UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 WASHINGTON D.C. 20460

OFFICE OF THE ADMINISTRATOR

 SCIENCE ADVISORY BOARD

September 28, 2011

EPA-SAB-11-015

The Honorable Lisa P. Jackson

Administrator

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Subject: SAB Evaluation of the Effectiveness of Partial Lead Service Line Replacements

Dear Administrator Jackson:

Lead exposure causes adverse health effects including impaired neurodevelopment of children, and 

hypertension and cardiovascular disease in adults. EPA’s Office of Water regulates drinking water lead 

levels via the 1991 Lead and Copper Rule (LCR). The LCR established an action level for drinking 

water lead, above which water systems must install corrosion control treatment. If the action level is not 

met after installing corrosion control treatment, then lead service line replacement (LSLR) is required. 

Under the 2000 LCR revisions, water systems must replace only the portion of the lead service line that 

it owns. This is termed a partial LSLR (PLSLR). EPA’s Office of Water sought SAB evaluation of 

current scientific data to determine whether PLSLR is effective in reducing drinking water lead levels. 

EPA identified several studies for the SAB to consider, and the SAB reviewed additional studies for

their evaluation.

The SAB was asked to evaluate the current scientific data regarding the effectiveness of PLSLR

centered around five issues: associations between PLSLR and blood lead levels in children; lead tap 

water sampling data before and after PLSLR; comparisons between partial and full LSLR; PLSLR 

techniques; and the impact of galvanic corrosion. The SAB Drinking Water Committee was augmented 

for this evaluation (hereafter referred to as the “DWC Lead Panel” or “Panel”).

The SAB finds that the quantity and quality of the available data are inadequate to fully determine the 

effectiveness of PLSLR in reducing drinking water lead concentrations. The small number of studies 

available have major limitations (small number of samples, limited follow-up sampling, lack of 

information about the sampling data, limited comparability between studies, etc.) for fully evaluating 

PLSLR efficacy. Nevertheless, despite these limitations, the SAB concludes that PLSLRs have not been 

shown to reliably reduce drinking water lead levels in the short term, ranging from days to months, and 

potentially even longer. Additionally, PLSLR is frequently associated with short-term elevated drinking 

water lead levels for some period of time after replacement, suggesting the potential for harm, rather 

than benefit during that time period. Available data suggest that the elevated tap water lead levels tend to 

then gradually stabilize over time following PLSLR, sometimes at levels below and sometimes at levels 
2

similar to those observed prior to PLSLR. The SAB response to the EPA’s charge is detailed in the 

report. The major SAB comments and findings are provided below. 

• The SAB evaluated a study from the Centers for Disease Control and Prevention (CDC) that 

examined associations between childhood blood lead levels (BLLs) and PLSLR. BLLs are 

used as biomarkers for lead exposure. The results suggest that there is a potential for harm 

(i.e. higher BLLs) resulting from PLSLR, and provide no evidence of a demonstrable benefit 

from PLSLR on reductions in childhood BLLs in the short term (e.g., within approximately 

one year). The available scientific evidence regarding BLLs and PLSLRs, while limited to 

this study, does not support the use of PLSLR as an effective or safe measure to reduce shortterm Pb exposure of those served by lead service lines. The long term (e.g., over a period of 

years) relationship between PLSLRs and childhood BLLs cannot be determined from this 

publication.

• The SAB evaluated several studies of tap water lead levels both before and after PLSLR. The

weight of evidence indicates that PLSLR often causes tap water lead levels to increase

significantly for a period of days to weeks, or even several months. There are insufficient 

data to reliably predict whether the tap water lead level will significantly increase following a 

PLSLR in a given home or distribution system, the extent to which it will increase, or how 

long the increase will persist.

• In studies of full LSLR and PLSLR, the evaluation periods have been too short to fully assess

differential reductions in drinking water lead levels. With this caveat, full LSLR appears

generally effective in reliably achieving long-term reductions in drinking water lead levels, 

unlike PLSLR. Both full LSLR and PLSLR generally result in elevated lead levels for a 

variable period of time after replacement. The limited evidence available suggests that the 

duration and magnitude of the elevations may be greater with PLSLR than full LSLR. 

• Studies examining PLSLR techniques (e.g., cutting techniques, flushing) did not provide 

definitive information on the impact that these techniques could have on lead release. The 

studies that examined different cutting techniques are limited by sample size and do not 

clearly demonstrate a significant difference between the cutting methods. Line flushing 

appears to provide some benefit, but the time to realize the benefit (flushing for up to several 

weeks) precludes any likely practical implementation of this technique. The SAB finds that 

the development of a Standard Operating Procedure for PLSLR is premature. 

• Galvanic corrosion associated with PLSLR poses a risk of increased lead levels in tap water

by increasing the corrosion rate and/or increasing the chance that corroded lead will be 

mobilized. This risk may persist for at least several months and is very difficult to quantify

with currently available data. Insertion of a lead-free dielectric eliminates galvanic corrosion 

at the new pipe junction by breaking the electrical circuit between the new and old pipes, but 

it has no effect on depositional corrosion. The SAB concludes that insertion of a dielectric 

will likely reduce lead levels in tap water, but it cannot confidently estimate the magnitude of 

the reductions because the contribution of galvanic corrosion and depositional corrosion to 

drinking water lead levels has not been quantified.

In summary, the SAB found the available information is broadly suggestive that PLSLR may pose a risk 

to the population, due to the short-term elevations in drinking water lead concentrations. In answering 
3

the five charge questions, the larger picture which emerged is the lack of data available to fully evaluate 

the effectiveness of PLSLR, which limited the SAB’s ability to offer stronger conclusions and 

recommendations.

The SAB appreciates the opportunity to provide EPA with advice and looks forward to the Agency’s 

response. 

Sincerely,

/Signed/ /Signed/

Dr. Deborah L. Swackhamer Dr. Jeffrey K. Griffiths

Chair Chair

EPA Science Advisory Board SAB Drinking Water Committee

Enclosures
i

NOTICE

This report has been written as part of the activities of the EPA Science Advisory Board, a public 

advisory Panel providing extramural scientific information and advice to the Administrator and other 

officials of the Environmental Protection Agency. The Board is structured to provide balanced, expert 

assessment of scientific matters related to problems facing the Agency. This report has not been 

reviewed for approval by the Agency and, hence, the contents of this report do not necessarily represent 

the views and policies of the Environmental Protection Agency, nor of other agencies in the Executive 

Branch of the Federal government, nor does mention of trade names or commercial products constitute a 

recommendation for use. Reports of the EPA Science Advisory Board are posted on the EPA Web site 

at: http://www.epa.gov/sab.
ii

U.S. Environmental Protection Agency

Science Advisory Board

Drinking Water Committee Augmented for the Review of the Effectiveness of 

Partial Lead Service Line Replacements

CHAIR

Dr. Jeffrey K. Griffiths, Professor, Department of Public Health and Community Medicine, School of 

Medicine, Tufts University, Boston, MA

MEMBERS

Dr. George Alexeeff, Acting Director, Office of Environmental Health Hazard Assessment, California 

Environmental Protection Agency, Oakland, CA

Dr. Mark Benjamin, Professor, Department of Civil and Environmental Engineering, University of 

Washington, Seattle, WA

Dr. Joel Ducoste, Professor, Department of Civil, Construction, and Environmental Engineering, 

College of Engineering, North Carolina State University, Raleigh, NC

Dr. Susan Korrick, Assistant Professor of Medicine , Department of Medicine, Brigham and Women's 

Hospital, Channing Laboratory, Harvard Medical School, Boston, MA

Dr. Michael Kosnett, Associate Clinical Professor, Division of Clinical Pharmacology and Toxicology, 

Department of Medicine, University of Colorado Health Sciences Center, Denver, CO

Dr. Bruce Lanphear, Professor, Children’s Environmental Health, Faculty of Health Sciences, Simon 

Fraser University, Vancouver, BC, Canada

Dr. Desmond F. Lawler, Bob R. Dorsey Professor of Engineering, Department of Civil, Architectural 

and Environmental Engineering, University of Texas, Austin, TX

Dr. Frank Loge, Professor, Department of Civil and Environmental Engineering, University of 

California-Davis, Davis, CA

Dr. Stephen Randtke, Professor, Department of Civil, Environmental, and Architectural Engineering, 

University of Kansas, Lawrence, KS

Dr. A. Lynn Roberts, Professor, Department of Geography and Environmental Engineering, Johns 

Hopkins University, Baltimore, MD

Dr. Stephen Rothenberg, Senior Investigator, Environmental Health, Center for Study of Population 

Health, National Institute of Public Health, Cuernavaca, Mexico
iii

Dr. Richard Sakaji, Manager, Planning and Analysis for Water Quality, East Bay Municipal Utility 

District, Oakland, CA

Ms. Janice Skadsen, Environmental Scientist, CDM, Ann Arbor, MI

Dr. Virginia Weaver, Associate Professor, Departments of Environmental Health Sciences & Medicine, 

Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD

Dr. Robert Wright, Associate Professor, Pediatrics, Division of Environmental Health, Harvard School 

of Public Health, Boston, MA

Dr. Marylynn Yates, Professor of Environmental Microbiology, Department of Environmental 

Sciences, University of California-Riverside, Riverside, CA

SCIENCE ADVISORY BOARD STAFF

Mr. Aaron Yeow, Designated Federal Officer, U.S. Environmental Protection Agency, Science 

Advisory Board (1400R), 1200 Pennsylvania Avenue, NW, Washington, DC, Phone: 202-564-2050, 

Fax: 202-565-2098, (yeow.aaron@epa.gov)
iv

U.S. Environmental Protection Agency

Science Advisory Board

BOARD

CHAIR

Dr. Deborah L. Swackhamer, Professor and Charles M. Denny, Jr. Chair in Science, Technology and 

Public Policy, Hubert H. Humphrey School of Public Affairs and Co-Director of the Water Resources 

Center, University of Minnesota, St. Paul, MN

SAB MEMBERS

Dr. David T. Allen, Professor, Department of Chemical Engineering, University of Texas, Austin, TX

Dr. Claudia Benitez-Nelson, Full Professor and Director of the Marine Science Program, Department 

of Earth and Ocean Sciences, University of South Carolina, Columbia, SC

Dr. Timothy J. Buckley, Associate Professor and Chair, Division of Environmental Health Sciences, 

College of Public Health, The Ohio State University, Columbus, OH

Dr. Patricia Buffler, Professor of Epidemiology and Dean Emerita, Department of Epidemiology, 

School of Public Health, University of California, Berkeley, CA

Dr. Ingrid Burke, Director, Haub School and Ruckelshaus Institute of Environment and Natural 

Resources, University of Wyoming, Laramie, WY

Dr. Thomas Burke, Professor, Department of Health Policy and Management, Johns Hopkins 

Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD

Dr. Terry Daniel, Professor of Psychology and Natural Resources, Department of Psychology, School 

of Natural Resources, University of Arizona, Tucson, AZ

Dr. George Daston, Victor Mills Society Research Fellow, Product Safety and Regulatory Affairs, 

Procter & Gamble, Cincinnati, OH

Dr. Costel Denson, Managing Member, Costech Technologies, LLC, Newark, DE

Dr. Otto C. Doering III, Professor, Department of Agricultural Economics, Purdue University, W. 

Lafayette, IN

Dr. David A. Dzombak, Walter J. Blenko, Sr. Professor of Environmental Engineering , Department of 

Civil and Environmental Engineering, College of Engineering, Carnegie Mellon University, Pittsburgh, 

PA

Dr. T. Taylor Eighmy, Vice President for Research, Office of the Vice President for Research, Texas 

Tech University, Lubbock, TX
v

Dr. Elaine Faustman, Professor and Director, Institute for Risk Analysis and Risk Communication, 

School of Public Health, University of Washington, Seattle, WA

Dr. John P. Giesy, Professor and Canada Research Chair, Veterinary Biomedical Sciences and 

Toxicology Centre, University of Saskatchewan, Saskatoon, Saskatchewan, Canada

Dr. Jeffrey K. Griffiths, Professor, Department of Public Health and Community Medicine, School of 

Medicine, Tufts University, Boston, MA

Dr. James K. Hammitt, Professor, Center for Risk Analysis, Harvard University, Boston, MA

Dr. Bernd Kahn, Professor Emeritus and Associate Director, Environmental Radiation Center, Georgia 

Institute of Technology, Atlanta, GA

Dr. Agnes Kane, Professor and Chair, Department of Pathology and Laboratory Medicine, Brown 

University, Providence, RI

Dr. Madhu Khanna, Professor, Department of Agricultural and Consumer Economics, University of 

Illinois at Urbana-Champaign, Urbana, IL

Dr. Nancy K. Kim, Senior Executive, Health Research, Inc., Troy, NY

Dr. Catherine Kling, Professor, Department of Economics, Iowa State University, Ames, IA

Dr. Kai Lee, Program Officer, Conservation and Science Program, David & Lucile Packard Foundation, 

Los Altos, CA (affiliation listed for identification purposes only)

Dr. Cecil Lue-Hing, President, Cecil Lue-Hing & Assoc. Inc., Burr Ridge, IL

Dr. Floyd Malveaux, Executive Director, Merck Childhood Asthma Network, Inc., Washington, DC

Dr. Lee D. McMullen, Water Resources Practice Leader, Snyder & Associates, Inc., Ankeny, IA

Dr. Judith L. Meyer, Professor Emeritus, Odum School of Ecology, University of Georgia, Lopez 

Island, WA

Dr. James R. Mihelcic, Professor, Civil and Environmental Engineering, University of South Florida, 

Tampa, FL

Dr. Jana Milford, Professor, Department of Mechanical Engineering, University of Colorado, Boulder, 

CO

Dr. Christine Moe, Eugene J. Gangarosa Professor, Hubert Department of Global Health, Rollins 

School of Public Health, Emory University, Atlanta, GA

Dr. Horace Moo-Young, Dean and Professor, College of Engineering, Computer Science, and 

Technology, California State University, Los Angeles, CA
vi

Dr. Eileen Murphy, Grants Facilitator, Ernest Mario School of Pharmacy, Rutgers University, 

Piscataway, NJ

Dr. Duncan Patten, Research Professor, Hydroecology Research Program , Department of Land 

Resources and Environmental Sciences, Montana State University, Bozeman, MT

Dr. Stephen Polasky, Fesler-Lampert Professor of Ecological/Environmental Economics, Department 

of Applied Economics, University of Minnesota, St. Paul, MN

Dr. Arden Pope, Professor, Department of Economics, Brigham Young University , Provo, UT

Dr. Stephen M. Roberts, Professor, Department of Physiological Sciences, Director, Center for 

Environmental and Human Toxicology, University of Florida, Gainesville, FL

Dr. Amanda Rodewald, Professor of Wildlife Ecology, School of Environment and Natural Resources, 

The Ohio State University, Columbus, OH

Dr. Jonathan M. Samet, Professor and Flora L. Thornton Chair, Department of Preventive Medicine, 

University of Southern California, Los Angeles, CA

Dr. James Sanders, Director and Professor, Skidaway Institute of Oceanography, Savannah, GA

Dr. Jerald Schnoor, Allen S. Henry Chair Professor, Department of Civil and Environmental 

Engineering, Co-Director, Center for Global and Regional Environmental Research, University of Iowa, 

Iowa City, IA

Dr. Kathleen Segerson, Philip E. Austin Professor of Economics , Department of Economics, 

University of Connecticut, Storrs, CT

Dr. Herman Taylor, Director, Principal Investigator, Jackson Heart Study, University of Mississippi 

Medical Center, Jackson, MS

Dr. Barton H. (Buzz) Thompson, Jr., Robert E. Paradise Professor of Natural Resources Law at the 

Stanford Law School and Perry L. McCarty Director, Woods Institute for the Environment, Stanford 

University, Stanford, CA

Dr. Paige Tolbert, Professor and Chair, Department of Environmental Health, Rollins School of Public 

Health, Emory University, Atlanta, GA

Dr. John Vena, Professor and Department Head, Department of Epidemiology and Biostatistics, 

College of Public Health, University of Georgia, Athens, GA

Dr. Thomas S. Wallsten, Professor and Chair, Department of Psychology, University of Maryland, 

College Park, MD

Dr. Robert Watts, Professor of Mechanical Engineering Emeritus, Tulane University, Annapolis, MD

Dr. R. Thomas Zoeller, Professor, Department of Biology, University of Massachusetts, Amherst, MA
vii

SCIENCE ADVISORY BOARD STAFF

Dr. Angela Nugent, Designated Federal Officer, U.S. Environmental Protection Agency, Science 

Advisory Board (1400R), 1200 Pennsylvania Avenue, NW, Washington, DC, Phone: 202-564-2218, 

Fax: 202-565-2098, (nugent.angela@epa.gov)
viii

ACRONYMS AND ABBREVIATIONS

AL Action Level 

BLL Blood Lead Level

EPA United States Environmental Protection Agency

CDC Centers for Disease Control and Prevention

LCR EPA’s Lead and Copper Rule

LSL Lead Service Line

LSLR Lead Service Line Replacement

OW EPA’s Office of Water

Pb Lead

PLSLR Partial Lead Service Line Replacement

SAB Science Advisory Board
ix

TABLE OF CONTENTS

1. EXECUTIVE SUMMARY................................................................................................... 1

2. INTRODUCTION................................................................................................................. 4

3. RESPONSE TO EPA CHARGE......................................................................................... 5

3.1. Issue 1 – Studies Examining Associations Between Elevated Blood Lead Levels and 

Partial Lead Service Line Replacements (PLSLR)................................................................. 5

3.2. Issue 2 – Studies Evaluating PLSLR with Tap Sampling Before and After Replacements... 9

3.3. Issue 3 – Studies Comparing PLSLR with Full Lead Service Line Replacements.............. 13

3.4. Issue 4 – Studies Examining PLSLR Techniques................................................................. 15

3.5. Issue 5 – Studies Examining Galvanic Corrosion................................................................. 20

3.6. Conclusion ............................................................................................................................ 23

4. REFERENCES.................................................................................................................... 24

APPENDIX A – EPA CHARGE TO THE COMMITTEE .................................................. A-1

APPENDIX B - Rationale and Recommendations for a Reanalysis of 

Brown et al. (2011)............................................................................................................ B-1

APPENDIX C - Reported Tap Water Lead Levels Following PLSLR................................ C-1

APPENDIX D - Sampling Methods for Lead in Tap Water................................................. D-1

APPENDIX E - Techniques for Locating, Identifying, Replacing, and Rehabilitating 

Lead Service Lines............................................................................................................ E-1
1

1. EXECUTIVE SUMMARY

This report was prepared by the Science Advisory Board (SAB) Drinking Water Committee Augmented 

for the Review of the Effectiveness of Partial Lead Service Line Replacements (hereafter “DWC Lead

Panel” or “Panel”), in response to a request by EPA’s Office of Water to evaluate the current scientific 

data to determine the effectiveness of partial lead service line replacements (PLSLR) in reducing 

drinking water lead (Pb) levels. The charge to the SAB was centered around five issues. They were: 

associations between PLSLR and blood lead levels (BLLs) in children; water sampling data at the tap 

before and after PLSLR; comparisons between partial and full lead service line replacements (LSLRs);

PLSLR techniques; and the impact of galvanic corrosion. The SAB DWC Lead Panel held a public 

meeting on March 30-31, 2011, and a follow-up teleconference on May 16, 2011, to deliberate on the 

charge. This report was subsequently reviewed and approved by the Chartered SAB on July 19, 2011. 

This Executive Summary highlights the SAB’s major findings and conclusions.

The number of studies to examine the ability of PLSLR to reduce lead exposure is small and those 

studies have major limitations (small number of samples, limited follow-up sampling, lack of 

information about the sampling data, limited comparability between studies, etc.). Overall the SAB finds 

that, based on the current scientific data, PLSLRs have not been shown to reliably reduce drinking water 

lead levels in the short term, ranging from days to months, and potentially even longer. Additionally, 

PLSLR is frequently associated with short-term elevated drinking water lead levels for some period of 

time after replacement, suggesting the potential for harm, rather than benefit during that time period. 

Available data suggest that the elevated tap water lead levels tend to then gradually stabilize over time 

following PLSLR, sometimes at levels below and sometimes at levels similar to those observed prior to 

PLSLR. 

Issue 1 - Associations Between PLSLR and Blood Lead Levels in Children

The current scientific literature was reviewed, and Brown et al. (2011) is the only study found that 

directly examines the relationship between childhood blood lead levels (BLLs) and PLSLRs. BLLs are 

used as biomarkers for lead exposure. The results of Brown et al. (2011) provide no evidence of 

demonstrable benefits from PLSLR on reductions in childhood BLLs in the short term (e.g., within 

approximately one year). In fact, the results provide suggestive evidence of the potential for harm (i.e., 

higher BLLs) related to PLSLR, among children living in households at which a PLSLR was performed.

This finding is scientifically consistent with the observation that drinking water Pb levels often increase 

after PLSLR (see Issue 2). 

Design limitations in Brown et al. (2011) preclude reliance on this single study as the basis for final 

conclusions about the relation of BLLs with PLSLR. These limitations include the following: a lack of 

information on both individual-level potential confounders and potential confounders related to houses 

that had PLSLR; not accounting for the timing of PLSLR relative to the measurement of BLLs; not 

accounting for the duration of residence in housing; possible ascertainment bias in the detection of 

elevated BLLs; potential for measurement error in the assignment of BLLs; low statistical power due to 

the limited number of children with elevated BLLs in the subanalyses; limited BLL data for formula-fed 

infants under one year of age who are at greatest risk; and limited ability to generalize the findings to 

other populations, communities, and water systems. In addition, the long-term relationship (over a 

period of years) between PLSLR and childhood BLLs cannot be determined from Brown et al. (2011). 

The SAB has several recommendations to address these limitations, such as a reanalysis of Brown et al. 

(2011) using expanded data resources and improved methods as outlined in Appendix B. 
2

Issue 2 - Water Sampling Data at the Tap Before and After PLSLR

The weight of evidence indicates that PLSLR often causes tap water Pb levels to significantly increase 

for a period of days to weeks, or even several months. Available data suggest that tap water Pb levels 

tend to gradually stabilize over time following PLSLR, sometimes at levels below or above those 

observed prior to PLSLR. There are insufficient data to reliably predict whether the tap water Pb level 

will significantly increase following a PLSLR in a given home or distribution system, the extent to 

which it will increase, or how long the increase will persist.

The magnitude and duration of elevated tap water Pb levels following PLSLR may be influenced by the 

extent of disturbance of the lead service line (LSL), as well as any countermeasures taken to offset such 

effects (as discussed under Issue 4); the quantity and characteristics of the deposits in the LSL and 

downstream plumbing materials; the chemistry of the local water supply, including treatment to control 

corrosion; biological activity; localized corrosion; and other factors. Reasons for the increase in a given 

setting are generally not known. 

Issue 3 - Comparisons Between Full and Partial Lead Service Line Replacements

Several studies that compared partial and full LSLRs were evaluated. The SAB finds that in these 

studies, the time periods of evaluation of Pb concentrations following partial and full LSLR have been 

inadequate to fully evaluate the effectiveness of reducing drinking water Pb levels. Nevertheless, for the 

time periods reported in the studies, the SAB concludes that in water distribution systems optimized for 

corrosion control, full LSLRs have been shown to be a generally effective method of reducing drinking

water Pb levels. However, PLSLRs have not been shown to be reliably effective in reducing drinking 

water Pb levels, at least in the time frames of the reported studies. Both full LSLRs and PLSLRs 

generally result in elevated Pb levels for a variable period of time after replacement, but the limited 

evidence available suggests that the duration and magnitude of the elevations may be greater with 

PLSLR than full LSLR. 

Issue 4 - PLSLR techniques

Several studies were evaluated that examined the impact that PLSLR techniques can have on Pb release. 

These included different cutting techniques, different joining techniques, the effectiveness of flushing, 

and public education. The SAB concludes that the studies do not provide definitive information on the 

impact that PLSLR techniques can have on Pb release. The studies that examined different cutting 

techniques are limited by sample size and do not clearly demonstrate a significant difference between 

the cutting methods. One study examined the use of a heat shrink Teflon sleeve as a joining technique, 

but the results are inconclusive, and the technology is still very new and has not been extensively 

evaluated. Line flushing appears to provide some benefit, but the time to realize the benefit (flushing up 

to several weeks) precludes any likely practical implementation of this technique.

Part of the PLSLR technique involves public notification and education. Informing the public about the 

risk of Pb exposure is a critical component of a PLSLR program. While the agency has published 

guidance (last revised in 2008), it does not specifically address PLSLR. The SAB recommends that EPA 

review and update the 2008 guidance in light of PLSLR and mitigation of Pb spikes following PLSLR. 

The SAB concludes that public education should complement engineering practices and should not be 

relied on as a replacement for engineering practices.
3

Given the lack of definitive studies on the effectiveness of different procedures and approaches to 

PLSLR, development of standard operating procedures to mitigate the impacts on tap water Pb levels 

from PLSLR is premature. 

Issue 5 - Galvanic Corrosion

Several studies have been conducted to identify and quantify the significance of galvanic corrosion 

when PLSLRs are implemented. The conclusions that have been drawn from the studies vary widely, in 

part because of the disparate procedures and metrics that have been used to assess the corrosion process, 

and in part because the process itself is complex and might proceed at vastly different rates in different 

systems. Despite some divergence of opinion as to the severity of the problem posed by galvanic 

corrosion, there seems to be widespread agreement that the electrical potentials and currents change 

when Pb and copper are brought into electrical contact, and that the region over which these changes are 

substantial is confined to a few inches on either side of the contact point.

The available evidence strongly supports the contention that galvanic corrosion increases the corrosion 

rate of the Pb pipe near the point of metal/metal contact shortly after the contact is made. It also supports 

the contention that galvanic corrosion can be significant for periods of at least several months thereafter. 

The time frame and magnitude of this increase are uncertain and probably differ among different 

systems, depending on the water quality and other local conditions. The SAB is not aware of evidence 

suggesting that Pb that is oxidized galvanically is more or less likely to be mobilized than Pb that is 

oxidized by other mechanisms. The SAB therefore concludes that galvanic corrosion associated with 

PLSLR does pose a risk of increased Pb levels in tap water, and that this risk might persist for periods of 

at least several months, but that the risk is unlikely to be uniform on either a temporal or spatial basis 

and is therefore very difficult to quantify given current information and the heterogeneity of water 

systems and conditions in the United States.

Insertion of a dielectric breaks the electrical connection between the new and old pipes, and thereby 

eliminates galvanic corrosion at the copper and Pb pipe junction, but it has no effect on depositional 

corrosion or the galvanic corrosion that can subsequently ensue at the site of depositional corrosion. 

Because the relative magnitudes of galvanic corrosion at the pipe juncture and depositional corrosion 

have not been quantified, it is not possible to state with confidence how much galvanic corrosion will be 

reduced by insertion of a dielectric. However, there is no question that some reduction will be achieved. 

The SAB concludes that insertion of a lead-free dielectric is likely to have beneficial effects on Pb

concentrations in tap water, albeit of uncertain magnitude, but the SAB did not evaluate other factors or 

consequences associated with this practice. Given the relatively low direct cost of inserting such a 

device, the SAB has concluded that doing so would be appropriate in situations where the decision to 

implement a PLSLR has been made, provided that other issues (e.g., electrical grounding requirements, 

durability, and pipe-thawing practices) are adequately addressed. 

 
4

2. INTRODUCTION

Human exposure to lead (Pb) has been shown to cause adverse health effects on the neurodevelopment 

of children, including deficits in IQ and altered behavior, as well as hypertension and cardiovascular 

disease in adults. Lead in water is an established source of Pb exposure to the general population, 

including both adults and children. It has been estimated that 20% of children’s overall Pb intake in the 

United States comes from Pb in drinking water (Lanphear et al., 2002). This value may vary widely 

depending on the source and volume of water consumed. Water may represent a much greater 

proportion of Pb intake for infants fed with formula reconstituted with tap water than for other children 

(Shannon and Graef, 1989). Indeed, high water Pb levels can be a singular cause of Pb poisoning in 

infancy (Shannon and Graef, 1989).

A key source of Pb in drinking water is Pb that has been leached from materials present in water 

distribution systems, including Pb in service lines and household fixtures. There are a number of factors 

associated with Pb leaching into water, including water quality, the types of chemicals used in water 

disinfection, water temperature, and pH. The Pb content of solder, fixture constituents, scale deposits,

and the service lines themselves are also important factors. 

EPA’s Office of Water (OW) regulates drinking water Pb levels through the 1991 Lead and Copper Rule 

(LCR) by establishing a treatment technique to minimize Pb levels in tap water. The LCR established an 

action level (AL) for Pb in drinking water, above which, water systems are required to install corrosion 

control treatment. It should be noted that the AL is not a health-based level and that EPA’s health-based 

maximum contaminant level goal (MCLG) for lead is zero. If the AL is still not met after installing 

corrosion control treatment, LSLR is required. Under the 2000 LCR revisions, a water system is 

required to replace only the portion of the lead service line (LSL) that it owns (a water system is also 

required to offer replacement of the lead service that they do not own, at cost, to the owner). 

Replacement of only a portion of the LSL is referred to as a partial lead service line replacement

(PLSLR). 

EPA’s OW requested that the Science Advisory Board (SAB) evaluate the current scientific data to 

determine the effectiveness of PLSLR in reducing drinking water Pb levels. In response to this request, 

the SAB Drinking Water Committee (DWC) was augmented with additional experts, hereafter referred 

to as the “DWC Lead Panel” or “Panel”. 

EPA’s charge to the SAB, presented in Appendix A, is centered around five issues: associations between 

PLSLR and blood lead levels (BLLs) in children, tap water sampling data before and after PLSLR, 

comparisons between full and partial LSLRs, PLSLR techniques, and the impact of galvanic corrosion. 

EPA identified several studies pertaining to each of the issues for the SAB to consider in their evaluation, 

but the SAB was also encouraged to identify and use any additional studies for their evaluation. The 

SAB DWC Lead Panel held a public meeting on March 30-31, 2011 and a follow-up teleconference on 

May 16, 2011 to deliberate on the charge. The Chartered SAB approved the report on July 19, 2011. The 

response to the charge is detailed in this report. 
5

3. RESPONSE TO EPA CHARGE

Overall Charge

EPA is seeking SAB evaluation of current scientific data to determine whether partial lead service line 

replacements are effective in reducing lead drinking water levels. EPA has identified several studies for 

the SAB to consider for the evaluation. The SAB may also consider other relevant studies for the 

evaluation.

3.1. Issue 1 – Studies Examining Associations Between Elevated Blood Lead Levels and Partial 

Lead Service Line Replacements (PLSLR)

A recently published study by the Centers for Disease Control (Brown et al. 2011) examined an 

association between children’s blood lead level, lead service lines, and water disinfection in Washington, 

DC using data from 1998 to 2006. How does this study inform the available information on the 

effectiveness of partial lead service line replacement in reducing drinking water exposure to lead?

Summary and Conclusions from Brown et al. (2011)

The SAB did not identify any other peer reviewed literature in addition to Brown et al. (2011) that 

explicitly addresses the relationship between BLLs and PLSLRs.

Brown et al. (2011) used administrative data from the Washington, D.C. Childhood Lead Poisoning 

Prevention Program (CLPPP) to characterize BLLs among children less than 6 years of age between 

1998 and 2006. Data obtained from the Washington, D.C. Water and Sewer Authority (WASA) were 

then used to characterize the water delivery system applicable to the child’s listed address. Specifically, 

it was noted whether the address was served by an LSL, had a PLSLR performed, or had a non-Pb pipe

delivery system prior to the BLL measurement. By matching CLPPP and WASA address data, the 

relationship between childhood BLLs and household water characteristics was assessed for 63,854 

children. The study found that children with higher BLLs were more likely to have an LSL; this 

relationship was stronger during the time period of November 2000 through June 2004 when chloramine 

was being used as the water disinfectant (Brown et al., 2011, Table 2). Key to Issue 1, was the finding 

that, in a subset of 3,651 children with BLLs measured between 2004 to 2006, residing in a household 

which had a PLSLR performed, as compared to a household with an LSL not replaced, resulted in an 

odds ratio of 1.1 (95% CI: 0.8, 1.3, p=0.671

 1 p-values were not reported in Brown et al., 2011 but were calculated from the frequency data presented in the right half of 

Table 3 using a two-sided Fisher’s exact test.

) of having a BLL between 5-9 μg/dL and an odds ratio of

1.4 (95% CI: 0.9, 2.1, p=0.181

) of having a BLL ≥10 μg/dL compared to having a BLL < 5 μg/dL 

(Brown et al., 2011, right half of Table 3). The mean time between PLSLR and BLL measurement was 

approximately 10-11 months.

Thus, Brown et al. (2011) provides no evidence of a benefit to PLSLR as measured by childhood BLLs, 

compared to having an LSL not replaced, in the short term (e.g., within approximately one year). In fact, 

the study’s results provide suggestive evidence of the potential for harm (i.e., greater Pb exposure as 

evidenced by higher BLLs) related to PLSLR. This finding is consistent with the observation that

drinking water Pb levels often increase after PLSLR (see Issue 2). 
6

Limitations and Caveats to the Interpretation of Brown et al. (2011)

There are a number of design limitations in Brown et al. (2011) that preclude reliance on this single 

study as the basis for final conclusions about the relationship between BLLs and PLSLRs. These include 

the following:

1. Perhaps the most important is that the administrative databases used did not include 

information on individual-level potential confounders, a common limitation of administrative 

data. For example, it is not known how children living in homes where a PLSLR was 

performed compared to those living in homes with an intact LSL with regard to potential 

confounding variables such as socioeconomic status, ethnicity, tap water Pb levels and 

consumption, alternative drinking water sources, point-of-use water treatment, Pb content of 

household plumbing fixtures, or Pb paint hazards. The study used age of housing as a proxy 

for confounding by Pb paint hazards. However, age of housing was only available for a 

subset of the children and was not used in the analyses to assess the relationship between 

BLLs and PLSLRs. Not accounting for such confounders could have biased the findings. For 

example, if households living in home where a PLSLR was performed filtered their drinking 

water in response to the PLSLR, the observed relationship between BLLs and PLSLRs would 

underestimate the true risk to BLLs. This factor may have been particularly important in 

Washington, D.C. during the time period of 2004 to 2006, when potential risks associated 

with Pb in drinking water were widely publicized in the media.

2. There was a lack of information regarding potential confounding factors associated with a 

household having a PLSLR vs. an intact LSL. For example, it is not known whether PLSLR 

may have been preferentially conducted in households with the historically highest levels of 

water Pb. If so, it is possible that some children at residences where PLSLRs were performed

may have sustained higher chronic Pb exposure prior to the replacement, and this in turn may 

have influenced the comparison of BLLs between households with PLSLRs and households 

with intact LSLs.

3. The study neither accounted for the timing of PLSLR relative to measurement of BLLs nor 

the duration of residence in housing with an LSL, though the timing between PLSLR and 

BLL measures was available in the study’s administrative data. In the latter case, the authors 

reported that BLLs were measured, on average, 10-11 months after a PLSLR, a lag which 

may have attenuated any associations. Lack of accounting for such factors could result in 

exposure misclassification. Such misclassification, if non-differential, would attenuate 

associations. If the misclassification was differential, it would bias findings, with the 

direction of bias dependent upon how such factors were distributed between children living 

in homes where a PLSLR was performed compared to those living in homes with an intact 

LSL. 

4. There was possible ascertainment bias in the detection of elevated BLLs. For example, the 

implementation of a PLSLR at a household may have increased parental awareness regarding 

the hazards of childhood Pb exposure, and may have motivated a higher rate of BLL

screening in children already subject to other risk factors for elevated BLLs. 

5. There was potential for measurement error in assignment of BLLs. Although many children 

had more than one BLL measurement, analyses were restricted to one BLL value per child by 
7

using the lowest available finger stick (capillary blood) or the highest available venous value 

for a given child, an approach that may not fully capture a given child’s BLL. 

6. The PLSLR sub-analyses were based on a modest number of children with elevated BLLs. 

Specifically, among children who lived in housing with a PLSLR, 598 had BLLs < 5 μg/dL, 

105 had BLLs = 5-9 μg/dL, but only 27 had BLLs ≥ 10 μg/dL. In addition, due to the very 

unequal distribution of subjects in the two water service line groups (PLSLR vs. intact LSL), 

and the use of categorical BLL outcome logistic analysis with low a posteriori probability of 

BLLs exceeding 10 μg/dL, the power of the analysis to detect a difference in the BLLs in the 

two water service line groups was low. A post-hoc power analysis shows that with an alpha 

probability criterion of 0.05, there was only 25% power in the study to detect a significant 

odds ratio of 1.36 (calculated from the frequency data in the right hand side of Table 3 in 

Brown et al., 2011). 

7. A significant limitation from the perspective of public health protection is that the CLPPP 

data had relatively little (13%) BLL data for infants less than one year of age, the group most 

likely to be affected by water Pb levels via consumption of baby formula reconstituted with 

tap water. 

8. Finally, given substantial local variability in water systems, the ability to generalize the 

Brown et al. (2011) findings to other populations, communities, and water systems may be 

limited.

Recommendations for Future Research

Some of the above limitations could be addressed by additional studies. For example, replicating Brown 

et al. (2011) in other communities could be of value regarding the ability to generalize the findings. 

Long term prospective studies assessing repeated BLLs – including child and early infant levels as well 

as data on drinking water Pb levels and consumption patterns – before and after PLSLR could provide 

valuable information regarding the relationship between BLLs and PLSLRs over time. However, the 

most cost-effective and expeditious way of addressing the need for robust data relevant to Issue 1 would 

likely be a reanalysis of Brown et al. (2011) using expanded data resources and improved methods. For 

example, even given the limitations of the data described above, a reanalysis of the original BLLs using 

a tobit regression for censored outcomes would increase the power to detect significant increases in 

BLLs associated with PLSLRs, should they exist. In addition, fully utilizing available data (e.g., age of 

housing, time between PLSLR and BLL testing, multiple BLL measurements) would improve a 

reanalysis of the data. A subset of the data used in Brown et al. (2011) was reviewed as part of this 

response to Issue 1 and recommendations for further EPA analyses of these data were made as described 

in detail by Panel member, Dr. Stephen Rothenberg (see Appendix B). 

Public Health Considerations

The short-term and long-term consequences of PLSLR on BLLs may differ. For example, children’s 

BLLs may increase substantially in the first few months following a PLSLR due to short term elevations 

in drinking water Pb concentration, a possibility not specifically investigated by Brown et al. (2011). 

However, short-term elevations in BLLs, particularly in children for whom Pb is a well-established and 

potent neurodevelopmental toxicant, can have long-term adverse health impacts. 
8

To demonstrate the role of water Pb elevations on childhood BLLs, the SAB used EPA’s Integrated 

Exposure Uptake and Biokinetic Model (IEUBK ) (USEPA, 2009) to estimate BLLs for infants (ages 0-

12 months) resulting from a moderate range of water Pb concentrations (Table 1). The IEUBK model 

has been extensively reviewed, tested, and validated and is used throughout EPA to predict childhood 

BLLs from lead exposure. These BLL predictions are based on a simplifying assumption that all of the 

infant’s Pb exposure is from drinking water, consumed directly as a beverage and indirectly in the 

preparation of food and beverages (including infant formula). In addition, the calculations include the 

following inputs: first, that typically a formula-fed infant consumes approximately 500 ml of water/day 

but may consume up to 1500 ml of water/day (USEPA, 2008), and, second, that the bioavailability of 

ingested water Pb is approximately 50% in infants (ATSDR, 1995). For example, with water Pb levels 

varying from 10-30 μg/L and intake between 0.5 and 1.5 liters/day, the predicted geometric mean infant 

BLLs resulting from water intake alone range from 1.2 to 8.2 μg/dL (Table 1), a range associated with 

demonstrable adverse impacts on neurodevelopment (Bellinger 2008; Lanphear et al., 2005). This model 

predicts that 34% of infants consuming 1.5 liters/day of tap water with a Pb concentration of 30 μg/L 

will have BLLs in excess of 10 μg/dL (Table 1). 
9

Table 1: Predicted Infant Blood Lead Levels by Tap Water Lead Concentrations and Water

Intake for Formula-fed Infants 

Predicted geometric mean blood lead (Pb) (μg/dL): 0-12 months*

Water Consumption (L/day)

0.500 1.500

water Pb 

(μg/L)

Blood Pb 

(μg/dL) 

levels

% 

above 5 

μg/dL

% above 

10 

μg/dL

Blood 

Pb 

(μg/dL) 

levels

% 

above 5 

μg/dL

% above 

10 

μg/dL

10 1.2 0.0 0.0 3.3 18.7 0.9

15 1.7 1.2 0.0 4.7 44.7 5.4

20 2.3 4.7 0.1 6.0 64.8 13.7

30 3.3 18.7 0.9 8.2 85.6 34.1

* Predictions from EPA’s Integrated Exposure Uptake Biokinetic (IEUBK) 

model (USEPA, 2009) with absorption fraction (bioavailability) = 50% and 

input parameters for all other sources of Pb set to zero.

Summary and Conclusions

The task for Issue 1 was to assess the evidence in the available medical literature, including the study by 

Brown et al. (2011), regarding the effectiveness of PLSLR in reducing drinking water exposure to Pb. 

There is well-documented and substantial population morbidity associated with even low-level Pb 

exposure in humans, especially for hypertension and related cardiovascular disease risk in adults, and 

neurodevelopment in children (Menke et al., 2006; Bellinger 2008; Lanphear et al., 2005). The 

relationship between Pb exposure and BLL is well established. Thus, the effectiveness of a technology

or process, such as PLSLR, to reduce or eliminate Pb exposure should be possible to gauge by 

examining BLL, a biological marker of Pb exposure, when other Pb exposures are held constant or are 

accounted for.

The results of Brown et al. (2011) provide no evidence of an effective drinking water Pb reduction via 

PLSLR in the short term (e.g., within approximately one year). Specifically, there was no demonstrable

benefit as evidenced by a reduction in childhood BLL from having had a PLSLR compared to having an 

intact LSL. In fact, the study results provide suggestive evidence of the potential for harm (i.e. higher 

BLLs) from PLSLRs. In summary, the available scientific evidence regarding BLLs and PLSLRs, albeit 

limited, does not support use of PLSLR as an effective or safe measure to reduce short term Pb exposure 

of those served by LSLs. However, the long-term (e.g., over a period of years) relationship between

PLSLRs and childhood BLLs cannot be determined from Brown et al. (2011).

3.2. Issue 2 – Studies Evaluating PLSLR with Tap Sampling Before and After Replacement

There are a number of studies that evaluated partial lead service line replacement with tap sampling 

conducted both before and after the replacement (Britton et al., 1981; Gittelman et al., 1992; Muylwyk 

et al., 2009; Sandvig et al., 2008; Swertfeger et al., 2006; USEPA 1991a; USEPA 1991b; Weston et al., 

1990). These studies use a variety of sampling protocols and the timing of sampling after replacement 

differed between studies. What conclusions can be drawn from these studies regarding the effectiveness 
10

of partial lead service line replacement in light of the different sampling protocols and different timing 

of sampling? Please comment on the changes in lead concentrations in drinking water after partial lead 

service line replacements and the duration of those changes.

The weight of evidence (summarized in Appendix C) clearly indicates that PLSLRs often cause tap 

water Pb levels to increase significantly for a period of days to weeks, or even several months. After this 

period the water Pb levels stabilize, sometimes at levels below and sometimes at similar levels as those 

observed prior to PLSLR. It appears that the latter tends to be the case when the tap water Pb levels are 

initially close to or below the AL. In some cases, variations in tap water Pb levels have been observed 

many months after a PLSLR, but the SAB found no evidence that such variations were caused by 

PSLSRs; and it is reasonable to assume they are attributable to other factors. Long-term data are sparse, 

so it is not possible to reliably predict whether the tap water Pb level will significantly increase 

following a PLSLR in a given home or distribution system, the extent to which it will increase, or how 

long the increase will persist. It is nonetheless clear that tap water Pb levels of significant concern may 

persist until the remaining portion of the LSL and any Pb-contaminated piping within the home are 

replaced. Furthermore, the Pb concentrations to which consumers of unfiltered tap water are actually 

exposed to following PLSLR may be significantly higher or lower than the concentrations found using 

the sampling protocols specified in the LCR or other common sampling protocols that can potentially 

undersample or oversample particulate Pb (see Appendix D). 

The magnitude and duration of elevated tap water Pb levels following PLSLR may be influenced by the 

extent of disturbance of the LSL, as well as any countermeasures taken to offset such effects (as 

discussed under Issue 4); the quantity and characteristics of the deposits in the LSL and downstream 

plumbing materials; the chemistry of the local water supply, including treatment to control corrosion; 

biological activity; localized corrosion; and other factors. Unfortunately, studies documenting elevated 

tap water Pb levels following PLSLR have generally not studied the mechanisms involved, so the reason 

for the increase in a given setting is generally not known. Some investigators have speculated that 

particulate Pb is released into the water when Pb-contaminated encrustations are physically or 

hydraulically disturbed. There is a substantial amount of evidence that such disturbances can and do 

occur and that they result in release of particulate Pb (e.g., HDR, 2009; Deshommes et al., 2010; 

McFadden et al., 2011). Some investigators speculate that galvanic corrosion (a process in which an 

electrical connection between different metals can accelerate the corrosion of the less noble metal) may 

occur when the new line is connected and that Pb levels decline as the new material is gradually 

passivated; this possibility is discussed further in the response to Issue 5.

A critical consideration in evaluating the effectiveness of PLSLR is the extent to which it actually 

reduces human exposure to Pb. In promulgating the LCR in 1991, EPA assumed that “partial removal of 

a lead service line will reduce...exposure...because there will be a smaller volume of water in contact 

with the lead service line” (USEPA, 1991a). EPA noted that this assumption was consistent with the 

results of a study of 2000 homes in the UK and with mass transfer modeling. PLSLR obviously 

eliminates a portion of the potential for exposure, since the Pb removed from the system is no longer 

available as a source of exposure; and in certain situations PLSLR would be expected to significantly 

reduce actual long-term exposure to Pb. For example, this could be the case where most of the Pb in tap 

water is dissolved, the LSL is the predominant and proximate source of Pb, and a significant fraction of 

the water actually consumed first sits in the utility-owned portion of the line long enough for the Pb

concentration to significantly increase.

However, the weight of evidence is that PLSLR often causes short-term increases in tap water Pb levels 

and is unlikely to reduce actual exposure in proportion to the fraction of the LSL removed. In many 
11

situations, PLSLR is likely to result in little or no reduction in actual exposure, e.g., where the proximate 

source of most of the Pb actually consumed is household plumbing materials (Pb-bearing faucets, 

fittings, and soldered joints) or Pb-contaminated encrustations in the customer-owned portions of the 

system, especially those capable of releasing Pb-bearing particles into the water. The following 

paragraphs elaborate on several of these points.

If Pb in drinking water were associated only with LSLs and faucet fixtures, and if consumers flushed 

the faucet before taking a drink of water, it might be reasonable to assume that potential Pb exposure 

would be reduced roughly in proportion to the fraction of the LSL removed, with actual exposure 

depending on use patterns and other factors. However, Pb can accumulate in interior plumbing 

downstream from an LSL, especially in galvanized pipes (Sandvig et al., 2008; HDR, 2009; and 

McFadden et al., 2011). This phenomenon, referred to as “seeding” by some investigators (e.g., Sandvig 

et al., 2008), occurs when dissolved and particulate Pb are released from an LSL and captured 

downstream by various mechanisms. These mechanisms include: adsorption of dissolved Pb onto scale 

deposits and corrosion products; incorporation of dissolved Pb into scales by precipitation and coprecipitation; and deposition of Pb-bearing particles onto surfaces, especially the very irregular and 

rather porous surfaces typically associated with iron rust (which develops in galvanized pipe after the 

protective zinc layer dissolves away). Thus, the entire plumbing system, not just the LSL, may be a 

significant source of Pb; and Pb-contaminated encrustations may contain enough Pb to pose a significant 

health hazard for many years after the LSL has been partially or fully replaced.

Since 1991, a number of studies have documented the importance of particulate Pb in tap water (e.g., 

McNeill and Edwards, 2004; Triantafyllidou and Edwards, 2007; HDR, 2009; Deshommes et al., 2010). 

It is now widely recognized that a large fraction of the Pb in a given water sample may be present in 

particulate form, and that particulate Pb can be sporadically released into the water from LSLs or from 

Pb-contaminated household plumbing downstream from an LSL. Such releases can result from sudden 

increases in flow rate (such as those caused by fully opening a tap), variations in water quality, seasonal 

changes in temperature, bacterial growths, and other physical or hydraulic disturbances to the system 

such as PLSLR and “water hammer” (the banging of a pipe caused by a sudden increase or decrease in 

flow rate).

Although the concentration of dissolved Pb (including soluble complexes) in tap water can exceed the 

AL, Pb is relatively insoluble in tap water. Dissolved Pb concentrations exceeding 100 μg/L are 

generally not expected to be found in systems with optimized corrosion control. Particulate Pb

concentrations, however, can be much greater. For example, McNeill and Edwards (2004) found 508 

μg/L of particulate Pb in a first-draw sample collected by a surveyed water utility, and they found over 

2,000 μg/L of Pb (mostly particulate) in two samples collected during a pipe loop study. HDR (2009) 

reported finding 2,172 μg/L of Pb in a sample influenced by “water hammer,” but the dissolved Pb

concentration was below the AL. Britton and Richards (1980) reported a Pb concentration of over 4 

mg/L in a first draw sample collected one week after a PLSLR, and most of the Pb in this sample was 

presumably particulate given the solubility of Pb in tap water. The potential for the tap water Pb

concentration to be this high, in even a single sample, in a household served or previously served by an 

LSL, merits careful consideration in future exposure assessments. The bioavailability of Pb is expected 

to vary with particle size and composition, and this also merits further evaluation.

Even in cases where particulate Pb does not pose a problem, PLSLRs may result in little or no benefit if 

much of the water consumed is initially stagnant for an extended period of time in the customer-owned 

portion of the LSL, in Pb-contaminated household piping, or in Pb-bearing fixtures. Consumers who fail 
12

to flush their lines before drawing a glass of water may be exposed to relatively high concentrations of 

dissolved Pb. Those who flush their lines using a change in water temperature as an indication that the 

water is coming from the main may be exposed to high Pb levels if the customer-owned portion of the 

LSL is significantly colder than room temperature.

An important consideration in evaluating the effectiveness of PLSLR is the extent to which the shortterm increases in exposure following PLSLR are offset by the long-term reductions in exposure 

anticipated following PLSLR. EPA implemented the current LSL replacement program based on the 

premise that “lead is primarily of concern because of ... chronic health effects, rather than acute toxicity” 

and the long-term benefits of PLSLR outweigh the adverse effects of short-term increases in tap water 

Pb levels (USEPA, 1991a). The SAB concludes this premise should be thoroughly re-evaluated, based 

on current information, for the following reasons:

1. The health risks associated with even relatively short-term exposures could be substantial 

depending on the magnitude and duration of elevated Pb levels, water intake, and individual 

susceptibility.

2. Tap water Pb levels observed following PLSLR are often high enough to be of concern from 

a human health standpoint, and they may remain elevated for longer periods of time than 

previously thought and stabilize at levels higher than anticipated.

3. Recent data published after 1991 demonstrate that young children are vulnerable to Pb at 

exposure levels lower than were previously recognized.

\

4. The tap water Pb levels to which consumers are actually exposed following PLSLR may be 

higher than those determined using current sampling protocols, which tend to undersample 

particulate Pb (Appendix D), and consumers can be exposed to Pb not only by drinking Pbcontaminated tap water but also by ingesting food cooked with tap water or beverages or 

infant formula prepared using tap water. 

5. Sporadic release of particulate Pb into tap water from Pb-contaminated interior plumbing 

materials can result in extremely high tap water Pb levels, reducing the anticipated 

effectiveness of PLSLR.

If the health risks associated with short-term increases in tap water Pb levels following PLSLR are 

significant, it may be possible to achieve significant risk reduction by modifying the LSLR requirements 

in the LCR. Options for reducing exposure include using point-of-use treatment capable of removing 

both dissolved and particulate Pb, public education, full LSLR, and replacement of any plumbing 

materials encrusted with Pb-bearing deposits. As discussed in the response to Issue 3, full LSLRs are 

generally more effective than PLSLRs in reducing tap water Pb levels, but full LSLRs can also result in 

short-term increases in tap water Pb levels that merit further evaluation and perhaps improved mitigation 

measures. Full LSLRs are currently recommended, but few home owners choose this option due to its 

cost. Options for increasing participation in full LSLR programs include public education as well as 

economic inducements such as subsidies, loan programs, and mandatory notification of prospective 

home buyers that the home contains a LSL.

Several public commenters, as well as several Panel members, noted that most PLSLRs are done by 

utilities for reasons other than compliance with the LCR. Some utilities voluntarily replace more LSLs 
13

than required under the LCR; but most replacements are done in the normal course of utility operations 

such as repairing leaks and replacing mains, sometimes in emergency situations. In most cases, such 

replacements are partial because the majority of home owners choose not to replace the privately owned 

portion of the line. The SAB’s consensus is that these voluntary PLSLRs pose short-term exposure risks 

(and potential long-term health risks) similar to those associated with mandatory PLSLRs, since they are 

expected to result in similar short-term increases in tap water Pb levels; and they may pose even greater 

exposure risks if the risks are not as well managed, e.g., by notifying consumers, flushing the lines, etc. 

Most voluntary replacements involve LSLs that either must be disturbed (e.g., to permit installation of a 

new main) or that are disturbed before being recognized as LSLs, so disturbance of the lines and the 

resulting short-term increases in tap water Pb levels are unavoidable. Thus, voluntary PLSLRs may 

represent an opportunity for significant risk reduction if properly managed. Options for risk reduction 

include public education, encouraging full replacements, recommending point-of-use treatment while Pb

levels remain elevated, using bottled water, and recommending or requiring certain management 

practices such as line flushing. Some utilities already employ some of these practices.

Accurate assessment of the effectiveness of PLSLR in reducing exposure to Pb depends, in part, on the 

accurate determination of tap water Pb concentrations, which in turn, depends on collection of 

representative samples. The sampling protocols specified in the LCR were designed to determine Pb

only in: (1) first-draw samples of standing water (to assess the effectiveness of optimized corrosion 

control and the potential for exposure to Pb in the first glass of drinking water drawn without flushing 

the tap); and (2) water left standing in the customer-owned portion of LSL. These and other common 

sampling methods may fail to produce samples containing representative concentrations of particulate 

Pb (Appendix D). Therefore, results obtained using these methods may result in significant 

underestimation of exposure to Pb in tap water or overestimation when using methods designed to 

dislodge particulate Pb. There appears to be no simple solution to this problem, but the limitations of 

current sampling protocols should be carefully considered in future revisions to the LCR, in evaluating 

studies of Pb in tap water, and in assessing the potential impacts of tap water Pb levels on human health.

Summary

The weight of evidence indicates that PLSLR often causes tap water Pb levels to significantly increase 

for a period of days to weeks, or even several months. Available data suggest that tap water Pb levels 

tend to gradually stabilize over time following PLSLR, sometimes at levels below those observed prior 

to PLSLR, and sometimes at levels similar to those observed prior to PLSLR. There are insufficient data 

to reliably predict whether the tap water Pb level will significantly increase following a PLSLR in a 

given home or distribution system, the extent to which it will increase, or how long the increase will 

persist.

3.3. Issue 3 – Studies Comparing PLSLR with Full Lead Service Line Replacements

There are a number of studies that compared partial lead service line replacements with full lead 

service line replacements (HDR Engineering, 2009; Sandvig et al., 2008; Swertfeger et al., 2006). What 

conclusions can be drawn from these studies regarding the relative effectiveness of partial lead service 

line replacement versus full lead service line replacement in reducing drinking water lead levels in both 

the short-term and long-term?
14

The studies cited in the charge that provided direct or indirect comparisons between partial and full 

LSLRs were reviewed. HDR Engineering (2009) compared Pb concentrations after partial or full LSLR 

in households with galvanized premise plumbing. Pb concentrations in tap water were not substantially 

lower in the homes with full LSLRs. The LSLs were believed to have ‘seeded’ the galvanized premise 

plumbing with Pb prior to the LSLR, and the Pb released from the ‘seeded’ premise plumbing was 

believed to account for much of the load observed in tap water after the (partial or full) replacement of 

the service line. 

In Sandvig et al. (2008), corrosion control was identified as the most effective method, and a necessary 

first step, to achieve LCR compliance. The report recognized, however, that LSLR was inevitable on a 

site-by-site basis when routine maintenance required replacement of parts of the distribution system. For 

homes with LSLs, those lines were found to contribute 50 to 75% of the Pb mass in household tap water,

premise plumbing was found to contribute an additional 20 to 35% of the Pb mass (likely from ‘seeding’ 

from LSLs), and faucets were found to contribute 1 to 3% of the Pb mass. PLSLR did not reduce Pb

levels in the first liter collected during sampling, and resulted in only minimal improvement in total 

mass measured in household tap water over the entire duration of sampling. Full LSLR reduced the total 

mass of Pb measured in tap water during sequential sampling as well as in the first liter collected. It was 

also found that the effectiveness of full LSLR relative to PLSLR in reducing tap water Pb levels is 

highly site specific. Both partial and full LSLR generally result in elevated Pb concentrations for sitespecific durations after replacement. 

In the study performed by Swertfeger et al. (2006), 21 houses were sampled: (a) five houses with a full 

LSLR; (b) five houses with a PLSLR; (c) six houses with a PLSLR with Teflon® shrink wrap tubing 

around the cut section at the property line; and (d) five control sites where no work was performed on 

the LSL. Corrosion control measures were implemented in the distribution system at roughly the same 

time as partial and full LSLR, confounding any comparison of Pb levels in the tap water immediately 

after the LSLR. However, comparing Pb levels in tap water one year after replacement are deemed 

credible as a basis for comparing the effectiveness of partial versus full LSLR. At that time, all five

households with a full LSLR, but only three of the five homes with a PLSLR, had Pb levels less than 5 

μg/L; the other two households with a PLSLR had Pb levels close to the LCR AL of 15 μg/L. 

The studies by Britton et al. (1981), Gittelman et al. (1992), Muylwyk et al. (2009), USEPA (1991a,

1991b), and Weston et al. (1990) were also considered. The study by Wujek (2004) was not considered 

relevant to this issue because the disinfectant was changed from chloramine to free chlorine between the 

pre- and post-PLSLR sampling, making it impossible to draw any valid, causal relationship between the 

line replacement and Pb concentrations measured in the tap water. In all the studies conducted to date

(with the exception of the one-year sample followup in the 2006 Swertfeger et al. study), the time period 

of evaluation of Pb concentrations following partial and full LSLRs has been inadequate to fully 

evaluate their relative long-term effectiveness. Nevertheless, based on review of the above mentioned 

studies, the SAB concludes (Pb levels are in reference to total Pb, inclusive of both dissolved and 

particulate Pb): 

• In water distribution systems optimized for corrosion control, full LSLR has been shown to 

be a generally effective method in achieving long-term reductions in drinking water Pb levels. 

However, full LSLR often results in elevated and inconsistent Pb levels (frequently above the 

LCR AL) for a variable period of time after replacement.
15

• PLSLR has not been shown to be reliably effective in reducing drinking water Pb levels, at 

least in the time frames of the reported studies. Pb levels are typically elevated for a variable 

period of time after replacement, as is the case for full LSLR. The limited evidence available 

suggests that the duration and magnitude of the elevations may be greater with PLSLR than

full LSLR. 

• Following full LSLR, in households with non-leaded household plumbing, elevated Pb levels 

in drinking water largely originate from release of Pb that has been deposited onto non-Pb

premise plumbing. The problem is apparently more acute in households with galvanized 

plumbing.

• Management of Pb consumption by residents following partial or full LSLR would benefit 

from more aggressive occupant education. In the judgment of theSAB, occupant education 

has been inadequate and has therefore not been nearly as protective of the public health as is 

possible. Occupant education should reflect (in layman’s terms) the knowledge gained from 

the studies cited in this report about the lengthy period of elevated Pb levels in both firstflush and profile samples of tap water. Specific suggestions could be given about flushing the 

lines and monitoring Pb levels over a period of months.

• The contribution of Pb mass measured in household tap water during profile sampling is 

greatest from the LSLs, followed by premise piping, and then faucets. The contribution from 

water meters is negligible. For this reason, the strategy for reducing drinking water Pb levels 

should be done in that same order, that is, (1) full LSLR; (2) removal of Pb precipitate and 

Pb-contaminated deposits in premise plumbing; (3) replacement of Pb-bearing faucets. 

Removal of Pb from premise plumbing after full LSLR may involve, but is not limited to, 

aggressive flushing strategies; in cases in which the deposits are heavily encrusted with Pb, 

simple water flushing might be inadequate. 

Summary

Several studies that compared partial and full LSLRs were evaluated. The SAB finds that in these 

studies, the time periods of evaluation of Pb concentrations following partial and full LSLR have been 

inadequate to fully evaluate the effectiveness of reducing drinking water Pb levels. Nevertheless, for the 

time periods reported in the studies, the SAB concludes that in water distribution systems optimized for 

corrosion control, full LSLRs have been shown to be a generally effective method of reducing drinking 

water Pb levels. However, PLSLRs have not been shown to be reliably effective in reducing drinking 

water Pb levels, at least in the time frames of the reported studies. Both full LSLRs and PLSLRs 

generally result in elevated Pb levels for a variable period of time after replacement, but the limited 

evidence available suggests that the duration and magnitude of the elevations may be greater with 

PLSLR than full LSLR. 

3.4. Issue 4 – Studies Examining PLSLR Techniques

Some studies have looked at other factors that can influence lead levels following a partial lead service 

line replacement, such as the pipe cutting, flushing to clear the lines and pipe joining techniques (Boyd 

et al., 2004; Kirmeyer et al., 2000; Sandvig et al., 2008; Wujek et al., 2004). What conclusions can be 

drawn from these studies regarding techniques that should be followed for partial lead service line 
16

replacements to reduce lead drinking water exposures? Please comment on whether a standard 

operating procedure can be developed to minimize spikes in drinking water lead levels after partial lead 

service line replacement.

LSLR is one of two “treatment techniques” identified by EPA that can be used to achieve compliance 

with the LCR and is typically the last treatment technique available to a water utility to gain compliance 

with the LCR. By listing several techniques associated with LSLR in the issue statement, as “other 

factors,” it would appear the intent of the issue is to focus solely on the physical techniques used to 

remove the LSL. However, most water utilities follow a systematic procedure that involves several other 

steps when fully or partially removing an LSL. Some of these steps are required by regulation and some 

are outlined in EPA guidance. Not all involve physical contact with the service line, yet all are critical to 

the success of a LSL replacement program and are necessary for reducing Pb exposure. Therefore, water 

pressure and flow changes, cutting techniques, joining techniques, flushing, and public education were 

considered in the discussion on PLSLR techniques2

 2 Information on locating and identifying LSLs is provided in Appendix E. Replacement and rehabilitation techniques are 

also discussed in Appendix E. At present, these techniques are not thought to affect lead release from PLSLR.

. 

The studies supplied with the issue statement provide limited insight on the impact that PLSLR 

techniques can have on Pb release. Based on the limited research available, the SAB can find no clear 

evidence that the techniques used for PLSLR are responsible for the elevated Pb levels observed in tap 

water following PLSLR. 

Water Pressure Changes and Flow which Affect Pb Release

Since water is under pressure, it must be shut off at the main or the main must be depressurized 

(disrupting flow to other parts of the distribution system) before work on the service line can begin. 

Water shutoff at the service connection is a quick and efficient way to isolate the worksite in preparation 

for a PLSLR with minimal service disruption. Shutting the water off to the home for a PLSLR is a onetime event that is not as frequent as the local mechanical actions of turning a faucet on or off. 

Boyd et al. (2006) used LSLs recovered from a water distribution system in pipe loops to examine how 

the intermittent operation of faucets might affect Pb release following a PLSLR. The different loops 

were operated with intermittent flow (one with slow opening and closing movements and one with rapid 

movements) to simulate the opening and closing of a faucet. These loops showed continual releases of 

Pb for over two weeks after startup. The study data provide some insight on how normal pressure 

transients under household flow conditions could impact Pb release after a PLSLR. The flow rates used 

in the study were atypical of both high and low flow faucets typically provided by home faucets, but the 

results did demonstrate that the on/off operation of faucets could produce elevated Pb releases in the 

LSLs. Having the researchers provide their raw data for further analysis would be a potential means of 

gathering more information that could be used to evaluate the role of pressure and flow transients in Pb

exposure within the home. 

In similar tests with galvanically coupled (Pb-Cu) pipes exposed to flow twice per day, Cartier et al.

(2011) found that lead was released in spikes of up to a few hundred micrograms per liter for at least six 

months after the pipes were connected, when high water flow rates (32 L/min) were used. The spikes 

were less frequent and less severe at medium flow rates (8 L/min), and were virtually non-existent at 

low flow rates (1.3 L/min). These results emphasize the importance of specifying the flow rate when 
17

sampling for Pb concentrations in drinking water and demonstrate that an incorrect conclusion could be 

drawn about the potential human exposure to lead if sampling is conducted at lower flow rates than are 

commonly used when consumers open their taps.

In summary, Pb release appears to be affected by water flow and pressure changes associated with 

faucet use under experimental conditions. No clear conclusions can be drawn regarding how pressure 

changes or flow could be managed or optimized so as to minimize Pb exposure after PLSLR. 

Cutting Techniques

Once the LSL has been located and exposed for removal and the water shutoff, the line must be 

disconnected or severed so it can be detached from the main and the premise plumbing. Generally with a 

PLSLR, the LSL is severed close to the curb stop or water meter. When a full LSL replacement is done,

the LSL will be severed closer to the house. 

Two studies (Sandvig et al., 2008 and Wujek, 2004) examined the methods used to cut into the existing 

service line in an attempt to determine their impact on Pb release following a PLSLR. The available 

techniques that were examined were using a hacksaw, pipe cutter, and pipe lathe. The Sandvig et al. 

(2008) study examined the use of a hacksaw and disc cutter on PLSLR. Five PLSLR cases were 

conducted with a hacksaw which resulted in an increase in the mass release of Pb following PLSLR in 

three of the five cases. Using a disc cutter in three PLSLRs resulted in only one case showing an 

increase in the mass of Pb level released following PLSLR. However, due to the limited sample size and 

high degree of variability in the total Pb mass released, the difference between the two groups is not 

likely to be statistically significant. The Wujek study conducted Pb profiles before and after PLSLR and 

was used to demonstrate the effectiveness of PLSLR. However, this study has been criticized because 

data were collected during a transition in disinfection which could have affected the measured water Pb 

levels. The Wujek finding that Pb levels decreased after PLSLR could in fact be in part or whole due to 

changes in water treatment, rather than the replacement of Pb-releasing service lines. 

In summary, given the variable circumstances, the small sample size, and the fact that the other variables 

associated with PLSLR, such as flushing, were not adequately controlled, the SAB concluded that they 

could not determine if any one cutting technique provided any benefit over another. 

Joining Techniques

Connecting two dissimilar metals creates a potential for galvanic corrosion, an issue addressed in Issue 5. 

Swertfeger et al. (2006) investigated the use of Teflon® sleeves to connect the two pipe ends in a 

PLSLR. When used in combination with a union, the sleeve serves as a dielectric. Swertfeger et al. 

(2006) found that Pb concentrations in first-draw samples after PLSLR were slightly lower when the 

pipes were joined by heat shrink Teflon® sleeves compared to when the pipes were directly joined. The 

results for total Pb release (including water collected after the first-draw sample) were not provided and 

could be a source of additional information. Given that this is a new technique that has not been 

extensively evaluated, the SAB does not believe that there is sufficient evidence to assess its potential 

benefits. 

 
18

Flushing

In a service line replacement, the objective of flushing is to remove any materials that may have been 

introduced into the new service line while the service line was open and exposed to the surrounding 

environment (e.g., dirt, bacteria, etc.) or that were released from the interior pipe walls when the pipe 

was disturbed (corrosion products and biofilms). Following service line replacement, the line will be 

flushed at the point of connection and/or at the household faucet. Flushing at the point of connection is 

likely to be more vigorous than flushing via household faucets because the latter restrict water flow to a 

greater extent than the larger diameter connection pipes. The scouring of the inside of the pipe caused by 

flushing can expose new pipe surface when materials next to or bound to the surface are caught or 

entrained by the passing water. These newly exposed pipe surfaces may then undergo restabilization or 

passivation. Restabilizing pipe surfaces is known to be a relatively slow process. The elevated water Pb 

levels observed after PLSLR which only declined after an extended period could be an indication that 

optimal corrosion control conditions may not be optimal for passivation. 

As noted previously, Boyd et al. (2006) examined the impact of flow on Pb release in pipe loops 

composed of Pb pipe removed from a water utility system. The study examined both “low” and “high” 

flow conditions with both continuous and intermittent flow. The flow rates were lower than expected for 

normal water use, but the study suggests that allowing water to continually flow through the service line 

will stabilize the service line resulting in reduced Pb release. The authors state that “the total lead 

concentrations eventually can be reduced below the AL and stabilized provided sufficient water is 

flushed through the pipe”. For the pipes studied under intermittent flow conditions, Pb continued to be 

released from the line over the 2-week test period. This study was limited to one utility. 

Sandvig et al. (2008) recommended that a rigorous flushing regime of up to 60 minutes might help to 

reduce particulate Pb following PLSLR. At Seattle Public Utilities, it was found that 63 days of 

intermittent flushing at 1 L/min for 3 hours per day was required before the Pb levels stabilized below 

the AL following a physical disturbance to the water meters. DC Water found that flushing immediately 

after LSLR was effective at reducing tap water Pb levels and they recommended 60 minutes of flushing 

after PLSLR. However, the study did not include longer term follow-up to examine reoccurrence of Pb

over time. Greater Cincinnati Water Works examined Pb in plumbing components at one tap for 2 years. 

They found that Pb decreased but was still present based on sampling after a variety of flushing times.

In summary, line flushing appears to provide some benefit, but the magnitude of the water flow, and the 

duration of time, required to realize this benefit is not well understood. The time to realize the benefit 

(up to several weeks of flushing in the reviewed studies) likely precludes any practical implementation 

of this technique. 

Public education

In 2008, EPA published a revised public education guidance document. This document extensively 

addresses public notification and education regarding mitigation measures should the water Pb AL be 

exceeded. Additional public education requirements are addressed in other EPA publications (USEPA, 

1991a, 1998, 2010; and the Safe Drinking Water Act Amendments of 1996). The LCR includes 

mandatory language for all utilities whether they meet or exceed the action levels specified in the LCR. 

Thus, public education is a method with the potential for mitigating Pb exposure from tap water. 
19

The public education guidance establishes requirements for content and delivery of public education 

materials, mandatory language, water testing services, procedures for establishing a task force and 

program implementation approaches. The guidance addresses LSLR, but not specifically PLSLR. The 

document includes a recommendation for customers to “Run water for 15-30 seconds to flush Pb from 

interior plumbing [or insert a different flushing time if your system has representative data indicating a 

different flushing time would better reduce Pb exposure in your community and if the State Primacy 

Agency approves the wording] or until it becomes cold or reaches a steady temperature before using it 

for drinking or cooking, if it hasn’t been used for several hours. [It is likely that systems with lead 

service lines will need to collect data to determine the appropriate flushing time for lead service lines.]” 

While this guidance provides for broad consideration for establishing utility-specific flushing times, the 

guidance may not adequately address the flushing needed for reducing the risk from PLSLRs. The SAB 

recommends that USEPA review the 2008 guidance in light of current information on PLSLR impacts 

on water quality in order to address the specific concerns regarding mitigation of lead spikes following 

replacement. EPA should also review sampling and flushing protocols to ensure they accurately reflect 

maximum flow rates from faucets that are certified to meet the plumbing “green” codes. 

The guidance also includes other mitigation options to reduce lead, including the purchase of bottled 

water or a point-of-use treatment device: “You may want to consider purchasing bottled water or a water 

filter. Read the package to be sure the filter is approved to reduce lead or contact NSF International at 

800-NSF-8010 or www.nsf.org for information on performance standards for water filters. Be sure to 

maintain and replace a filter device in accordance with the manufacturer’s instructions to protect water 

quality.” Even if a proper point-of-use treatment device is used, the consumer is responsible to see the 

device is properly installed, operated, and maintained; failure to do so would likely result in higher Pb

exposure. 

The SAB concludes that public education cannot be expected to provide public health protection if the 

formulated advice is not well grounded in science. If the fundamental tenets of Pb release are not well 

understood, it could result in an unsuspecting public being unintentionally exposed to elevated Pb levels. 

In addition, public education should complement engineering practices rather than be viewed as a sole 

means to solving a water quality issue. 

The SAB found no information to suggest that PLSLR undertaken voluntarily in the course of 

maintenance or repair operations differ from PLSLR undertaken to ensure compliance with the LCR in 

their capacity to cause elevations in the lead content of water at the tap. However, the lack of mandatory 

water lead testing and homeowner education associated with voluntarily PLSLR suggests that in practice, 

voluntary replacement might be associated with greater exposure of the public to lead. 

Conclusion

The SAB reviewed studies of techniques which could mitigate exposure to lead in drinking water after 

PLSLR. In general, only scanty information is available. There is some evidence that flushing may be 

beneficial, however studies regarding the magnitude and duration of the flushing process are lacking. 

Public education has the potential to provide some benefit as well, and there may be an opportunity for 

enhancing the mitigation of Pb exposure if voluntary PLSLR also triggered public education. 
20

Given the lack of definitive studies on the effectiveness of different procedures and approaches to 

PLSLR, recommendations regarding standard operating procedures to mitigate the impacts on lead

exposure relating to PLSLR cannot be made at this time. 

Several Panel members also suggested that one method that would reduce drinking water lead exposure 

(due to the short-term drinking water lead level elevations) would be to refrain from conducting PLSLRs. 

However, other Panel members indicated that this might not be practical due to the fact that most 

PLSLRs are "voluntary" and are performed in the normal course of utility operations such as repairing 

leaks, replacing mains, and sometimes in emergency situations.

The SAB recommended that EPA note that the following set of studies could inform this issue: 

• Cutting techniques: Future studies could be conducted under carefully controlled conditions to 

ensure the elements that comprise PLSLR (e.g., cutting and flushing) can be isolated and 

evaluated for their individual effectiveness on the mitigation of Pb exposure after PLSLR and 

LSLR.

• Flushing: The relationship of flushing on Pb release under different water quality conditions and 

water use patterns could be studied under carefully crafted protocols that isolate the impacts of 

flushing from the other components of PLSLR.

3.5. Issue 5 – Studies Examining Galvanic Corrosion

Galvanic corrosion is a possibility if copper pipe is joined directly with the remaining portion of the 

lead service line. Several studies examined the issue of galvanic corrosion (Boyd et al., 2010b; DeSantis 

et al., 2009; Deshommes et al., 2010; Rieber et al., 2006; Triantafyllidou et al., 2010). What conclusions 

can be drawn from these studies regarding the potential for elevated lead levels at the tap from galvanic 

corrosion? Please comment on the inclusion of a dielectric between the lead and copper pipes as a way 

to minimize spikes in drinking water lead levels after partial lead service line replacements. Please 

comment on the inclusion of the dielectric as part of the standard operating procedures for partial lead 

service line replacements.

Issue 5 focuses on galvanic corrosion, a process in which an electrical connection between different 

metals can accelerate the corrosion of the less noble metal. In responding to this issue, the SAB 

considered both the intentional, direct connection that can occur between a copper and a Pb pipe during 

PLSLR, and also depositional corrosion, in which copper ions in solution can be deposited as metallic 

copper when they contact a less noble metal such as Pb. When the copper is deposited in this way, a new 

copper/Pb interface is created, and the conditions necessary for galvanic corrosion to proceed are 

established. Although the theory of depositional corrosion is well developed, insufficient data exist to 

fully assess its significance in systems with LSLs. To the extent that depositional corrosion occurs, it can 

affect Pb in two ways: Pb is oxidized when the copper is first deposited, and the copper/Pb electrical 

connection can subsequently serve as a site of galvanic corrosion.

Several studies have been conducted to identify and quantify the significance of galvanic corrosion 

when PLSLRs are implemented. Parameters related to Pb corrosion that have been measured in these 

studies include the profiles of electrical potential (Reiber and Dufresne, 2006; Boyd et al., 2010b) and 

current as a function of distance from the site of electrical contact, the magnitude of the galvanic current 

(Triantafyllidou and Edwards, 2010), and Pb release into the water (Boyd et al., 2010b; Triantafyllidou 
21

and Edwards, 2010); in addition, precipitates that accumulate near the site of metal/metal contact have 

been characterized (DeSantis et al., 2009). The conclusions that have been drawn from the studies vary 

widely, in part because of the disparate procedures and metrics that have been used to assess the 

corrosion process, and in part because the process itself is complex and might proceed at vastly different 

rates in different systems. Despite some divergence of opinion as to the severity of the problem posed by 

galvanic corrosion, there seems to be widespread agreement that the electrical potentials and currents 

change when Pb and copper are brought into electrical contact, and that the region over which these 

changes are substantial is confined to a few inches on either side of the contact point.

In several studies (e.g., Reiber and Dufresne, 2006), the parameters that were measured to assess the rate 

of galvanic corrosion changed substantially when the pipes were first joined, but the magnitude of these 

changes diminished significantly during a period of days to a few weeks thereafter. These observations, 

in combination with the limited spatial extent of the perturbation in electrical potential, have been 

invoked to support the contention that galvanic corrosion is unlikely to present a long-term problem, 

especially in systems where the water quality has been controlled to limit the Pb corrosion rate. 

However, one other study has suggested that corrosion can continue at a significant rate for at least 

several months (Britton and Richards, 1981).

Part of the apparent discrepancy in the conclusions drawn in different studies is probably related to the 

different metrics employed. The studies that relied on Pb release did not account for Pb that was 

oxidized but not mobilized (i.e., that was converted to solids that remained at or near the site of 

corrosion). Also, the fact that galvanic corrosion occurs primarily over a small area in these systems 

does not imply that it is inconsequential, especially in light of the exceedingly small length and depth of 

pipe that must corrode to pose a potential risk to a consumer, if that Pb exits the tap in a small volume of 

water. There is little doubt that Pb can sometimes be released long after it corrodes, in response to 

physical or chemical changes in the system (e.g., stagnation, water hammer, and/or high water velocities 

- Deshommes et al., 2010; Boyd et al., 2004).

The studies that relied on measurements of galvanic current provide a direct indication of the rate at 

which metallic Pb is converted to ionic Pb, but not of the rate or likelihood that the corroded Pb will be 

carried to the tap. If the water chemistry is well controlled (e.g., if a free chlorine residual is always 

present), this corroded Pb might remain attached to the pipe almost indefinitely. The presence of large 

amounts of Pb-containing solids near Pb/copper joints decades after the galvanic connection was made 

(DeSantis et al., 2009) provides evidence that substantial corrosion can occur at such sites and that some 

portion of the corrosion products might remain in place for long periods, but it sheds no light on the 

question of how often, or in what doses, the Pb is mobilized. In addition, even in systems where the 

normal conditions favor retention of corroded Pb near the site of corrosion, changes in water quality due 

to stagnation, changes in treatment processes, blending of source waters, or other phenomena could 

mobilize the corrosion products.

Another source of the discrepancy is the complex interactions of the parameters that govern corrosion. 

For example, corrosion metrics have been reported to depend (in part) on the degree of passivation of 

the Pb pipe (Reiber and Dufresne, 2006; Boyd et al., 2010b); the ratio of the cathode to the anode areas 

(i.e., the length ratio of the copper pipe to Pb pipe) (Reiber and Dufresne, 2006; Triantafyllidou and 

Edwards, 2010); the configuration of the galvanic contact (e.g., direct connection vs wired/jumpered 

connection) (Boyd et al., 2010b); and the chemistry of the water, including the concentration and 

identity of passivating agents or disinfectants present (Boyd et al., 2010b), the pH of the water (Boyd et 

al., 2010b), and the chloride to sulfate ratio (Edwards and Triantafyllidou, 2007; Triantafyllidou and 
22

Edwards, 2010). It has also been argued that the presence of microenvironments (Nguyen et al., 2010) 

that might result from localized corrosion, from biological activity, or from occasional periods of 

stagnation could affect corrosion. Such microenvironments might not be detected by measurements of 

the system properties at just a few locations that are more representative of the average system 

conditions. Studies in which water is continuously circulated could, therefore, potentially yield different 

results from those in which the water is allowed to stagnate (Triantafyllidou and Edwards, 2010). 

The direct question asked in Issue 5 was: What conclusions can be drawn from these studies regarding 

the potential for elevated lead levels at the tap from galvanic corrosion? The SAB notes that galvanic 

corrosion has the potential to contribute to elevated Pb levels in tap water by (1) increasing the rate of 

corrosion and/or (2) increasing the likelihood that corroded Pb will be mobilized. The available evidence 

strongly supports the contention that galvanic corrosion increases the corrosion rate near the point of 

metal/metal contact shortly after the contact is made. It also supports the contention that galvanic 

corrosion can be significant for periods of at least several months thereafter. The time frame and 

magnitude of this increase are uncertain and probably differ among different systems, depending on the 

water quality and other local conditions. The SAB is not aware of evidence suggesting that Pb that is 

oxidized galvanically is more or less likely to be mobilized than Pb that is oxidized by other 

mechanisms. The SAB therefore concludes that galvanic corrosion associated with partial lead service 

line replacement does pose a risk of increased Pb levels in tap water, and that this risk might persist for 

periods of at least several months, but that the risk is unlikely to be uniform on either a temporal or 

spatial basis and is therefore very difficult to quantify. 

The SAB was also asked to comment on the inclusion of a dielectric between the lead and copper pipes 

as a way to minimize spikes in drinking water lead levels after partial lead service line replacements and 

on the inclusion of the dielectric as part of the standard operating procedures for partial lead service 

line replacements.

Insertion of a dielectric breaks the electrical connection and thereby eliminates galvanic corrosion 

associated with the direct connection between copper and Pb pipes, but it has no effect on depositional 

corrosion or the galvanic corrosion that can ensue at such a site. As noted earlier, one approach for 

inserting a dielectric is to use heat-shrink Teflon® to join the two pipe ends. Because the relative 

magnitudes of galvanic corrosion at the pipe juncture vs. that induced by depositional corrosion have not 

been quantified, it is not possible to state with confidence how much galvanic corrosion will be reduced 

by insertion of a dielectric. However, there is no question that some reduction will be achieved.

The short-term elevations (“spikes”) in drinking water Pb levels that are commonly observed 

immediately after PLSLR could be caused by both mobilization of lead that was oxidized prior to the 

replacement and the relatively high rate of galvanic corrosion when the pipes are first joined. The 

insertion of a dielectric will eliminate the contribution of galvanic corrosion to these spikes. Because the 

relative importance of the two contributions is uncertain, the quantitative effect of inserting the dielectric 

cannot be predicted; it is likely that spikes in Pb concentration would still be seen in tap water even if a 

dielectric were inserted, but the magnitude of those spikes might diminish in some cases. The general 

situation is largely the same in the longer term, except that the reasons for any spikes are less clear and 

predictable (e.g., they might occur because of a transient change in water quality, rather than the known 

physical disruption associated with a PLSLR). Under the circumstances, the SAB concludes that 

insertion of a lead-free dielectric is likely to have beneficial effects on Pb concentrations in tap water, 

albeit of uncertain magnitude. Given the relatively low direct cost of inserting such a device, the SAB 

has concluded that doing so would be appropriate in situations where the decision to implement a 
23

PLSLR has been made, provided that other issues (e.g., electrical grounding requirements, durability, 

and pipe-thawing practices) are adequately addressed. The SAB is aware that insertion of a dielectric 

might result in other costs or have other consequences. For example, it would reduce the effectiveness of 

the water pipe as an electrical grounding device and would interfere with the use of electrical currents to 

thaw frozen water lines. These and other secondary phenomena have not been considered as part of this 

assessment.

Summary

The available evidence strongly supports the contention that galvanic corrosion increases the corrosion 

rate of the Pb pipe near the point of metal/metal contact shortly after the contact is made. The SAB 

concludes that galvanic corrosion associated with PLSLR does pose a risk of increased Pb levels in tap

water, and that this risk might persist for periods of at least several months, but that the risk is unlikely 

to be uniform on either a temporal or spatial basis and is therefore very difficult to quantify given 

current information and the heterogeneity of water systems and conditions in the United States. Insertion 

of a dielectric breaks the electrical connection between the new and old pipes, and thereby eliminates 

galvanic corrosion at the copper and Pb pipe junction, but it has no effect on depositional corrosion or 

the galvanic corrosion that can subsequently ensue at the site of depositional corrosion. The SAB 

concludes that insertion of a lead-free dielectric is likely to have beneficial effects on Pb concentrations 

in tap water, albeit of uncertain magnitude, but the SAB did not evaluate other factors or consequences 

associated with this practice. 

3.6. Conclusion

The number of studies to examine the ability of PLSLR to reduce lead exposure is small and those 

studies have major limitations (small number of samples, limited follow-up sampling, lack of 

information about the sampling data, limited comparability between studies, etc.). Overall the SAB finds 

that, based on the current scientific data, PLSLRs have not been shown to reliably reduce drinking water 

lead levels in the short term, ranging from days to months, and potentially even longer. Additionally, 

PLSLR is frequently associated with short-term elevated drinking water lead levels for some period of 

time after replacement, suggesting the potential for harm, rather than benefit during that time period.

Available data suggest that the elevated tap water lead levels tend to then gradually stabilize over time 

following PLSLR at levels both above and below those observed prior to PLSLR. 
24

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Piping and the Contents of Lead in Drinking Water. Prepared for the District of Columbia Water and 

Sewer Authority. September 2009.

Kirmeyer, G.J., Boyd, G.R., Tarbet, N.K., Serpente, R.F., 2000. Lead Pipe Rehabilitation and 

Replacement Techniques. Prepared for the American Water Works Research Foundation, Report 90789. 

Lanphear, B.P., Hornung, R., Ho, M., Howard, C.R., Eberly, S., Knauf, K., 2002. Environmental lead 

exposure during early childhood. Journal of Pediatrics 140:40-47. 

Lanphear, B.P., Hornung, R., Khoury, J., Yolton, K., Baghurst, P., Bellinger, D.C., Canfield, R.L., 

Dietrich, K.N., Bornschein, R., Greene, T., Rothenberg, S.J., Needleman, H.L., Schnaas, L., Wasserman,

G., Graziano, J., Roberts, R., 2005. Low-level environmental lead exposure and children’s intellectual 

function: an international pooled analysis. Environ Health Perspect 113:894-899.

McFadden, M.; Giani, R.; Kwan, P.; Reiber, S., 2011 Contributions to Drinking Water Lead from

Galvanized Iron Corrosion Scales. JAWWA, 103:4 April.

McNeill, L.S. and Edwards, M., 2004. Importance of Pb and Cu Particulate Species for Corrosion 

Control. Journal of Environmental Engineering, 130(2):136-144.

Menke A, Muntner P, Batuman V, Silbergeld EK, Guallar E., 2006. Blood lead below 0.48 μmol/L (10 

μg/dL) and mortality among US adults. Circulation 114:1388-1394. 

Muylwyk, Q., Gilks, J., Suffoletta, V., Olesiuk, J., 2009. Lead Occurrence and the Impact of LSL 

Replacement in a Well Buffered Groundwater. Proceedings of the 2009 AWWA Water Quality 

Technology Conference. Seattle, WA.

Nguyen, C. K.; Stone, K. R.; Dudi, A.; and Edwards, M. A., 2010. Corrosive microenvironments at lead 

solder surfaces arising from galvanic corrosion with copper pipe. Environ. Sci. Technol. 44: 7076-7081.

Reiber, S., and Dufresne, L., 2006. Effects of External Currents and Dissimilar Metal Contact on 

Corrosion of Lead from Lead Service Lines. Prepared for USEPA Region III. 

Sandvig, A., Kwan, P., Kirmeyer, G., Maynard, B., Mast, D., Trussell, R.R., Trussell, S., Cantor, A., 

Prescott, A., 2008. Contribution of Service Line and Plumbing Fixtures to Lead and Copper Compliance 

Issues. Prepared for the American Water Works Research Foundation, Report 91229.

Shannon, M., Graef, J.W., 1989. Lead intoxication from lead-contaminated water used to reconstitute 

infant formula. Clin Pediatr 28:380-382.

Swertfeger, J., Hartman, D.J., Shrive, C., Metz, D.H., DeMarco, J., 2006. Water Quality Effects of 

Partial Lead Service Line Replacement. Proceedings of the 2006 AWWA Annual Conference. San 

Antonio, TX.
26

Switzer, J.A., Rajasekharan, V.V., Boonsalee, S., Kulp, E.A., Bohannan, E.W., 2006. Evidence that 

monochloramine disinfectant could lead to elevated Pb levels in drinking water. Environ Sci Technol.

40(10):3384–3387.

Triantafyllidou, S., Parks, J., Edwards, M., 2007. Lead Particles in Potable Water. JAWWA 99(6): 107-

117. 

Triantafyllidou, S. and Edwards, M., 2010. Contribution of Galvanic Corrosion to Lead in Water After 

Partial Lead Service Line Replacements. Prepared for the Water Research Foundation, Report 4088b.

USEPA, 1991a. Maximum Contaminant Level Goals and National Primary Drinking Water Regulations 

for Lead and Copper; Final Rule. Federal Register. Vol. 56, No. 110, p. 26505, June 7, 1991.

USEPA, 1991b. Summary: Peach Orchard Monitoring, Lead Service Line Replacement Study. Prepared 

by Barbara Wysock. Office of Drinking Water Technical Support Division. April 1991.

USEPA, 1998. National Primary Drinking Water Regulation: Consumer Confidence Reports; Final Rule. 

Federal Register. Vol. 63, No. 160, pp. 44511-44536, August 19, 1998.

USEPA, 2008. Child-specific exposure factors handbook (final report). Chapter 3: Water ingestion. U.S. 

EPA, Washington, D.C., EPA/600/R-06/096F.

USEPA, 2009. Integrated Exposure Uptake Biokinetic model for lead in children. Version 1.1 Build 11. 

U.S. EPA, Washington, D.C., NTIS #PB93-963510, EPA 9285.7-15-1.

USEPA, 2010. National Primary Drinking Water Regulations: Public Notification Rule. Federal 

Register. Vol. 65, No. 87, pp. 25982- 26049, May 4, 2000.

Weston, R.F., and EES, 1990. Lead Service Line Replacement: A Benefit-to-Cost Analysis. American 

Water Works Association, Denver, CO. p. 4-46.

Wujek, J.J. 2004. Minimizing Peak Lead Concentrations after Partial Lead Service Line Replacements. 

Presented at the AWWA Water Quality Technology Conference. San Antonio, TX.
A-1

APPENDIX A – EPA Charge To The Committee

EPA published the Lead and Copper Rule (LCR) on June 7, 1991 to control lead and copper in drinking 

water at the consumers’ taps. The LCR established a treatment technique to minimize lead and copper in 

drinking water (unlike most other rules that establish a Maximum Contaminant Level). When lead levels 

in drinking water exceed the action level of 15 μg/L, the LCR requires corrosion control treatment as the 

primary means of controlling lead in the drinking water. Public education for lead is also triggered by 

the initial lead action level exceedance. Lead service line replacement is an additional action required 

under the LCR when a system that has installed corrosion control treatment fails to meet the action level 

for lead. Under the 2000 LCR revisions, water systems are required to replace only the portion of the 

lead service line that it owns. When a water system replaces only a portion of the lead service line (the 

portion it owns), this is referred to as a partial lead service line replacement (PLSLR). Further regulatory 

background is presented in Attachment 1. 

Overall Charge

EPA is seeking SAB evaluation of current scientific data to determine whether partial lead service line 

replacements are effective in reducing lead drinking water levels. EPA has identified several studies for 

the SAB to consider for the evaluation, listed in Attachment 2. The SAB may also consider other 

relevant studies for the evaluation.

Specific Issues

Issue 1 – Studies Examining Associations Between Elevated Blood Lead Levels and PLSLR 

A recently published study by the Centers for Disease Control (Brown et al., 2011) examined an 

association between children’s blood lead level, lead service lines, and water disinfection in 

Washington, DC using data from 1998 to 2006. How does this study inform the available information on 

the effectiveness of partial lead service line replacement in reducing drinking water exposure to lead? 

Issue 2 – Studies Evaluating PLSLR with Tap Sampling Before and After Replacements

There are a number of studies that evaluated partial lead service line replacement with tap sampling 

conducted both before and after the replacement (Britton et al., 1981; Gittelman et al., 1992; Muylwyk

et al., 2009; Sandvig et al., 2008; Swertfeger et al., 2006; USEPA 1991a; USEPA 1991b; Weston et al., 

1990). These studies use a variety of sampling protocols and the timing of sampling after replacement 

differed between studies. What conclusions can be drawn from these studies regarding the effectiveness 

of partial lead service line replacement in light of the different sampling protocols and different timing 

of sampling? Please comment on the changes in lead concentrations in drinking water after partial lead 

service line replacements and the duration of those changes. 

Issue 3 – Studies Comparing PLSLR with Full Lead Service Line Replacements

There are a number of studies that compared partial lead service line replacements with full lead service 

line replacements (HDR Engineering, 2009; Sandvig et al., 2008; Swertfeger et al., 2006). What 

conclusions can be drawn from these studies regarding the relative effectiveness of partial lead service 

line replacement versus full lead service line replacement in reducing drinking water lead levels in both 

the short-term and long-term?
A-2

Issue 4 – Studies Examining PSLR Techniques

Some studies have looked at other factors that can influence lead levels following a partial lead service 

line replacement, such as pipe cutting, flushing to clear the lines, and pipe joining techniques (Boyd et 

al., 2004; Kirmeyer et al., 2000; Sandvig et al., 2008; Wujek, 2004). What conclusions can be drawn 

from these studies regarding techniques that should be followed for partial lead service line 

replacements to reduce lead drinking water exposures? Please comment on whether a standard operating 

procedure can be developed to minimize spikes in drinking water lead levels after partial lead service 

line replacement.

Issue 5 – Studies Examining Galvanic Corrosion

Galvanic corrosion is a possibility if copper pipe is joined directly with the remaining portion of the lead 

service line. Several studies examined the issue of galvanic corrosion (Boyd et al., 2010; DeSantis et al., 

2009; Deshommes et al., 2010; Rieber et al., 2006; Triantafyllidou et al., 2010). What conclusions can 

be drawn from these studies regarding the potential for elevated lead levels at the tap from galvanic 

corrosion? Please comment on the inclusion of a dielectric between the lead and copper pipes as a way 

to minimize spikes in drinking water lead levels after partial lead service line replacements. Please 

comment on the inclusion of the dielectric as part of the standard operating procedures for partial lead 

service line replacements.
A-3

APPENDIX A (cont’d)

Attachment 1 – Regulatory Background on the EPA Lead and Copper Rule

The LCR is a complicated rule because exposure to lead from drinking water results primarily from the 

corrosion of household plumbing materials and water service lines. EPA published the LCR on June 7, 

1991 to control lead and copper in drinking water at the consumers’ taps. The LCR established a 

treatment technique to minimize lead and copper in drinking water (unlike most other rules that establish 

an MCL). The LCR requires corrosion control treatment as the primary means of preventing lead and 

copper from contaminating drinking water. For systems serving 50,000 or fewer people, installation of 

corrosion control treatment is triggered when more than 10 percent of the samples from households with 

plumbing materials more likely to produce elevate levels of lead exceed an action level (15 μg/L for lead 

or 1300 μg/L for copper). Systems must treat drinking water to make it less corrosive to the materials it 

comes into contact with on its way to consumer’s taps. Public education for lead is also triggered by the 

initial lead action level exceedance. Lead service line replacement is an additional action required under 

the LCR when a system that has installed corrosion control treatment fails to meet the action level for 

lead. Lead service line replacement is the issue on which we are seeking SAB input.

Water systems exceeding the action level for lead after installing corrosion control must replace 

annually at least 7 percent of the initial number of lead service lines in its distribution system. The LCR 

requires that a water system replace that portion of the lead service line that it owns. When there is split 

ownership, the water system typically owns to the edge of the property line. In these cases where the 

system does not own the entire lead service line, the system must notify the owner of the line that the 

system will replace the portion of the service line that it owns and offer to replace the owner's portion of 

the line. A system is not required to bear the cost of replacing the privately-owned portion of the line, 

nor is it required to replace the privately-owned portion where the owner chooses not to pay the cost of 

replacing the privately-owned portion of the line. A system can stop replacing lines if it can meet the 

lead action level for two consecutive 6-month monitoring periods.

There are three ways a lead service line can be considered replaced under the LCR. First, sites where all 

service line samples test at or below the lead action level of 0.015 mg/L can be considered replaced. 

Second, sites where the entire line is replaced – either the water system owns the entire line or the 

homeowner agreed to pay for the replacement of their portion of the line when the system was replacing 

its portion. Third, when the homeowner does not agree to pay to replace their portion of the lead service 

line, then the system will replace the portion under its ownership. This third type of replacement is 

referred to as a partial lead service line replacement. (It should be noted that systems that meet the lead 

action level also sometimes replace their portion of lead service lines that they encounter while doing 

routine maintenance or emergency repairs to the distribution system. These “voluntary” replacements 

are not subject to the requirements of the LCR and occur fairly frequently.)

Under the current version of the LCR, a utility only controls that portion of the service line which it 

owns3

 3 When EPA promulgated the LCR in 1991, the Agency required water systems to replace the portion of the lead service line 

which the System controlled. The Agency’s definition of control of lead service lines went beyond utility ownership alone to 

include a rebuttable presumption that the utility controls the water service line up to the wall of the building unless the utility 

does not own the line and neither has the authority to replace, repair or maintain the service line, nor has the authority to set 

standards for construction, maintenance, or repair of the line. This definition would have facilitated removal of full lead 

service lines. The Agency was sued, and the Court remanded this definition of control back to the Agency because EPA had 

. EPA promulgated the current lead service line replacement requirements in 2000 as part of the 
A-4

LCR Minor Revisions Rule. In developing these requirements EPA considered the available studies 

evaluated partial lead service line replacement with tap sampling conducted both before and after the 

replacement. Based upon the available data EPA promulgated the current requirements for lead service 

line replacement. 

Under the LCR, when the system does not own the entire lead service line, the system must notify the 

owner of the line that it will replace the line that it owns and offer to replace the owner’s portion of the 

line. The system is not required to pay for the replacement of the privately-owned portion of the line nor 

is it required to replace that portion where the owner chooses not to pay for its replacement. The LCR 

does contain additional requirements when the owner does not agree to replace their portion of the line, 

resulting in partial lead service line replacement. The system must also do the following: At least 45 

days prior to the partial lead service line replacement, notice must be provided to the residents of all 

building served by the line explaining that they may experience a temporary increase in lead levels in 

their drinking water, along with guidance on measures consumers can take to minimize their exposure to 

lead. In addition, the water system shall inform the residents served by the line that the system will, at 

the system’s expense, collect a sample from each partially-replaced service line for analysis of lead 

content within 72 hours after the completion of the partial replacement of the service line. The system 

shall collect the sample and report the results to the owner and residents served by the line within three 

business days of receipt of results.

 

not provided adequate opportunity for public comment on that aspect of the proposed rule. The Court did not rule on the 

substantive legal issues regarding EPA’s authority to require utilities to take actions on private property. EPA revised the 

regulations in response to the remand. 
A-5

APPENDIX A (cont’d)

Attachment 2 – Studies Identified by EPA

Studies identified by EPA for Issue 1: 

Brown, M.J., et al., 2011. Association between children’s blood lead levels, lead service lines, and water 

disinfection, Washington, DC 1998-2006. Environmental Research, 111(1):67-74.

Studies identified by EPA for Issue 2:

Britton, A. and Richards, W.N., 1981. Factors Influencing Plumbosolvency in Scotland. Journal of the 

Institute for Water Engineers and Scientists. Vol. 35, No. 5, pp. 349 - 364. 

Gittelman, T.S. et al., 1992. Evaluation of Lead Corrosion Control Measures for a Multi-source Water 

Utility. Proceedings of the 1992 AWWA Water Quality Technology Conference. Toronto, Ontario, 

Canada. pp. 777 - 797.

Muylwyk, Q. et al., 2009. Lead Occurrence and the Impact of LSL Replacement in a Well Buffered 

Groundwater. Proceedings of the 2009 AWWA Water Quality Technology Conference. Seattle, WA. 

Sandvig, A et al., 2008. Contribution of Service Line and Plumbing Fixtures to Lead and Copper 

Compliance Issues. Prepared for the American Water Works Research Foundation, Report 91229. 

Swertfeger, J. et al., 2006. Water Quality Effects of Partial Lead Service Line Replacement. Proceedings 

of the 2006 AWWA Annual Conference. San Antonio, TX.

USEPA., 1991a. “Maximum Contaminant Level Goals and National Primary Drinking Water 

Regulations for Lead and Copper; Final Rule.” Federal Register. Vol. 56, No. 110, p. 26505. June 7, 

1991.

USEPA., 1991b. “Summary: Peach Orchard Monitoring, Lead Service Line Replacement Study.” 

Prepared by Barbara Wysock. Office of Drinking Water Technical Support Division. April 1991.

Weston and EES, 1990. Lead Service Line Replacement: A Benefit-to-Cost Analysis. American Water 

Works Association, Denver, CO. p. 4-46.

Studies identified by EPA for Issue 3:

HDR Engineering, 2009. An Analysis of the Correlation between Lead Released from Galvanized Iron 

Piping and the Contents of Lead in Drinking Water. Prepared for the District of Columbia Water and 

Sewer Authority. September 2009.

Sandvig, A et al., 2008. Contribution of Service Line and Plumbing Fixtures to Lead and Copper 

Compliance Issues. Prepared for the American Water Works Research Foundation, Report 91229. 

Swertfeger, J. et al., 2006. Water Quality Effects of Partial Lead Service Line Replacement. Proceedings 

of the 2006 AWWA Annual Conference. San Antonio, TX.
A-6

Studies identified by EPA for Issue 4:

Boyd, G. et al, 2004. Pb in Tap Water Following Simulated Partial Lead Pipe Replacements. Journal of 

Environmental Engineering. Vol. 130. Number 10. pp. 1188 – 1197. 

Kirmeyer, G. et al, 2000. Lead Pipe Rehabilitation and Replacement Techniques. Prepared for the 

American Water Works Research Foundation, Report 90789. 

Sandvig, A et al., 2008. Contribution of Service Line and Plumbing Fixtures to Lead and Copper 

Compliance Issues. Prepared for the American Water Works Research Foundation, Report 91229. 

Wujek, J.J. 2004. Minimizing Peak Lead Concentrations after Partial Lead Service Line

Replacements. Presented at the AWWA Water Quality Technology Conference. San Antonio, TX.

Studies identified by EPA for Issue 5:

Boyd, G., Reiber, S., and Korshin, G., 2010. Galvanic Couples: Effects of Changing Water Quality on 

Lead and Copper Release and Open-Circuit Potential Profiles. Proceedings of the 2010 AWWA Water 

Quality Technology Conference. Savannah, GA. 

DeSantis, M. et al., 2009. Mineralogical Evidence of Galvanic Corrosion in Domestic Drinking Water 

Pipes. Proceedings of the 2009 AWWA Water Quality Technology Conference. Seattle, WA. 

Deshommes, E. et al., 2010. Source and Occurrence of Particulate Lead in Tap Water. Water Research. 

pp. 3734 – 3744. 

Reiber, S., and Dufresne, L., 2006. Effects of External Currents and Dissimilar Metal Contact on 

Corrosion of Lead from Lead Service Lines. Prepared for USEPA Region III. 

Triantafyllidou, S. and Edwards, M., 2010. Contribution of Galvanic Corrosion to Lead in Water After 

Partial Lead Service Line Replacements. Prepared for the Water Research Foundation, Report 4088b. 
B-1

APPENDIX B - Rationale and Recommendations for a Reanalysis of Brown et al. (2011)

Rationale for Reanalysis

Table 3 of Brown et al. (2011) contains key epidemiological information for assessing the effects of 

partial lead service line replacement on the blood lead of children less than six years of age. For the 

following reasons, a reanalysis of the data presented in this paper might offer expanded insight into the 

influence of PLSLR on childhood BLLs: 

1. The presented data did not adjust for potential confounders, such as alternative sources of 

lead exposure (measured in other parts of the paper by estimating the age of the residence), 

sex of subject, a variable indicating the switch from the older bronze fittings in the house to 

the “lead-free” fittings, adjusted for age instead of limited to children under 6, etc.

2. The analysis did not assess the comparison of partial replacement vs. lead service line not 

replaced in periods other than between 7/1/2004 – 12/31/2006. Including earlier periods 

would not only assess partial line replacement effects under different water treatment regimes, 

the earliest periods, before the lead in water problem was divulged to the public, would be 

freer of confounding due to people modifying their water use habits after partial line 

replacement.

3. The authors are unclear about the “logistic regression” they used in the analysis. Unqualified 

“logistic regression” is usually understood as a dichotomous outcome logistic regression. The 

outcome measure used in Table 3 is a three category ordered blood lead variable. The most 

powerful logistic statistical technique used for ordered categorical outcomes is some form of 

ordinal logistic regression, the specific type used depending on the data set and model 

satisfying certain assumptions. In the event that none of the ordinal logistic regression 

techniques can be used, multinomial logistic regression, ignoring the ordered nature of the 

categories, can be used. Multinomial logistic regression is essentially a time-saving way of 

performing multiple binary logistic regression.

4. The authors do not mention diagnosing their models, leaving open the question of complying 

with model assumptions regardless of the logistical regression technique used.

5. The authors do not present a trend analysis of the odds ratios for the three ordered categories 

of blood lead.

6. Since the original dependent variable was a continuous presumably log-normally distributed 

variable that was then categorized, sound statistical procedures suggest using a probit, rather 

than a logit, model if category blood lead must be used. Information criteria can be used to 

assess which model, logistic or probit, best fits the data.

7. The selection of any limited dependent variable analysis technique for these data is 

questionable since the original blood lead values were available. Tobit regression on leftcensored blood lead values (or transformations of the same) provides the most powerful 

means of assessing the effect of partial lead service line replacement.

8. Selection of the highest venous blood lead value and the lowest capillary blood lead value for 

each subject has sound antecedents, as explained in the article. Nonetheless, a frequent error 
B-2

in taking capillary samples is to squeeze the puncture wound to aid in blood expression, a 

procedure that can lead to sample dilution from extracellular fluid. Capillary samples that 

were included in the lowest blood lead category could come from children with higher blood 

lead, especially if they were below the detection limit. Possible dilution in capillary samples 

could be examined in children with more than one capillary sample within a certain time 

interval. At the very least, capillary samples should be identified in the data set used for 

reanalysis by a dummy variable indicating capillary or venous origin. 

9. All multiple samples, capillary or venous, that bracket the period of partial line replacement 

would allow powerful repeated measures analyses in the same children to provide an 

alternative assessment of the effects of partial line replacement. The before and after 

assessment in the same children would allow more confident attribution of causality to blood 

lead changes associated with partial line replacement.

Recommendations for Reanalysis

The Centers for Disease Control and Prevention (CDC) had provided EPA’s Office of Water (OW) with 

a dataset which was shared with theSAB, hereafter referred to as “the data set.” This data set is the most 

recent version of the data set used by Brown et al. (2011) to analyze the effect of partial lead service line 

replacement (PLSLR) on blood lead concentrations of children in the Washington, DC metropolitan 

water district. Though there are many issues that can be addressed using this longitudinal data set, here 

the focus will be on improving the analysis of Brown et al. published as the right side of their Table 3. 

The original analysis focused on the difference in blood lead of children under age 6 among those living 

in residences with lead service lines after PLSLR and those not experiencing PLSLR during the period 

of 07/01/2004 – 12/31/2006, when chloramine (combined with orthophosphate) was used as the water 

disinfectant. Brown et al. used blood lead grouped into three categories of outcome, < 5 μg/dL, 5-9 

μg/dL, ≥ 10 μg/dL . Most blood lead was reported as whole number μg/dL, though some were reported 

as decimal number μg/dL. The assumption made here is that the middle blood lead category included 

children with blood lead up to 9.9 μg/dL. In addition, a fractional blood lead value (1.4 μg/dL) was used 

as the censoring value of the lowest blood lead measurements, below the detection limit of the analytical 

procedure for blood lead.

Brown et al. reported the results of a simple polytomous logistic regression, using blood lead category as 

the outcome and having or not a PLSLR before the blood lead measurement in children living in 

residences with a lead service line. They reported their results as odds ratios, though the recommended 

interpretation of coefficients of polytomous logistic regression is relative risk ratio.

The motive behind characterizing blood lead in three categories appeared to be the current CDC 

recommendation, dating from 1991, that the action limit for children be 10 μg/dL and a more recent 

amendment of 5 μg/dL for pregnant women. Most active researchers consider these action limits 

currently baseless, as all research with blood lead in children shows no lower threshold for lead effect. 

The analysis by Brown et al. did not take into account the interval between PLSLR and the blood lead 

measurement used in the analysis. It also did not take into account the limited data on age of housing, a 

proxy for other lead exposure sources in the children’s residence, though it should be noted that this 

would reduce the number of subjects available for analysis. The data set reviewed as part of this SAB 

charge did not list subject sex, though this variable was available to Brown et al., given their descriptive 
B-3

analysis divided by sex. Inclusion of sex in any subsequent analysis would serve to further reduce 

unexplained variance in blood lead outcome.

Since there is little current reason to adopt the CDC action limits for children (and pregnant women) 

blood lead, the major recommendation for reanalysis of the PLSLR data is to use as much of the blood 

lead data as possible in its original format instead of categorizing the variable. Due to the left-hand 

censoring of the original blood lead variable to account for the measurement detection limit, the most 

powerful statistical tool for analyzing these data, ordinary least squares (OLS) regression, is not 

recommended for analysis. Application of OLS regression to censored data will distort both coefficients 

and standard errors.

Recommendation 1

Tobit regression is specifically designed to analyze censored outcome data. It gives less biased 

coefficients and more efficient standard errors than OLS applied to the same data. It is available in most 

major statistical packages, including SAS, Stata, and SPSS. It is more powerful than polychotomous 

logistic regression and will return any blood lead differences between PLSLR and non-PLSLR groups, 

instead of just differences in category of blood lead.

Some of the outcome data within the specified date interval includes multiple measurements of blood 

lead on the same subjects. Brown et al. used a selection algorithm to pick the single blood lead 

measurement used in their analysis of PLSLR effect: if the blood sample was drawn by venous blood 

sample, they selected the highest blood lead available in the multiple blood lead series for that subject; if 

the blood sample was by finger-stick and thus capillary, they selected the lowest blood lead available for 

that subject; in the case of unknown method of blood draw, they defaulted to the capillary blood 

selection criterion. The algorithm was applied to several hundred subjects with multiple blood lead 

measurements.

Though there is sufficient information in the literature to support such an algorithm to reduce artifact, 

especially for capillary samples, a result of using the algorithm was to not always select the blood lead 

sample nearest to the PLSLR event. The mean interval between PLSLR and blood sample was over 300 

days with a range extending to two years. The selection algorithm was responsible for lengthening the 

time interval between PLSLR and blood lead draw, since the first available blood lead measurement for 

each subject was not always used.

Recommendation 2

Tobit regression should be used on data generated by using the Brown et al. selection algorithm for 

multiple blood lead samples in the same subjects. An alternative tobit analysis should be used selecting 

the first available blood lead measurement after PLSLR (or in the case of the non-PLSLR group, the first 

available blood lead measurement within the specified time period). Dummy variables indicating sample 

type (venous, capillary, and unknown) should be included in the tobit regression. If gender is available 

in the data set it should also be included in the tobit regression.

If PLSLR produces an increase in water lead downstream of the replacement and that increase decreases 

in time after replacement, as the admittedly flawed available data seems to indicate, then the time 

between the PLSLR and drawing the blood sample will influence the lead concentration of the blood 

sample.
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Lead solubility in water is influenced by water temperature. Though measurements of water sample 

temperature are not available in the data set, the date of the blood sample and the date of the PLSLR are 

available. Since water temperature varies according to season, these dates can be used as proxies for 

water temperature.

Recommendation 3

Include the interval between PLSLR replacement and blood draw as a continuous variable in the tobit 

regression. Include the date of blood draw as a cyclic (sum of sine and cosine terms, assuming a 12 

month periodicity) indicator of water temperature.

Age is an important determinant of blood lead in children. The dependency of blood lead on age often 

follows a non-linear pattern, rising from birth to 1-2 years, then decreasing.

Recommendation 4

Include a second-order polynomial term for subject age in the tobit regression.

Comparing two independent groups, though a standard in experimental design, depends on being able to 

control for group differences that not are not the focus of the research to avoid detecting spurious 

relationships. Repeated measures designs are one of the best means to assure that subject-specific 

characteristics are either maintained or measured and thus controlled for during the course of the 

research. A subset of subjects has blood lead measurements both before and after PLSLR during the 

time period considered. Please consider that blood lead measurements may be biased toward higher 

values in children with multiple blood lead measures, since elevated blood lead is often an indication for 

making multiple measurements. Thus, this analysis should be considered supplemental to the group 

comparison analyses considered above. Change in blood lead will be the important outcome in such 

analyses, not absolute blood lead.

Recommendation 5

Use a mixed model, repeated measures analysis on only the subjects with before and after PLSLR blood 

lead measures. The analysis will be with unbalanced panels, as each subject will have a varying number 

of pre and/or post-PLSLR blood lead measures. Though Stata has a random effects tobit model available, 

it does not have a mixed tobit model in the current version 11. SAS may have a mixed model tobit 

available. To our knowledge, only LIMDEP (Econometric Software) has an unbalanced mixed model 

tobit design available.

Model coefficients and standard errors are interpretable only to the degree to which model assumptions 

are met. A case in point is the form of the outcome variable. Skewed outcome variables often result in 

residual heteroscedasticity, a violation of a model assumption. Often there are remedies for noncompliance with model assumptions as simple as variable transformation.

Recommendation 6

All models should be thoroughly diagnosed for compliance with model assumptions. Alternative forms 

of the outcome variable, blood lead, should be tested for assumption compliance. Each tobit model 

should be tested with blood lead in original format and natural log transformed blood lead to determine 

the best fitting characterization. Continuous independent variables in various transformations should 
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also be considered to better determine the functional form of the fit. Heteroscedasticity-robust standard 

errors should be calculated where variable transformation cannot resolve issues of heteroscedasticity of 

model residuals. Boot-strap standard errors may also be calculated and compared to the standard errors 

calculated according to other formulations. Care should be taken to avoid multiple collinearity. 

The data set used for analysis could be expanded if it is found that the Washington, DC water supply has 

continued to use chloramine with orthophosphate beyond the 12/31/2006 cutoff date applied in the 

Brown et al. analyses.

Recommendation 7

Consider using data collected after 12/31/2006 to expand the analyzed data set to improve power. 
C-1

APPENDIX C - Reported Tap Water Lead Levels Following PLSLR

Table C-1: Summary of Relevant Findings

Study Summary of Relevant Findings

Britton and Richards, 

1990

First-draw (FD) and random daytime (RDT) samples were collected on 

10 days prior to a single PLSLR, 5 to 16 days after the PLSLR, then 2 

and 4 mos. later. Prior to PLSLR only 1 sample (out of 20) had >0.1 mg 

Pb/L. On days 5 – 16, 3 of 10 FD samples and 3 of 10 RDT samples had 

>0.5 mg Pb/L, with a maximum of >4 mg Pb/L in the day-8 FD sample. 

On days 56 – 63, all FD and RDT samples (6 each) had <0.1 mg Pb/L; 

however, on days 64 – 69, all samples (4 of each type) had 0.1 – 0.25 

mg Pb/L (perhaps for reasons unrelated to PLSLR, such as a change in 

water quality or temperature). After 4 mos., all FD and RDT samples 

(10 each) had <0.1 mg Pb/L, and the avg. Pb level was about 20 – 25% 

lower than pre-PLSLR; but the lower Pb levels may have been due in 

part to the long-term effects of optimized corrosion control treatment 

(OCCT) implemented shortly before pre-PLSLR sample collection.

Commons, 2011 FD and “run until cold” samples (6 h stagnation) were collected before 

and 12-h, 3.d, 2-wks, and 4-mos after PLSLR at 8 sites. Profile samples 

were also collected before and 4 mos after PLSLR. After 12 h, Pb was 

higher in FD samples at 6 of 8 sites, but the increase was <5 μg/L at 2 

sites. After 2 wks, Pb levels were more variable than before PLSLR but 

similar on average. After 4 mos, sequential sampling showed an average 

reduction of 62% in Pb delivered to the tap (range = 36 – 79%).

The data are further examined, collectively, in Table C-2. Pb levels in 

the first-draw samples were significantly elevated (nearly four-fold, on 

average) after 12 hours; but at 3 days and 2 weeks, they were not 

significantly different from pre-PLSLR levels; and after 4 mos they 

were lower. The results for the run-until-cold samples were similar; the 

Pb levels were slightly higher, on average, at 3 days and 2 weeks, but 

the averages were below the AL and the “error bars” overlapped with 

those of the pre-PLSLR samples.

Temperature data were not presented. The Pb levels after 4 mos may 

have been lower due to a lower water temperature. Temperatures of FD 

samples collected inside the home after 6 hours stagnation should be 

similar year round, but the customer-owned LSLs may have been colder. 

Gittelman et al., 1992 Data from 21 LSLR sites are summarized (unclear if partial or full 

LSLRs; presumably FD samples; sample timing not described; study 

presumably done prior to OCCT). Pb increased slightly after LSLR, 

with 90th percentile ~14 ppb and maximum ~17 ppb.

HDR, 2009

(same study reported 

by McFadden et al., 

2011, who showed 

only summary data)

Profile samples were collected before LSLR, after PLSLR, and then 

again after FLSLR at 4 sites, 3 with galvanized plumbing and 1 with 

mixed materials.

At site G1, Pb levels were increased in some samples 1 d, 2 wks and 4 

wks after PLSLR; at 8 wks, Pb was elevated only in the FD sample and 

avg. Pb was ~40% lower the pre-PLSLR. After FLSLR, Pb was <AL in 

all samples from 1 d on, and more than 50% lower than the pre-LSLR. 

Results were similar at site G3, but following FLSLR, Pb levels were 
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elevated on day 1 and in the 8-wk FD sample (18 ppb).

At site G2, post-PLSLR Pb levels were elevated in the interior-plumbing 

portions of all profiles (1-d and 2, 4, and 8-wk), but lower in the new Cu

line; similar results were obtained following FLSLR.

At site M1, Pb levels were higher 1 d and 2 wks after PLSLR, but 4 and 

8 wks later Pb was <AL in all samples and ~33% lower on avg. than 

pre-PLSLR. After FLSLR, Pb was <AL, except the FD and 2nd-draw 

samples on day 2 (~19 & 22 ppb, resp.), and >50% lower on avg. than 

pre-LSLR.

Muylwyk et al., 2009 Compliance and profile samples (30-min stagnation) were collected at 3 

sites in Guelph, Ontario (PLSLRs, with a full LSLR completed at one 

site on day 7).

At site 1, Pb was > 20 ppb in all pre-LSLR samples. After PLSLR, Pb 

levels were variable for 3 days, but < 20 ppb in all samples and <10 ppb 

in all compliance samples (Ontario standard). After full LSLR (day 7), 

Pb was <10 ppb in all samples (1 d and 1, 2, 3, and 7 wks later), and 

91% lower after 2 months.

At site 3, Pb was ~21–24 ppb in all pre-LSLR samples. After PLSLR, 

Pb was lower in most samples, but elevated (20 to 45 ppb) in some 

samples during the first 7 days (and in one compliance sample taken 3 

months later). Pb was 43% lower after 9 months; but Pb levels were > 

10 ppb in all compliance samples during the following year.

At site 5, Pb was 45–160 ppb in the pre-LSLR samples and 60 ppb in 

the pre-PLSLR compliance sample, but <45 ppb in all post-PLSLR 

samples except one. Pb levels in were variable over the next year and 

remained > 10 ppb in compliance samples until the 6 mo and 1 yr 

samples were collected.

Sandvig et al., 2008 Case studies and field studies were done at several utilities. Case study 

results included: 1) at DCWASA, Pb levels > 1,000 ppb were observed 

following PLSLR; 2) at Louisville Water Co., elevated Pb levels were 

found while flushing immediately after PLSLR, but could be reduced to 

<AL by forward flushing for 15 minutes; and FD samples after PLSLR 

were all < 6 ppb at four locations, with one exception; 3) at Madison 

Water Utility, total Pb was erratic for several years after FLSLR, which 

was attributable to Pb associated with Fe & Mn scales; and 4) at 

Cincinnati, a 1991 study found high Pb levels immediately after PLSLR 

(about 300 ppb in one sample, according to DeMarco, 2004), but lower 

levels 9 months later.

FD and profile samples (after 6 hrs stagnation) were collected in 

cooperation with 4 utilities for 14 FLSLRs, 2 PLSLRs, and 1 PLSLR 

where the customer’s line was copper. In Boston, particulate Pb was 

elevated (up to 800 ppb) at 3 of 4 sites immediately after FLSLR. For 

the PLSLRs: in DC, Pb in the FD samples increased from 3.7 to 7.5 ppb 

after 2 months, but Pb was <AL and the total mass of Pb in the profile 

samples was 15 μg lower; and, in Toronto, Pb in the FD samples 

dropped from 18.8 to 16.0 after 2 months, but was still >10 ppb, the 

provincial standard. Many sites registered high Pb for up to 3 days 

following both partial and full LSLRs; but by 1 to 2 months after partial 

or full LSLR, all sequential samples at the tap were either lower than 
C-3

before or essentially the same. They concluded that “elevated lead levels 

may occur in standing samples in the short term (up to 3 days), and may 

in some cases persist for longer periods of time, particularly if only a 

portion of the lead service line is removed”; and a “rigorous flushing 

regime (up to 60 minutes) may help...”

Swertfeger et al.,

2006

Samples were collected before, one wk after, and at one mo intervals 

after 5 FLSLRs, 5 PLSLRs, 6 PLSLRs with the freshly cut end protected 

by Teflon, and 5 control sites. Samples were FD after at least 6 h 

stagnation, then after a 3-min flush and a 10-min flush. Tap flow rates 

not reported. The pH of the distributed water was increased from 8.5 to 

8.8 before 1-wk samples at all sites and the 1-mo samples at the FLSLR 

sites were collected, causing Pb levels to decrease at the control sites.

Overall, PLSLR sites had Pb levels similar to those at the control sites. 

Only FLSLR resulted in a significant Pb reduction, short (first week) or 

long term, at all sites tested. Elevated Pb levels were observed for a 

week to a month at 4 of 11 PLSLR sites. After 1 mo, Pb averaged 11.5 

μg/L for the controls and 10 μg/L for the PLSLRs. The authors 

concluded that PLSLR may not necessarily be effective in reducing 

water lead levels compared with performing no replacement.

USEPA, 1991b

(Internal EPA report 

by Wysock)

Morning FD and service line samples (based on wasting an estimated 

volume of water) were collected 4 times before and 3 times after 

PLSLRs at 15 sites (8 with no internal LSLs). Softeners in 14 of 15 

homes were to have been bypassed, but all may not have been bypassed. 

Results before and after did not differ at the 95% confidence level for 

either FD or LSL samples; but all sites had Pb levels <AL prior to 

PLSLR, so replacement would not have been required under the LCR.

Weston and EES, 

1990 (cited as 

AWWA, 1990 in 

Table 11 in the LCR, 

USEPA, 1991a)

At 9 sites in Newport News, samples were collected at the water meter 

(not the tap) before, immediately after, and 2 wks after (presumably 

partial) LSLRs. Pb levels were elevated, up to 106 ppb, at 8 of 9 sites 

immediately after LSLR, but all lower 1 to 2 weeks later.

Data Provided by Public Commenters

Commenter Summary of Relevant Results

Steve Reiber, March 

30, 2011

In one graph (p. 7 of his presentation), Mr. Reiber presented data from 

DC Water showing average post-PLSLR Pb levels in FD and run-tocold samples over time, e.g., within 3 days (n = 229), 4 to 7 days (n 

=105), etc. The total number of samples represented in 511. The data 

clearly show that, on average, post-PLSLR Pb levels were sharply 

elevated within the first 3 days (average = 381 ppb in FD samples) and 

from days 4 to 7 (average = 81 ppb in FD samples); but the average Pb 

levels in both FD and run-to-cold samples were <15 ppb for all time 

periods between 1 wk and 1 mo, and <10 ppb between 1 and 2 mos. 

Post-PLSLR Pb levels, on average, clearly dropped dramatically after 1 

wk; however, the spread of the data (standard deviation and maximum 

values) was not shown, so the magnitude and duration of elevated Pb 

levels at individual sites are not evident.

A second graph (p. 8) shows profile samples collected at one home after 

PLSLR. Pb levels were high in a galvanized section of pipe 1 d after 
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PLSLR, but only slightly elevated at 2 and 4 weeks (one sample > 15 

ppb in each case), and low (all < 15 ppb) at 8 weeks.

Ralph Scott, May 10, 

2011

Mr. Scott provided DC Water data on post-PLSLR Pb levels, but noted 

that some sample dates may be in error and that homeowners were 

instructed to run all their home plumbing fixtures at a high rate for 

several minutes prior to collecting samples. He stated that the average 

FD level was 200 ppb and the average 2nd draw (run-to-cold) level was 

43 ppb; but it is not clear which data set these average were derived 

from. The data in Table D2 (324 samples collected at various times after 

PLSLRs) show a median Pb level of 9 ppb in FD samples; but the 90th 

percentile was 70 ppb, 30 samples had Pb > 0.1 mg/L and 9 had Pb > 

1.0 mg/L. So, although FD Pb levels were, on average, <AL, they can be 

much higher in some samples. Since the sampling dates are in question, 

it is not clear whether the high levels occurred immediately after PLSLR 

or later on, nor can possible seasonal effects be reliably ascertained. If 

the FD samples were collected after an appropriate (e.g., 6 h) stagnation 

period, the results are not comparable with those of FD samples in other 

studies. Until these issues are addressed and resolved, it is not possible 

to draw many reliable conclusions from these data.

Mr. Scott also provided copies of LCR compliance reports obtained 

from DC Water. The report for Jan – June 2006 shows 90th percentile 

Pb at 10 ppb in FD and 12 ppb in 2nd-draw samples (82% full lead 

lines; 18% partial). The July – December 2006 report shows 90th 

percentile Pb at 12 ppb in FD (76% full lead lines; 24% partial). The 

data were presumably collected using the sampling procedures specified 

by the LCR; but the results for full and partial LSLRs are not broken 

down separately, so it is not clear whether the results for the PLSLR 

samples were lower than those for no replacement. In any event, since 

the 90th percentile values were below the AL, no LSLRs were required.

Thomas W. Curtis, 

May 12, 2011

Mr. Curtis provided data summaries (Tables C-3 and C-4) obtained from 

DC Water. Table C-4 summarizes data for FD and 2nd-draw (run to 

cold) samples after no replacement, PLSLR, and FLSLR during periods 

of stable OCCT. Pb levels 1 – 3 yrs after PLSLR were similar to those 

for no replacement (2006 – 2007), but were clearly much higher than 

those found 2 yrs after full LSLR (March 2008 special study). Based on 

the 2009 – 2010 data, Pb levels 2 – 4 yrs after PLSLR were significantly 

lower than in the “no replacement” samples, and the 90th percentile 

values were 4.2 and 3.6 ppb in the FD and 2nd-draw samples, resp.

Table 2 summarizes data for 1st and 2nd draw samples 5 – 8 mos postLSLR (18 full, 7 partial). Pb levels were low (median and average 

values all < 2.3 μg/L) and similar for both full and partial LSLR. The 

accompanying text indicates that only one sample exceeded 10 ppb 

(11.5 in a 2nd draw post-PLSLR sample). Collectively, these data 

suggest that PLSLR, after an extended period of time, on average, does 

little or no harm and perhaps some good.
C-5

Additional References

Commons, C., 2011. Effect of Partial Lead Service Line Replacement on Total Lead at the Tap. 

Unpublished report describing a study by the Rhode Island Department of Health, submitted to the Panel 

during the comment period.

Demarco, J., 2004. Case Study #1: Greater Cincinnati Water Works Partial Lead Service Line 

Replacement. USEPA Workshop on Lead Service Line Replacement. October 26-27, Atlanta, Ga.
C-6

Table C-2: Further analysis of the combined results of Commons (2011) for 8 PLSLRs

Time

Sample

Type

Avg. Pb

(mg/L)

Std. Dev.

(mg/L)

n > AL

(out of 8)

Pre-PLSLR First Draw 0.016 0.010 4

12 hours First Draw 0.061 0.055 6

3 days First Draw 0.019 0.019 2

2 weeks First Draw 0.014 0.007 4

4 months First Draw 0.007 0.004 0

Pre-PLSLR Run until cold 0.009 0.004 1

12 hours Run until cold 0.031 0.029 4

3 days Run until cold 0.012 0.007 2

2 weeks Run until cold 0.011 0.007 3

4 months Run until cold 0.003 0.002 0
C-7

Table C-3: Observed Lead Levels After LSLR
C-8

Table C-4: Lead Levels Observed 5 – 8 months After LSLR
D-1

APPENDIX D - Sampling Methods for Lead in Tap Water

This appendix identifies methods for collecting samples for the determination of Pb in tap water, 

summarizes their purposes, and describes some of their strengths and weaknesses. The purposes of this 

discussion are: 1) to serve as a source of information for readers who may be unfamiliar with one or 

more of the methods described, 2) to support statements made in the main body of the report regarding 

the tendency of sampling methods to undersample or oversample particulate Pb, and 3) to help the 

reader understand why Pb levels in samples collected using a particular method are not necessarily a 

good measure of the Pb levels to which consumers of drinking water are actually exposed. The SAB did 

not intend to prepare an exhaustive list of all methods in use, to exhaustively review and evaluate 

available methods, or to recommend particular methods for future use.

Tap-water samples for Pb analysis may be collected in a number of ways, each reasonably well-suited 

for a specific purpose but having significant limitations when used for purposes other than its originally 

intended purpose. Sampling protocols used in recent studies include: 

1) First draw sampling – required by 40 CFR 141.86(b)2 for monitoring lead and copper 

under the LCR, except for lead service line samples. A 1-liter sample of water that has been 

stagnant in the plumbing system for at least 6 hours is drawn from a cold-water tap in a 

kitchen or bathroom. First-draw samples are well suited for determining the concentrations of 

lead released from plumbing materials in the faucet and lines and fittings under the sink. This 

is useful in assessing water corrosivity and the effectiveness of a utility’s optimized corrosion 

control program, and also in determining the Pb levels to which consumers may be exposed 

if they take a drink of water, after it has stood for 6 hours in the faucet, before flushing the 

water from the tap. First-draw samples are not filtered, so they may contain particulate Pb; 

but particulate Pb initially present in the water, prior to stagnation, may settle out in the water 

lines during the stagnation period and may therefore be significantly undersampled when the 

sample is collected. First-draw samples often have Pb levels grossly different from those in 

subsequent samples collected sequentially, as documented in numerous studies, some of 

which are cited in Table C-1. This is especially true in samples collected in homes having 

full or partial LSLs, or in homes having interior plumbing materials heavily encrusted with 

Pb-bearing deposits (HDR, 2006; McFadden et al., 2011). In such cases, both dissolved and 

particulate Pb levels can be much higher than those in the first-draw sample.

2) LSL sampling – required by 40 CFR 141.86(b)3 for determining Pb concentrations in water 

left standing in an LSL for at least 6 hours. The results are used to determine if a line is 

exempt from replacement (if all samples contain <0.015 mg/L of Pb) and for the 

homeowner’s information following PLSLR. Three options for collecting the sample are 

specified: i) wasting a volume calculated based on the interior diameter and length of the 

pipe between the tap and service line before collecting a sample, ii) tapping directly into the

service line, or iii) allowing the water to run until there is a significant change in temperature. 

For homes with LSLs, this protocol nicely complements first-draw sampling by attempting to 

obtain a sample from the LSL itself. However, all three sampling options are problematic in 

that the Pb levels measured may be considerably lower than those to which the consumer is 

actually exposed when drinking water left standing in the LSL. Water collected using the 

first sampling option may not be from the LSL, because pipe volume between the LSL and 

the tap could be miscalculated as a result of mathematical or measuring errors, or because the 

volume of the pipe occupied by scale and corrosion products was not taken into account. A 
D-2

sample drawn directly from the LSL will be a standing water sample, so particulate Pb could 

potentially be grossly undersampled due to settling. Particulate Pb could also be oversampled 

or undersampled depending on flushing of the line (flow rate and duration) prior to the 

stagnation period, since aggressive flushing can increase particulate Pb levels (by dislodging 

them from the pipe surfaces) or flush them out the system. If the third option is employed, a 

significant change in temperature could indicate the presence of relatively Pb-free water from 

the main rather than water from the LSL; and difficulty sensing a temperature change, as may 

occur in the summer months when surface water temperatures are often close to room 

temperature, may result in collection of a sample from a random location.

3) Profile sampling – used to examine the Pb concentration profile in household plumbing. A 

series of samples is collected, typically after the water has been left standing for at least 6 

hours, with the last samples representing water coming directly from the main. This 

technique can be used to determine if elevated Pb levels are associated with an LSL and 

perhaps, in some cases, with the connection between an LSL and a service line composed of 

copper or galvanized iron. The samples are usually drawn rather slowly, to minimize mixing 

and so the volume of each sample can be carefully measured; but Pb levels are known to vary 

with flow rate (e.g., Britton and Richards, 1990; HDR, 2009; Deshommes et al, 2010; 

McFadden et al, 2011). Using a low flow rate minimizes erosion and resuspension of 

particulate Pb, so this method can potentially result in gross underestimation of particulate 

Pb. Another disadvantage of this protocol is that a large number of samples must be collected 

and analyzed, increasing monitoring costs.

4) Random daytime sampling – used to collect representative samples of tap water during the 

course of a normal day. Random samples can potentially provide a better estimate of human 

exposure than other types of samples. However, the concentrations of total, dissolved, and 

particulate Pb are expected to be much more variable in such samples than in other types of 

samples; thus, a large number of samples is typically needed to obtain meaningful results. 

Furthermore, random samples can produce biased results if the sampling schedule is not truly 

random or if the samples differ in certain ways from those actually consumed. For example, 

if samples are not collected early in the morning for fear of waking the residents, a 

representative number of first-draw (standing water) samples may not be included and the 

results for dissolved Pb may therefore be biased on the low side; or, if the samples are 

collected without flushing and the consumer normally flushes the tap first, the results may be 

biased high.

5) Others protocols – used by researchers for specific purposes. Examples include high 

velocity, particle stimulation, and water hammer simulation sampling protocols designed to 

stimulate release of particulate lead (e.g., HDR, 2009; Deshommes et al, 2010). When using 

these protocols the Pb levels in the samples may exceed those to which consumers are 

normally exposed but they may represent worst-case conditions reasonably well.

The sampling protocols currently specified in the LCR have significant limitations, as do other protocols. 

The SAB recognizes that these protocols were adopted for pragmatic reasons. However, the SAB also 

recognizes that the results obtained using these methods are widely perceived as being useful for 

estimating the tap-water Pb levels to which humans are exposed when in fact they may result in

significant underestimation or overestimation of actual exposure. Exposure assessments are complicated 

not only by the limitations of sampling methods but also by the fact that, in a given home, little or no 

information is typically available regarding consumer behavior, e.g., how long the tap is run before 
D-3

taking a drink, how fast the water is run when flushing, how rapidly the tap is turned on and off, whether 

the water is filtered, how much water is actually consumed, whether the water is used for cooking, etc. 

The limitations of current sampling protocols and their usefulness in producing data suitable for 

exposure assessments should be carefully considered in future revisions to the LCR, in evaluating the 

results of studies of Pb in tap water, and in assessing the impacts of tap-water Pb levels on human health. 
E-1

APPENDIX E - Techniques for Locating, Identifying, Replacing, and Rehabilitating Lead Service 

Lines

Although seemingly a simple matter, the replacement of any water service line, regardless of the 

material of composition, is not a simple one-step task. While the response to Issue 4 highlights those 

techniques used in PLSLR that the SAB finds to have the greatest potential for releasing lead following 

a PLSLR, the list of techniques discussed is not complete. This appendix describes additional techniques 

that are used to locate lead service lines, identify/confirm the composition of the service line material, 

then replace or rehabilitate the line. The SAB finds that these techniques do not contribute to the 

elevated Pb levels observed following a PLSLR. Their inclusion in this appendix is offered as 

verification that the techniques were considered during the deliberations. 

Locating and Identifying LSLs

LSLs cannot be replaced until they are located and identified. Work by Deb et al. (1995) provided a 

summary that describes the techniques available for locating and identifying LSLs. Although some 

techniques used for locating service lines are minimally invasive (some of the direct methods used to 

identify the service line material require physical access and direct contact with the service line) there is 

no evidence to suggest that these methods contribute to lead release following PLSLR. The SAB found

no evidence that these methods contribute to the elevated lead levels following PLSLR. 

Using indirect methods for locating and identifying LSLs requires an extensive database that accurately 

characterizes home age, plumbing materials, and renovation history. In general, the indirect methods 

have been demonstrated to be less accurate than direct methods leading to the misidentification and 

subsequent misclassification of LSLs1

 1 According to Deb et al. (1995) indirect methods of LSL identification were not 100% accurate. In their two case studies, the 

accuracy of identifying LSLs was 73.7% and 92.2%. 

. The SAB is confident that indirect LSL locating techniques do 

not contribute to lead release following PLSLR. 

Replacement and Rehabilitation Techniques

According to Kirmeyer et al. (2000) the techniques used to access or rehabilitate LSLs include: open 

trench, pipe bursting, pipe pulling (moling), lining an existing LSL, or coating an existing LSL. Unlike 

the open trench, which exposes the service line, replacing an LSL by pipe bursting or pipe pulling 

(moling) on a new or existing route involves minimal trenching. In pipe bursting, the LSL is replaced by 

following the existing service line, forcing it to expand and burst, then pulling (or pushing) a new line in 

through the existing hole and reconnecting the service at both ends. An alternative to bursting the LSL 

involves pulling a new service line into a hole bored (moling) along the same route following parallel to 

the existing line.

Unlike the replacement techniques previously mentioned, LSL rehabilitation is a process whereby the 

LSL is left in place, but the interior surface is covered or coated to prevent contact between the lead 

surface and the water. There are two processes that fall into this category described by Kirmeyer et al. 

(2000), slip lining and pipe coating. Although these techniques have been employed by some utilities in 

the UK and the Netherlands, practical and regulatory concerns have thus far limited their use in the U.S. 
E-2

Although the Kirmeyer et al. (2000) study provided an excellent summary of techniques that could be 

used for a PLSLR, the study did not include a water quality evaluation of these rehabilitation techniques, 

hence the SAB was unable to evaluate the impact that the techniques might have on lead release. 

Generally, the SAB finds that, unless the PLSLR technique involves direct physical contact with the 

service line, it is reasonable to assume that the act of replacing the service line will have minimal impact 

on lead release following partial or full LSLR.