Drinking Water
Safeguarding the District of Columbia's Supplies and Applying Lessons Learned to Other Systems Gao ID: GAO-04-974T July 22, 2004Concerns have been raised about lead in District of Columbia drinking water and how those charged with ensuring the safety of this water have carried out their responsibilities. The 1991 Lead and Copper Rule (LCR) requires water systems to protect drinking water from lead by, among other things, chemically treating it to reduce its corrosiveness and by monitoring tap water samples for evidence of lead corrosion. If enough samples show corrosion, water systems officials are required to notify and educate the public on lead health risks and undertake additional efforts. The Washington Aqueduct, owned and operated by the U.S. Army Corps of Engineers, treats and sells water to the District of Columbia Water and Sewer Authority (WASA), which delivers water to D.C. residents. EPA's Philadelphia Office is charged with overseeing these agencies. GAO is examining (1) the current structure and level of coordination among key government entities that implement the Safe Drinking Water Act's regulations for lead in the District of Columbia, (2) how other drinking water systems conducted public notification and outreach, (3) the availability of data necessary to determine which adult and child populations are at greatest risk of exposure to elevated lead levels, and what information WASA is gathering to help track their health, and (4) the state of research on the health effects of lead exposure. The testimony discusses preliminary results of GAO's work. GAO will report in full at a later date.
This statement discusses GAO's preliminary observations and highlights areas of further examination. One of the key relationships in the effort to ensure the safety of the District's drinking water is the one between WASA, the deliverer of water, and EPA's Philadelphia Office, which oversees WASA's compliance with drinking water regulations. Recent public statements and corrective actions by these parties clearly indicate that coordination and communication between them could have been better in the years preceding the current lead controversy. GAO's future work will examine (to the extent appropriate) the interrelationships among other key agencies (such as the Aqueduct and the D.C. Department of Health); how other water systems in similar situations interacted with federal, state, and local agencies; and what the experiences of these other jurisdictions may suggest concerning how improved coordination can better protect drinking water in the District of Columbia. Other water systems facing elevated lead levels used public notification and education practices that may offer lessons for conducting outreach to water customers. For example, some of the practices of the two water systems we have begun to examine--the Massachusetts Water Resources Authority and the Portland (Oregon) Water Bureau--include tailoring their communications to varied audiences in their service areas, testing the effectiveness of their communication materials, and linking demographic and infrastructure data to identify populations at greatest risk from lead in drinking water. WASA faces challenges in collecting the information needed to identify District citizens at greatest risk from lead in drinking water. Specifically, WASA has partial information on which of its customers have lead service lines, and is in the process of obtaining more complete information. GAO's future work will examine the efforts of other water systems to go one step further by linking data on at-risk populations (such as pregnant mothers, infants, and small children) with data on homes suspected of being served by lead service pipes and other plumbing fixtures that may leach lead into drinking water. Nationally, much is known about the hazards of lead once in the body and how lead from paint, soil, and dust enter the body, but little research has been done to determine actual lead exposure from drinking water, and the information that does exist is dated. In our future work, we will examine the plans of EPA and other organizations to fill this key information gap.
GAO-04-974T, Drinking Water: Safeguarding the District of Columbia's Supplies and Applying Lessons Learned to Other Systems
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Testimony:
Before the Subcommittee on Environment and Hazardous Materials,
Committee on Energy and Commerce, House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery Expected at 9: 30 a.m. DST:
Thursday, July 22, 2004:
Drinking Water:
Safeguarding the District of Columbia's Supplies and Applying Lessons
Learned to Other Systems:
Statement of John B. Stephenson, Director, Natural Resources and
Environment:
GAO-04-974T:
GAO Highlights:
Highlights of GAO-04-974T, a statement to the Subcommittee on
Environment and Hazardous Materials, Committee on Energy and Commerce,
House of Representatives
Why GAO Did This Study:
Concerns have been raised about lead in District of Columbia drinking
water and how those charged with ensuring the safety of this water have
carried out their responsibilities. The 1991 Lead and Copper Rule
(LCR) requires water systems to protect drinking water from lead by,
among other things, chemically treating it to reduce its corrosiveness
and by monitoring tap water samples for evidence of lead corrosion. If
enough samples show corrosion, water systems officials are required to
notify and educate the public on lead health risks and undertake
additional efforts. The Washington Aqueduct, owned and operated by the
U.S. Army Corps of Engineers, treats and sells water to the District of
Columbia Water and Sewer Authority (WASA), which delivers water to D.C.
residents. EPA‘s Philadelphia Office is charged with overseeing these
agencies.
GAO is examining (1) the current structure and level of coordination
among key government entities that implement the Safe Drinking Water
Act‘s regulations for lead in the District of Columbia, (2) how other
drinking water systems conducted public notification and outreach, (3)
the availability of data necessary to determine which adult and child
populations are at greatest risk of exposure to elevated lead levels,
and what information WASA is gathering to help track their health, and
(4) the state of research on the health effects of lead exposure.
The testimony discusses preliminary results of GAO‘s work. GAO will
report in full at a later date.
What GAO Found:
This statement discusses GAO‘s preliminary observations and highlights
areas of further examination.
One of the key relationships in the effort to ensure the safety of the
District‘s drinking water is the one between WASA, the deliverer of
water, and EPA‘s Philadelphia Office, which oversees WASA‘s compliance
with drinking water regulations. Recent public statements and
corrective actions by these parties clearly indicate that coordination
and communication between them could have been better in the years
preceding the current lead controversy. GAO‘s future work will examine
(to the extent appropriate) the interrelationships among other key
agencies (such as the Aqueduct and the D.C. Department of Health); how
other water systems in similar situations interacted with federal,
state, and local agencies; and what the experiences of these other
jurisdictions may suggest concerning how improved coordination can
better protect drinking water in the District of Columbia.
Other water systems facing elevated lead levels used public
notification and education practices that may offer lessons for
conducting outreach to water customers. For example, some of the
practices of the two water systems we have begun to examine – the
Massachusetts Water Resources Authority and the Portland (Oregon) Water
Bureau – include tailoring their communications to varied audiences in
their service areas, testing the effectiveness of their communication
materials, and linking demographic and infrastructure data to identify
populations at greatest risk from lead in drinking water.
WASA faces challenges in collecting the information needed to identify
District citizens at greatest risk from lead in drinking water.
Specifically, WASA has partial information on which of its customers
have lead service lines, and is in the process of obtaining more
complete information. GAO‘s future work will examine the efforts of
other water systems to go one step further by linking data on at-risk
populations (such as pregnant mothers, infants, and small children)
with data on homes suspected of being served by lead service pipes and
other plumbing fixtures that may leach lead into drinking water.
Nationally, much is known about the hazards of lead once in the body
and how lead from paint, soil, and dust enter the body, but little
research has been done to determine actual lead exposure from drinking
water, and the information that does exist is dated. In our future
work, we will examine the plans of EPA and other organizations to fill
this key information gap.
www.gao.gov/cgi-bin/getrpt?GAO-04-974T.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact John Stephenson at
(202) 512-3841 or stephensonj@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
Thank you for the opportunity to discuss our work to date on the issues
surrounding elevated levels of lead in Washington, D.C. drinking water.
At the request of this Subcommittee, we are examining issues concerning
lead in drinking water generally and the situation in Washington, D.C.,
in particular. Our testimony today lays out our preliminary
observations on these issues and highlights areas of further
examination.
Although rarely the sole cause of lead poisoning, lead in drinking
water can significantly increase a person's total lead exposure. EPA
estimates that drinking water is the source of about 20 percent of
Americans' lead exposure, but that it may be as high as 60 percent for
infants who drink baby formulas and concentrated juices that are mixed
with water. Adults who drink water with high lead concentrations could
develop kidney problems or high blood pressure. Developing fetuses,
infants and young children are more vulnerable to lead from all
sources, including drinking water. Their exposure to lead may delay
their physical or mental development.
The delivery of safe water to residents requires that water systems and
regulators work cooperatively in fulfilling the requirements of the
Safe Drinking Water Act.[Footnote 1] In most cases, states have primary
oversight and enforcement authority under the Act. Lead in drinking
water is regulated under the Act's 1991 Lead and Copper Rule.[Footnote
2] The rule requires water systems to treat their water to limit its
corrosiveness, monitor tap water samples for evidence of elevated
levels of lead, and report this information to their state. In
addition, drinking water systems may consult with state health agencies
when communicating with their customers about health risks from
drinking water.
The relationship between regulators and water systems is more
complicated in the District of Columbia, where the Washington Aqueduct,
owned by the U.S. Army Corps of Engineers, draws and treats water from
the Potomac River. The Aqueduct sells the treated water to the District
of Columbia Water and Sewer Authority (WASA), which distributes it to
District residents. The Environmental Protection Agency's (EPA)
Region III Office in Philadelphia, Pennsylvania, has primary oversight
and enforcement authority for the District's public water systems. The
District of Columbia's Department of Health, while having no formal
role under the Safe Drinking Water Act, is responsible for educating
District residents on potential health risks.
In the District, the Washington Aqueduct treats drinking water and
monitors for most contaminants, while WASA monitors tap water samples
for lead and reports these results to EPA's Philadelphia Office. Tap
water monitoring is important because, unlike most drinking water
contaminants, lead is not generally introduced to drinking water
supplies from source water. Rather, lead leaches into drinking water as
it travels through lead service pipes, over pipe joints connected with
lead-based solder, and through brass plumbing fixtures that contain
lead. According to EPA, its Philadelphia Office is responsible for
providing technical assistance to the Aqueduct and WASA on how to
comply with federal regulations; ensuring that they report the
monitoring results to EPA by required deadlines; taking enforcement
actions if violations occur; and using those enforcement actions to
return the water systems to compliance in a timely fashion.
Significant concerns were raised in early 2004 about how federal and
local agencies were carrying out their responsibilities under the Safe
Drinking Water Act. At that time, the local media reported that a
number of tap water samples showed elevated levels of lead.
You asked that we (1) examine the current structure and level of
coordination among key government entities that implement the Safe
Drinking Water Act's regulations for lead in the District of Columbia,
and identify any improvements to increase efficiency and
accountability, (2) determine how other drinking water systems that
exceeded the EPA action level for lead have conducted public
notification and outreach, (3) assess the availability of data
necessary to determine which adult and child populations are at
greatest risk of exposure to elevated lead levels, and what information
WASA is gathering to help track their health, (4) evaluate the state of
research on lead exposure, and how this information could help inform
other drinking water utilities of potential problems in their systems.
To respond to these questions, we are interviewing key officials and
staff with the federal and local agencies responsible for managing
drinking water and monitoring health for lead exposure in Washington,
D.C., including officials at EPA's headquarters and in its Philadelphia
Office, WASA, the Washington Aqueduct, and the D.C. Department of
Health. We are also (1) reviewing records documenting key activities
and interactions among these agencies, and examining their current
responses to the lead problem, (2) contacting academic and non-
governmental experts in lead contamination, and (3) examining how other
water systems facing similar circumstances notified and educated their
customers on lead health risks, and how they interacted with federal,
state, and local agencies to respond to the problem. Many of the facts
and circumstances surrounding the District's lead controversy are the
subject of active litigation. Accordingly, we do not take a position on
these issues and on how they bear on the question of interagency
coordination and communication, and instead report them only as stated
by the affected parties.
We are here to present our preliminary observations on these issues. We
will report our final findings and any recommendations we may develop
at a later date. In summary:
* Providing safe drinking water requires that water systems,
regulators, and public health agencies fulfill individual roles, yet
work together in a coordinated fashion. It is particularly important
that these entities report and communicate information to each other in
a timely and accurate manner. Recent public statements and corrective
actions by the responsible entities, particularly EPA and WASA, clearly
indicate that coordination could have been better in the years
preceding the current controversy. As our work continues, we will seek
to examine (to the extent appropriate) specific ways in which improved
coordination between EPA and WASA could help both agencies better
fulfill their responsibilities. We will also examine interrelationships
among other key agencies (such as the Aqueduct and the D.C. Department
of Health); how other water systems in similar situations interacted
with federal, state, and local agencies; and what the experiences of
these other jurisdictions may suggest concerning how improved
coordination can better protect drinking water in the District of
Columbia.
* Other water systems facing elevated lead levels used public
notification and education practices that appear to offer lessons for
conducting outreach to water customers, including those in the District
of Columbia. For example, some of the practices of the two systems we
have begun to examine--the Massachusetts Water Resources Authority and
the Portland Water Bureau--include tailoring their communications to
varied audiences in their service areas, testing the effectiveness of
their communication materials, and linking demographic and
infrastructure data to identify populations at greatest risk from lead
in drinking water.
* WASA faces challenges in collecting the information needed to
identify District citizens at greatest risk from lead in drinking
water. Specifically, it has partial information on which of its
customers have lead service pipes, although it is currently in the
process of obtaining more complete information. In our future work, we
will examine the efforts of other water systems to go one step further
by linking data on at-risk populations (such as pregnant mothers,
infants, and small children) with data on homes suspected of being
served by lead service pipes and other plumbing fixtures that may leach
lead into drinking water.
* Much is known about the hazards of lead in the human body and about
how lead from paint, soil, and dust enter the body. However, little
research has been done to determine actual lead exposure from drinking
water, and the information that does exist is dated. In our future
work, we will examine the plans of EPA and other organizations to fill
this key information gap.
Background:
Lead is unusual among drinking water contaminants in that it seldom
occurs naturally in source water supplies like rivers and lakes.
Rather, lead enters drinking water primarily as a result of the
corrosion of materials containing lead in the water distribution system
and in household plumbing. These materials include lead service pipes
that connect a house to the water main, household lead-based solder
used to join copper pipe, and brass plumbing fixtures such as faucets.
The Safe Drinking Water Act is the key federal law protecting public
water supplies from harmful contaminants. The Act established a
federal-state arrangement in which states may be delegated primary
implementation and enforcement authority ("primacy") for the drinking
water program. Except for Wyoming and the District of Columbia, all
states and territories have received primacy. For contaminants that are
known or anticipated to occur in public water systems and that the EPA
Administrator determines may have an adverse impact on health, the Act
requires EPA to set a non-enforceable maximum contaminant level goal
(MCLG) at which no known or anticipated adverse health effects occur
and that allows an adequate margin of safety. Once the MCLG is
established, EPA sets an enforceable standard for water as it leaves
the treatment plant, the maximum contaminant level (MCL). The MCL
generally must be set as close to the MCLG as is "feasible" using the
best technology or other means available, taking costs into
consideration.
The fact that lead contamination occurs after water leaves the
treatment plant has complicated efforts to regulate it in the same way
as most contaminants. In 1975, EPA set an interim MCL for lead at 50
parts per billion (ppb), but did not require sampling of tap water to
show compliance with the standard. Rather, the standard had to be met
at the water system before the water was distributed. The 1986
amendments to the Act directed EPA to issue a new lead regulation, and
in 1991, EPA adopted the Lead and Copper Rule.
Instead of an MCL, the rule established an "action level" of 15 ppb for
lead in drinking water, and required that water systems take steps to
limit the corrosiveness of their water. Under the rule, the action
level is exceeded if lead levels are higher than 15 ppb in over 10
percent of tap water samples taken. Large systems, including WASA,
generally must take at least 100 tap water samples in a 6-month
monitoring period. Large systems that do not exceed the action level or
that maintain optimal corrosion control for two consecutive 6-month
periods may reduce the number of sampling sites to 50 sites and reduce
collection frequency to once per year. If a water system exceeds the
action level, other regulatory requirements are triggered. The water
system must intensify tap water sampling, take additional actions to
control corrosion, and educate the public about steps they should take
to protect themselves from lead exposure. If the problem is not abated,
the water system must annually replace 7 percent of the lead service
lines under its ownership.
The public notification requirements of the Safe Drinking Water Act are
intended to protect public health, build trust with consumers through
open and honest sharing of information, and establish an ongoing,
positive relationship with the community.[Footnote 3] While public
notification provisions were included in the original Act, concerns
have been raised for many years about the way public water systems
notify the public regarding health threats posed by contaminated
drinking water. In 1992, for example, we reported, among other things,
that (1) there were high rates of noncompliance among water systems
with the public notification regulations in effect at that time and (2)
notices often did not clearly convey the appropriate information to the
public concerning the health risks associated with a violation and the
preventive action to be taken.[Footnote 4] The 1996 Amendments to the
Safe Drinking Water Act attempted to address many of these concerns by
requiring that consumers of public water supplies be given more
accurate and timely information about violations and that this
information be in a form that is more understandable and useful.
Drinking water is provided to District of Columbia residents under a
unique organizational structure:
* The U.S. Army Corps of Engineers' Washington Aqueduct draws water
from the Potomac River and filters and chemically treats it to meet EPA
specifications. The Aqueduct produces drinking water for approximately
1 million citizens living, working, or visiting in the District of
Columbia, Arlington County, Virginia, and the City of Falls Church,
Virginia. Managed by the Corps of Engineers' Baltimore District, the
Aqueduct is a federally owned and operated public water supply agency
that produces an average of 180 million gallons of water per day at two
treatment plants located in the District. All funding for operations,
maintenance, and capital improvements comes from revenue generated by
selling drinking water to the District of Columbia, Arlington County,
Virginia, and the City of Falls Church, Virginia.
* The District of Columbia Water and Sewer Authority buys its drinking
water from the Aqueduct. WASA distributes drinking water through 1,300
miles of water mains under the streets of the District to individual
homes and buildings, as well as to several federal facilities directly
across the Potomac River in Virginia. From its inception in 1938 until
1996, WASA's predecessor, the District of Columbia Water and Sewer
Utility Administration, was a part of the District's government. In
1996, WASA was established by District of Columbia law as a
semiautonomous regional entity. WASA develops its own budget, which is
incorporated into the District's budget and then forwarded to Congress.
All funding for operations, improvements, and debt financing come from
usage fees, EPA grants, and the sale of revenue bonds.
* EPA's Philadelphia Regional Office has primary oversight and
enforcement responsibility for public water systems in the District.
According to EPA, the Regional Office's oversight and enforcement
responsibilities include providing technical assistance to the water
suppliers on how to comply with federal regulations; ensuring that the
suppliers report the monitoring results to EPA by the required
deadlines; taking enforcement actions if violations occur; and using
those enforcement actions to return the system to compliance in a
timely fashion.
* The District's Department of Health, while having no formal role
under the Act, is responsible for identifying health risks and
educating the public on those risks.
Coordination Among Agencies Is Critical To Ensure Safe Drinking Water:
Providing safe drinking water requires that water systems, regulators,
and public health agencies fulfill individual responsibilities yet work
together in a coordinated fashion. It is particularly important that
these entities report and communicate information to each other in a
timely and accurate manner. In the case of drinking water in the
District of Columbia, one of the key relationships is the one between
WASA, the deliverer of water to District customers, and EPA's
Philadelphia Office, the regulator charged with overseeing WASA's
compliance with drinking water regulations. Of particular note, one of
WASA's key obligations is to monitor the water it supplies to District
customers through a tap water sampling program, and to report these
results accurately and in a timely manner to EPA's Philadelphia Office.
As EPA itself has noted, one of the Philadelphia Office's key
obligations is to ensure that WASA understands the reporting
requirements and reports monitoring results by required deadlines.
It is noteworthy that WASA and EPA have taken or agreed to take steps
that are clearly intended to improve communication and coordination
between the agencies. For example:
* Under the Consent Order signed by EPA and WASA on June 17, 2004, WASA
agreed to improve its format for reporting tap water samples by
ensuring that the reports include tap water sample identification
numbers, sample date and location, lead and copper concentration,
service line materials, and reasons for any deviation from previously
sampled locations. The monitoring reports are also to include the
laboratory data sheets, which contain the raw test data recorded
directly by the laboratory. Under the Order, WASA also agreed to submit
to EPA for comment a plan and schedule for enhanced information,
database management, and reporting. The plan is to describe how
monitoring reports will be generated, maintained, and submitted to EPA
in a timely fashion.
* EPA's Philadelphia Office has altered the way in which it will handle
compliance data from WASA and the Washington Aqueduct. According to the
office, compliance data from both water systems will now be sent to
those in the Office responsible for enforcing the Safe Drinking Water
Act, so as to separate the enforcement/compliance assurance function
from the municipal assistance function.
Aside from the tap water monitoring issue, EPA's Philadelphia Office
acknowledges that its oversight of WASA public notification and
education efforts could have been better, noting that "In hindsight,
EPA should have asked more questions about the extent, coverage and
impact of DC WASA's public education program, and reacted to fill the
public education gaps where they were evident."[Footnote 5] To address
the problem, the Philadelphia Office reported on its website that it
will have to make some improvements in the way it exercises its own
oversight responsibilities.[Footnote 6] Suggested improvements include
obtaining written agreement from WASA to receive drafts of education
materials and a timeline for their submission, reviewing drafts of
public education materials for compliance with requirements, as well as
effectiveness of materials and delivery, and acquiring outside
expertise to assist in evaluating outreach efforts.
As our work continues, we will seek to examine (to the extent it does
not conflict with active litigation) other ways in which improved
coordination between WASA and EPA could help both agencies better
fulfill their responsibilities. We will also examine interrelationships
that include other key agencies, such as the Aqueduct and the D.C.
Department of Health. We will also examine how other water systems in
similar situations interacted with federal, state, and local agencies.
These experiences may offer suggestions on how coordination can be
improved among the agencies responsible for protecting drinking water
in the District of Columbia.
Experiences of Other Water Systems Highlight Effective Ways to Inform
and Educate the Public:
WASA is not the first system to exceed the action level for lead.
According to EPA, when the first round of monitoring results was
completed for large water systems in 1991 pursuant to the Lead and
Copper Rule, 130 of the 660 systems serving populations over 50,000
exceeded the action level for lead. EPA data show that since the
monitoring period ending in 2000, 27 such systems have exceeded the
action level.[Footnote 7] As part of our work, we will be examining the
innovative approaches some of these systems have used to notify and
educate their customers. I would like to touch on the activities of two
such systems, the Massachusetts Water Resources Authority and the
Portland, Oregon, Water Bureau. Each of these systems has employed
effective notification practices in recent years that may provide
insights into how WASA, and other water systems, could improve their
own practices.
Massachusetts Water Resources Authority:
The Massachusetts Water Resources Authority (MWRA) is the wholesale
water provider for approximately 2.3 million customers, mostly in the
metropolitan Boston area. Under an agreement with the Massachusetts
Department of Environmental Protection, monitoring for lead under the
Lead and Copper Rule occurs in each of the communities that MWRA serves
and the results are submitted together. Initial system-wide tap water
monitoring results in 1992 showed a 90th percentile lead concentration
of 71 ppb (meaning 10 percent of its samples scored at this level and
above). According to MWRA, adjustments in corrosion control have led to
a reduction in lead levels, but the 90th percentile lead concentration
in MWRA's service area has still been above the action level in four of
the seven sampling events since early 2000.
According to an MWRA official, the public education program for lead in
drinking water is designed to ensure that all potentially affected
parties within MWRA's service area receive information about lead in
drinking water. He noted, for example, that while the Lead and Copper
Rule requires that information be sent to consumers in their water
bills, the large population of renters living in MWRA's service area
often do not receive water bills. Therefore, MWRA included information
about lead in its consumer confidence report, which is sent to all
mailing addresses within the service area. Additionally, MWRA uses
public service announcements, interviews on radio and television talk
shows, appearances at city councils and other local government agency
meetings, and articles in local newspapers to convey information. MWRA
also conducted focus groups to judge the effectiveness of the public
education program and continually makes changes to refine the
information about lead in drinking water.
An MWRA official also noted that MWRA focuses portions of its lead
public education program on the populations most vulnerable to the
health effects of lead exposure. For example, MWRA worked with
officials from the Massachusetts Women, Infants and Children
Supplemental Nutrition Program (WIC) to design a brochure to help
parents understand how to protect their children from lead in drinking
water. Among other things, the brochure includes the pertinent
information in several foreign languages, including Spanish,
Portuguese, and Vietnamese. The WIC program also includes information
on how to avoid lead hazards when preparing formula.
Portland Water Bureau:
The Portland Water Bureau provides drinking water to approximately
787,000 people in the Portland metropolitan area, nearly one-fourth of
the population of Oregon. Since 1997, the city has exceeded the lead
action level 6 times in 14 rounds of monitoring. According to Bureau
officials, the problem stems mainly from lead solder used to join
copper plumbing and from lead in home faucets. Portland's system has
never had lead service lines, and the Water Bureau finished removing
all lead fittings within the water system's control in 1998.
The Portland Water Bureau sought flexibility in complying with the Lead
and Copper Rule. The state of Oregon allowed the Water Bureau to
implement a lead hazard reduction program as a substitute for the
optimal corrosion control treatment requirement of the Lead and Copper
Rule. Portland's lead hazard reduction program is a partnership between
the Portland Water Bureau, the Multnomah County and Oregon State health
departments, and community groups. According to Portland Water Bureau
officials, the program consists of four components: (1) water treatment
for corrosion control; (2) free water testing to identify customers who
may be at significant risk from elevated lead levels in drinking water;
(3) a home lead hazard reduction program to prevent children from being
exposed to lead from lead-based paint, dust, and other sources; and (4)
education on how to prevent lead exposure targeted to those at greatest
risk from exposure.
As the components suggest, the program is focused on reducing exposure
to lead through all exposure pathways, not just through drinking water.
For example, the Water Bureau provides funding to the Multnomah County
Health Department's LeadLine--a phone hotline that residents can call
to get information about all types of lead hazards. Callers can get
information about how to flush their plumbing to reduce their lead
exposure and can request a lead sampling kit to determine the lead
concentration in the drinking water in their home. The Water Bureau
also provides funding for lead education materials provided to new
parents in hospitals, for billboards and movie advertisements targeted
to neighborhoods with older housing stock, and to the Community
Alliance of Tenants to educate renters on potential lead hazards. Each
of these materials directs people to call the LeadLine if they need
additional information about any lead hazard. The Water Bureau
evaluates the results of the program by tracking the number of calls to
the LeadLine, and by surveying program participants to determine their
satisfaction with the program and the extent to which the program
changed their behavior.
In January 2004, the Portland Water Bureau sent a targeted mailing to
those residents most likely to be affected by lead in drinking water.
The mailing targeted homes of an age most likely to contain lead-
leaching solder where a child 6 years old or younger lived.
Approximately 2,600 postcards were sent that encouraged residents to
get their water tested for lead, learn about childhood blood lead
screening, and reduce lead hazards in their homes. Water Bureau
officials said that they obtained the information needed to target the
mailing from a commercial marketing company, and that the commercial
information was inexpensive and easy to obtain.
WASA Faces Challenges in Identifying At-Risk Populations:
In an ideal world, a water utility such as WASA would have several
different types of information that would allow it to monitor the
health of individuals most susceptible to the health effects of lead in
drinking water. The utility would know the location of all lead service
lines and homes with leaded plumbing (pipes, solder and/or fixtures)
within its service area. The utility would also know the demographics
of the residents of each of these homes. With this information, the
utility could identify each pregnant woman or child six years old or
younger who would be most likely to be exposed to lead through drinking
water. These individuals could then be educated about how to avoid lead
exposure, and lead exposure for each of these individuals could then be
monitored through water testing and blood lead testing.
Unfortunately, WASA and other drinking water utilities do not operate
in an ideal world. WASA does have some information on the location of
lead service lines within its distribution area. Its predecessor
developed an inventory of lead service lines in its distribution system
in 1990 as part of an effort to identify sampling locations to comply
with the Lead and Copper Rule. According to WASA officials, identifying
the locations of lead service lines was difficult because many of the
records were nearly 100 years old and some of the information was
incomplete. According to this 1990 inventory, there were approximately
22,000 lead service lines. WASA updated the inventory in September
2003, and estimated that it had 23,071 "known or suspected" lead
service lines. WASA subsequently identified an additional 27,495
service lines in the distribution system made of "unknown" materials.
Consequently, there is some uncertainty over the actual number and
location of the lead service lines in WASA's distribution system. The
administrative order that EPA issued in June 2004 requires WASA to
further update its inventory of lead service lines.
Regardless of the information WASA has about the location of lead
service lines, according to WASA officials, WASA has little information
about the location of customers who are particularly vulnerable to the
effects of lead. The District's Department of Health is responsible for
monitoring blood lead levels for children in the District. Officials
from the Department of Health told us that they maintain a database of
the results of all childhood blood lead testing in the District, and
have studied the distribution of blood lead levels in children on a
neighborhood basis. However, according to a joint study by the D.C.
Department of Health and the Centers for Disease Control and Prevention
(CDC) published in March 2004, it is difficult to discern any effect of
lead in drinking water on children's blood lead levels because the
older homes most likely to have lead service lines are also those most
likely to have other lead hazards, such as lead in paint and dust. This
joint study also described efforts by the Department of Health and the
United States Public Health Service to conduct blood lead monitoring
for residents of homes whose drinking water test indicated a lead
concentration greater than 300 ppb. None of the 201 residents tested
were found to have blood lead levels exceeding the levels of concern
for adults or children, as appropriate.
Researchers Face Gaps in Knowledge Regarding the Risks Posed by Lead in
Drinking Water:
A good deal of research has been conducted on the health effects of
lead, in particular on the effects associated with certain pathways of
contamination, such as ingestion of leaded paint and inhalation of
leaded dust. In contrast, the most relevant studies on the isolated
health effects of lead in drinking water date back nearly 20 years--
including the Glasgow Duplicate Diet Study on lead levels in children
upon which the Lead and Copper Rule is partially based.[Footnote 8]
According to recent medical literature and the public health experts we
contacted, the key uncertainties requiring clarification include the
incremental effects of lead-contaminated drinking water on people whose
blood lead levels are already elevated from other sources of lead
contamination and the potential health effects of exposure to low
levels of lead. As we continue our work, we will examine the plans of
EPA and other organizations to fill these and other key information
gaps.
Lead is a naturally occurring element that, according to numerous
studies, can be harmful to humans when ingested or inhaled,
particularly to pregnant and nursing women and children aged six or
younger. In children, for example, lead poisoning has been documented
as causing brain damage, mental retardation, behavioral problems,
anemia, liver and kidney damage, hearing loss, hyperactivity, and other
physical and mental problems. Exposure to lead may also be associated
with diminished school performance, reduced scores on standardized IQ
tests, schizophrenia, and delayed puberty.
Long-term exposure may also have serious effects on adults. Lead
ingestion accumulates in bones, where it may remain for decades.
However, stored lead can be mobilized during pregnancy and passed to
the fetus. Other health effects in adults that may be associated with
lead exposure include irritability, poor muscle coordination and nerve
damage, increased blood pressure, impaired hearing and vision, and
reproductive problems.
There are many sources of lead exposure besides drinking water,
including the ingestion of soil, paint chips and dust; inhalation of
lead particles in soil or dust in air; and ingestion of foods that
contain lead from soil or water. Extensive literature is available on
the health impacts of lead exposure, particularly from contaminated air
and dust. CDC identified in a December 2002 Morbidity and Mortality
Weekly Report the sources of lead exposure for adults and their
potential health effects.[Footnote 9] In a September 2003 Morbidity and
Mortality Weekly Report, CDC identified the most prevalent sources of
lead in the environment for children, and correlated high blood lead
levels in children with race, sex, and income bracket.[Footnote 10] The
surveys suggest that Hispanic and African-American children are at
highest risk for lead poisoning, as well as those individuals who are
recipients of Medicaid. Dust and soil contaminated by leaded paint were
documented as the major sources of lead exposure. Children and adults
living in housing built before 1950 are more likely to be exposed to
lead paint and dust and may therefore have higher blood lead levels.
Articles in numerous journals have reported on the physical and
neurological health effects on children of lead in paint, soil, and
dust. The New England Journal of Medicine published an article in April
2003 that associated environmental lead exposure with decreased growth
and delayed puberty in girls.[Footnote 11] In 2000, the Journal of
Public Health Medicine examined the implications of lead-contaminated
soil, its effect on produce, and its potential health effects on
consumers.[Footnote 12] Lead can also enter children's homes if other
residents are employed in lead contaminated workplaces. In 2000,
Occupational Medicine found that children of individuals exposed to
lead in the workplace were at higher risk for elevated blood lead
levels.[Footnote 13] The EPA has aided in some similar research through
the use of its Integrated Exposure Uptake Biokinetic Model for Lead in
Children (IEUBK). This model predicts blood lead concentrations for
children exposed to different types of lead sources.[Footnote 14]
According to a number of public health experts, drinking water
contributes a relatively minor amount to overall lead exposure in
comparison to other sources. However, while lead in drinking water is
rarely thought to be the sole cause of lead poisoning, it can
significantly increase a person's total lead exposure--particularly for
infants who drink baby formulas or concentrated juices that are mixed
with water from homes with lead service lines or plumbing systems. For
children with high levels of lead exposure from paint, soil, and dust,
drinking water is thought to contribute a much lower proportion of
total exposure. For residents of dwellings with lead solder or lead
service lines, however, drinking water could be the primary source of
exposure. As exposure declines from sources of lead other than drinking
water, such as gasoline and soldered food cans, drinking water will
account for a larger proportion of total intake. Thus, according to
EPA, the total drinking water contribution to overall lead levels may
range from as little as 5 percent to more than 50 percent of a child's
total lead exposure.[Footnote 15]
Mr. Chairman, this completes my prepared statement. I would be happy to
respond to any questions you or other Members of this Subcommittee may
have at this time.
Contact and Acknowledgments:
For further information, please contact John B. Stephenson at (202)
512-3841. Individuals making key contributions to this testimony
included Steve Elstein, Samantha Gross, Karen Keegan, Jessica Marfurt,
and Tim Minelli.
FOOTNOTES
[1] 42 U.S.C. 300f-300j.
[2] 40 C.F.R. pt. 141, subpart I. The Lead and Copper Rule established
an action level of 15 parts per billion (ppb) for lead in drinking
water. Under the rule, the action level is exceeded if lead levels are
higher than 15 ppb in over 10 percent of tap water samples taken. For
each monitoring period, a system must report the lead level at the 90th
percentile of homes monitored. For example, if a system monitors 100
homes, it sorts its results from the lowest to the highest
concentrations and reports the concentration it observed in the 90th
sample.
[3] Public Notification Handbook, EPA Office of Water (EPA 816-R-00-
010, June 2000).
[4] U.S. General Accounting Office, Drinking Water: Consumers Often Not
Well-Informed of Potentially Serious Violations, GAO/RCED-92-135
(Washington, D.C. June 1992).
[5] Letter from William C. Early, Regional Counsel, EPA Region III, to
Eric H. Holder, Jr., Covington & Burling (June 25, 2004) attaching
EPA's Response to May 13, 2004, letter from Covington & Burling,
Response #26.
[6] http://www.epa.gov/dclead/pep_recommendations.htm.
[7] EPA Office of Ground Water and Drinking Water, Summary: Lead action
level exceedences for medium (3,300-50,000) and large (>50,000) public
water systems (Updated as of June 1, 2004).
[8] Lacey R.F., et al. Lead in Water, Infant Diet and Blood: The
Glasgow Duplicate Diet Study. The Science of the Total Environment, 41
(1985) 235-257.
[9] Centers for Disease Control and Prevention. Morbidity and Mortality
Weekly Report: Adult Blood Lead Epidemiology and Surveillance - United
States 1998-2001. 13 December 2002.
10] Centers for Disease Control and Prevention. Morbidity and
Mortality Weekly Report: Surveillance for Elevated Blood Lead Levels
Among Children - United States 1997-2001. 12 September 2003.
[11] Sherry G. Selevan, Deborah C. Rice, Karen A. Hogan, Susan Y.
Euling, et al. "Blood lead concentration and delayed puberty in girls."
The New England Journal of Medicine. Boston: Apr 17,
2003. Vol. 348, Iss. 16; pp. 1527-1536.
[12] Prasad LR, Nazareth B. "Contamination of Allotment Soil with Lead:
Managing Potential Risks to Health." Journal of Public Health Medicine.
22(4) December 2000: 525-30.
[13] Chan, J, et al. "Predictors of Lead Absorption in Children of Lead
Workers." Occupational Medicine. Vol 50, Issue 6, 398-405, 2000.
[14] U.S. Environmental Protection Agency. The IEUBK Model
http:www.opa.gov/superfund/programs/lead/ieubk.htm 16 April 2004.
[15] U.S. Environmental Protection Agency. Lead and Copper Rule. The
Federal Register. Vol. 56 NO. 110, 7 June 1991.
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