/lead-and-copper-rule.

What Clarksville Water System is Doing to Reduce or Eliminate Lead Levels in Its Drinking Water

EPA regulations for lead in drinking water give utilities a multi-faceted approach to reduce or eliminate lead levels in drinking water. Clarksville Gas and Water (CGW) has utilized many of these approaches over the last 30 years.

Corrosion Control

Since 1991, CGW has maintained a food-grade phosphate-based corrosion control program. Clarksville is very fortunate that the Cumberland River provides the city with raw source water. Water from the Cumberland River has many naturally occurring minerals, a stable pH (low to non-corrosive), and alkalinity to provide the Clarksville Water Treatment Plant a very reliable, high-quality raw water to treat. In addition to the excellent stability of its water, CGW treats its finished water with a low dose of sodium ortho-polyphosphate, which provides a microscopic coating on the interior walls of the water pipes in the Clarksville Water System. This coating helps protect iron, lead or other constituents from leaching out of the pipe and contaminating the water. A good corrosion control program is essential in reducing/eliminating lead levels in drinking water.

orthophophate_pipe_example_graphic

Removal/Replacement of Lead and Galvanized Water Service Lines

Clarksville Gas and Water (CGW) strives to continuously provide you, our customer, with the highest quality of safe drinking water. CGW is taking a proactive approach to make the City of Clarksville and the parts of Montgomery County we serve a lead-safe system. We are committed to protecting the health of our rate-payers from potential hazards caused by lead and galvanized service lines. Service lines are generally small diameter pipes that branch off of larger water mains to serve individual customers.

CGW has no water mains made from lead (some lead service lines may still exist in specific areas), however, many service lines (and some water mains) are made of galvanized metal. CGW has set a goal of removing all lead and galvanized service lines (and galvanized mains) during the next three to five years (CGW Goal: utility-side galvanized services will be replaced by August 1, 2024).

From the early 1990’s to date, when CGW construction crews found a leaking lead or galvanized water service, they replaced it with a new copper (or PEX) water service (on the city-owned side of the meter). Replacing hundreds, if not thousands, of lead and galvanized water services through those years placed Clarksville in a good position today with the new EPA LCRR requirements (Effective December 16, 2021, compliance must be met by October 16, 2024).

Since 2015/16, CGW has made a direct concerted effort to identify and replace the remaining lead (and galvanized) services in the water system. In 2023, Clarksville Water System has no known lead service line left in the water system (utility-side or customer-side), but several galvanized water services still exist on both the utility-side and customer-side of the meter. Our goal is to have all galvanized utility-side water services replaced by August 1, 2024. A program to identify the service line material for every house/building built before 1989 in the Clarksville system is underway. 

CGW crews will visit every meter that fits the above criteria and pothole the service line on each side (both city side and customer side) of the meter box and identify the materials as follows:

  1. Lead requiring replacement
  2. Galvanized requiring replacement
  3. Non-lead or galvanized

The materials identification process is ongoing (estimated completion on July 1, 2023) and data is available for all CGW customers at this link. CGW will replace all lead and galvanized services on the city-side by August 1, 2024. The customer/homeowner is responsible to replace the private service line from the meter to the foundation of the house/building. For full LSL removal credit, the water service must be replaced from the water main to the foundation of the house/building.

Ownership of Water Service Lines

In typical cases, the water mains lie underneath the street, the right-of-way, or a utility easement and the “utility-side” connection runs from the water main to the meter box (usually close to the private property line). CGW owns and is responsible for this section of the service line.

The property owner owns the “private side” service line from the meter (usually close to or at the property line) to the foundation of the home, business or other building as well as the internal plumbing. This private side service line may be made from lead or galvanized metal. The property owner is responsible for this section. Brass fittings, faucets and solder may also exist in the plumbing of the home or business and could cause lead to be present in drinking water. 

Please utilize the interactive map (link here) to see what material type CGW has identified your service to be. If you have a galvanized service line, CGW recommends that you to contact a plumber to have it replaced. CGW further recommends that you identify internal plumbing to determine whether you need to replace the plumbing or household plumbing fixtures. 

Identification of Water Service and Plumbing Material 

To determine water service line and plumbing materials, please see the video below or follow this link to EPA’s website, https://www.epa.gov/sciencematters/epa-researchers-share-approaches-identify-lead-service-lines.

Schools and Child Care Facilities

Clarksville Gas and Water is partnering with public schools, private schools, and licensed child care facilities that receive their water from the Clarksville Water System to work toward a zero-lead goal. In doing so, CGW is meeting with the schools and licensed child care facilities and setting up water sampling schedules. 

For schools and child care facilities, please follow the below link to EPA’s 3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities (English and Spanish Versions).

https://www.epa.gov/system/files/documents/2021-07/epa-3ts-guidance-document-english.pdf

https://www.epa.gov/system/files/documents/2021-07/epa-3ts-guidance-document-spanish_0.pdf

https://www.epa.gov/system/files/documents/2021-07/3ts_checklist_establishing_a_program_508_0.pdf

If you have questions or concerns about lead in water at schools and licensed child care facilities, please contact your school or licensed child care facility or contact the Montgomery County Health Department at

Montgomery County Health Department

330 Pageant Lane

Clarksville, TN 37040

(931) 648-5747

https://mcgtn.org/health

Clarksville-Montgomery County School System

621 Gracey Avenue

Clarksville, TN 37040

(931) 648-5600

https://www.cmcss.net/

or contact the Clarksville Water Treatment Plant at (931) 553-2440.