Get the lead out - and galvanized too while we’re at it!
By Marc Santos, PE and Maureen Cunningham
Image: A confirmed galvanized service line from the author’s (Maureen Cunningham) 1938 home.
To date, much of the discussion around water service lines, replacement, and public health, rightfully so, has been centered on toxic lead pipes. These pipes, called lead service lines (LSLs), are a significant source of lead in water, and likely the largest source. But it’s important to remember, they are not the only potential source of lead in drinking water. A larger and longer term discussion of safe drinking water and even ‘lead-free water’ will inevitably have to include a focus on another kind of water service line as well - those made of galvanized iron or steel [1].
Galvanized service lines (GSLs) are raising more and more attention in the effort to replace lead pipes, and even causing a fair amount of confusion among some water utilities. While it is important to continue to focus on the replacement of LSLs as soon as possible, and we hope, over the coming decade, GSLs are becoming harder to ignore as a vector for lead exposure and risk. GSLs will be also further scrutinized and addressed through the US EPA’s proposed Lead and Copper Rule Improvements (LCRI) once they are promulgated. In this blog, we’ll take a deeper dive into the confusion around GSLs to provide clarity on why they are important and why utilities should be considering their removal as part of their lead service line replacement (LSLR) plans.
What are galvanized service lines and why are they a source of lead in drinking water?
Galvanized pipes are iron or steel pipes that have been dipped in a zinc coating to prevent corrosion and rust. There are also lead-line galvanized pipes, which are further discussed in sections below. Galvanized pipes have been used since the late 1800s and were commonly used in homes built in the 1950s and 1960s. The lead levels found in the zinc coating of galvanized iron or steel pipes prior to 2014 were in the range of 0.5% and 2%. The Reduction of Lead in Drinking Water Act, passed in 2011 but effective in January 2014, lowered the maximum lead content of the “wetted surfaces of plumbing products,” which included galvanized pipes, to a weighted average of 0.25%.
GSLs can serve as a source of lead exposure in two key ways:
By capturing lead released from upstream lead sources (e.g. lead service lines or lead connectors), which can later be released over time as the result of pipe disturbances or changes in the water chemistry; and
By corrosion and leaching into drinking water from the lead that is found in the zinc coating of galvanized pipes or in the lead lining of lead-lined galvanized pipes.
To understand the level of exposure related to upstream lead sources, water utilities need a deeper understanding of the entire service line between the water main and customer home (including connectors) rather than just determining the privately-owned service line material in the household connection. Finding this information can be difficult due to a lack of adequate and historic recordkeeping. Making things more complicated, even if a lead source was removed upstream in the past, the risk in the downstream galvanized line can remain.
Lead exposure through corrosion and leaching is managed by water utilities through corrosion control treatment (CCT) mandated in the 1991 Lead and Copper Rule, but still can pose a risk if the CCT is not managed correctly or if the water chemistry changes. The latter was the cause of the Flint, MI lead contamination crisis in 2014 when the city changed its water source without implementing CCT. It should be noted that utilities who have managed continuous and effective CCT practices over time may have also maintained better GSL pipe condition overall. However, even with CCT, the risk always remains and is only completely removed when these pipes are replaced.
From a performance standpoint, GSLs also have the potential for higher levels of corrosion and rusting than other modern service line materials. In our discussion with 26 utilities from 16 states, many mentioned GSLs as a common culprit of service line water leaks. As a result, utilities (or homeowners) in many states are actively replacing galvanized lines to address service line water loss. From a water quality perspective, galvanized pipes can also perform poorly with regard to biofilm formation, and therefore, arguably present a higher potential for Legionella. Even without mandates around replacing galvanized service lines, the justifications for doing so start to build.
How do I know if I have a galvanized service line?
Just like identifying LSLs, identifying GSLs is easy and can be done by homeowners or water utilities through physical inspection, except for the issue of lead-lined pipes discussed below. A regular magnet will stick to galvanized iron pipes but not to lead, plastic, or copper piping and is a common way to determine the service line material. When developing a service line inventory, there are many resources available to help utilities understand other ways to first identify the presence of a GSL, and to conduct the second, far more difficult task of determining if it was ever downstream of lead-containing pipe or connector. The removal methods for GSLs are essentially the same as for LSLs, with similar cost efficiencies and site-specific considerations, including the use of various trenchless methods to minimize the construction disturbance during the replacement process.
What are the existing federal regulations around galvanized service lines, and how will they change with the proposed new improvements?
The Lead and Copper Rule (LCR) of 1991 was the start of regulating lead (and copper) in drinking water in this country, and the rule established corrosion control as the primary treatment technique for both lead and galvanized pipes. While galvanized pipes were mentioned in the LCR several times, it was mostly in the context of the effectiveness of CCT.
Thirty years later, the Lead and Copper Rule Revisions (LCRR) of 2021 brought the issue of galvanized service lines to the forefront, with over 100 mentions in the 115-page document, and importantly, began to treat some GSLs as a similar risk as LSLs. In particular, the rule established the definition of Galvanized Requiring Replacement (GRR) service lines as GSLs that is or ever have been downstream of a lead service line or are currently downstream of a service line of unknown material, or “status lead unknown service line.” The EPA maintained that the classification of GRRs “allows their correct material composition to be listed while maintaining they are not to be classified as ‘‘Non-lead’’ because they must be replaced as part of the system’s LSLR program.” This puts an emphasis on not only the identification of lead service lines throughout a distribution system but also on the replacement of GSLs alongside lead service lines, because many water utilities may find it difficult to prove that a GSL was never downstream of lead in the absence of extensive historical records. Under the LCRR, GRRs are treated on par with LSLs - they must be identified and inventoried; customers served by a GRR need to be informed; and EPA recommends that they be immediately replaced. Just like for LSLs, if the 90th percentile for sample results exceeds the trigger or action levels for lead, it is mandatory to replace GRRs.
The draft Lead and Copper Rule improvements (LCRI) came out in late 2023 with new language around GSLs [2]. The proposed rule was submitted to the Executive Office of the President on August 1, 2024 for review by the Office of Information and Regulatory Affairs within the Office of Management and Budget (OMB), and it is expected that this rule will be enacted by October 2024. In the proposed rule, GRR pipes will be required to be replaced in all occasions that they are identified. This mandatory removal would only be avoided if the utility can provide a burden of proof and document that an LSL or lead connector was never upstream of the GSL.
Separately, some states have provided additional specific guidance for GRRs beyond the LCRR (e.g. Michigan, New Jersey, Pennsylvania). These states have more stringent requirements and/or further clarify the actions to be taken for lead GSLs in addition to lead goosenecks, pigtails, fittings, or connections. The State of New Jersey, for example, decided in 2021 that all galvanized lines are considered LSLs and therefore require replacement, stating simply in their definitions that “a galvanized service line shall be considered to be a lead service line.” At the municipality level, many utilities such as Eau Claire, WI, are also proactively replacing all galvanized lines to take the most conservative and preventative approach for GSLs. The EPA, in its 1991 LCR, mentioned that Akron, OH had replaced its lead and galvanized lines starting in 1964.
The total number and geographic locations of galvanized pipes nationally will not be fully apparent until water utilities around the country fulfill the service line material inventory mandate in the LCRR, which goes into effect on October 16, 2024. That said, we are currently unsure how many of the country’s tens of thousands of water utilities will comply by that deadline. Regardless, data collected for the 7th Drinking Water Infrastructure Needs Survey and Assessment (DWINSA) [3] show projections of 2.8 million “standalone” galvanized pipes that have never been downstream of a source of lead, so therefore are categorized as ‘non-lead’ for federal regulatory purposes. The 7th DWINSA shows an estimated 9.2 million pipes that are projected to be either LSLs or GRRs, of which the percentage of GRRs is unclear at this time. If the LCRI is promulgated this fall, then all of those 9.2 million pipes, regardless of whether they are LSLs or GRRs, will need to be replaced in a ten-year timeline from the compliance date of the regulation, with the exception of those cities who are granted a deferral.
One more thing to worry about: lead-lined galvanized pipes
The debate around which pipe material is the most appropriate for drinking water service lines has long been an issue. Notably, the proceedings of the Massachusetts Board of Health meeting in July 1900 seem just as relevant today. At this meeting over a century ago, the water professionals in attendance were pondering the “lead-pipe question” in which lead poisoning was acknowledged as a “familiar subject,” and the benefits of various water service line materials was the topic du jour. At the time, a new product – lead-lined galvanized (lead-lined) pipe – was ”supplanting lead pipe” with a cost approximately 40 percent less than lead pipes, as shown in Figure 1.
Figure 1. Relative cost for foot for a 1” line in 1900.
These lead-lined pipes - which CDM Smith says are lead pipes (not galvanized) “for all intents and purposes” - are different from galvanized pipes, because they contain a thin liner of lead on the interior surface of the pipe which is in contact with finished drinking water.
Image: “Fire and water engineering v.35:1904”
By contrast, galvanized pipes have a layer of zinc coating that may contain lead. These lead-lined pipes were produced by the Lead-lined Iron Pipe Company from Wakefield, Massachusetts starting in the late 1800s, and by 1904, had been used in states including Maryland, Massachusetts, New Hampshire, New Jersey, New York, and Ohio.
Today, with limited records on lead-lined pipes other than from the above referenced company’s production, they are not widely discussed as part of LSL programs. However, they have the same inherent health risks as lead pipes, and therefore should be treated as a similar public health risk - and perhaps more so since a homeowner cannot identify them from a visual inspection. EPA is aware of their existence and they are “subject to the same LCRR requirements as other LSLs in the inventory.” Although not often acknowledged, these lead-lined pipes do in fact exist in drinking water systems and are more common than is currently thought, with occurrences in at least 23 states across the US. The City of Eau Claire, WI, is an example of a utility that has from time to time come across these lines and has a policy of replacing these pipes along with all of other GSLs they find. Trenton and Hamilton, NJ may be other cities who came across and replaced lead-lined pipes, which have been identified using a portable x-ray fluorescence (XRF) device.
From a practical perspective, if the new LCRI comes into effect this fall, then any GRR would be required to be replaced. However, all other GSLs (i.e. standalone galvanized) that are non-GRRs may in fact be lead-lined pipes – unless proven otherwise through historical records or inspection. For those utilities going through the effort of identifying GSLs, it would seem prudent to rule out that the GSLs are not lead-lined as part of inventorying activities, which requires an added level of inspection. In general, invasive inspections are not ideal due to the potential for disturbing scale or corrosion inside of galvanized pipes; however, non-invasive inspection techniques of these GSLs are developing, such as the specific X-ray fluorescence (XRF) instrument mentioned in the example from New Jersey above. XRF tools that can penetrate the depth of pipe wall (i.e. beyond surface detection), like the Viken Detection K-shell XRF PB200e have the potential to detect lead-lined pipes. Utilities can use these tools by placing them in contact with an exterior portion of the galvanized pipe found in a valve box, inside a household, or temporarily exposed through potholing activities. This additional verification step of course has an associated cost, which can reach $25k - $30k per instrument (which we verified with one vendor), but it would provide an important inspection and measure of public health protection should the GSL remain in service. Cost-sharing or joint procurement of this equipment might be an approach taken at a state or regional level.
Confusion around the use of federal funds
All of this service line replacement work comes with a hefty price tag, even when leveraging cost efficiencies. While federal funding is still available to support LSL activities, even the restrictions on funding uses gets a little bit confusing. While funds under the Bipartisan Infrastructure Law (BIL) through the Drinking Water State Revolving Fund (DWSRF) for LSLR covered the replacement of GRRs under Federal Fiscal Year 2022 and 2023 (Years 1 and 2 of five years of BIL funding), the funding has some limitations when it comes to GRRs in FY24. In particular, FY24 BIL LSLR funds are only allowed for replacement of GRRs where there was a “known” LSL upstream, that is, the upstream service line material cannot be “unknown.” Ultimately, this needs to be clarified, with clearer mandates and guidelines.
Utilities: Identify and replace
In summary, galvanized service lines - because of the potential risk of lead exposure - cannot be seen as an add-on to a service line identification and replacement program, but must be an integral part of it. New Jersey and other states have realized this, and so soon must the whole country. We therefore have several recommendations moving forward on how water utilities should treat galvanized pipes in a water system:
Identify galvanized service lines alongside other service line materials and determine if they are galvanized requiring replacement (GRR);
Perform identification activities to confirm whether GSLs - regardless of whether they were previously or are currently downstream of lead - are lead-lined or not;
Include a long-term plan to replace all lead-lined pipes and GRRs along with LSLs; and
Expedite the replacement of lead-lined galvanized lines and GRRs along with LSLs - as all pose a risk to public health.
EPA and states: Simplify guidance and enable use of funding for replacement
The current rulemaking and guidance is causing confusion, which is not ideal when we’re dealing with something so closely tied to human health. The EPA and then states can support the above recommendations for utilities and encourage them in its own guidance and future rulemaking. Most importantly, on the issue of funding, EPA and state agencies should allow and encourage water utilities to replace all lead-lined pipes and GRRs using all current and future federal, state, and other public funding.
Considering the potential negative health impacts and well-documented downsides of GSL performance, the replacement of lead-lined and galvanized pipes is just as necessary and urgent, in some cases, as the replacement of lead service lines. This process can be expedited if utilities choose to proactively replace galvanized lines in the near term, while contractors are engaged for LSL replacement work. For those utilities already replacing LSLs, replacing the galvanized lines in parallel will provide cost efficiencies, and utilities may realize the potential side benefits of reduced water leakage that come with replacing old galvanized pipes. The days are numbered for galvanized pipes, but utilities - with support from the EPA - have the opportunity to strategically remove those pipes now to alleviate the burden on future generations.
[1] Although EPIC primarily focuses on lead service line replacement, drinking water can contain lead from additional sources, not only from lead, lead-lined, and galvanized service lines but also from goosenecks, pigtails, connectors, solder, and household plumbing fixtures and fittings containing lead. All of the risks of lead in drinking water must be addressed if we want to move towards a goal of ‘lead-free water.’
[2] EPIC provided comments on the proposed rule.
[3] Using the figures from the updated 7th DWINSA update released in 2024.