water research 43 (2009) 26472656

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Computational modelling to investigate the sampling of lead

in drinking water
Colin R. Hayes*
School of Engineering, University of Wales Swansea, Singleton Park, Swansea SA2 8PP, United Kingdom

article info

abstract

Article history:

The monitoring of lead in drinking water is beset by difficulties relating to the inherent

Received 13 October 2008

temporal variation of lead emissions at individual premises. Such difficulties are com-

Received in revised form

pounded by spatial variation when considering an entire water supply area (e.g., City or

18 February 2009

Town), which is necessary to determine compliance with regulatory standards and to judge

Accepted 16 March 2009

the efficacy of corrective measures. A computational modelling system, that uses a Monte

Published online 24 March 2009

Carlo probabilistic framework for simulating lead emissions within a water supply area,
has been successfully validated in a range of UK case studies and enabled corrective

Keywords:

treatment measures to be optimised for a range of water types. This modelling system

Lead

includes the simulation of a range of sampling methods, and has made it possible to

Drinking water

undertake an exhaustive comparison between daily average lead emissions (DAC which

Plumbosolvency

are equivalent to weekly average lead concentrations as a consequence of the modelling

Sampling

system used), random daytime sampling (RDT), 30 min stagnation sampling (30MS) and 6 h

Computational modelling

stagnation sampling (6HS). It is concluded that: (a) the stringency of UK and US compliance
assessment methods for lead in drinking water is fairly similar for waters of reduced
plumbosolvency, despite different sampling approaches; (b) RDT sampling is equivalent to
random DAC for waters of moderate plumbosolvency; (c) RDT sampling is more stringent
than random DAC for waters of low plumbosolvency; (d) all random sampling methods
suffer from poor reproducibility, albeit less so for low plumbosolvency water; and (e) fixed
point stagnation sampling may not be representative.
2009 Published by Elsevier Ltd.

1.

Introduction

In the United Kingdom (UK) prior to the mid-1970s, lead in

drinking water was not perceived to be a problem, except for
cities like Glasgow where extensive use of lead piping and lead
lined roof tanks were used to convey slightly acidic upland
water supplies. In consequence, few water authorities bothered to test for lead, and commonly, sampling at consumers
taps was not practised. In this era, sampling problems with
lead in drinking water were not an issue.

* Tel.: 44 (0)1792 602257.

E-mail address: c.r.hayes@swansea.ac.uk
0043-1354/$ see front matter 2009 Published by Elsevier Ltd.
doi:10.1016/j.watres.2009.03.023

Following a UK-wide survey (Department of Environment,

1977) for lead in drinking water in the mid-1970s, the more
widespread occurrence of high lead concentrations was
realised, including high alkalinity groundwater supply areas (at
this time high lead was taken to mean >100 mg/l, following the
then World Health Organization guidelines). Three major lead in
drinking water assessment exercises then followed in the UK:
[1] In the late 1970s and early 1980s, water authorities were
required (Department of Environment, 1980) to undertake

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water research 43 (2009) 26472656

a representative number of supply area assessments, based

on random daytime sampling and the use of statistical
look-up tables for determining probability of compliance, to
identify which areas were in need of possible corrective
action. The monitoring protocol did not specify the period
of time over which the sampling was to be undertaken
and consequently many surveys were carried out during
the winter months. Also, some water authorities only
carried out limited numbers of surveys, believing that
a small number of supply types would be representative
(such as ground and surface derived supply examples).
With hindsight, it is certain that plumbosolvency problems
were under-estimated, and only limited corrective treatment actions were taken (mostly pH elevation of low
alkalinity waters).
[2] In the late 1980s and early 1990s, water companies in
England and Wales were required (Department of Environment, 1989) to undertake surveys of their water supply
areas, to determine compliance with the lead standard of
50 mg/l, that had been promulgated to implement the first
of the European drinking water directives (European
Commission, 1980). Again, random daytime samples were
taken, but the definition of the word random was
ambiguous in the guidance. Most water companies
surveyed randomly throughout their water supply areas,
whereas a minority surveyed randomly but only from
houses believed to be supplied by lead pipe-work. The
latter had been intended, as confirmed by later Government reports (Drinking Water Inspectorate, 1996). Not
surprisingly a much greater proportion of water supply
areas were found to be in need of corrective action by those
water companies who had adopted this approach, because
the former approach is less stringent as houses without
lead pipe-work are included. In overall consequence,
dosing of ortho-phosphate corrosion inhibitor was initiated for around 25% of UK water supplies.
[3] In 1998, the UK Government decided (Drinking Water
Inspectorate, 1998) to seek compliance with the updated
European lead standards of 25 mg/l and 10 mg/l (legal
requirements from December 2003 and December 2013,
respectively) by a treatment based strategy that would
minimise the replacement of lead pipe-work. Guidance
was circulated by the Drinking Water Inspectorate in
2000 and 2001 (Drinking Water Inspectorate, 2000, 2001)
in which water companies were required to develop
a strategy that included monitoring to demonstrate that
the treatment measures had been successful (or otherwise). This guidance made reference to both random
daytime sampling and to the use of fixed point sampling at
houses and/or lead pipe test rigs, but was not prescriptive.
In over-all consequence, over 95% of UK water supplies are
now dosed with ortho-phosphate, the remaining issue
being the extent to which such dosing has been optimised.
Looking more broadly at the rest of the European Union,
the second drinking water directive (European Commission,
1998) has an acknowledged problem (Hulsmann and Cortvriend, 2006) concerning the sampling of lead, copper and
nickel at points of consumer use. In Annex 1, Part B, Note 3,
this directive states that the parametric value for lead, copper

and nickel applies to a sample of water intended for human

consumption obtained by an adequate sampling method at
the tap and taken so as to be representative of a weekly
average value ingested by consumers. It is not disputed that
the standards for these metals apply at points of consumer
use, but what is disputed is how the samples should be taken.
Where sampling for lead is being undertaken, it was clear
from a recent European Research Workshop (Cost Action 637,
2007) that a wide range of approaches are in use, some
of which will either miss or underestimate the concentrations
of lead at the consumers taps.
In the United States (US), a more detailed prescriptive
approach (US Environmental Protection Agency, 1995) has
been in place since 1990, the Lead and Copper Rule (LCR). The
LCR requires prescribed numbers (dependent on the population involved) of fixed monitoring points to be selected and
their periodic survey. Compliance with the 15 mg/l standard for
lead is based on the 90th percentile concentration of the
samples taken in each survey. Where the standard is
breached, corrective measures are required. In Canada, the
Health Ministry has recently published (Health Canada, 2007)
a consultation paper that proposes the implementation of
a more detailed regulatory regime for lead in drinking water,
largely based on the US LCR.
It can be readily concluded from the above that there is no
global consensus on how to monitor lead in drinking water,
and that the history of tackling the lead problem has been
hindered by sampling and surveying difficulties. A study in
Europe in the late 1990s (Van den Hoven et al., 1999) endeavoured to determine how best to sample for lead in drinking
water, but this was necessarily limited to a fairly small number
of samples because of logistic and cost constraints. Since this
study was reported, a computational modelling system has
been developed (Van der Leer et al., 2002) for predicting the
emissions of lead into drinking water across entire water
supply areas, and validated by numerous case studies, of
which several have been published (Hayes et al., 2006, 2008).
This modelling system includes the simulation of a range
of sampling methods, and has made it possible to undertake
an exhaustive comparison between composite sampling
(COMP) as used to determine weekly average lead emission
concentrations (in the model, COMP is equivalent to the
calculated daily average lead emission concentration DAC),
random daytime sampling (RDT), 30 min stagnation sampling
(30MS) and 6 h stagnation sampling (6HS). The results provide
a deeper insight into the behavioural characteristics of the
sampling methods and are summarised in this paper.

2.

The computational modelling procedure

The models, which are described in more detail elsewhere

(Van der Leer et al., 2002), enable the most relevant features of
a water supply zone to be incorporated in the prediction of
zonal compliance with lead standards, as a function of both
plumbosolvency (corrosivity of the water to lead) and the
zones physical characteristics. A zonal model simulates the
emissions of lead at individual simulated houses, through
time, across an entire water supply zone or area of supply. It
uses a single pipe model to determine the lead emission

water research 43 (2009) 26472656

profile at each simulated house, the characteristics of each

simulated house being the outcome of the random ascription
of variables, which follows the Monte Carlo method for
establishing a probabilistic framework.
The single pipe model simulates the dissolution of lead
into the water flowing through or stagnating in a coupled lead
pipe and non-lead pipe, over a 24-hour period. The coupled
pipes are broken down into a series of elements and when
assuming simple plug flow, each element is treated as a stirred tank, flow being simulated by passing the contents of each
stirred tank to the next at a time interval of one second. The
rate of lead dissolution is determined by reference to an
exponential curve that declines towards equilibrium, as
illustrated in Fig. 1.
As M (the initial mass transfer rate which determines the
initial slope of the dissolution curve) and E (the equilibrium
concentration) reduce, the water is less plumbosolvent
(less lead dissolves: curves AC) and these factors can be
determined by stagnation sampling at appropriate reference
houses or by laboratory plumbosolvency testing. Curves A1 and
A2 in Fig. 1 relate to different dissolution characteristics. The
exponential curve and the assumption of plug flow are both
approximations, but they enable the computational demands
of the model to be greatly reduced. Extensive research (Hayes,
2002; Van der Leer et al., 2002) has demonstrated that these
approximations are adequate when compared to the more
scientifically exact diffusion model and the three dimensional
simulation of turbulent flow. The governing mathematical
equations, that under-pin these modelling options, are
described in Van der Leer et al., 2002.
As a guide, a moderately plumbosolvent water (e.g., a high
alkalinity groundwater that has not been phosphated, or a low
alkalinity water that has been pH adjusted to 8.08.5 but not
phosphate dosed) will often be described by M 0.1 and
E 150. For 12 mm internal diameter lead pipes, the equilibrium concentration (E ) is predicted (Hayes, 2002) to occur after
about 8 h water stagnation, consistent with the observations
and predictions of others (Kuch and Wagner, 1983).
When the imaginary tap is closed (that is, zero flow), the
lead concentration increases over time as determined by M
and E. When the imaginary tap is open, the concentration of
lead in the emission from the pipe is either (i) a reflection of
the steady state flushed condition (with lead concentrations

Fig. 1 The dissolution of lead through time, under zero

flow conditions.

2649

normally below 1 mg/l unless the lead pipe is very long) or (ii) it
is determined by previous zero flow (stagnation) conditions,
as influenced by pipe geometry and the extent of the flow
event. It can be appreciated that the simulation of such events
in each stirred tank for every second of flow leads to millions
of calculations being performed for each simulated pipe.
Particulate lead is not simulated because the influencing
factors are highly variable and would be difficult to define.
Such factors would include the physical condition of lead
corrosion deposits and their fragility, fluctuations in water
flow and scouring effects, and the extent of loose iron corrosion deposits at any time or location. In the UK context, it has
not been found necessary to include particulate lead, as
demonstrated by case studies (Hayes et al., 2006, 2008) and
this is probably a reflection of the major reductions in iron
discolouration problems since the early 1990s following
extensive replacement or refurbishment of old cast iron water
mains. In circumstances where iron discolouration is significant, an adjustment would need to be made to the modelling
procedure reported here. This could be achieved empirically
by adjusting M and E.
The zonal model is set up by the random ascription of
a series of zonal characteristics, as derived from sets of agreed
statistical distributions, and by the use of agreed variables and
constants. The statistical distributions used in this study are
shown in Fig. 2 and have been used successfully in many
zonal modelling studies on the basis of the validation achieved with field data (e.g. Hayes et al., 2008). Where pipe-work
and residency surveys have been undertaken (Hayes et al.,
2006) the observed departures from the standard statistical
distributions were only minor. The standard distributions
have the following features:
 the length of lead and non-lead pipes have a log-normal
distribution, consistent with longer lengths occurring less
frequently;
 for the lead pipes, 95% are assumed to have an internal
diameter of 12 mm and 5% 18 mm, as relates to UK
conditions;
 the volume used per day relates to an individual simulated
house, the mean volume equating to the average water
consumption of a house in the UK and assumed to flow
through the simulated pipes;
 pattern A describes water usage in a house in which there is
residency throughout the hours when water is consumed
(not during the night when residents are asleep);
 pattern B describes water usage in a house in which all
residents are absent during office hours when no water is
used;
 patterns A and B are applied for three and two water use
frequencies respectively, such that the weighting of A to B is
3 to 2, albeit with the water use frequencies within the two
categories having an equal weighting.
Changes in any of these assumptions can be readily made,
for example: in response to a reduction in water consumption
following a programme of compulsory metering, all that
would be necessary would be to amend the computer file that
holds the assumed distribution of water consumptions and is
used in establishing the probabilistic framework. However,

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water research 43 (2009) 26472656

Volume per day

Length of non-lead pipe

25

20

20

20

15

15

15

25

Length of lead pipe

25

10

10

10

5
0

0
5

20 35 50 65 80 95

10

Length (m)

20

200 400 600 800

Volume (l)

Length (m)
Water use pattern A

Water use pattern B

16

25

Hour
Frequencies

12

20

10

15

14

8
6

Hour
Frequencies

10

2
0

0
1

7 10 13 16 19 22

hour

7 10 13 16 19 22

hour

Fig. 2 Statistical distributions used to set up the zonal model.

the work of Hayes (2002) has shown that changes to all variables, other than plumbosolvency (M and E ) and the
percentage of houses with lead pipes, have to be substantial to
have an effect on the models results.
The aim of this probabilistic Monte Carlo framework is to
describe the huge variation that undoubtedly occurs in real
water supply zones. If we can mimic this real-world variation
then the model can be used for predictive purposes, as has been
demonstrated by case studies (Hayes et al., 2006, 2008). It should
be appreciated that the average lead concentrations predicted
by the model relate to a single plumbosolvency condition
occurring in time, whether it is applied as a constant throughout
an area or as a range. In consequence, the predicted results
relate to an average condition over time. This is reasonable if the
periods of time under consideration extend to multiples of
a year, such that seasonal variation is accommodated.
The zonal model calculates the daily average concentration
(DAC) of the lead emissions for each simulated house and from
this can readily determine the percentage of simulated houses
that fail a series of specified standards (typically: 10, 25 and
50 mg/l). As the zonal model uses a range of water use patterns
(Fig. 2) that also span week-day and week-end consumptions,
the DAC is taken to be equivalent to the weekly average
concentration, and is therefore also equivalent to composite
sampling over a weekly period (COMP) as was used by Van den
Hoven et al., 1999. This is of interest as the EU directive (European Commission, 1998) describes the lead standards in terms
of weekly average lead concentrations ingested.
It is of course not possible to validate these DAC outputs
directly without exhaustive composite sampling (which is not
logistically feasible) and so a sampling model is used, in order
to characterise the behaviour of the simulated zone in a way
that can be validated by the data collected by water

companies. Random daytime (RDT) sampling is of greatest

relevance in the UK, as it has been used for regulatory
purposes for many years (UK Government, 1989).
In order to simulate a RDT survey, the specified number of
simulated houses are selected at random and then a sampling
time is selected at random between the hours of 09-00 and
17-00. The RDT sample is simulated by a stirred tank of one
litre capacity as the outlet from the pipe. At the time of
simulated sampling, the pattern of water use that has been
applied to the simulated house is used to determine the
immediately previous water pipe contact position. It is
routine to repeat the simulated survey, typically 100 times, in
order to be able to understand possible variation. The result
reported for the zone under investigation is the average
survey result from all the surveys simulated, although confidence bands are also computed and can be used if required in
model validation. Examples of the validation of the zonal
modelling procedure are given in Table 1. It can also be noted
that the predicted zonal compliance for zones in Cambridge
and Wales (UK), following the optimisation of ortho-phosphate dosing (Hayes et al., 2006) has been achieved in practice.
Therefore, the modelling procedure has been validated for
both pre- and post-ortho-phosphate dosing conditions.
Stagnation sampling is also used to characterise lead emissions. In the UK, 30 min stagnation samples have been most
commonly used as a treatment benchmarking technique at
fixed points (Hayes et al., 1997) as opposed to surveying zones for
compliance. In the US, 6 h stagnation sampling of selected fixed
points is used for regulatory assessment. To simulate a stagnation sample, the lead concentration in the simulated pipe is first
assumed to be zero and then follows the applied dissolution
curve (Fig. 1) whereby the lead concentration after 30 min or 6 h
stagnation is determined in a 1 l emission volume.

water research 43 (2009) 26472656

Table 1 Validation examples: predicted and observed

zonal failure rates for RDT samples (from Hayes et al.,
2006, 2008).
Study and
basis

Number of
samples

Bristol
Observed
Predicted
Cambridge: zone
new 1
Observed
Predicted
Cambridge: zone
new 2
Observed
Predicted
Cambridge: zone
old 1
Observed
Predicted
Cambridge: zone
old 2
Observed
Predicted
South East Wales
Observed
Predicted

% >10
mg/l

% >25
mg/l

% >50 mg/l

259

46.9
35.0

27.3
22.9

9.7
9.6

145

8.2
7.4

3.0
2.0

0.0
0.2

130

10.0
8.7

0.8
2.4

0.0
0.2

525

32.4
28.4

15.0
15.1

4.5
5.2

292

9.8
11.1

4.5
5.0

2.0
1.4

509

21.8
18.4

11.8
11.3

4.5
4.8

The greatest uncertainty in the modelling procedure is the

estimate of the extent to which lead pipes are present in
a zone. In the UK Cambridge and Bristol studies (Hayes et al.,
2006) this was not a problem as the water companies had
inspected a large proportion of the houses in their area. In the
Wales study (Hayes et al., 2008) such survey data was not
available; however, the extensive RDT data over a period of
around five years, prior to the commencement of orthophosphate dosing, was assessed on the basis that if the
analytical result for lead was below the limit of detection, then
no lead pipe was present. This simple method was used for all
zones studied and enabled an estimate of the occurrence of
lead pipes to be gained; the fact that validation of the model,
calibrated in this way, was validated well by actual RDT
sample data indicates the adequacy of the approach.

3.

2651

depending on the size of the zone being modelled. In this

study a zone size of 10,000 houses was used throughout and
the reproducibility of DAC simulations for all houses in the
zone, when looking at percentage failure to a range of lead
standards, was found to be better than 1%. However, in the
sampling simulations that followed, a single set of zonal
conditions was first established and then used repeatedly,
thereby removing this slight variation when comparing
sampling methods.
The simulated sampling surveys were all based on taking
100 1 l samples, selected randomly from the simulated houses
within the zonal modelling framework and randomly in time
between 09-00 and 17-00 h, except for DAC which was calculated for the total period of water flow. For each condition
under investigation, the surveys were repeated 100 times, such
that results were in effect based on 10,000 simulated samples.
Four sampling methods were compared:
[1] daily composite to determine average concentration
(DAC), equivalent to (COMP);
[2] random daytime (RDT);
[3] 30 min stagnation (30MS); and
[4] 6 h stagnation (6HS).
Samples types [1] to [3] were summarised to determine
percentage zonal failure rates against three lead standards
(10, 25 and 50 mg/l) whereas sample type [4] followed the US
LCR in which the 90th percentile concentration in a survey
was calculated and compared to the lead standard of 15 mg/l.
These methods were compared throughout for five zonal
conditions in which the percentage of houses with a lead pipe
was varied, between 10 and 90%, and for two plumbosolvency
conditions: [1] M 0.1 and E 150, equivalent to a moderately
plumbosolvent water, and [2] M 0.02 and E 30, equivalent
to a phosphated water in which there has been an 80%
reduction in plumbosolvency (which Hayes et al., 2006, 2008
demonstrates is readily achievable in practice).
For a zone with 50% of houses with a lead pipe, a further
investigation examined the effect of varying the ratio between
the equilibrium and 30 min stagnation lead concentrations,
which relate to different shapes of the lead dissolution curve
through time. Laboratory plumbosolvency testing using the
method of Colling et al. (1987) has indicated (Hayes, 2007) that
this ratio can vary markedly, between 1.3 and 6.6 for phosphated waters and more widely for non-phosphated waters.

Methodology for investigating sampling

There are two stages in the zonal-sampling modelling procedure. Firstly, the zonal characteristics are assembled by
randomised ascription of the variables used. The statistical
distributions (Fig. 2) that control this process define percentages of each value to be applied in the modelling framework.
The simplified description of each variable in a look-up table
format is very flexible and easy to amend, as opposed to
defining mathematically the shape of a curve (which in the
development of the model was found to give similar results).
In combination, the ranges in variables that are used give rise
to around 3000 permutations of pipe characteristics within
each zonal model. Each time the zonal model is executed,
a particular set of permutations is created, which differ

4.

Results

4.1.
Comparison of DAC, RDT, 30MS and 6HS: moderate
plumbosolvency
The averaged results for five zones with varying percentages
of lead pipes and moderately plumbosolvent water conditions
are shown in Table 2. Percentage failure is clearly a function of
both the stringency of the lead standard and the percentage of
simulated houses which have a lead pipe (albeit of varying
length and diameter), for all four sampling methods. For the
lead standard of 10 mg/l, 30MS gives a slightly higher failure
rate than RDT and DAC. The range of zonal failure rates

2652

water research 43 (2009) 26472656

Table 2 A comparison between sampling methods for

moderate plumbosolvency water and different extents of
lead pipes.
(a) Predicted DAC, RDT and 30MS against European standards
Percentage Standard
DAC
RDT
30MS
of houses
for lead
Average % Average % Average %
with a lead
(mg/l)
samples
samples
samples
pipe
>standard >standard >standard
10

10
25
50

3.71
1.13
0.18

3.94
1.56
0.43

4.53
2.22
0.00

30

10
25
50

12.35
2.91
0.69

12.28
5.18
1.37

14.23
7.09
0.00

50

10
25
50

20.41
4.66
1.00

20.23
8.02
1.91

24.27
11.63
0.00

70

10
25
50

28.65
7.38
1.62

27.33
11.60
2.76

33.89
16.80
0.00

90

10
25
50

37.85
9.50
1.85

36.39
15.28
3.69

43.38
21.33
0.00

(b) Predicted 6HS against the US standard of 15 mg/l

Percentage of Average %
Average 90th
% Surveys
houses with
samples
percentile
failing the
a lead pipe
>standard concentration (mg/l) standard
10
30
50
70
90

6.00
19.69
33.64
47.50
60.95

0.23
58.84
84.98
104.34
115.94

1
99
100
100
100

The averaged results shown derive from 100 surveys each of

100 samples. All samples were selected randomly from the
zonal model. Moderate plumbosolvency was defined by M 0.1
and E 150.

against 10 mg/l from DAC correlate very closely with RDT

(r2 0.99) suggesting that the methods are equivalent for nonphosphated waters, in general agreement with Van den
Hoven et al. (1999). Equivalence between DAC and RDT is less
for the 25 and 50 mg/l standards, due to the smoothing effect of
DAC that becomes more significant for the higher standards;
this indicates that RDT is the more stringent method for
assessing regulatory compliance with 25 mg/l.
The UK Government required (Drinking Water Inspectorate, 2000, 2001) corrective treatment action to be taken and/
or optimised if more than 5% of RDT samples had exceeded
the future European standard for lead of 10 mg/l, and then
subsequently to achieve no more than 2% or better through
optimisation (there is a gap between the UKs trigger and
subsequent target). It can be seen from Table 2 that zones in
which 10% of houses have a lead pipe were unlikely to require
such attention.
The relationship between DAC and 30MS is however
suspect as illustrated by Fig. 3 in which all 10,000 DAC and
30MS results have been compared for a selected condition.

Two trends are discernable for a zone in which 50% simulated

houses have a lead pipe:
[1] There is a declining relationship between DAC and the
number of simulated houses, which is a reflection of the
permutations of lead pipe and water flow characteristics
(the chart shows zero lead after 5000 houses because only
50% of houses were ascribed as having a lead pipe); and
[2] the incremental behaviour of 30MS is due to dilution from
water in the non-lead pipe between the simulated lead
pipe and tap outlet (as dictated by the discretised distribution of non-lead pipe length shown in Fig. 2) and to
dilution from incoming water prior to the lead pipe when
its length equates to less than 1 l in volume for 12 mm
internal diameter lead piping greater than 8.8 m in length,
and assuming no non-lead pipe between the lead pipe and
the tap outlet, the 30MS results would be constant for any
given plumbosolvency condition.
The basis for assessing compliance with the LCR is
different. If the percentage of houses with a lead pipe is 10%,
the 90th percentile concentration is generally very low and
only 1 in 100 surveys failed the 15 mg/l standard, a similar
result to that based on RDT sampling vs 10 mg/l and the UKs
5% trigger for action. For higher percentages of lead (30% plus)
the 90th percentile increases in proportion to the percentage
of houses with lead pipes, but the LCR assessment is very
similar or the same.

4.2.
Comparison of DAC, RDT, 30MS and 6HS: low
plumbosolvency
The averaged results for five zones with varying percentages
of lead pipes and low plumbosolvent water conditions (80%
reduction compared to moderate plumbosolvency) are shown
in Table 3. For DAC and RDT, similar trends are discernable to
those observed for moderately plumbosolvent water, with
both failure rates increasing with higher percentages of
houses with a lead pipe.
The RDT failure rates are noticeably higher than those based
on DAC and this is of regulatory significance. In the current
debate in Europe on what sampling method to use to determine
compliance with the lead standards of 25 and 10 mg/l, if RDT
sampling was adopted as the harmonised method, it would not
only be more feasible logistically (Van den Hoven et al., 1999)
but more stringent, providing no less public health protection
than the manner in which the standards are described in the
directive (European Commission, 1998).
The UK Government has indicated (Drinking Water
Inspectorate, 2000, 2001) that one measure of optimisation of
corrective treatment is that no more than 2% of RDT samples
should exceed 10 mg/l. This means that in zones with a higher
percentage of houses with a lead pipe the plumbosolvency of
the water must be reduced more than that in a zone with
a lower percentage of lead pipes, for water of similar plumbosolvency prior to corrective treatment. Table 3 also reveals
that 30MS fails to distinguish the influence of the percentage
of lead pipes.
With the US LCR and 6HS sampling, the influence of the
percentage of houses with a lead pipe is significant. Zones

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water research 43 (2009) 26472656

140

120

100
30ms
dac
80

60

40

20

0
1

812

1623

2434

3245

4056

4867

5678

6489

7300

8111

8922

9733

Fig. 3 A comparison of 30MS and DAC for a zone with 50% lead pipes and moderate plumbosolvency water (M [ 0.1,
E [ 150). The Y-axis is the lead concentration in mg/l. The X-axis is the number of simulated houses in the zone that had the
particular lead concentration predicted, both on the basis of 30MS and DAC.

with 10 or 30% lead mostly satisfy the LCR, zones with 70 or

90% lead substantially or completely fail the LCR, whereas
zones with 50% are border-line.
In Table 4, a direct comparison of DAC, RDT and 6HS
sampling has been made in relation to the 10 and 15 mg/l
standards (as far as was possible using the model as developed) and it can be inferred that the UK optimisation target of
no more than 2% RDT samples exceeding 10 mg/l is broadly
equivalent to no more than 10% 6HS samples exceeding 15 mg/l
(assuming this equates to a 90th percentile concentration).
This suggests (at face value) that the UK and US approaches
provide a similar level of public health protection for
phosphated waters of low plumbosolvency.

4.3.
Influence of the ratio between equilibrium (E ) and
30MS lead concentrations
30MS samples have been considered (Lacey and Jolly, 1986) to
be a reasonable measure of the average lead concentration
emitted from a lead pipe, in consideration of the water
consumption patterns that are encountered in various types
of domestic household in the UK. It is also reasonable to
suppose the higher the equilibrium lead concentration (E ), the
greater will be the chance of obtaining a failure. This supposition is borne out in Tables 5 and 6 for both moderate and low
plumbosolvent water:
 for a single pipe and moderate plumbosolvency water, with
M 0.1 kept constant, the predicted 30MS lead concentration increases as the ratio of E/30MS increases; a similar
effect is observed with low plumbosolvency water with
M 0.02;

 for a zone in which 50% houses have a lead pipe, the

percentage of predicted compliance samples failing their
respective standards increases as the equilibrium concentration increases when M is kept constant.
Differences between DAC and RDT are again of potential
regulatory significance for low plumbosolvent waters. The
influence on LCR compliance is also significant.
The phenomenon is illustrated in Fig. 1 by comparing curve
A1 with curve A2 and indicates that the relationship between
RDT and stagnation sampling can vary. That such variation in
E/30MS does occur has been shown by plumbosolvency
testing (Hayes, 2007). In consequence it is not possible to
utilise stagnation sampling to determine compliance with
lead standards unless the relationship with RDT sampling has
been characterised. In this context, RDT sampling is the only
method that can determine the spatial and temporal extent of
lead compliance across a zone (that is also logistically
feasible), given enough samples are taken.

4.4.

RDT re-sampling

The RDT sampling model also determines the result of

a second RDT sample from each simulated house where a RDT
sample in a survey exceeds specified standards for lead. The
second simulated sample is taken randomly in time within
the same time period (09001700 h) as for the first RDT sample,
at the same simulated house. For zones with a range of 1090%
houses with a lead pipe, the average re-sampling failure rates
vs 10 mg/l were found to be between 61.4 and 64.7% for
moderate plumbosolvency and between 38.9 and 51.3% for

2654

water research 43 (2009) 26472656

Table 3 A comparison between sampling methods for

low plumbosolvency water and different extents of lead
pipes.

Table 4 Direct comparison of DAC and RDT with 6HS

against standards of 10 and 15 mg/l for low
plumbosolvency water.

(a) Predicted DAC, RDT and 30MS against European standards

Sampling method Average % samples Average % samples

Percentage Standard
DAC
RDT
30MS
of houses
for lead
Average % Average % Average %
with a lead
(mg/l)
samples
samples
samples
pipe
>standard >standard >standard
10

10
25
50

0.18
0.00
0.00

0.41
0.02
0.00

0.00
0.00
0.00

30

10
25
50

0.75
0.00
0.00

1.34
0.01
0.00

0.00
0.00
0.00

50

10
25
50

0.86
0.01
0.00

1.93
0.04
0.00

0.00
0.00
0.00

70

10
25
50

1.54
0.01
0.00

2.96
0.04
0.00

0.00
0.00
0.00

90

10
25
50

1.79
0.00
0.00

3.47
0.01
0.00

0.00
0.00
0.00

(b) Predicted 6HS against the US standard of 15 mg/l

Percentage
of houses
with a lead
pipe
10
30
50
70
90

Average %
samples
>standard
2.80
6.41
11.76
16.44
21.80

Average 90th % Surveys

percentile
failing the
concentration standard
(mg/l)
0.53
11.83
17.08
20.98
22.28

0
5
62
98
100

The averaged results shown derive from 100 surveys each of 100
samples. All samples were selected randomly from the zonal
model. Low plumbosolvency was defined by M 0.02 and E 30.

low plumbosolvency conditions. It is clear that RDT resampling is not able to reliably confirm an initial RDT failure.

4.5.

Quantification of the variation inherent in sampling

In each simulated sampling survey, 100 samples were taken

randomly from throughout the zonal probabilistic framework
and randomly in time between 09-00 and 17-00 h, for all
sampling methods investigated with the exception of DAC
which is calculated from the lead concentrations throughout
the daily pattern of use (Fig. 2). With approximately 3000
permutations across 10,000 simulated houses, it is not
surprising that each survey can give different results, purely
by chance. To illustrate: (a) for a zone in which 50% houses
had a lead pipe and with moderate plumbosolvency water
(M 0.1 and E 150), the average percentage of RDT sample
exceeding 10 mg/l was 20.23% (Table 2) but with a minimum
of 12% and a maximum of 30% (standard deviation 3.81);
(b) for a zone in which 50% houses had a lead pipe and
with low plumbosolvency water (M 0.02 and E 30), the

DAC
RDT
6HS

>10 mg/l

>15 mg/l

0.84
1.91
N/A

0.30
0.51
11.76

N/A not available from model. The averaged results shown derive
from 100 surveys each of 100 samples for a zone with 50% houses
with a lead pipe. All samples were selected randomly from the
zonal model (additional simulations to those summarised in Table
3). Low plumbosolvency was defined by M 0.02 and E 30. The UK
optimisation target for plumbosolvency control is that no more
than 2% RDT samples exceed 10 mg/l, whereas the US target for LCR
compliance is that no more than 10% 6HS samples exceed 15 mg/l
(assuming equivalence to the 90th percentile concentration).

average percentage of RDT sample exceeding 10 mg/l was

1.93% (Table 3) but with a minimum of 0% and a maximum of
7% (standard deviation 1.49).
With moderately plumbosolvent water (M 0.1 and E 150)
the significance of the variation in survey results depends on
the numeric relationship between the lead emissions occurring in the zone and the water quality standard that applies.
The UK trigger for action (Drinking Water Inspectorate, 2000,
2001) of no more than 5% of RDT samples exceeding 10 mg/l is so
stringent in relation to moderately plumbosolvent water that
the inherent variation in survey results has little practical
significance. However, the close numerical relationship
between the UK optimisation target (no more than 2% RDT
samples exceeding 10 mg/l) and the results predicted for low
plumbosolvency water (M 0.02 and E 150) could have
practical and regulatory significance. For the simulation
reported in (b) above 71% of surveys had either a 0, 1 or 2%
failure rate, whereas 29% had a failure rate of 3% or greater.
For random 6HS sampling a similar pattern of variation
was obtained (see Table 3) and for low plumbosolvency water
and a zone with 50% of houses with lead piping, 62% of
surveys failed the US LCR and 38% of surveys passed.

Table 5 Effect of equilibrium concentration on the

predicted 30MS result for a single lead pipe.
(a) Moderate plumbosolvency (M 0.1)
Equilibrium (E ) lead
concentration (mg/l)

30MS lead
concentration (mg/l)

75
150
225
300
(b) Low plumbosolvency (M 0.02)
15
30
45
60

Ratio E/30MS

41.4
49.6
52.8
54.5

1.8
3.0
4.3
5.5

8.3
9.9
10.6
10.9

1.8
3.0
4.2
5.5

The results were obtained with a single lead pipe of 20 m length and
12 mm internal diameter, with no non-lead pipe.

2655

water research 43 (2009) 26472656

Table 6 Effect of equilibrium lead concentration on predicted compliance with zonal targets.
(a) Moderate plumbosolvency (M 0.1)
Equilibrium concentration
(mg/l)

75
150
225
300
(b) Low plumbosolvency (M 0.02)
15
30
45
60

Average %
DAC

Average %
RDT

Average %
6HS

Average 90th percentile

concentration

% 6HS surveys
failing

>10 mg/l

>10 mg/l

>15 mg/l

17.10
20.41
21.94
24.20

19.44
20.23
20.48
21.07

24.48
33.64
34.75
33.94

43.04
84.98
129.90
158.70

100
100
100
100

0.14
0.86
1.19
1.48

0.79
1.93
2.60
3.07

0.00
11.76
23.70
23.63

8.87
17.08
25.67
30.94

0
62
100
100

The averaged results shown derive from a simulated zone in which 50% houses have a lead pipe and from 100 surveys each of 100 samples. All
samples were selected randomly from the zonal model.

Although the real-world surveys undertaken to assess

compliance with the LCR are from selected properties that are
surveyed on a repeated basis, the simulations indicate the
sensitivity of property selection and the possibility for bias
which could in turn effect the extent of corrective action
perceived to be necessary.
Following optimisation of ortho-phosphate treatment to
reduce plumbosolvency in Cambridge and in Wales (Hayes et al.,
2006, 2008), the extent of real-world RDT samples complying
with the lead standard of 10 mg/l was 99.5% (>1000 samples) and
99% (>5000 samples) respectively, based on field sampling over
several years. The general consistency of these field data related
to percentage reductions in plumbosolvency that were better
than 80% in many cases, and suggests that potential sampling
error can be minimal when corrective treatment is optimised.
For supplies in which 80% reduction or less is being achieved, the
practical significance of sampling error will be greater.
An additional simulation that assumed 50% of houses with
a lead pipe and a 90% reduction in plumbosolvency (M 0.01
and E 15) obtained an average of 0.12% RDT samples >10 mg/l,
with a range of 01% and a standard deviation of 0.32%. As this
entire range is well below the 2% target, the variation is shown
to have no bearing on the conclusion made, when such a high
plumbosolvency reduction has been achieved.

5.

Conclusions

The successful validation of a modelling system that predicts

lead emissions across entire water supply zones enables
a searching examination of sampling methods to be undertaken, far more exhaustively than could be achieved by field
sampling.
For water with moderate plumbosovency, DAC and RDT
sampling are equivalent methods for zonal assessment
against the standard of 10 mg/l. For water with low plumbosolvency, RDT sampling is more stringent than DAC for this
standard.
In consequence, RDT sampling could be used to determine
compliance with the regulatory lead standards in Europe,
without diminishing the level of public health protection that

would be afforded by DAC/COMP. The use of RDT sampling for

assessing compliance with lead standards in the UK since
1989 is clearly vindicated.
30MS sampling is not appropriate for zonal assessment as
a survey tool because it suffers from dilution artefacts.
All randomly based sampling methods produce inherently
variable results, albeit reproducibility is better for waters with
a low plumbosolvency.
For waters with a very low plumbosolvency (assuming that
corrective treatment has been optimised to achieve plumbosolvency reductions of 90%) the inherent variation in RDT
sampling results has been shown to be of little or no practical
significance in relation to demonstrating the achievement of
the UK target (that no more than 2% RDT samples should
exceed 10 mg/l).
Fixed point stagnation sampling to assess zonal compliance,
as practised in the US, is prone to bias, as demonstrated by the
range in results obtained between randomly selected sampling
points for certain zonal conditions.
Whereas the UK target for optimising plumbosolvency
control is that no more than 2% of RDT samples should exceed
10 mg/l and the US target for compliance is that no more than
10% of 6HS samples should exceed 15 mg/l, the two approaches
have been shown to afford fairly similar levels of public health
protection, for phosphated waters achieving 80% lead
reductions.
Compliance with lead standards is influenced by the shape
of the lead dissolution curve, which is known to vary with
individual waters, such that a higher ratio of equilibrium
concentration to 30MS concentration will result in greater
extents of failure. Therefore, 30MS sampling at selected fixed
points alone may not be suitable for characterising zonal
compliance.

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