US lead pipe replacements stoke concerns about plastic and environmental injustice

Roughly 9.2 million lead pipes deliver drinking water to homes, schools and other buildings in the U.S., according to an Environmental Protection Agency (EPA) estimate released last month.

The Biden administration has announced its intention to replace all lead service lines within 10 years; and in 2021, Congress made $15 billion available for lead service line replacement through the bipartisan infrastructure law that passed last year. The EPA estimates the average cost to replace a lead service line is $4,700, putting the total need at $43 billion.

Scientists and drinking-water advocates say this fund is only a starting-point. A 2020 EPA analysis failed to consider many health outcomes from lead exposure, causing some experts to fear there’s a lack of willingness at the agency to address the problem. This could change, with new regulations on lead exposure expected from the EPA in September 2023. Advocates say upcoming rules need to include a mandate and funding for utilities to fully replace lead service lines so everyone can benefit from the program, including low-income customers.

Complicating lead pipe replacement are alternatives that may carry health risks of their own. A new report from Beyond Plastics, the Plastic Pollution Coalition and Environmental Health Sciences highlights a growing body of research that has found toxic chemicals in PVC and CPVC pipes — commonly used to replace lead lines — that have the potential to leach into drinking water. Health advocates say that in replacing lead lines, cities and states need to select safe materials to avoid a regrettable substitution, and many say copper is the best option. (Environmental Health Sciences publishes Environmental Health News, which is editorially independent.)

The EPA has chosen not to regulate plastic pipes or look into their potential health effects, Judith Enck, president of Beyond Plastics and former EPA regional administrator, told Environmental Health News (EHN).

“We’ve had about a half a dozen meetings with EPA, and every office we meet with points to another office,” she said, “It’s a lot of buck passing.”

Lack of federal motivation on lead replacement

lead in water

Lead was a common material for service lines, the pipes that connect a building to a water main, until Congress banned them in 1986 due to health risks. There is no safe level of lead exposure, the EPA says. In children, lead affects growth, behavior, IQ and more. Lead can impact pregnancies, causing early births and damage to a baby’s brain, kidneys and nervous system. In adults, lead can impact cardiovascular health, kidney function and fertility. Research has found that minority and low-income households are more likely to face lead exposure, often because their homes were built during the decades when lead service lines were most prevalent.

The EPA enforces the Lead and Copper Rule, which requires utilities to address contamination when more than 10% of customer taps have high levels of lead or copper. The Trump administration revised the rule, adding new testing requirements and protocols intended to require more action from utilities to reduce lead exposure.

When the agency released their economic analysis of the rule revisions, “I was appalled,” Ronnie Levin, instructor at the Harvard T.H. Chan School of Public Health and former EPA senior scientist, told EHN. The EPA recognizes eight health outcomes caused by lead, and eight that are likely caused by lead. “They only monetized one,” Levin said.

Related: Check out Beyond Plastics’ “The Perils of PVC Plastic Pipes” report

That means they didn’t quantify many health outcomes the rule revisions would improve by lowering lead exposure. With the single health outcome monetized, the EPA analysis found roughly $160 to $330 million in costs from the revisions, and $230 to $800 million in benefits.

“EPA considered both the quantifiable and the nonquantifiable health risk reduction benefits in promulgating the final Lead and Copper Rule…EPA exercised discretion to determine the approaches used to quantify benefits,” a spokesperson for the EPA told EHN in an email.

Levin ran the numbers herself, including as many EPA acknowledged health outcomes from lead as she could. In a peer-reviewed study recently published in the journal Environmental Research, she and a coauthor estimate $9 billion in health benefits and an additional $2 to $8 billion in savings on plumbing materials thanks to corrosion control required by the Lead and Copper Rule revisions.

The EPA’s underestimation of benefits demonstrates a lack of investment to address lead in drinking water, Levin said. “EPA, when it really wants to do something, loads on all the benefits it can marshal.” She’s concerned the incomplete health benefits analysis means the agency isn’t committed to solving this problem.

Environmental injustice and lead replacement

children environmental justice

Under the Biden administration, the Lead and Copper Rule will see another set of changes, which the EPA plans to announce in September 2023. The agency told an appeals court in December 2022 that it expects to require replacement of all lead service lines in that rulemaking.

Some utilities are ahead of the curve, and have used funds from last year’s infrastructure act and other sources to jump start lead service line replacement. “But until we actually get a requirement that those lead pipes are pulled out, we’re concerned that a lot of communities are just going to shrug their shoulders,” Erik Olson, attorney and senior strategic director of the NRDC’s Health and Food, People & Communities Program, told EHN.

To access state funds, utilities have to hire consulting firms to put together proposals for lead service line replacement, Olson explained. Low-income communities with fewer resources might not have the capacity to access the programs available now, but could be motivated with better funding and a mandate to replace service lines. Currently, the EPA is rolling out a technical assistance program in four states — Connecticut, New Jersey, Pennsylvania and Wisconsin — to help disadvantaged communities access funds.

“We’re hoping that EPA will require the full replacement and at the expense of the utility, because otherwise we’re just not going to see a solution to this problem and it really will be an environmental injustice,” Olson said.

When lead service lines are replaced by utilities, the Lead and Copper Rule requires them to address the portion they own. But that ownership is up for debate: many utilities say the property owner owns part of the service line, and that the utility is only responsible for a portion of it. Olson said utilities have been unable to provide documentation to back up this claim when asked by NRDC.

Still some cities, including Washington D.C., have required customers to pay for a portion of a lead service line replacement, generally costing a few thousand dollars.

A study of this program in Washington D.C. found that low-income neighborhoods were far less likely to receive full service line replacements. Neighborhoods with more Black residents were also less likely to receive full replacements. Instead, in many places the utility performed partial replacements, leaving some lead pipe intact.

These partial replacements “may be worse than doing nothing,” the study said. The partial replacement process can disturb pipe coatings and speed up corrosion, leading to higher lead contamination of water. For example, research on partial lead service line replacements in Halifax, Canada,, found that a partial replacement more than doubled lead release in the short term, and had no beneficial effects on lead contamination after six months. In 2019, Washington D.C.’s council changed their program to better fund full replacements and address past partial replacements.

“EPA strongly discourages water systems from conducting partial lead service line replacement,” said the EPA spokesperson.

PVC piping health impacts

The material that goes in to replace lead pipes can also create health concerns. Common replacements for lead service lines include pipes made from copper and plastics such as high-density polyethylene, polyvinyl chloride (PVC) and chlorinated polyvinyl chloride (CPVC). Plastic pipes tend to be the cheapest option, but a report last month highlights serious health risks from plastic PVC and CPVC pipes. Scientists have identified 59 chemicals that can leach from PVC pipes, but there’s a dearth of research on exactly what concentrations could be found in home tap water and what health risks they pose. The report shows that some toxics leach from plastic pipes, including vinyl chloride, a known carcinogen, and phthalates and organotins, endocrine-disruptors that impact the body’s hormone system.

Plastic pipes, particularly PVC and CPVC, could represent a regrettable substitution for lead pipes, said Enck in a press conference about the report.

“EPA does not have requirements for plumbing materials beyond the requirements for lead-free,” Senior Communications Advisor for EPA, Dominique Joseph, told EHN in an email. “EPA has supported the development of independent, third-party testing standards for plumbing materials under NSF/ANSI 61, which has been incorporated into many state and local plumbing codes.”

The report raises concerns about the rigor of the NSF/ANSI 61 standard, which was developed by NSF International, an industry-funded organization.

Beyond concerns for chemical leaching into drinking water, “Plastic pipes are an environmental justice issue,” Enck said. The vinyl chloride that makes the pipes is largely produced in the Gulf Coast and Appalachia, where surrounding communities face exposure to the carcinogen. Vinyl chloride was the principal chemical released in the February train derailment in East Palestine, Ohio. The train was also carrying PVC pellets on their way to a PVC pipe manufacturer, said Mike Schade, director of Mind the Store at Toxic-Free Future, at a press conference for the report.

Copper can also corrode from pipes and cause health issues in high concentrations, but this is less common than high lead levels, and can be managed with corrosion control, said NRDC’s Olson. Recycled copper is the best choice for service lines to protect public health, the report concludes.

Cities take action on lead pipes

PVC pipes health risk

Some cities have made drinking water exposures a priority, and set an example for others to follow, Olson said. He points to Newark, New Jersey, which replaced more than 20,000 lead service lines with copper at no expense to property owners within a few years.

Somerville, Massachusetts, is replacing all of its non-copper service lines with copper, prioritizing lead pipe removals first. “Copper tubing is the preferred water service material as it is sturdier and has a longer life span,” Karla Cuarezma, project manager for Somerville, said in an email to EHN.

Troy, New York, also plans to replace lead pipes with copper. This pipe material preference has been in the city’s code for many decades, and they’re planning to stick with it, Chris Wheland, Troy’s superintendent of public utilities, told EHN. He added that at high water pressures plastic pipes don’t last as long.

After facing criticisms for a slow start to the lead service line replacement program, Troy is putting a $500,000 fund to work to identify lead service line locations and begin some replacements. But Wheland said this is only a start, Troy will need $30 million to finish the job and replace all of its lead service lines.

“We also have many other programs that we have to fund,” he said, “I still have to maintain the water plant, I still have to maintain pipes to the water plant and out of the water plant, because if I don’t have a water plant to give you water, there’s no sense in worrying about the lead pipe.”

Correction: A previous version of this story stated that Dr. Levin’s study reviewing the EPA’s lead and copper rule was a non-peer-reviewed preprint rather than peer-reviewed, published paper.