The Total Number of Lead Service Lines Is Unknown, and National, State, and Local Estimates Vary

The total number of lead service lines is unknown and while national,  state, and local estimates exist, approaches used to count lead service  lines vary. The Lead and Copper Rule Does Not Generally Require Water Systems to Maintain Complete Information about Lead Service Lines or Report Such Information to EPA

The total number of lead service lines is unknown, in part because the  Lead and Copper Rule does not require all water systems to develop and  maintain a complete inventory of lead service lines, and there are no  national repositories of information about lead service lines. EPA agreed with  the recommendation but has not implemented it. An April 2016 American Water Works Association study estimated 6.1  million lead service lines nationwide. EPA  officials in one region we interviewed said that estimates of lead service  lines can decrease or increase as a water system replaces lead service  lines and as a water system does or does not count lead service lines on  private property. In May 2018, a representative of the Greater Cincinnati Water  Works water system estimated there were approximately 7 percent of  publicly owned and approximately 18 percent privately owned lead  service lines out of a total of 240,000 service lines in the area served by  that water system. Most States Reported Fulfilling EPA’s Request, but Potential Challenges Remain that EPA Information Sharing Could Help to Address

While most states informed EPA that they intend to fulfill the agency’s  request to work with water systems to publicize inventories of lead service  lines, EPA has identified potential challenges to these efforts. Nonetheless, the agency has not followed up with all states since 2016 to  share information about how to address these challenges. Of the approximately 43 states that  responded that they would fulfill EPA’s request, almost all (39) reported in  subsequent letters to or meetings with EPA that they had encouraged  water systems to publicize their materials inventories or other information  about lead service lines. As of January 2018, we found 12 of these  water systems had publicized information on the inventory of lead service  lines; the rest had not. The information on the websites for the 12 water  systems varied. According to EPA’s February 2016  letter, the agency’s objective in encouraging states to work with water  systems to post, on a public website, the water system’s original materials  inventory along with any additional updated map or inventories of lead  service lines was to assure the public that lead risks were being  addressed. By sharing  information with all states about the approaches that some states and  water systems are using to successfully identify and publicize information  about lead service lines, including responses to potential challenges, EPA  could encourage states to be more transparent to the public and support  the agency’s objectives for safe drinking water. (Recommendation 1)

	Agency Comments

We provided a draft of this report to EPA for review and comment. Appendix I: Objectives Scope and Methodology

Our objectives were to examine (1) what is known about the number of  existing lead service lines nationally, and among states and water  systems; and (2) state responses to EPA’s February 2016 request to  work with water systems to publicize inventories of lead service lines and  any steps EPA has taken to follow up on these responses. On  behalf of the Lead Service Line Replacement Collaborative, the  organizations we spoke with are collecting examples of states’ and water  systems’ experiences in conducting inventories of lead service lines, as  the first step in replacing lead service lines.
Why GAO Did This Study

The crisis in Flint, Michigan, brought increased attention to lead in drinking water infrastructure. Lead in drinking water primarily comes from corrosion of service lines connecting the water main to a house or building. In 1991, EPA issued the Lead and Copper Rule that required water systems to conduct a “materials inventory” of lead service lines. In light of the events in Flint, EPA sent a letter to all states in February 2016 encouraging them to work with water systems to publicly post the materials inventory, along with any additional updated maps or inventories of lead service linesactions the rule does not require.
A House Committee report accompanying a bill for the Department of the Interior, Environment and Related Agencies Appropriations Act, 2017, includes a provision for GAO to review lead service lines. This report examines (1) what is known about the number of existing lead service lines among states and water systems and (2) states' responses to EPA's February 2016 request to work with water systems to publicize inventories of lead service lines and any steps EPA has taken to follow up on these responses. GAO reviewed existing studies of lead service lines, reviewed the websites of the 100 largest water systems, and interviewed EPA officials in headquarters and its 10 regional offices.

What GAO Found

The total number of lead service lines is unknown and while national, state, and local estimates exist, approaches used to count lead service lines vary. A 2016 American Water Works Association study estimated that nationally there were 6.1 million lead service lines, but the study has significant sampling limitations and, as a result, likely does not accurately reflect the total number of lead service lines nationwide. In addition, at least two statesMassachusetts and Washingtonpublished reports with estimates of lead service lines and reported 22,023 and 1,000-2,000 lead service lines as of 2016 and 2017, respectively. Certain water systems also have estimates, such as the approximately 7 percent of publicly owned lead service lines out of the area's total number of service lines cited by a representative for the system serving Cincinnati, Ohio and surrounding areas, as of May 2018.
While most states informed the Environmental Protection Agency (EPA) that they intend to fulfill the agency's request to publicize inventories of lead service lines, EPA has identified potential challenges to these efforts. Of the approximately 43 states that responded that they would fulfill EPA's request, almost all (39) reported to EPA that, although they had encouraged water systems to publicize inventories, few systems had completed these actions. GAO found in January 2018 that, of the 100 largest water systems, 12 had publicized information on the inventory of lead service lines. According to EPA, among challenges in conducting inventories of lead service lines and publicizing information about lead service lines were concerns about posting on public websites information about lead service lines on private property; and a lack of records about the locations of lead service lines. EPA told GAO the agency was focused on state compliance with drinking water rules, and not following up with information on how states could address the challenges cited. By sharing information with all states about the approaches that some states and water systems are using to successfully identify and publicize information about lead service lines, including responses to potential challenges, EPA could encourage states to be more transparent to the public and support the agency's objectives for safe drinking water.

What GAO Recommends

GAO recommends that EPA share information about the successful approaches states and water systems use to identify and publicize locations of lead service lines with all states. EPA agreed with the recommendation.