Irish Water. Lead in Drinking Water. Mitigation Plan. Issues Paper. June Lead in Drinking Water Mitigation Plan - Issues Paper

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1 Irish Water Lead in Drinking Water Mitigation Plan Issues Paper June Lead in Drinking Water Mitigation Plan - Issues Paper

2 Summary Factsheet Drinking Water as produced and distributed by Irish Water is free from lead. However, it can dissolve low concentrations of lead as it passes through lead pipework in service connections to properties. There are public health risks from consumption of lead in drinking water. Lead pipes may have been used in water service connections and in inside plumbing in properties built up to and including the 1970s. We estimate that lead pipework is in up to 200,000 residential properties in Ireland as well as many of the commercial and public buildings. The maximum allowable limit for lead concentration in drinking water since December, 2013 is 10 µg/l (10 parts per billion) reduced from 25 µg/l which was the limit from The World Health Organisation (WHO), the Environmental Protection Agency and the Health Service Executive recommend lead pipe replacement (both lead service connections in the public supply and lead plumbing in private properties) as the ultimate goal in reducing long-term exposure to lead. Irish Water is currently mapping areas likely to have lead pipework and is using water sampling programme data to identify those at risk. Irish Water has begun the process of advising customers where lead pipes have been identified through the national metering programme We propose to develop a nationwide sampling programme to support our risk assessment of lead concentrations in drinking water. We Water also proposes that a national programme of replacement for public lead service pipes is required. Research indicates that unless the public and private supply pipes are both replaced, lead levels in the water could remain higher than the Drinking Water Regulation limit. Replacing the public supply pipe or the private pipe of its own does not resolve the problem. Where lead pipework or plumbing fittings occur within a private property, it is the responsibility of the property owner to replace it. Further information on Public Water Supplies and Lead in Drinking Water can be found online at or by calling Irish Water at LoCall or Lead in Drinking Water Mitigation Plan - Issues Paper

3 Chapter 1: Introduction 3 Lead in Drinking Water Mitigation Plan - Issues Paper

4 Lead in Water Supplies The drinking water produced in Irish Water s treatment plants for supply through the public water mains to each property meets all the requirements of the European Union (Drinking Water) Regulations 2014 (the Drinking Water Regulations) with regard to the limit for lead. However, lead can dissolve into water in low concentrations as it passes through lead pipes and plumbing. Wherever lead pipework is present, the possibility of lead in the drinking water exists. Irish Water s records currently show there are no lead water mains in Ireland. There are still some lead pipes in the public network, but these are mostly in old shared connections or in the short pipes connecting the (public) water main to the (private) water supply pipes in older properties. The use of lead pipes in water supplies has been documented in many countries from Roman times. In Ireland, lead was used for service connections to buildings (the pipes linking the water mains to individual properties) and in internal plumbing up to and including the 1970s. It was not generally used in the public distribution network, but was commonly used in shared backyard water mains serving groups of terraced houses, typically in older local authority built housing schemes. Lead pipes were not used in buildings constructed after the 1970 s. Local authority housing pre-1950's was built in terraces and the supply (usually small diameter and often lead or gun-barrel (containing lead)) pipe was laid in the backyards of properties. Looped at both ends, this was a low cost approach to servicing housing stock, enabling shorter runs of smaller diameter pipe to be used with shorter connections to the kitchen tap. Why can lead pipes be a problem? When lead is in contact with water, the metal can slowly dissolve. This process is known as plumbosolvency. The level at which lead can dissolve varies with the length of lead pipe, local water chemistry, temperature and the amount of water used at the property. Health studies in recent decades have identified risks to health from ingestion of lead. As a result, measures to reduce exposure to lead have been introduced in many countries worldwide, over the last 30 years. These measures included the removal of lead from petrol, paints, electronic goods and plumbing materials. However, removal of existing lead pipes is a long term objective and in the meantime, other countries have often implemented alternative mitigation measures to reduce health impacts. Since December 2013, the acceptable concentration of lead in drinking water 1 is 10 micrograms per litre (µg/l), based on standards set in the Drinking Water Regulations. Prior to that date, in the Drinking Water Regulations. the standard was 25µg/l, reduced from 50µg/l in This shows the increasing focus on minimising exposure to lead on health grounds in recent years. The World Health Organisation (WHO), the Environmental Protection Agency (EPA) and the Health Service Executive (HSE) advise that pregnant women and young children are particularly vulnerable to the effects of lead. These organisations recommend that replacement of all lead pipework is the best long term solution to eliminate lead from drinking water. Current advice from the HSE and the EPA, based on WHO recommendations, is that no concentration of lead in drinking water is completely safe. Recognising that all lead pipes will not be removed in the short term, there are likely to be properties where lead levels are in excess of current limit. The immediate focus of this issues paper is to inform those at risk as far as is practicable and to look at mitigation options which should result in the reduction of exposure to lead. Responding to the Lower Lead Limit The challenge posed by the 2013 lead limit has been signalled since 1998 in Ireland. Prior to the establishment of Irish Water, the issue was not addressed effectively. Successive annual EPA Drinking 4 Lead in Drinking Water Mitigation Plan - Issues Paper

5 Water Reports identified the need for Water Services Authorities to plan and implement measures to meet the limit. In the EPA s Drinking Water In Ireland report of 2004, the EPA encouraged local authorities (who acted as Water Services Authorities before the establishment of Irish Water) to replace public side lead services and suggested that orthophosphate dosing should be considered to mitigate lead concentrations in drinking water: Sanitary authorities must consider this problem in more detail if compliance with the standard of 10 μg/l is to be achieved by In particular some sanitary authorities may need to consider phosphate dosing to reduce the plumbosolvency of the water. This practice is widespread in the UK and in Europe but is currently not practiced in Ireland. Furthermore, the low levels of lead sampling required by the Drinking Water Regulations meant that the scale of potential non-compliance was not adequately reflected in published data. Over the past number of years the EPA has identified that the level of lead compliance would reduce once the 2013 limit came into force. Irish Water estimates that with intensified monitoring, the true level of compliance may be as low as 85-95%, far lower than the current 98.5% (EPA 2014). Recognising that removal of lead pipes would be extremely costly and would take many decades, the UK Drinking Water Inspectorate (DWI) instructed UK water companies to add orthophosphate to all drinking water supplies in Adding approximately 1 milligram per litre (mg/l) of this food grade chemical creates a coating on lead and other metal pipes which prevents the lead dissolving into the water. This practice is now the accepted lead mitigation in many countries and has resulted in very high levels of compliance for lead (99%), in relatively short timeframes. Although it is proving less popular in Europe due to environmental considerations, the practice has been implemented in USA and Canada. Actions taken to date Since the 1970s, there has been an international health focus on reducing societal exposure to lead, particularly for young children. Lead has been banned from petrol, paints and electronic goods already. Lead pipework was commonly used and is being gradually replaced by water utility companies and property owners in many countries. However, given its extent and the complexity of water services connections into and within properties, it is recognised that full removal of lead will take a number of decades to achieve. Irish Water was established in 2013 and took over responsibility for public water services in Ireland from January, 2014 and immediately identified lead in drinking water as a very significant issue. The Irish Water Capital Investment Plan (CIP ) committed to developing a lead strategy in More extensive sampling by Irish Water has identified levels of lead at customer properties multiples greater than the new lead limit. Where exceedences have been confirmed, they have been notified to EPA, HSE and the affected customers. This in turn has given rise to a much greater public awareness of lead pipes as an issue for drinking water quality. Moreover, it has become clear that the problem is nationwide and that the presence of lead piping is a likely indicator of lead in drinking water. A national approach is required to resolve the lead issue involving Irish Water and other stakeholders including the EPA, HSE, CER and the Department of Environment Community and Local Government (DECLG). Irish Water has researched international experience in dealing with lead in drinking water and made its initial assessment of the scale of lead in the system as a basis for developing this Issues Paper and in the preparation of a Lead in Drinking Water Mitigation Plan. In preparing this paper, we have liaised extensively with the DECLG, the EPA and the HSE. Due to the scale of the problem and the cost implications of replacing lead pipework we propose a long term integrated approach, which considers all available measures in the mitigation of health risks to the public. Irish Water is collating data from the Local Authorities (LA), the water metering programme and property age data from the Central Statistics Office (CSO) onto a Geographical Information System (GIS) to identify 5 Lead in Drinking Water Mitigation Plan - Issues Paper

6 locations of properties likely to have lead pipes and which may exceed the drinking water limit. This is detailed further in Chapter 3. Irish Water has begun the process of advising customers where lead pipes have been identified through the national metering programme and our website provides advice to customers on lead in drinking water and includes the Health Services Executive (HSE) and Environmental Protection Agency (EPA) Joint Position Paper Lead (Pb) in Drinking Water, December 2013, which is available from the following link: The potential solutions being considered by Irish Water are detailed in Chapter 4. These include: Advice to customers in properties that may be at risk; Actions that can be taken to reduce lead concentrations at a property; and, Irish Water s long term goal for full removal of all public side lead pipework (This will only be effective, if property owners replace their lead pipework in the same timeframe). However, as this will require significant capital investment and will involve many different stakeholders, including local authorities and private property owners, an interim short term response is required which recognises the presence of lead in drinking water and the options to mitigate health risks associated with it. For the past 20 years, there has been a significant investment in water conservation and service improvement programmes that have focussed on water main replacement in areas with backyard services due to high levels of leakage. Prior to investment, customers in these properties generally experience very poor levels of services in terms of pressure and interruptions due to leakage and bursts. Backyard services have often been built/extended over by property owners and consequently cannot be exposed for repair. Years of incremental leakage and bursts have gone unrepaired, with the only practical solution being to lay a new water mains public road at the front of the property. These programmes have been a priority since the 1990's. Irish Water has continued to remove lead service connections and improve customer service levels as part of our water conservation and water main rehabilitation programmes under the Capital Investment Plan Irish Water has established lead pipe replacement opt-in scheme, where Irish Water will also replace the pipework between the water main and the outer edge of the property boundary, if a property owner replaces the lead pipework on their property. Strategic Environmental Assessment (SEA) with Public Consultation Irish Water is finalising its Water Services Strategic Plan (WSSP) which is a Tier 1 (High Level) Plan, outlining current and future challenges, and targets and strategies to meet these challenges over a 25 year time period. The WSSP is prepared under Section 33 of the Water Services (No 2) Act, 2013 and will ultimately be submitted in mid-2015 for approval of the Minister of the Environment, Community & Local Government. The WSSP references lead in drinking water among the issues to be addressed in the short term and identifies the need for a Lead in Drinking Water Mitigation Plan to be prepared (strategy WS1e) in order to deliver Irish Water s key aim to manage the sustainability and quality of drinking water from source to tap to protect human health (aim WS1). The Lead in Drinking Water Mitigation Plan will provide a detailed framework of measures for implementation to effectively address lead in drinking water and may be considered a subset of Irish Water s Tier 2 National Water Resources Plan (strategy WS1a) which is also required to deliver Aim WS1 Where Plans and Programmes relating to water management can impact on the environment, they require a Strategic Environmental Assessment (SEA) to address environmental considerations at Plan level and, where relevant, an Appropriate Assessment (AA) to address issues arising under the Habitats Directive, 6 Lead in Drinking Water Mitigation Plan - Issues Paper

7 such as impacts on designated conservation areas. Due to the risk of one of the potential mitigation measures being considered (orthophosphate dosing) to impact on the environment, Irish Water will undertake both SEA and AA processes during the preparation of its Lead in Drinking Water Mitigation Plan. Feedback on this Issues Paper This Issues Paper has been prepared to enable an initial public consultation on the issues around compliance with the lead standard in drinking water, the need to protect public health and the issues associated with the measures to be considered in framing an Irish Water Lead in Drinking Water Mitigation Plan. A key objective of this document and the associated public engagement is to alert all customers potentially at risk to the fact that they may have lead concentrations in their water supply that are in excess of the current limit. Whilst the presence of lead piping in a property does not automatically mean that lead concentrations will exceed the limit, we estimate that this is likely to be the case in the majority of properties. We are now seeking your views on our approach to preparing our Lead in Drinking Water Mitigation Plan and its associated environmental assessments (Strategic Environmental Assessment (SEA) and Appropriate Assessment (AA). We will then prepare the Draft Plan, SEA & AA documents which we will publish for a period of statutory consultation, taking account of your views before the Plan is finalised. In the interim, we will be rolling out a lead information campaign, whilst continuing public lead pipe replacement and carrying out a pilot treatment optimisation study, as well as other research projects. In this first phase of non-statutory public consultation, we are setting out the key issues and options for public engagement and feedback. At the end of each section of this Issues Paper, we have included a number of questions inviting feedback on specific issues. However, we welcome your views on any aspect and relevant feedback will be taken into account in preparing the draft Plan. Responses to the consultation can be made online at plans/futureplans/ by to [email protected] or posted to the address below: Lead in Drinking Water Mitigation Plan Issues Paper PO Box 860 South City Delivery Office Cork City The closing date for receiving responses is 15th July Further information on Public Water Supplies and Lead in Drinking Water can be found online at or by calling Irish Water at LoCall or IRISH WATER S VISION Through responsible stewardship, efficient management and strong partnerships, Ireland has a world-class water infrastructure that ensures secure and sustainable water services, essential for our health, our communities the economy and the environment 7 Lead in Drinking Water Mitigation Plan - Issues Paper

8 Chapter 2: Background to Irish Water 8 Lead in Drinking Water Mitigation Plan - Issues Paper

9 Overview of Irish Water Irish Water was established as a subsidiary of the Ervia Group (formerly Bord Gáis Éireann) in 2013.Ervia now has responsibility for the delivery of gas and water infrastructure services in Ireland. Establishing Irish Water involved the creation of the required utility organisation, management systems and processes required to efficiently deliver water and wastewater services, drawing on the experience and expertise of Bord Gáis Éireann, as a modern, efficient and customer focused energy utility. Irish Water brings the water and wastewater services of the 31 local authorities together under one national service provider. From the 1 st January, 2014, Irish Water became responsible for all public water services, involving the supply of drinking water and the collection, treatment and disposal of wastewater. Irish Water took on the operation of the assets through Service Level Agreements (SLAs) with all 31 local authorities who continue to provide day to day operations on behalf of Irish Water. We also took over all of the capital investment decisions and implementation of the capital programme delivery across the country, subject to the approval of the CER. In discharging its role as the national water services utility, responsible for water services operations and investment, Irish Water is accountable to: a) The economic regulator, the Commission for Energy Regulation (CER), which is charged with protecting the interests of the customer, while approving an appropriate funding requirement sufficient to enable the utility to deliver the required services to specified standards in an efficient manner; and, b) The environmental regulator, the Environmental Protection Agency (EPA), which sets standards and enforces compliance with EU and National Regulations for drinking water supply and wastewater discharge to water bodies. The EPA liaises with the HSE in matters of public health. Our Water Supply Responsibilities Irish Water is responsible for the public supply of drinking water to over 80% of the population. Our water supply responsibilities extend from the abstraction of water from wells, rivers, lakes and reservoirs, to treatment of this water such that it is suitable for human consumption and onward delivery to our customers homes and business premises. We are not responsible for Group Water Schemes or private water supplies. Whilst we do provide water to some Group Water Schemes connected to the public network, we are not responsible for their distribution networks and other Group Water Scheme infrastructure such as reservoirs and pumping stations. Neither are we responsible for private wells. Our Water Supply Assets We are responsible for water supply to 3.3 million people and the operation of a large portfolio of assets including over 800 water treatment plants, thousands of reservoirs, pumping stations and approximately 60,000kilometres of water mains. Due to the previously fragmented nature of water services in Ireland, the level and quality of data and records currently available varies widely. Consequently, we are carrying out detailed asset surveys to increasing levels of detail and prioritising critical assets, as a basis for strategic planning of our operations and investments. 9 Lead in Drinking Water Mitigation Plan - Issues Paper

10 Figure 1: Irish Water Asset Responsibility (in Blue) What are the Legal Responsibilities of Water Supply? In terms of statutory obligations with respect to lead in drinking water, Regulation 6 of the Euopean Union (Drinking Water Regulations) 2014 sets out Irish Water s Duties in relation to water on premises (i.e. within households or public buildings).this states that: Regulation 6(1) A water supplier shall not be in breach of its obligations under Regulation 4(1) where non-compliance is due to the domestic distribution system in a premises, or the maintenance thereof, and that distribution system is not in the charge or control of the water supplier in its capacity as a water supplier. Therefore, Irish Water is not legally responsible for water exceeding the lead concentration if this is due to lead pipework which it does not own or operate (i.e. within a property boundary). However, the Regulations further state that: Regulation 6(3) Without prejudice to paragraph (4), where a non-compliance referred to in paragraph (1), or a risk of such non-compliance, is in a premises where water is supplied for human consumption as part of a commercial or public activity (including, but not limited to, schools, hospitals and restaurants) Irish Water or the relevant local authority shall ensure that appropriate action is taken promptly (whether by the owner of the premises or the water supplier, or both, as Irish Water or the relevant local authority may consider appropriate) to (a) immediately prevent, or restrict as Irish Water or the relevant local authority deems appropriate, the further supply of water for human consumption to the public through the domestic distribution system of the premises until the system is restored to such condition as to no longer be a cause or a risk of such non-compliance, and 10 Lead in Drinking Water Mitigation Plan - Issues Paper

11 (b) restore the domestic distribution system of the premises to a standard necessary for compliance with these Regulations, and Irish Water or the relevant local authority may issue such directions as it considers necessary for this purpose. Therefore, if Irish Water is aware of a lead non-compliance with the Drinking Water Regulations in a commercial premises (i.e. where members of the public may be drinking water on the premises), it has a duty to ensure that appropriate action is taken (whether by the owner of the premises or by Irish Water (as Irish Water considers appropriate) to ensure that the drinking water on the premises is restricted and that the domestic distribution system at the premises is restored to a standard necessary to ensure compliance with the Drinking Water Regulations. Irish Water may issue directions as it considers necessary for this purpose. Regulation 6(5) Where a non-compliance referred to in paragraph (1), or a risk of such noncompliance, is in a premises where water is supplied for human consumption but not as part of a commercial or public activity, Irish Water or the relevant local authority shall nevertheless ensure that (a) (i) appropriate measures are taken to reduce or eliminate the risk of noncompliance with the parametric value, including advising premises owners affected of any possible remedial action which could be taken by them, or (ii) other measures are taken, such as application of appropriate treatment techniques, to change the nature or properties of the water before it is supplied so as to reduce or eliminate the risk of the water not complying with the parametric value after supply. Therefore, if Irish Water is aware of a lead non-compliance with the Drinking Water Regulations in a home (or non-commercial premises), it has a duty to advise the premise s owner that the water at their premise may not comply with the lead limit in the regulations. It may offer advice on remedial and other measures to reduce the risk of non-compliance. Role of the Public Stakeholders There are a number of public authorities who regulate Irish Water and are important with regard to the consultation and delivery of the Lead in Drinking Water Mitigation Plan. The Department of Environment, Community and Local Government (DECLG) is responsible for policy and legislation in relation to water quality issues taking account of any advice of the Minister for Health on matters pertaining to public health. Specific arrangements are in place to regulate and supervise the supply of drinking water. These arrangements reflect the fact that the majority of people in Ireland receive their drinking water through public supplies, with the remainder provided through group water schemes and private wells. The Commission for Energy Regulation (CER) ensures that water services are provided by Irish Water in an economic and efficient manner. The costs and efficiencies of our proposals for delivery of the Plan must be approved by the CER. The Environmental Protection Agency (EPA) regulates both environmental matters and drinking water quality standards. The EPA is the authority required to verify compliance of water intended for human consumption with the parametric limits specified in the Drinking Water Regulations. The Health Service Executive (HSE) is responsible for the protection of public health and, under the Drinking Water Regulations, where Irish Water considers that a supply of water constitutes a danger to public health, we are required to consult with the HSE and agree the actions to be taken to protect human health. 11 Lead in Drinking Water Mitigation Plan - Issues Paper

12 The relevant stakeholders are presented in the graphic below. HSE DECLG EPA Local Authorities CER Irish Water Consumers Figure 2: Public Stakeholders 12 Lead in Drinking Water Mitigation Plan - Issues Paper

13 Chapter 3: Risk Assessment and Sampling 13 Lead in Drinking Water Mitigation Plan - Issues Paper

14 Who is responsible for the pipework? Irish Water is responsible for the pipes under the road or paths to the outer edge of the boundary of the property. The property owner is responsible for the pipe from the outer edge of the property boundary (i.e. to a position such that any works on the pipe would not interfere with your property or its foundations) to the building and all the inside plumbing. Typically 75-90% of the pipe length from the water mains to the customer s tap is within the property boundary and is the responsibility of the homeowner. The water pipe which joins our water main to your property is called the service connection. Service connection pipes can be either separate (one pipe per property), or shared (two or more properties fed by a single common service pipe). Irish Water is not responsible for either separate or shared supply pipes. However, we are responsible for some pipes at the rear of older terraced housing where the water is supplied by a looped shared service pipe, connected to the public supply at both ends. Depending on the age of a property, supply pipes (either separate or shared) may be of lead or materials containing lead. Figure 3: Pipe responsibility Q2. While Irish Water is responsible for replacement of lead pipes in service connections for which it has assumed responsibility, it remains the property owner s responsibility to replace lead pipes on their property. Would you be willing to replace pipes on your property to reduce your exposure to lead? 14 Lead in Drinking Water Mitigation Plan - Issues Paper

15 Risk based prioritisation Irish Water is proposing that a risk based approach is taken to how we deal with lead identified in water supply in excess of the current limit. This approached is aimed at addressing the largest populations, at the highest risk, in the shortest timeframe. The risk assessment consists of a number of elements: areas that are likely to give rise to the highest lead concentrations (plumbosolvency risk); areas that are likely to have the most lead pipework; and, priority properties within these areas (e.g. schools, crèches) Plumbosolvency risk classification The risk classifications identifies the potential for lead exceedance (concentrations of lead in excess of the current limit) in each water supply zone and looks at the chemical properties of the water (ph, alkalinity and hardness) and therefore can assess how readily it dissolves lead. This information will help us to prioritise the areas where lead pipes are likely to result in higher lead concentrations. Our proposed risk classification is presented in the table below: Type of Source and Treatment Risk Classification Soft water, ph<7, high colour, from an upland lake or river, disinfection treatment only. Very High Other lakes, rivers and springs, disinfection only High Lake and river sources with conventional treatment (filtration and disinfection) Moderate Hard Water, groundwater Moderate Identification of at risk areas This step uses available data to identify the properties that are likely to have lead pipes. The primary indicator for the presence of lead pipework is the year in which the property was built; data which is available from the Central Statistics Office. Significant numbers of service connections between the water mains and the customers property are made from lead. As part of our national domestic metering project, these pipes are being identified and tagged and the information up-loaded on our Geographical Information System (GIS). This process is showing that thus far at least 5% of houses metered may have lead service connection pipes and are very likely to have lead plumbing. Irish Water is in the process of writing to all these customers to make them aware of the risk and to provide advice on actions that they can take to mitigate the risk. However, we think that the proportion identified is an under-estimate and that a much higher proportion of older houses have lead service connections and plumbing, but have not been metered yet. In total, we estimate that 140, ,000 houses may have lead pipework. 15 Lead in Drinking Water Mitigation Plan - Issues Paper

16 We estimate that a further 30,000-40,000 homes are served by shared looped backyard pipes. These are typically terraced housing schemes built pre-1970, which were supplied with water through a shared backyard service connection pipe, which may have been made of lead. In addition, there are several thousand public buildings, workplaces, schools, medical centres and other buildings which were constructed pre Many of these buildings are likely to have some lead pipework within the property unless it has been replaced. There are no records available to Irish Water to identify these properties at present. Whilst the GIS system illustrates areas at risk, it does not provide Irish Water with the specific addresses at risk and further work is required to identify and confirm that lead was installed at specific properties. Raheny Case Study Dublin City Council conducted a detailed study of properties in Raheny, North Dublin for compliance with the lead drinking water limit. The key findings were: 15 of the 16 properties failing the 10µg/L limit had no Irish Water owned or controlled lead pipework (i.e. all lead pipework was within the property). Flushing reduced lead concentrations but did not achieve compliance with the Drinking Water Regulations. Identification of priority properties This step identifies the non-domestic properties that are likely to be occupied by those most at risk from exposure i.e. young children and women. Non-domestic customer records from the Local Authorities and the An Post GeoDirectory data will be used to identify service connections serving schools, crèches, medical centres and other public buildings. These will be prioritised for inspection of the public side service pipe connection and replacement where they are found to be lead. 16 Lead in Drinking Water Mitigation Plan - Issues Paper

17 Q3. Do you agree with the proposed approach to identifying properties at risk from lead and do you have any comments? Risk based prioritisation of solutions Recognising lead as a national issue which will take many years to address, Irish Water proposes to prioritise its programmes based on the information gathered regarding locations likely to have the highest lead concentrations (plumbosolvency risk) and which are likely to have the most lead pipes. i.e. areas which have a higher plumbosolvency risk and where there are a larger number of older properties will be dealt with first. Q.4 Do you agree with our risk assessment approach and do you have any comments? Water Quality Sampling The previous sections outlined the data that is available on the likelihood of lead concentrations in water supplies in excess of current standards. There is no single comprehensive data source available that provides us with the specific addresses of properties with lead supply or service connection pipes. This is why we constantly refer to properties at risk, or that are likely to have lead pipes. Without comprehensive and accurate data, it is very difficult to develop efficient programmes to address lead compliance. Sampling water at every property would confirm the presence of lead pipes, but it is not practicable to sample every household in Ireland. To establish a clear picture of the lead problem in a water supply zone (WSZ) and to help us identify the most appropriate lead reduction measures to be implemented, we propose to start a national random-day-time (RDT) sampling programme. The proposed sampling programme would go far beyond the requirements of the Drinking Water Regulations (2014) providing enough data coverage to ensure that Irish Water s resources are focussed on in the right areas. Using RDT, large number of samples can be taken relatively quickly across a large number of properties. An additional benefit of the RDT programme is that it will enable us identify elevated lead concentrations at properties that would not have been picked up from the available data source, e.g. properties where poor quality plumbing fittings or lead solder has been used. Previous investigations into the application of RDT sampling for lead concluded: RDT sampling as practised in the UK is adequately representative of the range of circumstances that occur; For houses with daytime residency, RDT is not sensitive to time period of sampling; and, Aggregation of results over several years provides a clear picture of the lead problem in a WSZ Due to the seasonal effects of temperature and other factors, six sampling periods (i.e. sampling every second month) will be used to gather a full annual profile of lead compliance. To achieve an adequate level of statistical confidence in the results, no property will be sampled more than once per year. The sampling programme will require an estimated 44,000 samples to be carried out across all WSZs to establish the full year lead risk profile. This represents a significant increase in sampling activity when 17 Lead in Drinking Water Mitigation Plan - Issues Paper

18 compared to the 2,000-3,000 lead samples reported by the Local Authorities to the EPA in previous years and a very significant increase over the specified number of compliance monitoring samples required by the Drinking Water Regulations. Q5. Do you agree with our proposed sampling programme? 18 Lead in Drinking Water Mitigation Plan - Issues Paper

19 Chapter 4: Solution Options towards Lead Compliance 19 Lead in Drinking Water Mitigation Plan - Issues Paper

20 Introduction For drinking water to comply with the Drinking Water Regulations in terms of lead requirements is a complex challenge. It involves a wide range of stakeholders, and a range of solutions across the areas supplied by our 856 water treatment plants. There is no quick solution and full compliance will take time. Our proposed approach to achieving Drinking Water Regulation lead compliance aims to reduce the health risk as quickly as possible through a combination of: a national public information campaign to inform households of the risks and actions to take; lead pipe replacement; and, water chemistry optimisation to reduce its potential to dissolve lead (plumbosolvency risk). These three actions are detailed below. Public Information Campaign Irish Water is proposing a major public information programme to be initiated in June 2015, involving all major stakeholders including the Environmental Protection Agency (EPA) and the Health Services Executive (HSE). This will be facilitated by a range of communications materials and using various communication channels, targeted at customers who possibly have lead pipes in their properties. This is the most effective way to address what is a national public health issue. Where we have knowledge of properties with lead pipework derived from the metering project, we are contacting these customers individually. We are mapping areas likely to have lead pipework, based on property age and we will combine these maps with existing water sampling data to inform customers in these areas. The communications will provide advice, agreed with the EPA and HSE on the actions which can be taken. We are proposing that we provide the information through the following means: Press releases to the media informing of the availability of information. Printed leaflets delivered to all properties identified as having lead pipework from the metering project. Dedicated webpage with advice and downloadable leaflets. Briefing local authority staff and elected representatives. Telephone and advice made available (telephone number and contact details would be included on our webpage and leaflets); and Social media (Irish Water s Facebook and Twitter accounts) would be used to broaden the message. We will recommend practical steps customers can take, until the property owner replaces the lead pipework in their property. These include: How to identify lead pipes Flushing of pipework after several hours of non-use. Evidence from international and local studies indicates that this is likely to reduce the concentration although it does not guarantee compliance with the lead limit. Take water for drinking and cooking directly from the mains-fed tap. This is normally the cold tap at the kitchen sink and is likely to have the least risk. Never use water from the hot water tap for drinking or cooking. Heating increases the amount of lead that can be absorbed from plumbing. 20 Lead in Drinking Water Mitigation Plan - Issues Paper

21 Use of bottled water for vulnerable persons, particularly children and pregnant women. Bottled water for infant feeds should be checked to ensure it is low in sodium; and Boiling water does not reduce lead concentrations in the water. Q6. How would you like to receive information on steps you can take to reduce you exposure to lead? Irish Water Lead Pipe Replacement Programme Irish Water proposes to replace all lead service connections for which it is responsible (including looped backyard service connections in terraced housing). In Chapter 3 it was stated that plumbosolvency risk, property age, metering and sampling programme data will be used to target the locations for pipe replacement. At a minimum, we estimate that at least ten years and a number of investment cycles will be required to replace all public lead service connections and will cost million. The lead pipework replacement programme would be subject to approval of funding by the CER. The level of funding available will determine the number of lead pipes replaced each year and will be influenced by the overall level of funding available to Irish Water and the competing priorities to be addressed. Q8. Do you agree with our timeframe for replacement of public side lead pipework? Household Lead Pipes Replacement Research from international lead pipe replacement programmes employed by other water utility companies indicates that the full length of pipe from the public water main to the customer s tap must be replaced in order to achieve compliance with the relevant lead standards. The replacement of lead pipes within a property is the sole responsibility of the property owner, but where a property owner replaces the lead pipework on their property, Irish Water will also replace the pipework between the water main and the outer edge of the property boundary. Q9. Would you avail of our proposal to replace the public side lead connection pipe when a property owner replaces their internal lead pipework? Plumbosolvency Reduction Virtually all water has the corrosive ability to lead to a breach of the lead limit if the water flows through lead pipework. However, there are treatment (corrosion control) measures that can be taken by water suppliers to reduce plumbosolvency. Internationally, corrosion control is practised by treatment with orthophosphate at the water treatment plant and this option is discussed below. The addition of a chemical, phosphoric acid, in conjunction with ph adjustment at water treatment plants can prevent the solution of lead into water from lead pipework by producing a coating on the inside the lead pipe. Phosphoric acid forms orthophosphate in the water. The addition of phosphoric acid is subsequently referred to as orthophosphate dosing in this document. This process has been used successfully in the UK, USA, Canada and mainland Europe to reduce lead concentrations in drinking water. Northern Ireland Water has been successfully applying orthophosphate dosing and ph control at its treatment plants since 2002/2003 and is achieving high levels of lead compliance. In the UK, the current programme of orthophosphate dosing has greatly reduced the 21 Lead in Drinking Water Mitigation Plan - Issues Paper

22 concentration of lead at consumers taps, with more than 99% of random daytime samples complying with the limit of 10 micrograms per litre 2. The orthophosphate is dosed into the water at a rate of up to 1.5 mg/l (P) in a similar process to the addition of chlorine for disinfection. The orthophosphate used for dosing is food-grade and is a clear, odourless liquid which is also found in many food products, such as cereals and fruit desserts. Orthophosphate dosing takes a period of 6-12 months to develop a full coating, after which dosing at typically 0.5mg/l (parts per million) must be maintained in order to sustain the protective coating. As an interim approach to minimising lead exceedences in drinking water, Irish Water is proposing that orthophosphate dosing equipment would be installed at treatment plants, with lead replacement being progressed in parallel. This means that the lead exceedance would be mitigated at the majority of properties with lead pipes, even though lead pipe removal by Irish Water and property owners has not been completed. Specific local constraints on dosing with orthophosphate will be considered at each water treatment plant. In addition to orthophosphate dosing, effective ph control is essential, where a water treatment plant does not already have a suitable ph control system, Irish Water will install a new or upgraded system. Environmental Implications The addition of orthophosphate will increase the concentration of orthophosphate in the drinking water by a small amount (but well within the drinking water regulation limits). However, some of the added orthophosphate will possibly enter the environment through leakage from the water distribution network and through septic tank systems. Additional orthophosphate in the wastewater will be intercepted at wastewater treatment plants where the impact can be offset, where the treatment process is so designed. Studies in the UK have shown that the existing phosphate load into the environment from wastewater is made up of 29% from food additives, 14% from laundry detergents, 9% from dishwasher detergents and 6% from orthophosphate dosing. We intend to study the potential environmental impacts from orthophosphate dosing in Ireland by carrying out a pilot programme at our Limerick City plant in the coming months which will help to inform the Plan. Orthophosphate discharged to the environment has the potential to result in environmental impacts by promoting algal production in nutrient sensitive waters which can result in water quality degradation. Therefore, an environmental risk assessment will be required for each water supply considered for orthophosphate dosing. A scheme specific assessment and implementation plan is proposed including consultation with EPA in each case. Because the Irish Water Lead in Drinking Water Mitigation Plan will be implemented at a national scale and has the potential to impact on the environment, it will be subject to an SEA and AA process prior to its finalisation. It is important to note that orthophosphate dosing is being considered as an interim measure for the reduction of lead concentrations in drinking water. The dosing would be required to continue whilst lead pipework is in use. It therefore, does not form a final solution which can only come through the replacement of lead pipework. Figure 4 An orthophosphate dosing unit 2 Hayes, C.R et al., Optimisation of orthophosphate dosing for controlling lead in drinking water. Journal of Water and Health, Lead in Drinking Water Mitigation Plan - Issues Paper

23 Irish Water is considering incorporating in its Plan the roll-out of orthophosphate dosing at up to 400 water treatment plants, subject to environmental assessment and approval of the economic regulator, the Commission for Energy Regulation (CER). The capital cost of the programme is estimated at 50 million with an annual operational cost estimated at 5 million, assuming 400 plants are included. Q10. Do you agree with our proposals to reduce the plumbosolvency of water through the addition of orthophosphate taking account of the positive health benefits and potential environmental impacts? Research & Further Investigations by Irish Water Irish Water, as part of the process of preparing the draft Plan, will continue to reference international experience and research. It will also conduct further local investigations to help inform the detailed plan. This work will include: 1. Limerick Corrosion Treatment Pilot (Clareville Water Treatment Plant) This project will involve adding orthophosphate to the Limerick City water supply, in tandem with optimising ph correction, while monitoring: a. The levels of lead in test sites in the water supply area and how these are changing over time; and, b. Orthophosphate levels in the wastewater stream to the wastewater treatment plant and in receiving waters before and during the process. This work will contribute to our understanding of the effectiveness of the programme, the level of risk to the environment as well as optimising the operations and costs involved. 2. STRIVE (Science, Technology, Research & Innovation for the Environment Programme) A pilot project in Dundalk, Co Louth commenced in 2013 and jointly sponsored by Irish Water/Louth County Council & EPA is entitled Quantify the effect of Lead Pipe Removal on Lead Concentrations in Drinking Water. This involves trials of partial & full pipe replacements, as well as chemical lining trials for small bore pipework, at selected properties. The project also examines the most effective sampling techniques to best represent the lead levels in the water and the impacts of ph adjustments at the treatment plant. This research project will assist in clarifying these aspects of the lead issue and its mitigation, as part of the process of developing the Plan. 23 Lead in Drinking Water Mitigation Plan - Issues Paper

24 Chapter 5: Next Steps What we have done to date We have estimated the scale of the lead issue, researched international experience and practices and consulted with the key regulatory stakeholders to develop a coherent response to the problem. The purpose of this document is to present the options and considerations that will likely form the basis for a Lead in Drinking Water Mitigation Plan. We will take account of all feedback from the public consultation on this document when preparing the draft Plan and SEA/AA documentation. However, whilst preparing and discussing this Plan we have also taken a number of immediate, on the ground actions, including: Immediate expansion of the sampling programme. Progressing lead pipe removal (public side & backyard) schemes at Mallow, Limerick, Tralee and elsewhere, within our approved Capital Investment Plan (CIP) where the lead risk is high and coinciding with key leakage reduction objectives. Reviewing the current guidance of the EPA/HSE and referencing to it on our website and in our publications. Communicating to customers where the metering programme has identified lead pipes. Carrying out a review of international best practice and engaging a leading international expert to advise us. Developing an implementation plan and budget for short term random daytime sampling programme and introduction of orthophosphate dosing pilot project in the Limerick City water supply (subject to agreement of the public stakeholders) Establishing a lead pipe replacement opt-in scheme where Irish Water will also replace the pipework between the water main and the outer edge of the property boundary, if a property owner replaces the lead pipework on their property. Having regard to the Government s National Strategy to reduce exposure to Lead in Drinking Water Preparing the Draft Lead in Drinking Water Mitigation Plan and Environmental Assessments During this non-statutory public consultation, Irish Water will begin the scoping of the SEA with the Statutory Environmental Authorities identified in the SEA legislation and the Screening/Scoping of the AA. Following the evaluation of the feedback from this public consultation on our Issues Paper, Irish Water will prepare a Draft Lead in Drinking Water Mitigation Plan and in tandem will prepare the environmental assessment reports required under SEA and AA legislation. The preparation of the environmental assessments will inform the development of the Plan. These documents will then be made available for the statutory consultation period required under SEA legislation. Following the evaluation of feedback from the statutory consultation, the Plan will be finalised and implemented in conjunction with funding approvals by the Economic Regulator (CER) 24 Lead in Drinking Water Mitigation Plan - Issues Paper

25 Indicators and Targets Subject to the outcome of non-statutory and statutory public consultations CER approval and SEA/AA processes, we are proposing the following indicators and targets for the implementation of the final Lead in Drinking Water Mitigation Plan. We will identify households at high risk as far as practicable by the end of We will install orthophosphate dosing plants in all high risk water supplies where it is technically, economically and environmentally viable to do so within a three year period,(i.e. by the end of 2018). We will remove all public-side lead pipework within a ten year period (i.e. by the end of 2025). We will also prepare a programme for decommissioning of the orthophosphate dosing from water supplies when we have completed public side lead replacement and the annual sampling programme indicates that the risk to households has reduced to compliance levels. Q11. Do you agree with these targets? Are there other indicators you would suggest that should be included? 25 Lead in Drinking Water Mitigation Plan - Issues Paper

26 Summary In summary, Irish Water is addressing the issue of Drinking Water Regulation non-compliant lead concentrations in drinking water. Irish Water is beginning this process from a position of limited historic data and public awareness of the problem and is in the process of developing a Plan and full programme of measures to address the aspects within its remit. We are seeking regulatory and stakeholder agreement to these measures by subjecting our proposals to public consultation and environmental assessment. In the meantime, we are mobilising our project team to begin to deliver the measures necessary to protect public health. These measures include the dissemination of public information, response service to customer queries and piloting of orthophosphate dosing in Limerick during 2015 to inform the effectiveness and environmental assessment of this aspect of a Plan. We are considering orthophosphate dosing at priority water treatment plants as a proven mitigation strategy subject to the outcome of public consultation and SEA/AA processes. 26 Lead in Drinking Water Mitigation Plan - Issues Paper

27 Glossary and Abbreviations Abbreviations CER DECLG EPA HSE LA WSZ CSO GIS Commission for Energy Regulation Department of Environment, Community and Local Government Environmental Protection Agency Health Service Executive Local Authority Water Supply Zone Central Statistics Office Geographical Information System Glossary Abstraction Discharge Drinking Water Regulations European Directive Groundwater Network Plumbosolvency Raw Water Water Supply Zone The removal of water from a river, lake or groundwater usually with the use of a pump. Treated effluent from a wastewater treatment plant which is returned to the water environment. This is usually from a pipe and outflow structure into a river or the sea. European Union (Drinking Water) Regulations S.I. No. 122 of A legal act of the European Union which requires member states to achieve a particular result. Examples are the Drinking Water Directive, Urban Wastewater Treatment Directive and the Water Framework Directive. Water located beneath the ground surface in soil and rock pore spaces and fractures within rock formations. The interconnection of pipes and pumping stations used for the distribution of treated water and the collection of wastewater. The ability of water to dissolve lead into water supplies from lead pipes. Water abstracted for drinking water purposes before treatment. The area supplied by an individual water supply scheme. This typically includes one or more abstractions (from a river, lake or groundwater), a treatment plant, storage in reservoirs and the distribution pipe network to deliver the water to each household or business. 27 Lead in Drinking Water Mitigation Plan - Issues Paper