Drinking Water
EPA Should Strengthen Ongoing Efforts to Ensure That Consumers Are Protected from Lead Contamination Gao ID: GAO-06-148 January 4, 2006Elevated lead levels in the District of Columbia's tap water in 2003 prompted questions about how well consumers are protected nationwide. The Environmental Protection Agency (EPA), states, and local water systems share responsibility for providing safe drinking water. Lead typically enters tap water as a result of the corrosion of lead in the water lines or household plumbing. EPA's lead rule establishes testing and treatment requirements. This report discusses (1) EPA's data on the rule's implementation; (2) what implementation of the rule suggests about the need for changes to the regulatory framework; and (3) the extent to which drinking water at schools and child care facilities is tested for lead.
EPA's data suggest that the number of drinking water systems with elevated lead levels has dropped significantly since testing began in the early 1990s. However, EPA's database does not contain recent test results for over 30 percent of large and medium-sized community water systems and lacks data on the status of water systems' efforts to implement the lead rule for over 70 percent of all community systems, apparently because states have not met reporting requirements. In addition, EPA's data on water systems' violations of testing and treatment requirements are questionable because some states have reported few or no violations. As a result, EPA does not have sufficient data to gauge the rule's effectiveness. Implementation experiences to date have revealed weaknesses in the regulatory framework for the lead rule. For example, most states do not require their water systems to notify homeowners that volunteer for periodic lead monitoring of the test results. In addition, corrosion control can be impaired by changes to other treatment processes, and controls that would help avoid such impacts may not be adequate. Finally, because testing indicates that some "lead-free" products leach high levels of lead into drinking water, existing standards for plumbing materials may not be sufficiently protective. According to EPA officials, the agency is considering some changes to the lead rule. On the basis of the limited data available, it appears that few schools and child care facilities have tested their water for lead, either in response to the Lead Contamination Control Act of 1988 or as part of their current operating practices. In addition, no focal point exists at either the national or state level to collect and analyze test results. Thus, the pervasiveness of lead contamination in the drinking water at schools and child care facilities--and the need for more concerted action--is unclear.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-06-148, Drinking Water: EPA Should Strengthen Ongoing Efforts to Ensure That Consumers Are Protected from Lead Contamination
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Report to Congressional Requesters:
January 2006:
Drinking Water:
EPA Should Strengthen Ongoing Efforts to Ensure That Consumers Are
Protected from Lead Contamination:
GAO-06-148:
GAO Highlights:
Highlights of GAO-06-148, a report to congressional requesters:
Why GAO Did This Study:
Elevated lead levels in the District of Columbia‘s tap water in 2003
prompted questions about how well consumers are protected nationwide.
The Environmental Protection Agency (EPA), states, and local water
systems share responsibility for providing safe drinking water. Lead
typically enters tap water as a result of the corrosion of lead in the
water lines or household plumbing. EPA‘s lead rule establishes testing
and treatment requirements. This report discusses (1) EPA‘s data on the
rule‘s implementation; (2) what implementation of the rule suggests
about the need for changes to the regulatory framework; and (3) the
extent to which drinking water at schools and child care facilities is
tested for lead.
What GAO Found:
EPA‘s data suggest that the number of drinking water systems with
elevated lead levels has dropped significantly since testing began in
the early 1990s. However, EPA‘s database does not contain recent test
results for over 30 percent of large and medium-sized community water
systems and lacks data on the status of water systems‘ efforts to
implement the lead rule for over 70 percent of all community systems,
apparently because states have not met reporting requirements. In
addition, EPA‘s data on water systems‘ violations of testing and
treatment requirements are questionable because some states have
reported few or no violations. As a result, EPA does not have
sufficient data to gauge the rule‘s effectiveness.
Implementation experiences to date have revealed weaknesses in the
regulatory framework for the lead rule. For example, most states do not
require their water systems to notify homeowners that volunteer for
periodic lead monitoring of the test results. In addition, corrosion
control can be impaired by changes to other treatment processes, and
controls that would help avoid such impacts may not be adequate.
Finally, because testing indicates that some ’lead-free“ products leach
high levels of lead into drinking water, existing standards for
plumbing materials may not be sufficiently protective. According to EPA
officials, the agency is considering some changes to the lead rule.
On the basis of the limited data available, it appears that few schools
and child care facilities have tested their water for lead, either in
response to the Lead Contamination Control Act of 1988 or as part of
their current operating practices. In addition, no focal point exists
at either the national or state level to collect and analyze test
results. Thus, the pervasiveness of lead contamination in the drinking
water at schools and child care facilities”and the need for more
concerted action”is unclear.
Water Distribution System from the Treatment Plant to Household
Plumbing:
[See PDF for image]
[End of table]
What GAO Recommends:
Among other things, GAO recommends that EPA improve its data on key
aspects of lead rule implementation, strengthen certain regulatory
requirements and oversight, and assess the problem of lead in drinking
water at schools and child care facilities. In commenting on a draft of
this report, EPA generally agreed with our findings and
recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-06-148.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact John B. Stephenson at
(202) 512-3841 or stephensonj@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Inadequate Data Impair EPA's Ability to Oversee Implementation of the
Lead Rule:
Weaknesses in the Regulatory Framework for the Lead Rule May Undermine
Public Health Protection:
Limited Data Indicate Few Schools and Child Care Facilities Test or
Take Other Measures to Control Lead in Their Water Supplies:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: Detailed Analysis of Corrective Action Milestone Data
Reported to EPA, by State, through June 2005:
Appendix III: Number of Lead Rule Violations Reported to EPA Between
1995 and June 2005 (by State):
Appendix IV: Information on Selected EPA and State Enforcement Actions,
by Type, from 1995 to June 2005:
Appendix V: Comments from the Environmental Protection Agency:
Appendix VI: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Corrective Action Milestone Data Reported by the States
through June 2005, by System Size and Type of Milestone:
Table 2: Differences in Reported Information on Lead Service Line
Replacement, as of June 2004:
Table 3: Percentage of Systems with Violations from 1995 to June 2005:
Table 4: State Activities to Ensure that Water Systems Are Taking Lead
Samples at Appropriate Sites:
Table 5: State Role in Selecting Sites for Reduced Monitoring:
Table 6: States That Require More Frequent Monitoring to Evaluate the
Effects of Treatment Changes:
Table 7: State Views on Extent to Which Water Systems Are Notifying
Homeowners of the Results of Lead Testing:
Table 8: Examples of Different Reporting Practices for Lead Testing in
Combined Water Distribution Systems as of June 2005:
Table 9: Applicability of Standards for Lead-Free Plumbing Products:
Table 10: Summary of NSF Test Results Regarding Lead Content of
Plumbing Products Voluntarily Submitted to NSF for Certification:
Table 11: Information on Recent Efforts to Test for and Remediate Lead
in Drinking Water in Five School Districts:
Figures:
Figure 1: Water Distribution System from the Treatment Plant to
Household Plumbing:
Figure 2: Process Drinking Water Systems Follow to Comply with EPA's
Lead Rule:
Figure 3: Number of Community Water Systems That Exceeded the Lead
Action Level During the Initial Monitoring Period (1992-1994) and Their
Most Recently Completed Monitoring (2002-June 2005), by System Size:
Figure 4: Summary of State Efforts to Address Lead in Drinking Water at
Schools and Child Care Facilities:
Abbreviations:
ANSI: American National Standards Institute:
EPA: Environmental Protection Agency:
LCCA: Lead Contamination Control Act:
NSF: NSF International:
Letter January 4, 2006:
The Honorable James M. Jeffords:
Ranking Minority Member:
Committee on Environment and Public Works:
United States Senate:
The Honorable John D. Dingell:
Ranking Minority Member:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Hilda L. Solis:
Ranking Minority Member:
Subcommittee on Environment and Hazardous Materials:
Committee on Energy and Commerce:
House of Representatives:
When testing in the District of Columbia during 2003 revealed that over
4,000 households had elevated levels of lead in their drinking water,
the ensuing publicity prompted questions about how well local drinking
water systems are protecting consumers from lead contamination
nationwide. The adverse health effects associated with exposure to lead
can be severe, including delays in normal physical and mental
development in infants and young children, and damage to kidneys and
reproductive systems for the population at large. Although rarely the
sole cause of lead poisoning, lead in drinking water can be a
significant contributor to a person's total exposure--and can account
for as much as 60 percent of the exposure for infants who drink baby
formula or concentrated juices mixed with water. Because children are
most vulnerable to adverse health effects from lead exposure, the
adequacy of controls over lead in water supplies serving schools and
child care facilities is particularly important.[Footnote 1] In
response to the discovery of lead contamination in the District of
Columbia, the Environmental Protection Agency (EPA) launched a broad
examination of the implementation of drinking water regulations it
issued in 1991--known as the Lead and Copper Rule--to determine whether
elevated lead levels are a national problem.[Footnote 2] EPA issued the
rule as part of its efforts in implementing the Safe Drinking Water
Act, and established testing and treatment requirements to control lead
and copper in public water supplies.[Footnote 3]
Responsibility for ensuring safe drinking water is shared by EPA, the
states, and, most importantly, local water systems. In general, EPA
sets standards to protect drinking water quality and to ensure the
proper operation and maintenance of public water systems. EPA also
oversees state implementation of the Safe Drinking Water Act and
applicable regulations where states have assumed primary responsibility
for enforcement. The states ensure that local water systems meet EPA
and state requirements, provide technical assistance, and take
enforcement action, as necessary. In addition, the states collect
information on the results of drinking water monitoring, among other
things, and report the information to EPA. At the local level, public
water systems operate and maintain their facilities in accordance with
federal and state requirements, periodically test the drinking water to
ensure that it meets quality standards, install needed treatments, and
report required information to the states.
In contrast to most drinking water contaminants, lead is rarely found
in the source water used for public water supplies. Instead, lead
enters tap water as a result of the corrosion that takes place over
time when materials containing lead in the water distribution system or
household plumbing come into contact with water. For example, lead can
leach out of service lines, pipes, brass and bronze fixtures, solders,
or other materials, and contaminate drinking water. To address this
problem, EPA established requirements for corrosion control treatment,
source water treatment, lead service line replacement, and public
education. The lead rule requires water systems to test the tap water
at a specified number of locations that are at high risk of lead
contamination.[Footnote 4] In general, if lead concentrations exceed 15
parts per billion in more than 10 percent of the samples, a water
system has exceeded the action level and must (1) provide public
education materials to its customers and (2) conduct additional testing
to determine if treating lead contamination from the water's source may
be necessary. Water systems that exceed the action level may also be
required to install corrosion control treatment to reduce the water's
corrosiveness. When treatment is not effective in controlling lead
levels, a water system must annually replace at least 7 percent of any
lead service lines it owns. To further address the problem of lead in
household plumbing, the Congress amended the Safe Drinking Water Act in
1986 and 1996 to, among other things, ban the use of lead solder and
plumbing materials that are not "lead-free."
In addition, under the Lead Contamination Control Act of 1988, the
Congress required the recall of drinking water coolers with lead-lined
tanks, banned the manufacture and sale of water coolers that were not
lead-free, and required states to establish programs to assist local
agencies in testing and correcting for lead in water supplies in
schools and child care facilities.[Footnote 5] While the Consumer
Product Safety Commission was responsible for managing the recall, EPA
was responsible for distributing a list of banned coolers and
publishing and distributing guidance on detecting and remediating lead
contamination in school drinking water supplies.
In March 2005, we issued a report that focused on the lead
contamination problem in the District of Columbia's drinking water
supplies.[Footnote 6] For a national perspective on controlling lead in
drinking water, you asked us to determine (1) the extent to which EPA
has sufficient data to oversee implementation of the lead rule, (2)
what implementation of the rule to date suggests about the need for
changes to the regulatory framework, and (3) the extent to which
drinking water supplies at schools and child care facilities are tested
for lead and their users protected from elevated lead levels. For
information on the data EPA uses for oversight of lead rule
implementation, we analyzed EPA data on the results and frequency of
lead testing, the status of corrective actions, and violations. We
determined that the data on results and frequency of testing were
sufficiently reliable to show compliance trends. However, we found that
other data on corrective actions and violations were not sufficiently
reliable to assess the status of efforts to implement and enforce the
lead rule. For information on experiences in implementing the lead rule
and the need for changes to the regulatory framework, we analyzed the
responses to a 2004 EPA information request on states' implementation
policies and practices, the results of EPA-sponsored expert workshops,
and relevant documents. We also obtained test results from NSF
International on lead content and lead leaching of plumbing fittings
and fixtures. To assess data reliability, we obtained information on
NSF International's procedures for data quality control and determined
that the data were sufficiently reliable for illustrative purposes. For
information on efforts to control lead in drinking water at schools and
child care facilities, we analyzed the results of a 2004 50-state
information request by EPA, an EPA workshop that focused specifically
on schools and child care facilities, and relevant documents.
We supplemented the information collected under each objective by
contacting state and local drinking water officials in 10 states. We
selected eight of the states--California, Illinois, Iowa,
Massachusetts, Michigan, New York, Pennsylvania, and Washington--
because they either had a relatively high number of water systems with
test results that exceeded or fell just below the lead action level, or
they added to the geographical diversity of our selections. We also
obtained information from Connecticut and Florida, two states that EPA
identified as particularly active in addressing potential lead
contamination in water supplies serving child care facilities. In all
10 states, we obtained information from state drinking water program
managers, state public health or education officials, and local school
districts that have efforts under way to test for and remediate lead
contamination. (App. I contains a detailed description of our scope and
methodology.) We performed our work between June 2004 and November 2005
in accordance with generally accepted government auditing standards.
Results in Brief:
While EPA's data suggest that the number of drinking water systems with
elevated lead levels has declined significantly since the early 1990s,
the agency does not have a complete picture of how states and water
systems are implementing the lead rule because data on key aspects of
water systems' compliance with regulatory requirements are incomplete
or questionable. According to EPA's data, the number of systems
exceeding the lead action level dropped by nearly 75 percent from the
initial monitoring conducted during 1992 to 1994--shortly after the
lead rule took effect--and the period from 2002 to June 2005. However,
our analysis disclosed that EPA's database does not contain recent test
results on over 30 percent of the community water systems, apparently
because states have not met reporting requirements. EPA's data on the
status of water systems' efforts to implement the lead rule are
similarly incomplete. The agency requires the states to report certain
"milestones" to indicate whether a water system's lead levels are
acceptable or whether the system is implementing required corrective
actions, such as installing corrosion control treatment and replacing
lead service lines. Through June 2005, however, EPA's database did not
contain any milestone information on more than 70 percent of the
nation's community water systems. Finally, because some states reported
few or no violations of lead rule testing and treatment requirements
over multiple years, the completeness of these data is questionable.
EPA has been slow to take action on these data problems and, as a
result, lacks the information it needs to evaluate how effectively the
lead rule is being implemented and enforced nationwide.
The experiences of EPA, states, and water systems in implementing the
lead rule have revealed weaknesses in the regulatory framework,
including both oversight and the regulations themselves, which may be
undermining the intended level of public health protection.
Consequently, some changes to the regulatory framework are necessary.
First, the sites used for lead testing may no longer represent the
sites with the highest risk of contamination. For example, when the
sampling locations approved initially are no longer available or
appropriate, water systems identify new sites and states may not be
tracking the changes to ensure that new sites meet high risk criteria.
Another concern is that most states do not require their water systems
to notify the homeowners who volunteer for periodic lead monitoring of
the test results and do not know the extent to which such notifications
are actually occurring. In addition, the effectiveness of corrosion
control can be impaired by changes to other treatment processes and, in
some states, testing and other controls that would help avoid such
impacts may not be adequate. Finally, existing standards for plumbing
fixtures and devices may not be protective enough, according to some
experts, because testing has determined that some of the products
defined as "lead-free" under the Safe Drinking Water Act can still
contribute high levels of lead to drinking water. To improve
implementation of the lead rule, EPA is considering a number of changes
to its regulations, such as requiring advance notice of treatment
modifications that could affect corrosion control. EPA is also
considering changes to its guidance to improve and clarify specific
aspects of the lead rule.
Although data are limited, it appears that few schools and child care
facilities have tested their water supplies for lead--or adopted other
measures to protect users from lead contamination--either in response
to the Lead Contamination Control Act of 1988 or as part of their
current operating practices. Little data are available to assess (1)
the scope and effectiveness of the effort to recall water coolers or
(2) the extent and results of any testing. In addition, although the
act required states to establish programs to assist local agencies in
addressing potential lead contamination at schools and child care
facilities, this provision was declared unconstitutional in 1996 and
state efforts were generally limited. Current efforts to detect and
remediate lead in drinking water at schools and child care facilities
appear limited, based on the results of EPA's 50-state information
request and our discussions with 10 states. In recent years, some of
these facilities have tested voluntarily, and school districts in some
cities such as Boston, Philadelphia, and Seattle, have detected
elevated lead levels at some drinking water outlets. However, little
information exists on the pervasiveness of the problem nationwide
because no focal point exists at the national or state level to collect
and analyze the test results or share information on effective
remediation strategies. State and local officials say that dealing with
other environmental problems in their facilities--including lead paint,
asbestos, and mold--is a higher priority because more information is
available on the nature and extent of these hazards.
We are making a series of recommendations to improve oversight and
implementation of the lead rule. Among other things, we are
recommending that EPA take steps to ensure that data on key aspects of
lead rule implementation are timely and complete so that the agency is
better able to assess the effectiveness of the rule and state oversight
and enforcement efforts. Other recommendations focus on strengthening
aspects of the regulatory framework, such as lead monitoring
requirements, review of treatment changes that could affect corrosion
control, and standards for plumbing fittings and fixtures. Finally, we
are recommending that EPA collect and analyze existing data to assess
the extent of lead contamination in drinking water at schools and child
care facilities and appropriate remedial actions. In commenting on a
draft of this report, EPA generally agreed with our findings and
recommendations. In particular, EPA acknowledged that it needs better
data to assess the effectiveness of lead rule implementation and
enforcement. In addition, EPA agreed that the aspects of the regulation
that we identified as needing improvement warrant additional attention
and noted its plans to address most of these areas by modifying the
rule or collecting additional information. EPA did not address our
recommendations regarding lead contamination and remedial actions at
schools and child care facilities.
Background:
Under the Safe Drinking Water Act, EPA is responsible for regulating
contaminants that may pose a public health risk and that are likely to
be present in public water supplies. EPA may establish an enforceable
standard--called a maximum contaminant level--that limits the amount of
a contaminant that may be present in drinking water. However, if it is
not economically or technically feasible to ascertain the level of a
contaminant, EPA may instead establish a treatment technique to prevent
known or anticipated health effects. In the case of lead, EPA
established a treatment technique--including corrosion control
treatment--because the agency believed that the variability of lead
levels measured at the tap, even after treatment, makes it
technologically infeasible to establish an enforceable standard. EPA
noted that lead in drinking water occurs primarily as a byproduct of
the corrosion of materials in the water distribution system or
household plumbing, some of which is outside the control of the water
systems. Figure 1 illustrates the distribution system for drinking
water and potential sources of lead contamination.
Figure 1: Water Distribution System from the Treatment Plant to
Household Plumbing:
[See PDF for image]
[End of figure]
EPA's lead rule also established a 15-parts-per-billion lead action
level, which is based on the 90th percentile level of water samples
taken at the tap. Water systems must sample tap water at locations that
are at high risk of lead contamination, generally because they are
served by lead service lines or are likely to contain lead solder in
the household plumbing. The number of samples that must be collected
varies depending on the size of the water system and the results of
earlier testing. Small or medium-sized systems whose test results are
consistently below the action level may be allowed to reduce the
frequency of monitoring and the number of samples collected.[Footnote
7]
To determine their test results at the 90th percentile level, water
systems must multiply the number of samples taken during a monitoring
period by 0.9 and identify the result at that level, after ranking the
results of the individual samples they collected in ascending order.
For example, a water system required to take 50 samples would rank the
results from 1 (for the lowest result) to 50 (for the highest result);
the 90th percentile level is the 45th result, 5 below the highest test
result for that monitoring period. When the 90th percentile results for
a water system are above 15 parts per billion, the system has exceeded
the lead action level and must meet requirements for public education
and source water treatment. Under the public education requirements,
water systems must inform the public about the health effects and
sources of lead contamination, along with ways to reduce exposure.
Source water responsibilities include, at a minimum, water monitoring
to determine if the lead contamination is from the water source rather
than--or in addition to--service lines or plumbing fixtures.[Footnote
8]
Water systems that exceed the action level may also be required to
install corrosion control treatment, except for large systems that may
qualify as having optimized corrosion control based on other
criteria.[Footnote 9] When either corrosion control or source water
treatment are not effective in controlling lead levels, the lead rule
calls for water systems with lead service lines to begin replacing them
at a rate of 7 percent annually (unless the state requires a higher
rate).
Figure 2: Process Drinking Water Systems Follow to Comply with EPA's
Lead Rule:
[See PDF for image]
[End of figure]
The states play an important role in ensuring that the lead rule is
implemented and enforced at the local level. Among other things, they
are responsible for (1) ensuring that water systems conduct required
monitoring and (2) reporting the results to EPA. If the systems must
take corrective action to address elevated lead levels, the states are
responsible for approving or determining the nature of the treatment or
other activities that will be required, ensuring that they are
implemented, and periodically reporting relevant information to EPA.
The Safe Drinking Water Act authorizes the states to assume primary
responsibility for enforcing the drinking water program--including the
lead rule--if they meet certain requirements, such as adopting drinking
water regulations at least as stringent as EPA's and having adequate
procedures to carry out and enforce the program's requirements. All
states except Wyoming have assumed primacy for managing their drinking
water programs.
In addition to requiring the regulation of lead in public water
supplies, the Safe Drinking Water Act also contains provisions to limit
the extent to which materials in the water distribution system and
household plumbing contribute to lead levels at the tap. Specifically,
the act banned the use of solder and other materials in the
installation or repair of public water systems or plumbing that are not
lead-free. In this regard, the act established a material standard by
defining "lead-free" to mean solders and flux containing no more than
0.2 percent lead, and pipes and pipe fittings containing no more than
8.0 percent lead.[Footnote 10] In addition, the act called for
development of voluntary performance standards and testing protocols
for the leaching of lead from new plumbing fittings and fixtures by a
qualified third party certifier or, if necessary, promulgated by EPA. A
third party certifier set such a standard in 1997, limiting the amount
of lead that the fittings and fixtures may contribute to water to 11
parts per billion.
To address the potential risks of lead contamination in water supplies
serving schools and child care facilities, Congress passed the Lead
Contamination Control Act of 1988.[Footnote 11] Among other things, the
act banned the manufacture and sale of drinking water coolers
containing lead-lined tanks and other water coolers that are not lead-
free and required (1) EPA to publish a list of such coolers and
distribute it to the states, (2) the Consumer Product Safety Commission
to issue an order requiring manufacturers and importers to repair or
replace lead-lined coolers or recall and provide a refund for them, and
(3) the states to establish programs to assist local agencies in
addressing potential lead contamination.[Footnote 12] In 1990, EPA
identified six models of water coolers from one manufacturer that
contained lead-lined tanks, but the agency was unable to obtain
information on the number of units produced. Regarding water coolers
that were not lead-free, EPA identified three manufacturers that
produced coolers containing lead solder that could contaminate drinking
water. The manufacturers reported producing at least 1 million of the
coolers.
Following the discovery of elevated lead levels in the District of
Columbia's drinking water, EPA undertook a year-long evaluation to gain
insight into how states and local communities are implementing the lead
rule and to determine whether the problems identified in the District
of Columbia are occurring elsewhere. EPA's activities included:
* a series of expert workshops on key aspects of the rule (monitoring
protocols, simultaneous compliance, lead service line replacement,
public education, and lead in plumbing fittings and fixtures),
* a review of state policies and practices for implementing the lead
rule,
* data verification audits that covered the collection and reporting of
compliance data for the lead rule in 10 states, and:
* an expert workshop and a review of state efforts to monitor for lead
in drinking water at schools and child care facilities.
Participants in EPA's expert workshops included representatives of
federal and state regulatory agencies, drinking water systems,
researchers, public interest groups, and others.
Inadequate Data Impair EPA's Ability to Oversee Implementation of the
Lead Rule:
Although EPA's data on the results of testing indicate that the lead
rule has largely been successful in reducing lead levels, the reporting
of these data has not been timely or complete. In addition, key data on
the status of water systems' efforts to implement the lead rule,
including required corrective actions, are incomplete. EPA's data on
lead rule violations are also questionable because of potential
underreporting by the states. The lack of data on key elements of lead
rule implementation makes it difficult for EPA and others to gauge the
effectiveness of efforts to meet and enforce the rule's requirements.
Although EPA's Data Suggest a Decline in Lead Levels, States' Reporting
on the Results of Lead Testing Has Not Been Timely or Complete:
When the lead rule was first implemented, initial monitoring disclosed
that several thousand water systems had elevated lead levels--that is,
more than 10 percent of the samples taken at these systems exceeded the
15-parts-per-billion action level. EPA's most recent data indicate that
the number of water systems that exceed the lead action level has
declined by nearly 75 percent since the early 1990s. The systems that
currently have a problem with elevated lead levels represent about 2
percent of all water systems and serve approximately 4.6 million
people. Figure 3 shows the results (by system size) of the initial lead
monitoring, conducted from 1992 to 1994, and more recent testing from
2002 through the quarter ending in June 2005.[Footnote 13]
Figure 3: Number of Community Water Systems That Exceeded the Lead
Action Level During the Initial Monitoring Period (1992-1994) and Their
Most Recently Completed Monitoring (2002-June 2005), by System Size:
[See PDF for image]
Notes: (1) Figure 3 includes data on active community water systems in
the 50 states and the District of Columbia. The size categories for the
water systems are based on population served, with large systems
serving populations of greater than 50,000, medium systems from 3,301
to 50,000, and small systems less than or equal to 3,300.
(2) Data for initial monitoring under the lead rule cover the period
from 1992 to 1994 because the testing was phased in by system size.
Large water systems began monitoring in January 1992, medium systems in
July 1992, and small systems in July 1993.
(3) Many water systems have obtained approval to reduce the frequency
with which they are required to monitor for lead from every 6 months to
once a year or once every 3 years. Thus, to capture the most recent
round of testing for all water systems, we included data from 2002
through June 2005, the most recent data available at the time of our
analysis. A few small systems have received approval to reduce their
monitoring to once every 9 years and may not be included in these
statistics.
(4) Some water systems may have tested their lead levels multiple times
during the periods covered in this analysis; however, we included only
the results of the initial monitoring and the most recent test result
for each system.
(5) We determined that the data are sufficiently reliable for the
purposes of examining trends in lead action levels.
[End of figure]
EPA, state, and water industry officials generally see the decline in
the number of systems with elevated lead levels as evidence that the
lead rule has been effective and point to corrosion control treatment
as the primary reason. Another indicator of success is the number of
water systems approved for reduced monitoring. Under the lead rule,
water systems can obtain state approval to reduce both the frequency of
monitoring and the number of samples included in the testing when test
results show lead levels consistently below the action level. According
to EPA's data, nearly 90 percent of all water systems have qualified
for reduced monitoring.
After several years of experience with the lead rule, in January 2000,
EPA made significant changes to the information states were required to
report for inclusion in the agency's database. Among other things, EPA
added a requirement for states to report, for large and medium-sized
systems, all 90th percentile test results, not just the results for
systems that exceed the action level. EPA said that it planned to use
these test results to show how levels of lead at the tap have changed
over time for large and medium systems and, by extrapolation, for small
systems.
Although the new reporting requirements took effect in January 2002,
EPA's database contained 90th percentile test results for only 23
percent of the large and medium systems by January 2004.[Footnote 14]
EPA officials explained that states were still having difficulty
updating their information systems to accommodate the new reporting
requirements and, for EPA, obtaining the data was not a priority at
that time. Following the detection of elevated lead levels in the
District of Columbia, however, EPA made a concerted effort to obtain
more complete information from the states, and, as of June 2004, EPA
reported that it had data for nearly 89 percent of the large and medium
systems (based on an analysis of test results submitted from January
2000 through May 2004). However, we also analyzed data on the results
of lead testing and found that EPA's database does not contain current
information for a much larger percentage of large and medium water
systems. Specifically, we found that for the period from January 2002
through June 2005, EPA's database lacks any test results for nearly 31
percent of the large and medium water systems.[Footnote 15] We could
not determine whether the data are missing because states have not
reported the results or because testing has not occurred. When asked
whether states have been updating test results in a timely manner since
2004, an official representing EPA said that the timeliness of recent
test data is unknown; the agency has not been tracking whether states
are adequately maintaining data on the results of lead testing.
Regarding the information required for small water systems--which is
limited to test results exceeding the action level--officials from both
the Office of Ground Water and Drinking Water and the Office of
Enforcement and Compliance Assurance indicated that some data are
probably missing but could not provide specific estimates. An official
from the Office of Ground Water and Drinking Water commented that EPA's
database likely includes most of the required small system data because
action level exceedances trigger follow-up activities and states are
more likely to pay attention to those cases.
EPA Does Not Have Complete Information on the Status of Water Systems'
Efforts to Implement Lead Rule:
As part of EPA's efforts to improve its indicators of lead rule
implementation, the agency restructured its reporting requirements and
reduced the number of "milestones" that states are required to report
from 11 to 3. EPA established three corrective action milestones,
including (1) a DEEM milestone, meaning that the system is deemed to
have optimized corrosion control; (2) an LSLR milestone, meaning that
the system is required to begin replacing its lead service lines; and
(3) a DONE milestone, meaning that the system has completed all
applicable requirements for corrosion control, source water treatment,
and lead service line replacement.[Footnote 16]
EPA officials told us that the vast majority of water systems should
have at least one milestone in the database. They indicated that in
most instances, systems should have a DEEM designation because they
have installed corrosion control or qualify for meeting the milestone
otherwise. However, we found that, overall, EPA has information on
corrective action milestones for only 28 percent of the community water
systems nationwide--and lacks any milestone data on the remaining 72
percent. Table 1 summarizes the results of our analysis.
Table 1: Corrective Action Milestone Data Reported by the States
through June 2005, by System Size and Type of MilestoneA:
System size: Large;
Number of water systems: 841;
Systems without any milestone data: Number: 600;
Systems without any milestone data: Percent: 71.3;
Systems with milestones: DEEM[B]: 202;
Systems with milestones: LSLR: 7;
Systems with milestones: DONE: 206;
Systems with milestones: Total systems with one or more milestones[C]:
Number: 241;
Systems with milestones: Total systems with one or more milestones[C]:
Percent: 28.7.
System size: Medium;
Number of water systems: 7,620;
Systems without any milestone data: Number: 5,335;
Systems without any milestone data: Percent: 70.0;
Systems with milestones: DEEM[B]: 2,122;
Systems with milestones: LSLR: 15;
Systems with milestones: DONE: 1,850;
Systems with milestones: Total systems with one or more milestones[C]:
Number: 2,285;
Systems with milestones: Total systems with one or more milestones[C]:
Percent: 30.0.
System size: Small;
Number of water systems: 42,991;
Systems without any milestone data: Number: 31,195;
Systems without any milestone data: Percent: 72.6;
Systems with milestones: DEEM[B]: 11,254;
Systems with milestones: LSLR: 21;
Systems with milestones: DONE: 8,838;
Systems with milestones: Total systems with one or more milestones[C]:
Number: 11,796;
Systems with milestones: Total systems with one or more milestones[C]:
Percent: 27.4.
System size: Total;
Number of water systems: 51,452;
Systems without any milestone data: Number: 37,130;
Systems without any milestone data: Percent: 72.2;
Systems with milestones: DEEM[B]: 13,578;
Systems with milestones: LSLR: 43;
Systems with milestones: DONE: 10,894;
Systems with milestones: Total systems with one or more milestones[C]:
Number: 14,322;
Systems with milestones: Total systems with one or more milestones[C]:
Percent: 27.8.
Source: GAO analysis of EPA data.
[A] This table reflects the milestone data that states reported for
active community water systems.
[B] In the case of the DEEM milestone, states are required to report
the basis for their determinations that systems have optimized
corrosion control and EPA established three reason codes for that
purpose. We found that EPA's database contained the required reason
codes for 100 percent of the 13,578 systems with a DEEM milestone.
[C] Because individual water systems may have multiple milestones in
EPA's database, this column represents the number of unique systems
with one or more milestones to avoid "double counting."
[End of table]
The extent to which milestone data were reported to EPA varied from
state to state. We found that 22 states had not reported milestones for
any of their water systems and another 8 states had reported data on
about 10 percent of their systems. (See app. II for a state-by-state
breakdown of reported milestone data.)
EPA officials believe that most water systems have actually taken the
steps necessary to meet the criteria for the DEEM milestone, at a
minimum, and attribute the lack of milestone data to non-reporting by
the states rather than noncompliance by the water systems. They also
suggested that some of the 22 states we identified as having reported
no milestone data, based on our analysis of EPA's current data, may
have reported corrective actions prior to 2000, when EPA modified the
number and type of milestones. However, we reviewed archived data in
EPA's database and found that 8 of the 22 states had also not reported
any milestones prior to 2000, and another 11 states had reported data
on no more than 10 percent of their systems. Overall, the 50 states had
reported milestone data for only 5.7 percent of their community water
systems prior to 2000.
Moreover, some information in EPA's database is inconsistent with other
reported data. Specifically, we found differences between the
information on lead service line replacement in EPA's database--systems
having an LSLR milestone--and the information states reported in the
agency's 50-state review of lead rule implementation policies and
practices. As table 2 shows, seven states reported requiring lead
service line replacement in response to EPA's June 2004 query but did
not have any LSLR milestones in EPA's database in the same time frame.
Table 2: Differences in Reported Information on Lead Service Line
Replacement, as of June 2004:
States reporting required lead service line replacement activity in
EPA‘s June 2004 information request[A]:
Arizona;
Connecticut;
Illinois;
Iowa;
Massachusetts;
Michigan;
Minnesota;
Montana;
New York;
Pennsylvania;
Utah;
Wisconsin.
12 states.
States reporting LSLR milestone in EPA‘s database as of June 2004[B]:
Illinois;
Massachusetts;
Minnesota;
Montana;
Pennsylvania;
Virginia.
6 states.
Source: GAO analysis of EPA data.
[A] In response to EPA's information request, 11 states reported that
some water systems were voluntarily replacing lead service lines--or,
in two instances, the "goosenecks" connecting the water main to a
service line. The 11 states included one state (Michigan) that also
reported requiring one or more systems to replace lead service lines.
[B] The District of Columbia was also identified in EPA's database with
an LSLR milestone.
[End of table]
In addition, after following up with state officials, we found that
EPA's database did not contain accurate data on the number of water
systems required to replace lead service lines because the states were
not providing timely updates or correcting erroneous information.
Data on Lead Rule Violations Are Questionable Because of Potential
Underreporting by the States:
Periodic audits by EPA--and our own analyses--raise questions about the
completeness of EPA's data on lead rule violations. To assess the
reliability of its drinking water data, EPA regularly conducts data
verification audits that evaluate state compliance decisions and the
adequacy of states' reporting to the national database. In addition,
EPA prepares a national summary evaluation of the reliability of
drinking water data every 3 years. While past data verification audits
have not assessed compliance decisions under the lead rule, to the
extent that states' reporting practices are relatively consistent
across regulations, the audits may shed some light on the types of
problems likely to be found in the reporting of lead rule data.
According to the most recent national summary of data
reliability,[Footnote 17] which covered audits conducted from 1999 to
2001, the estimated error rate for health-based violations--involving
maximum contaminant level or treatment technique requirements--was 35
percent, down from 60 percent in the prior national report, which
covered audits conducted from 1996 to 1998. For monitoring and
reporting violations, the estimated error rate was 77 percent, down
from 91 percent in the prior report. The March 2004 report said that
most violation errors resulted from incorrect compliance determinations
by the states, meaning that the state should have cited a violation but
did not. Other problems included "data flow" errors (when the state
correctly identified a violation but did not report it to EPA) and
errors in EPA's database (such as violations that were incorrectly
reported or not removed when rescinded).
Another analysis from EPA's March 2004 report did include the lead rule
and the results also raise questions about the completeness of EPA's
data on lead rule violations. The report states that by means of a tool
that tracks the number of violations reported in each state over a
period of several years, EPA determined that 14 states had not reported
any treatment technique violations under the lead rule during a 6-year
period from 1997 to 2002.[Footnote 18] The report noted that this
potential non-reporting should be evaluated further and recommended
that EPA and the states conduct annual evaluations of all instances of
potential non-reporting. EPA's Office of Ground Water and Drinking
Water asked the regional offices to follow up with the states regarding
the potential underreporting, as recommended in the March 2004 report
on data reliability. For the most part, however, the regions' responses
did not address the lack of treatment technique violations under the
lead rule in the applicable states; two of the regional offices did not
provide written responses. Officials from EPA's Office of Enforcement
and Compliance Assurance were not aware of the violations analysis. The
officials told us that because of limited resources, they focus their
efforts on helping to ensure that states address the worst compliance
problems--water systems identified as significant noncompliers as a
result of the frequency or severity of their violations.
A lack of violations--or a relatively low number of water systems with
violations--does not necessarily mean that states are not meeting
reporting requirements, or that their compliance monitoring and
enforcement efforts are inadequate. However, analyzing the violations
data and following up on the results could provide some useful insights
into the reasons for differences among the states; it could also help
identify problem areas and best practices. We updated EPA's analysis of
violations and, as table 3 shows, the percentage of water systems that
have had one or more violations over the past 10 years varies from
state to state, particularly in the case of monitoring violations.
Table 3: Percentage of Systems with Violations from 1995 to June
2005[A]:
Monitoring violations: Percent of systems with violations[B]: 0;
Monitoring violations: Number of states: 1;
Treatment technique violations: Percent of systems with violations[B]:
0;
Treatment technique violations: Number of states: 11.
Monitoring violations: Percent of systems with violations[B]: > 0 to 5;
Monitoring violations: Number of states: 10;
Treatment technique violations: Percent of systems with violations[B]:
> 0 to 1;
Treatment technique violations: Number of states: 16.
Monitoring violations: Percent of systems with violations[B]: > 5 to
10;
Monitoring violations: Number of states: 6;
Treatment technique violations: Percent of systems with violations[B]:
> 1 to 5;
Treatment technique violations: Number of states: 14.
Monitoring violations: Percent of systems with violations[B]: > 10 to
20;
Monitoring violations: Number of states: 11;
Treatment technique violations: Percent of systems with violations[B]:
> 5 to 10;
Treatment technique violations: Number of states: 6.
Monitoring violations: Percent of systems with violations[B]: > 20 to
30;
Monitoring violations: Number of states: 9;
Treatment technique violations: Percent of systems with violations[B]:
> 10;
Treatment technique violations: Number of states: 3.
Monitoring violations: Percent of systems with violations[B]: > 30 to
40;
Monitoring violations: Number of states: 7.
Monitoring violations: Percent of systems with violations[B]: > 40;
Monitoring violations: Number of states: 6.
Monitoring violations: Percent of systems with violations[B]: Total;
Monitoring violations: Number of states: 50;
Treatment technique violations: Percent of systems with violations[B]:
Total;
Treatment technique violations: Number of states: 50.
Source: GAO analysis of EPA data.
[A] We used 1995 as the starting point for our analysis because all
water systems should have completed their initial monitoring by the end
of 1994.
[B] Some water systems in EPA's database have multiple violations. To
avoid double counting, we identified the percent of unique systems with
one or more violations.
[End of table]
Appendix III contains a state-by-state analysis of lead rule violations
reported from 1995 to June 2005.
More recently, EPA conducted data verification audits during the fall
of 2004, which focused exclusively on states' compliance determinations
under the lead rule in five states and included the lead rule as part
of the audit in another five states. However, the results are not yet
available. EPA officials have been analyzing the data and obtaining
comments on the preliminary findings from the states; they expect to
issue a final report by the end of calendar year 2005.
Lack of Data Affects EPA's Ability to Evaluate the Effectiveness of
Lead Rule Implementation and Enforcement:
In changing its reporting requirements in January 2000, EPA recognized
that it needed better indicators of the lead rule's implementation.
Regarding the 90th percentile results of lead monitoring, EPA noted
that in terms of routine reporting, these data are the only measure it
has for showing the lead rule's effectiveness and said that, without
such data, the agency would have no way to measure progress.[Footnote
19] Similarly, EPA maintained that having information on water systems'
corrective action milestones, along with quarterly violation and follow-
up information, would provide data on the status of lead rule
implementation and allow the targeting of compliance and enforcement
activities.[Footnote 20] Given the reduced number of milestones, EPA
indicated that it would be critical for states to report the
information completely and in a timely manner, and that the agency
would be following up with the states to ensure that such reporting was
occurring.
Despite the importance of the 90th percentile results and corrective
action milestones to evaluating the lead rule's implementation, our
analyses confirmed or identified significant and longstanding gaps in
the amount of information available. Although EPA attempted to ensure
that it had complete data on the results of lead testing, following the
publicity surrounding the incidence of lead contamination in the
District of Columbia, the problems with incomplete test result data
have continued and the agency has not followed up on the missing
milestone data. EPA has also been slow to take action on the potential
underreporting of violations. As noted earlier, following its March
2004 report on data reliability, EPA did not determine the reasons for
the lack of violations reported by some states. EPA's previous summary
evaluation, which was issued in October 2000, identified similar
indications of underreporting and called for targeted attention to the
applicable states and regions to address the issues and develop action
plans.[Footnote 21]
EPA needs complete, accurate, and timely data to monitor water systems'
progress in implementing the lead rule, identify potential problem
areas and best practices, and take appropriate action. In particular,
not having complete or reliable data on corrective action milestones or
violations makes it difficult to assess the adequacy of EPA and state
enforcement efforts. However, officials from EPA's Office of
Enforcement and Compliance Assurance told us that the amount of
enforcement resources devoted to the drinking water program--including
enforcement of the lead rule--has declined in recent years. They also
told us that while they hold monthly meetings with their counterparts
in EPA's regional offices and state officials to discuss the more
significant violators, the officials have not systematically evaluated
state enforcement efforts with regard to the lead rule. See appendix IV
for information on EPA and state enforcement actions, by type, from
1995 to June 2005.
EPA and state officials attribute the problems with lead rule data to
the complicated nature of the rule, the incompatibility of EPA and
state information management systems, and resource constraints. For
example, EPA officials noted that it is difficult to ensure that the
database contains complete information--and includes data on every
system that is required to test for lead in a particular period--
because the frequency of required testing can vary depending on whether
a system has qualified for reduced monitoring (and maintains that
status in future periods). The same circumstances also make it
difficult to develop trend data. EPA and state officials indicated that
the January 2000 minor revisions to the lead rule, which made
significant changes in states' reporting requirements, exacerbated
existing problems with the transfer of accurate and timely data from
the states to EPA. For that and other reasons, modifying the states'
data systems to incorporate the new reporting milestones has been
delayed. In addition to problems with the structure of the information
systems--and technical problems in actually transferring data from the
states to EPA--EPA and state officials acknowledge that reporting water
systems' milestone data has been a low priority. The officials
explained that since January 2004, states have been focusing their
limited resources on reporting the 90th percentile test results for
large and medium water systems.
EPA and the Association of State Drinking Water Administrators have
been working on a Safe Drinking Water Information System modernization
effort that should address at least some of current data problems,
according to EPA officials. Among other things, the modernization will
make it easier to transfer data between states and EPA so EPA's data
will be more timely. To improve the accuracy of the data, EPA's system
will have a component designed to validate state data before it is
entered into the federal database. As of October 2005, EPA had
completed the transition to its modernized system for the entry of new
data.
Weaknesses in the Regulatory Framework for the Lead Rule May Undermine
Public Health Protection:
Based on their experiences in implementing the lead rule, EPA, state,
and water system officials have identified six aspects of the rule for
which oversight could be improved or the requirements modified to
increase public health protection. Specifically, their experiences
indicate that (1) the sampling sites used for lead testing may no
longer reflect areas of highest risk, (2) reduced monitoring may not be
appropriate in some instances, (3) the homeowners who participate in
tap monitoring may not be informed of the test results, (4) controls
over when and how treatment changes are implemented may not be
adequate, (5) data on the effectiveness of lead service line
replacement programs are limited, and (6) states vary in how they apply
the lead rule when water systems sell drinking water to other systems.
In addition, some of the officials responsible for implementing the
lead rule and other drinking water experts believe that existing
standards for plumbing fixtures may be outdated. EPA is considering
modifications to the lead rule that will address some of the problems
we identified.
Sampling Sites May No Longer Reflect Areas of Highest Risk:
Under the lead rule, water systems must select sampling sites that are
considered to be at high risk for contamination. The rule defines Tier
1 sites as single-family structures served by lead service lines,
and/or containing lead pipes (or copper pipes with lead solder
installed after 1982).[Footnote 22] According to participants in EPA's
workshop on monitoring protocols and state officials we interviewed,
one problem is that EPA has never updated its site selection criteria
and at least one of the criteria is outdated. Specifically, enough time
has elapsed so that lead solder in plumbing installed from 1983 to 1986
is no longer "fresh" (lead solder was banned in 1986). Experts believe
that, by now, solder from that period has been coated by a naturally
occurring film that prevents lead leaching. Moving the sampling sites
to other Tier 1 locations--for example, homes served by lead service
lines--could be problematic. In the preamble to the lead rule, issued
in 1991, EPA cited a survey by the American Water Works Association
which estimated that only about 20 percent of the nation's community
water systems have lead service lines. Moreover, although the lead rule
required water systems to do a "materials evaluation" to identify an
adequate pool of high risk sampling sites, according to EPA the
evaluation did not assess pipe materials system-wide, and many systems
do not have a complete inventory of their service lines.
A related problem is that sampling locations have likely changed over
time as sites are no longer available or appropriate, and states may
not have procedures in place to ensure that these locations continue to
represent the highest risk sites.[Footnote 23] In this regard, EPA
requested information from the states on how they "ensure that site
locations were correctly followed during system sampling rounds." As
table 4 shows, a significant number of states may not be tracking
changes in water systems' sampling locations.
Table 4: State Activities to Ensure that Water Systems Are Taking Lead
Samples at Appropriate Sites:
Activity: State uses tracking mechanisms such as special forms or
unique codes to control sampling sites;
Number of states: 14.
Activity: State reported a less rigorous or less defined means of
oversight[A];
Number of states: 11.
Activity: State requires notification when systems change sampling
locations but does not otherwise track sampling;
Number of states: 5.
Activity: State does not review or track sampling[B];
Number of states: 8.
Activity: State did not answer question or provided information that
was nonresponsive;
Number of states: 12.
Source: GAO analysis of EPA's information request on state
implementation policies and practices.
[A] For example, some states reported comparing the actual sampling
locations with the sampling plans, some said that they advise their
systems to continue sampling at the locations used during the initial
sampling rounds, and others reported "reviewing" each round of sampling
but did not mention comparing the sites to the sampling plans.
[B] Two of these states (California and Vermont) reported that they
lacked the resources to ensure that their water systems are taking
samples at the correct locations.
[End of table]
Another uncertainty is whether systems that are on reduced monitoring-
-and have been allowed to reduce the number of samples they collect--
are taking samples from locations that represent the highest risk sites
based on previous testing.[Footnote 24] According to the lead rule,
these water systems must take their samples from sites included in the
pool of high risk sampling sites identified initially. Although the
systems have some indication of which sites within the pool have
historically tested at higher or lower lead levels, the rule is silent
on how sites within the pool are to be selected for reduced monitoring,
except that they must be "representative" of the sites required for
standard monitoring. In addition, the rule provides that states may
specify the sampling locations. EPA requested information from the
states on what role they play in selecting the sites used for reduced
monitoring. We analyzed the states' responses and found that, in most
instances, the states' role is limited; table 5 summarizes the results
of our analysis.
Table 5: State Role in Selecting Sites for Reduced Monitoring:
Activity: State requires that highest risk sites, based on previous
test results, are selected;
Number of states: 3.
Activity: State policy ensures that some of the highest risk sites,
based on previous test results, are selected[A];
Number of states: 9.
Activity: State provides general guidance and may review the water
systems' selections[B];
Number of states: 19.
Activity: State plays no role in selecting sites for reduced
monitoring;
Number of states: 12.
Activity: State did not answer question or provided information that
was nonresponsive;
Number of states: 7.
Activity: Total;
Number of states: 50.
Source: GAO analysis of EPA's information request on state
implementation policies and practices.
[A] Among other things, some states require systems to select every
other sampling site after ranking the sites by result from prior
testing or alternate sites in each round of sampling.
[B] For example, many of these states instruct their water systems to
focus on Tier 1 sites first (if their sampling pool also contains Tier
2 or Tier 3 sites) or say that the sites must be representative of
those in the pool or of the distribution system.
[End of table]
Reduced Monitoring May Not Be Appropriate in Some Instances:
According to EPA's lead rule, small and medium-sized water systems
whose test results are consistently at or below the action level may
reduce the frequency of monitoring from once every 6 months to annually
and, if acceptable results continue, to once every 3 years.[Footnote
25] In addition, systems of any size that operate within water quality
control parameters reflecting optimal corrosion control treatment, as
specified by the state, may reduce the frequency of monitoring under
the same schedule.[Footnote 26] The rule also lays out conditions under
which water systems must return to standard monitoring--for example,
small and medium-sized systems that have exceeded the action level. In
addition, states have the flexibility to require systems to resume
standard monitoring if the state deems it to be appropriate.[Footnote
27] We analyzed EPA's compliance data and found some instances that
raise questions about the states' decisions to allow reduced
monitoring. Specifically, we found that 49 large and medium water
systems were exceeding the 15-parts-per-billion action level and
appeared to be on reduced monitoring schedules.[Footnote 28] In
addition, our analysis indicates that 104 large and medium systems with
lead levels of 13-15 parts per billion also appear to be on reduced
monitoring schedules. Although this is allowable under EPA's
regulations, according to some state officials, systems with lead
levels just below the action level should be subject to closer scrutiny
and, thus, may not be good candidates for reduced monitoring.
To determine how states exercised their discretion with regard to
monitoring frequency, we reviewed their responses to EPA's information
request, which asked the states to describe how they determine if
reduced monitoring is appropriate. According to their responses, the
states by and large adhere to the requirements of the lead rule and
allow reduced monitoring whenever a water system's test results are at
or below the action level in consecutive monitoring periods.[Footnote
29] Specifically, 40 states reported that they follow the federal
regulation, 6 states indicated that they may be using some additional
criteria for their reduced monitoring determinations,[Footnote 30] and
4 states did not answer or provided information that was nonresponsive.
EPA did not ask for the states' views on whether reduced monitoring is
appropriate when a water system's test results are at or just below the
action level or on circumstances in which states might determine that
previously approved reduced monitoring is no longer appropriate--and
the states did not volunteer such information. None of the states
reported using other criteria, such as test results that are at or just
below the action level, to delay or rescind approval for reduced
monitoring.
A key issue is whether water systems should be required to resume
standard monitoring following a major treatment change so that the
potential effects of the change can be evaluated. Given the
circumstances in which lead contamination became a problem in the
District of Columbia, when a change in the system's disinfection
treatment impaired the effectiveness of corrosion control, such
decisions can be critical. In its information request on state
implementation policies and practices, EPA asked the states whether
they had ever required a system to conduct more frequent monitoring to
evaluate the potential effects of a treatment change. It would have
been useful to know more about the states' policies and practices in
this regard, including how often the states required additional
monitoring and the criteria they used in making such determinations.
However, EPA's question was limited in scope and, as table 6 shows, the
states often did not elaborate.
Table 6: States That Require More Frequent Monitoring to Evaluate the
Effects of Treatment Changes:
State policy: States answered yes without elaborating on the frequency
of--or criteria for--such decisions;
Number of states: 11.
State policy: States answered yes and included some indication of how
often they required additional monitoring (7 states) or the criteria
used for these decisions (5 states)[A];
Number of states: 12.
State policy: State answer was ambiguous; it is unclear whether state
has ever required more frequent monitoring after a treatment change[B];
Number of states: 7.
State policy: States answered no, generally without elaboration[C];
Number of states: 16.
State policy: States did not answer question or provided information
that was nonresponsive[D];
Number of states: 4.
State policy: Total;
Number of states: 50.
Source: GAO analysis of EPA's information request on state
implementation policies and practices.
[A] For example, two states indicated that requiring more frequent
monitoring was relatively common, while others reported that it was
required in certain instances or occasionally. Examples of criteria for
more frequent monitoring include (1) test results following a treatment
change that are close to the lead action level and (2) installing
treatment that is designed or expected to change water quality.
[B] Responses from these states referred to state regulations or policy
(e.g., "this is embedded in the approval process") but did not directly
answer the question of whether the state had ever required a system to
conduct more frequent monitoring. In several instances, it seems likely
that water systems have been required to monitor following a treatment
change.
[C] Several states indicated that additional monitoring was recommended
or encouraged following a treatment change but not required.
[D] Two states did not answer the question and the responses from the
other two states only addressed monitoring requirements following
changes to corrosion control treatment.
[End of table]
In our discussions with 10 states, we found a variety of policies and
practices regarding reduced monitoring. For example, officials from
California and New York told us that they do not approve reduced
monitoring--or are reluctant to do so--when water systems' test results
are close to the lead action level. On the other hand, Connecticut and
Massachusetts officials indicated that they have systems that are on
reduced monitoring despite test results close to the action level.
Several other states indicated that, in the case of large water
systems, approval for reduced monitoring is linked to whether the
systems are meeting their water quality parameters--not the results of
lead monitoring. On the issue of monitoring following a major treatment
change, some participants at EPA's monitoring workshop stated that
standard compliance monitoring does not adequately evaluate the impact
of treatment changes and that monitoring immediately after major
changes should be required. Several of the states we contacted also
favor increased monitoring under these circumstances; Florida and New
York, for example, require systems to return to semi-annual monitoring
following a treatment change. Pennsylvania officials agree that the
state and water system should revisit the treatment approach when
monitoring results indicate that a treatment change is affecting water
chemistry. However, the officials acknowledged that they may not find
out about the impact of treatment changes in a timely manner when water
systems are on a triennial monitoring schedule.
Homeowners Who Participate in Periodic Tap Sampling May Not Be Notified
of the Test Results:
According to EPA's information request on state implementation policies
and practices, only two states require their water systems to notify
homeowners of the results of lead testing--Texas (only when results
exceed the action level) and Wisconsin. At least 17 other states
indicated that notification may be occurring voluntarily to varying
degrees. Table 7 summarizes the results of our analysis.
Table 7: State Views on Extent to Which Water Systems Are Notifying
Homeowners of the Results of Lead Testing:
Extent of notification: All systems notify homeowners;
Number of states: 1.
Extent of notification: Some systems notify homeowners[A];
Number of states: 15.
Extent of notification: Test results are provided only on request;
Number of states: 2.
Extent of notification: State is not aware of any systems that notify
homeowners;
Number of states: 6.
Extent of notification: State does not know what systems are doing[B];
Number of states: 18.
Extent of notification: State apparently misinterpreted EPA's
question[C];
Number of states: 8.
Extent of notification: Total;
Number of states: 50.
Source: GAO analysis of EPA's information request on state
implementation policies and practices.
[A] The states' answers varied considerably. For example, some states
indicated that their larger water systems are providing results to
homeowners and some indicated that homeowners got the results only if
they exceeded the action level.
[B] In a few instances, the states indicated that they recommended that
their water systems provide homeowners with test results. For example,
Hawaii recommends notifying the homeowner if test results exceed 100
parts per billion, both to alert the homeowner and to verify that the
sampling protocol was followed correctly. However, the states in this
category did not have information on whether homeowners were actually
getting test results.
[C] EPA asked if water systems provide homeowners with the lead
sampling results derived from "any volunteer sampling program." Based
on their answers, it appears that these states may have believed that
EPA was asking about any testing above and beyond the regular sampling
program involving residential tap samples. For example, several states
said that they were not aware of any systems performing volunteer
sampling programs and others indicated that their systems will conduct
lead testing for homeowners on request.
[End of table]
Controls over When and How Treatment Changes Are Implemented May Not Be
Adequate:
In some instances, changes to other treatment processes can make
corrosion control less effective. According to EPA, state, and industry
officials, one of the biggest challenges in implementing the lead rule
is achieving "simultaneous compliance" with other rules, including, in
particular, rules related to total coliform bacteria, surface water
treatment, and disinfection by-products. Changing the type of
disinfectant a system uses to control bacteria, for example, can impair
the effectiveness of a system's corrosion control treatment to prevent
lead contamination. Among other things, states assuming primary
enforcement responsibility must have a process for ensuring that the
design and construction of new or substantially modified water system
facilities will be capable of meeting drinking water regulations,
including the lead rule.[Footnote 31] In addition, in its minor
revisions to the lead rule, EPA added a requirement that certain water
systems must notify the state no later than 60 days after making a
change in water treatment.[Footnote 32] However, the responses to EPA's
information request raise questions about the nature and extent of
states' reviews of treatment changes. On the one hand, 31 states
indicated that they had some type of proactive process to review or
evaluate treatment changes, before or after the treatment was
installed, including 15 states that reported requiring some or all of
the affected water systems to provide information on the potential
effects of treatment changes on corrosion control.[Footnote 33] On the
other hand, it appears that in at least 15 states, the plan review
process may be limited, or the states may not be receiving
notifications from all their water systems. For example, some states
indicated that their review process only covers changes to a system's
physical infrastructure--or specifically excludes changes in the
chemicals used in a process. Other states reported that they are not
learning of some treatment changes until they conduct comprehensive
inspections of the water systems, or that small systems in particular
are not notifying the state when they change their treatment processes.
Some of the participants in EPA's May 2004 workshop on simultaneous
compliance cited a need for additional regulations or guidance to help
ensure that the effectiveness of corrosion control is maintained when
water systems make changes to other treatment processes. For example,
some participants suggested that the lead rule should better define or
even specify the types of treatment changes that (1) should be reported
to the state and (2) trigger additional monitoring or analysis. Along
those lines, Washington state officials told us that certain changes,
such as switching the disinfectant from chlorine to chloramines or
making adjustments that affect the water's pH or alkalinity, may
warrant closer review because of the potential impact on corrosion
control. The officials also noted that additional guidance from EPA on
these matters would be helpful. Others believe that small water
systems, in particular, need more guidance on the potential effects of
various treatment changes, and that operator certification and training
programs should be updated to address these topics.
Data on the Effectiveness of Lead Service Line Replacement Programs Are
Limited:
Under the lead rule, drinking water systems may be required to replace
lead service lines if test results exceed the action level after
installing corrosion control and/or source water treatment. Some of the
participants in an EPA workshop on lead service line replacement and
state officials we contacted raised questions about the effectiveness
of replacement programs, in part because such programs often result in
partial replacement only. Water systems are responsible for replacing
only the portion of the service lines they own. While residential
customers may, at their option, pay the cost of replacing the rest of
the service line--typically, the portion running from the curb stop or
property line to the household plumbing system--some evidence suggests
that customer participation in such programs is generally low.
According to workshop participants, little conclusive information is
available on the extent to which removing lead service lines lowers
lead levels at the tap. In a survey of water systems conducted for the
American Water Works Association, 18 of 27 respondents indicated that
lead service lines were not responsible for the highest levels of lead
in drinking water, and 20 of 29 respondents reported no observed
linkage between lead service lines and lead levels in drinking
water.[Footnote 34] However, the survey did not include information on
test results before and after replacement of lead service lines. The
American Water Works Association Research Foundation is sponsoring a
study of the relative contributions of service lines and plumbing
fixtures to lead levels at the tap; the projected completion is fall
2008.
The limited data on the extent and results of lead service line
replacement programs make it difficult to draw conclusions about the
programs' effectiveness or the need for additional regulations or
guidance. As noted earlier, EPA's data on corrective action milestones-
-including the LSLR milestone--are incomplete. Moreover, few states
reported requiring systems to replace lead service lines in response to
EPA's information request on state implementation policies and
practices. Specifically, when asked if they have any systems that have
been required to do lead service line replacement, five states answered
"yes" without elaborating and seven states reported a total of 27 water
systems that are (or were) replacing lead lines.[Footnote 35] In
addition, although the lead rule requires testing following partial
service line replacement, it appears that neither the states nor EPA
are collecting and analyzing these test results. EPA asked states to
describe the process they use to ensure that water systems are
following the requirements for lead service line replacement. Among
other things, the lead rule requires systems to collect samples within
72 hours following partial replacement and to notify homeowners and
occupants of the results. States may waive the requirement that these
test results also be provided to the states. Of the 12 states that
reported requiring one or more water systems to replace lead service
lines, only one indicated that its water systems might be required to
report the results of service line testing to the state.[Footnote 36]
Some of the officials we contacted raised concerns about whether the
benefits of replacement are enough to justify what can be a significant
investment. For example, Iowa drinking water officials commented that
partial replacement is not a good use of resources because it disturbs
the line, releasing lead particulate matter into the water, and still
leaves half the lead line in place. In addition, officials from the
Syracuse Water Department told us that they are planning to replace
lead service lines at a cost of $5.3 million, although they are
skeptical that the effort will significantly reduce lead levels, citing
the age of the housing stock and lead contributions from internal
residential plumbing. The officials attribute the city's problem with
elevated lead levels to a simultaneous compliance issue. Specifically,
adding a phosphate-based corrosion inhibitor to further reduce the
corrosiveness of the drinking water solves one problem but creates
another: excessive phosphates in the system's discharges to a local
lake.
Participants at EPA's workshop on lead service line replacement and
some of the state and water industry officials we contacted suggested
measures to help ensure that water systems maximize the potential
benefits of replacement efforts. For example, some workshop
participants called for EPA guidance on strategies to encourage full
service line replacement and motivate customers to have their portion
of the line removed. Such strategies might include subsidizing a
portion of the replacement cost, offering low interest loans or
property tax relief, requiring disclosure of lead service lines in
property sales, or providing more information on the health effects of
exposure to lead in drinking water. Others suggested that prioritizing
the replacement of lead service lines would help ensure that
replacement activities focus on the populations most at risk from
exposure to elevated lead levels. Some utilities are already
prioritizing service line replacement using criteria such as locations
with vulnerable populations, including schools and child care
facilities, locations where test results have exceeded the action
level, and lines serving 20 or more people in an 8-hour day.
States Vary in How They Apply the Lead Rule When Water Systems Sell
Drinking Water to Other Systems:
We found some differences among the states in how interconnected water
systems--generally comprising a system that sells drinking water along
with one or more systems that buy the water--are required to monitor
for lead and report the results. According to EPA's proposed
definitions, these interconnected water systems are known as "combined
water distribution systems."[Footnote 37] The variations in state
implementation practices create differences in the level of public
information and, potentially, public health protection. Combined
distribution systems account for a large and growing share of the
nation's community water systems so differences in how they implement
the lead rule could have broad implications for public health
protection. Overall, EPA estimates that there are currently about 2,800
combined distribution systems that encompass about 13,900 individual
systems, likely accounting for a significant share of all community
water systems.[Footnote 38] Under EPA regulations that establish
general requirements for drinking water monitoring, states may modify
the monitoring requirements imposed on combined distribution systems--
typically by reducing the number of samples required within the
combined system--"to the extent that the interconnection of the systems
justifies treating them as a single system for monitoring
purposes."[Footnote 39] However, in the case of the lead rule, EPA
strongly discouraged such modifications, commenting that they would not
be appropriate because the primary source of elevated lead levels at
the tap is materials within the distribution system.
At least four of the states we contacted--Massachusetts, Michigan,
Oregon, and Washington--approved modified sampling arrangements at
combined distribution systems. For example, the Massachusetts Water
Resources Authority, which supplies all of the drinking water for 30
communities,[Footnote 40] currently takes lead samples at 440 locations
under its modified sampling arrangement--significantly fewer than the
1,720 samples that would be required if each of the consecutive systems
tested for lead individually. On the other hand, if the combined
distribution system represented a single water system, only 100 samples
would be required.
EPA does not have comprehensive information on the extent to which
states are approving modified sampling arrangements at combined
distribution systems--or the reporting practices used by such systems.
As table 8 shows, we found differences in how combined distribution
systems calculated and reported their 90th percentile test results.
Table 8: Examples of Different Reporting Practices for Lead Testing in
Combined Water Distribution Systems as of June 2005:
Water wholesaler: Detroit, MI;
Number of consecutive systems fully supplied by the wholesaler[A]: 72;
How the systems are listed in EPA's database: Wholesaler and each
consecutive system are listed separately;
How the 90th percentile lead levels are calculated and reported in
EPA's database: Separate lead level calculations for the wholesaler and
each consecutive system.
Water wholesaler: Massachusetts Water Resources Authority (MA);
Number of consecutive systems fully supplied by the wholesaler[A]: 30;
How the systems are listed in EPA's database: One listing for the
combined distribution system (including the wholesaler and the
consecutive systems);
How the 90th percentile lead levels are calculated and reported in
EPA's database: One overall result, reported for the combined
distribution system.
Water wholesaler: Philadelphia, PA;
Number of consecutive systems fully supplied by the wholesaler[A]: 3;
How the systems are listed in EPA's database: Wholesaler and each
consecutive system are listed separately;
How the 90th percentile lead levels are calculated and reported in
EPA's database: Separate lead level calculations for the wholesaler and
each consecutive system.
Water wholesaler: Portland, OR;
Number of consecutive systems fully supplied by the wholesaler[A]: 15;
How the systems are listed in EPA's database: Wholesaler and each
consecutive system are listed separately;
How the 90th percentile lead levels are calculated and reported in
EPA's database: One overall result; same 90th percentile reported for
wholesaler and each consecutive system.
Water wholesaler: Seattle, WA;
Number of consecutive systems fully supplied by the wholesaler[A]: 19;
How the systems are listed in EPA's database: One listing for the
combined distribution system (including the wholesaler and the
consecutive systems);
How the 90th percentile lead levels are calculated and reported in
EPA's database: One overall result, reported for the combined
distribution system.
Source: GAO analysis of data from EPA and the wholesaler water systems.
[A] The water wholesalers may also partially supply other systems or
provide emergency supplies, and may sell water to certain non-
transient, noncommunity water systems--systems that serve at least 25
people for more than 6 months in a year--and generally are subject to
the same requirements as community water systems.
[End of table]
Not only do the reporting practices approved by the states affect the
amount of information available to the public--they can also have
implications for the corrective actions that are taken to reduce lead
levels. For example, reporting one overall result for lead testing can
be misleading if the 90th percentile levels at individual consecutive
systems would have exceeded the action level. In the case of the
Massachusetts Water Resources Authority, although EPA's database
contains the overall result for the combined system, authority
officials calculated the 90th percentile results for each of the
consecutive systems and determined that lead concentrations at some of
them exceeded the action level.[Footnote 41] State officials in
Massachusetts told us that until recently, none of the consecutive
systems whose individual test results exceeded the action level were
required to meet public notification or public education requirements
or to replace lead service lines--as long as the result for the
combined system met the action level. Although EPA regional officials
concurred with such arrangements when they were first established, EPA
is now considering how to ensure that the lead rule requirements will
be applied to each community within a combined distribution system.
Based on discussions with EPA regional officials, Massachusetts has
already changed its policy and will be revisiting agreements with
combined distribution systems.
Outdated Plumbing Standards Hinder Efforts to Reduce Exposure to Lead
in Drinking Water:
The standards applicable to plumbing products are important to utility
managers who are responsible for ensuring the quality of water at the
tap but have little control over household plumbing. However, existing
standards may not be protective enough, according to some experts,
because testing has determined that some of the products defined as
"lead-free" under the Safe Drinking Water Act can still contribute high
levels of lead to drinking water. For example, although the act
prohibits the use of solder or other plumbing materials in the
installation or repair of any public water system if it is not lead-
free, lead-free is defined to include materials that contain small
amounts of lead. That is, solders and flux may contain up to 0.2
percent lead, pipes and pipe fittings may contain up to 8 percent lead.
In addition, plumbing fittings and fixtures may leach lead up to 11
parts per billion into drinking water and still be deemed lead-free,
according to voluntary standards established by an independent
organization and accepted by EPA.[Footnote 42]
NSF International (NSF)--a not-for-profit, non-governmental
organization involved in standards development and product
certification--established the standard in 1997.[Footnote 43] NSF used
a voluntary consensus process that included representatives from
regulatory agencies, industry, water suppliers, consultants, and other
users of the products governed by the standard.
One problem with the current regulatory framework is that certain
devices used in or near residential plumbing systems are not covered by
all standards for lead-free plumbing. Table 9 shows how the standards
governing lead content and lead leaching apply to specific categories
of products.
Table 9: Applicability of Standards for Lead-Free Plumbing Products:
Type of plumbing product: Endpoint devices, such as kitchen and
lavatory faucets, water dispensers, drinking fountains, and residential
refrigerator ice makers[A].
8% limit on lead content;
11 ppb limit on lead leaching.
Type of plumbing product: In-line devices, such as meters and
valves[B].
8% limit on lead content.
Source: EPA and NSF International.
[A] NSF defines endpoint devices as mechanical plumbing devices,
components, and materials that are typically installed with the last
liter of the distribution system and are intended by the manufacturer
to dispense water for human consumption.
[B] NSF defines in-line devices as devices installed on a service line
of building distribution system downstream of the water main and before
endpoint devices. They include devices in a building used to measure or
control the flow of water in treatment, transmission, or distribution
systems and are in contact with drinking water.
[End of table]
Some of the products that are not covered by the voluntary leaching
standard have been found to contribute high levels of lead to drinking
water during testing. For example, tests conducted by NSF indicate that
certain meters and valves may contribute high levels of lead to
drinking water. At our request, NSF compiled test results for a
nonprobability sample of water meters and valves that had been
submitted for evaluation. While all of the products in the sample were
well below the 8 percent limit on lead content, the test results showed
that the amount of lead leached from the selected water meters ranged
from 0.4 parts per billion up to 39 parts per billion and, in the case
of valves, ranged from a low of 4.1 parts per billion to as much as 530
parts per billion. An NSF official commented that although these
products are representative of what is submitted to NSF for testing,
they are probably not representative of what is available in the
marketplace because some manufacturers have two product lines--a low-
lead line for buyers who specify products that meet NSF Standard 61 and
a higher-leaded line for other buyers.
Another issue is that NSF's testing protocol for lead leaching may not
accurately reflect actual conditions and may need to be modified. One
recent study identified several aspects of NSF's testing protocol that
should be reevaluated, including, for example, the chemistry of the
water in which tests are conducted. After demonstrating that
potentially unsafe devices could pass NSF's test, the study concluded
that the protocol "lacks the rigor necessary to prevent installation of
devices that pose an obvious public health hazard."[Footnote 44] NSF
officials told us that they are aware of the concerns and have already
made some clarifications and changes to the protocol. NSF has also
established a task force, the Drinking Water Additives Joint Committee,
which will be reviewing the protectiveness of NSF Standard 61 and
related testing.
Representatives of NSF, water utilities, and researchers also took
issue with the standard for lead content, noting that it has not been
updated to reflect current manufacturing capabilities and practices.
According to the American Water Works Association, manufacturing
technology in the plumbing industry has improved since the lead-free
definition was established nearly 20 years ago, and today's plumbing
products contain less lead as a result. Data on the lead content of
plumbing products voluntarily submitted to NSF for evaluation, shown in
table 10, suggest that manufacturers can produce products with lead
levels well below the 8 percent standard.
Table 10: Summary of NSF Test Results Regarding Lead Content of
Plumbing Products Voluntarily Submitted to NSF for Certification:
Lead content: 1.0% or less;
Results of testing on faucets: Cumulative number: 2,069;
Results of testing on faucets: Cumulative percent: 37.3;
Results of testing on meters and valves: Cumulative number: 930;
Results of testing on meters and valves: Cumulative percent: 75.1.
Lead content: 3.7% or less;
Results of testing on faucets: Cumulative number: 5,495;
Results of testing on faucets: Cumulative percent: 99.0;
Results of testing on meters and valves: Cumulative number: 1,104;
Results of testing on meters and valves: Cumulative percent: 89.1.
Lead content: 8.0% or less;
Results of testing on faucets: Cumulative number: 5,551;
Results of testing on faucets: Cumulative percent: 100.0;
Results of testing on meters and valves: Cumulative number: 1,236;
Results of testing on meters and valves: Cumulative percent: 99.8.
Total products tested;
Results of testing on faucets: Cumulative number: 5,551;
Results of testing on faucets: Cumulative percent: 100.0;
Results of testing on meters and valves: Cumulative number: 1,239;
Results of testing on meters and valves: Cumulative percent: 100.0.
Source: NSF.
Note: This table contains cumulative data on the number and percent
lead content of faucets, meters, and valves voluntarily submitted to
NSF for certification. The data should not be generalized beyond this
group.
[End of table]
According to NSF, the extent to which lead leaches from products
containing lead is not directly proportional to the level of lead used
in any one alloy contained in the product.[Footnote 45] NSF identified
several factors that contribute to the level of leaching, including the
corrosiveness of the water, lead content, the extent of the leaded
surface area, and the process used to manufacture the product. However,
the state regulators, water industry representatives, and other experts
we interviewed generally agreed that lowering the existing standard for
lead content is feasible and would provide an extra margin of safety.
Both the Copper Development Association and the Plumbing Manufacturers
Institute acknowledged that most plumbing products are below the 8
percent limit on lead content but prefer that plumbing standards focus
on performance--the leaching of lead--rather than content.
We did not attempt to determine the extent to which the standards for
lead-free plumbing products are enforced. According to NSF, the use of
plumbing products within a building is generally regulated at the
state, county, and city levels through plumbing codes. NSF
representatives also said that all model plumbing codes reference NSF
Standard 61 for pipes, fittings, and faucets.[Footnote 46] NSF reports
that most faucets sold at the retail and wholesale level are certified
to meet Standard 61, but fewer valves and other in-line devices are
certified to the standard because it is not required in model plumbing
codes.
State efforts to implement more stringent standards for plumbing
products appear limited, based on our discussions with federal and
state regulators and representatives of the water industry and plumbing
manufacturers. We identified two states in which such activities have
occurred:
* In California, the Attorney General sued 16 manufacturers and
distributors of kitchen and bathroom faucets in the early 1990s,
alleging that lead leaching from brass components of their faucets
violated California law.[Footnote 47] The suit resulted in settlement
agreements with the companies and a related court decision in which
they agreed to reduce leaching levels. According to an official with
the California Attorney General's Office, the limit on lead leaching is
5 parts per billion for residential kitchen faucets and 11 parts per
billion for all other faucets.
* According to officials with the Massachusetts Board of State
Examiners of Plumbers and Gas Fitters, in 1995 the board established a
3 percent limit on the lead content of endpoint and in-line devices
installed inside the home. Board officials acknowledge that enforcement
of the standard is difficult because products containing more than 3
percent lead may be sold in Massachusetts stores as long as the
products are not installed in Massachusetts homes. Moreover, the
packaging does not indicate lead content or certification to the state
standard.
At the local level, some water systems are installing no-lead meters--
which contain less than 0.25 percent lead--because of concerns about
the potential impact of leaded brass meters on lead levels at the tap.
In some instances, the water systems are targeting their meter
replacement to buildings housing schools and child care facilities.
EPA Is Considering Modifications to the Lead Rule to Address Some
Problem Areas:
Based on its year-long evaluation of the lead rule and how it is being
implemented, EPA concluded that the conditions that led to elevated
lead levels in the District of Columbia were not indicative of the
conditions nationwide. However, in November 2004, while its evaluation
was still ongoing, EPA issued a guidance memorandum to reiterate and
clarify specific regulatory requirements after the agency's review of
state programs and some press reports identified inconsistencies in how
drinking water systems and the states were carrying out the regulation.
The memorandum focused on requirements related to collecting samples
and calculating compliance. In addition, in March 2005, EPA announced a
Drinking Water Lead Reduction Plan to improve and clarify specific
areas of the rule and the agency's guidance materials. The plan
identifies nine targeted revisions of the regulations and updates to
two guidance documents.
Specifically, EPA's lead reduction plan calls for regulatory revisions
to the following:
* Monitoring requirements. These revisions would (1) clarify the number
of samples required, (2) clarify the number of locations from which
samples should be collected, (3) modify definitions of "monitoring
period" and "compliance period," (4) clarify the requirement to take
all samples within the same calendar year, and (5) reconsider allowing
large water systems that exceed the lead action level to qualify for
reduced monitoring as long as their test results for water quality
parameters are within acceptable limits.
* Treatment requirements. These revisions would require water systems
to notify the state of treatment changes 60 days prior to the change
rather than within 60 days following the change.
* Customer awareness requirements. These revisions would (1) require
water systems to disclose test results to homeowners and occupants who
participate in tap monitoring programs and (2) permit states to allow
water systems to modify flushing instructions--the amount of time that
homeowners are advised to run water before using it--to address local
circumstances.
* Lead service line replacement requirements. These revisions would
require water systems to reevaluate lead service lines that previously
"tested out" of the replacement program as a result of low lead levels
if a subsequent treatment change causes the systems to exceed the
action level.[Footnote 48]
In addition, EPA is considering updating its 1994 guidance on lead in
drinking water in schools and non-residential buildings, along with its
1999 guidance on simultaneous compliance.
So far, EPA has not released additional details on the nature of the
changes being considered in some areas (e.g., number of samples and
sampling locations) or what prompted its determination that revisions
to the lead rule and related guidance might be warranted. An EPA
workgroup, which was established when the lead reduction plan was
issued, is developing the proposed rule for the regulatory changes,
with a goal of releasing a proposal in late 2005 or early 2006.
Revisions to the guidance documents are scheduled to be completed about
the same time.
While the exact nature of some changes has yet to be defined, we asked
the 10 states we contacted for their views on whether the proposed
revisions would improve implementation of the lead rule. For the most
part, state officials were in favor of the proposed changes involving
the monitoring protocols. Although they wanted more details on how the
requirements would be revised, they believed the changes to be
relatively minor. In particular, most state officials agreed that large
water systems that exceed the action level should not be allowed to
reduce the frequency of lead monitoring based solely on their ability
to meet water quality parameters.
Regarding earlier notification of treatment changes, officials from all
10 states we contacted supported such a revision, particularly for
major treatment changes. The officials indicated that the notification
requirement would not have a significant impact on their own practices
because each of the states already had some type of process in place to
permit or review treatment changes. Five of the states questioned
whether 60 days advance notice would be sufficient to allow an adequate
review. Several states suggested that EPA should require expedited
monitoring of lead levels following major treatment changes--or issue
guidance on when it would be appropriate for states to require such
monitoring--and that EPA should issue guidance on what constitutes a
major treatment change. In addition, officials from two states
commented that EPA should require state approval of the treatment
changes in addition to advance notification.
On the proposed revisions involving customer awareness, all 10 states
agreed that homeowners that participate in the tap sampling program
should be informed of the test results--particularly if the results for
individual homeowners exceed the lead action level--whether or not the
90th percentile result for the entire system exceeds the action level.
One state was concerned about the additional resources that would be
required to track the water systems' actions. Nearly all of the states
also endorsed the proposal to give states and water systems more
flexibility in determining what flushing instructions are appropriate
in particular situations. Some states suggested that EPA guidance on
making such determinations would be useful.
Regarding the proposed reevaluation of lead service lines that tested
out of a replacement program, the states' views were mixed. Although
five states generally endorsed the idea, the other five states raised
several concerns, including the potential cost to local drinking water
systems, the administrative burden that such a requirement would impose
on states, and the need for more specific information on the types of
treatment changes that would trigger a reevaluation of lead service
lines.
Over the long term, EPA plans to examine other issues related to lead
rule implementation that may need to be addressed through regulation or
guidance. EPA officials have indicated that, in some instances, they
need more information to determine whether changes are warranted, and
they are in the process of collecting and analyzing data, or have
relevant research projects underway. According to EPA officials, some
of the issues they plan to review include the sampling protocol,
monitoring and reporting requirements for consecutive systems, the
impact of disinfection treatment on corrosion control, and the
requirements for lead service line replacement.
Limited Data Indicate Few Schools and Child Care Facilities Test or
Take Other Measures to Control Lead in Their Water Supplies:
Little information exists on the results of activities initiated after
enactment of the Lead Contamination Control Act (LCCA) of 1988,
including the recall of lead-lined water coolers from schools and child
care facilities. More recent efforts to detect and remediate lead in
the drinking water at such facilities also appear limited. As a result,
the extent to which drinking water may contain unacceptable levels of
lead at schools and child care facilities nationwide is uncertain. In
addition, no clear focal point exists at the federal or state level to
collect and analyze the results of testing and remediation efforts.
Moreover, state and local officials say that addressing other
environmental hazards at schools and child care facilities takes
priority over testing for lead in drinking water.
Little Information Exists on the Results of the Recall of Lead-Lined
Water Coolers and Other Activities Prompted by the LCCA:
The LCCA, enacted in 1988, laid out a number of requirements for EPA,
the Consumer Product Safety Commission, and the states to address the
potential risks of lead contamination in water supplies serving schools
and child care facilities. Among other things, the act:
* banned the manufacture and sale of drinking water coolers containing
lead-lined tanks and other water coolers that are not lead-free,
* required EPA to publish a list of such coolers and distribute it to
the states along with guidance on testing for and remedying lead
contamination in drinking water, and:
* required the Consumer Product Safety Commission to issue an order
requiring manufacturers and importers to (1) repair or replace the
coolers or (2) recall and provide a refund for them because coolers
containing lead-lined tanks were deemed to be imminently hazardous
consumer products.
In addition, the LCCA required states to establish programs to assist
local agencies in addressing potential lead contamination. While the
nature and extent of state activities varied widely, the program was
never funded, according to EPA officials. In 1996, the requirement was
determined to be unconstitutional.[Footnote 49]
To support the required recall, EPA identified six models of water
coolers containing lead-lined tanks, all produced by one company and
manufactured prior to April 1979. EPA could not obtain information on
the number of units produced. The Consumer Product Safety Commission
broadened the recall order to include all tank-type models of drinking
water coolers manufactured by the company, whether or not the models
were included on EPA's list.[Footnote 50] Under the terms of the order,
the manufacturer established a process under which qualified owners of
the affected coolers could request a refund or replacement. The
manufacturer was also required to notify appropriate officials and
organizations, including state and school officials and day care
centers, about the recall and the availability of refunds and
replacements.
Little information is available to determine the effectiveness of the
recall effort in removing lead-lined water coolers from
service.[Footnote 51] Not only is the number of coolers affected by the
recall unknown, but the Consumer Product Safety Commission did not have
summary data on the results of the recall. An agency official confirmed
information in a 1991 Natural Resources Defense Council report that, as
of 1990, the Commission had received approximately 1,200 inquiries
about the recall, 1,373 coolers had been determined to be eligible for
replacement, 514 had been replaced, and 105 refunds had been mailed to
customers.[Footnote 52] However, the official also said that many more
coolers were replaced after that date and that by 1993, the
manufacturer had received approximately 11,000 inquiries about the
recall. The official believed that the actual number of replacements
was potentially 10 times greater than those reported in 1991 and the
refunds four to five times greater. In addition, the recall order did
not specify an end date for filing a refund or replacement request so
an unknown number of coolers could have been taken out of service
without the knowledge of the manufacturer or the Commission subsequent
to 1993.
According to several state and school officials we interviewed,
virtually all of the water coolers affected by the recall have been
replaced or removed, either as a result of the publicity surrounding
the recall or because they had already been taken out of service. Some
of the six models covered by the recall were manufactured in the 1950s
and 1960s and are likely to have been retired because of their age or
maintenance problems.
Beyond the recall effort, little or no data are available to assess the
effectiveness of other actions taken in response to the LCCA. For
example, little information is available on the extent to which schools
and child care facilities were inspected to check potential lead
contamination from water coolers that were not lead-free. While the act
did not require EPA or the states to track or report on the results of
testing, EPA was responsible for publishing guidance and a testing
protocol to assist schools in determining the source and degree of lead
contamination in school drinking water supplies and remedying such
contamination. EPA published guidance for both schools and child care
facilities in 1989 and 1994, respectively.[Footnote 53]
We found no information indicating how pervasive lead-contaminated
drinking water in such facilities nationwide or within particular
states might be, but several studies conducted in the early 1990s
contained some limited information on testing efforts:
* In 1993, we reported on the results of a survey of 57 school
districts in 10 states.[Footnote 54] We found that 47 districts were
able to provide data on the results of testing, which showed that about
15 percent of the 2,272 schools tested had drinking water containing
levels of lead considered unacceptable by EPA. We also contacted child
care licensing agencies in 16 states to obtain information on their
activities for addressing lead hazards and found that none of the
agencies routinely inspected child care facilities for such hazards.
* A 1990 report by EPA's Inspector General found that, of the 13 school
districts surveyed, 10 conducted some testing for lead in drinking
water and 8 detected contamination, with some results exceeding
acceptable levels by a wide margin.[Footnote 55]
* According to the Natural Resources Defense Council's 1991
study,[Footnote 56] 47 states reported some testing of school drinking
water supplies, including 16 states that tested in "a few" to 25
percent of their schools, 27 states that tested from 25 percent to 82
percent of the schools, and 4 states that tested 95 percent or more of
their schools. The study also found that 17 states reported testing at
child care facilities.
In addition to these earlier studies, in 2004 EPA asked the states to
provide information on current state and local efforts to monitor and
protect children from lead exposure in drinking water at schools and
child care facilities.[Footnote 57] As part of that effort, seven
states also reported on the results of local testing following passage
of the LCCA, stating that elevated lead levels were found in at least
some of the locations tested.[Footnote 58] However, the states differed
significantly in the extent of their testing and how they summarized
the results. In five of the states, the results generally ranged from
about 1 percent to 27 percent of samples, facilities, or districts with
lead levels considered unacceptable by EPA--but the other two states
finding elevated lead levels used a different assessment measure.
Current Efforts to Detect and Remediate Lead in Drinking Water at
Schools and Child Care Facilities Also Appear Limited:
The extent of current testing and remediation activities for lead in
school and child care facility drinking water appears limited. The LCCA
does not require states to track or report such activities and, based
on the information that EPA collected from the states in 2004 and our
own contacts in 10 states, few states have comprehensive programs to
detect and remediate lead in drinking water at schools and child care
facilities. Figure 4 shows the nature and extent of these activities;
about half the states reported no current efforts.
Figure 4: Summary of State Efforts to Address Lead in Drinking Water at
Schools and Child Care Facilities:
[See PDF for image]
Notes: (1) All states but Colorado responded to EPA's information
request; about half the states submitted multiple responses, generally
because responsibility for addressing lead issues at schools and child
care facilities is shared by both health and environmental agencies.
(2) The figure summarizes the most frequently reported activities by
the states. While nearly half the states reported no activities, others
reported activities in more than one of the categories we used. In
addition to the activities summarized in figure 4, 26 states reported
having lead poisoning prevention programs that include testing blood
lead levels of children and investigating the source of any problems
identified. We did not include these programs in our summary because
the investigations usually focus initially on a child's home
environment and the presence of lead paint. However, they could
ultimately involve testing the drinking water at schools or child care
facilities.
(3) Some states reported testing for lead at schools or child care
facilities that have their own water systems. We did not include this
activity in figure 4 because such testing is required under the Safe
Drinking Water Act.
[End of figure]
Of the five states that reported having testing requirements, four--
Connecticut, New Hampshire, South Carolina, and Vermont--require child
care facilities to test their drinking water for lead contamination
when obtaining or renewing their licenses.[Footnote 59] In the fifth
state (Massachusetts), the testing requirement focuses on schools.
Water systems must include two schools among their sampling sites in
each round of lead testing, although the school data are not included
in the 90th percentile calculation to determine whether lead levels
exceed the action level. Massachusetts officials told us that, although
the testing requirement has been in place since 1992, it has not
received much attention until recently. The officials acknowledged that
most water systems repeatedly used the same schools as sampling sites
for the sake of convenience and said that the state has never
summarized the results of the school testing. Given the renewed
concerns about lead contamination following the detection of lead in
the District of Columbia's drinking water, Massachusetts now requires
water systems to rotate testing among schools and child care facilities
and plans to issue a summary report at the end of 2005.
In addition to these requirements, Florida's Department of
Environmental Protection reported to EPA that it had established a
voluntary program. Specifically, the state designated child care
facilities as Tier 1, high risk sites and gave water systems the option
of using the facilities as lead sampling sites and including them in
the calculation of the 90th percentile lead level. (According to a
Florida official, to be included as a sampling site, the child care
facility must meet other Tier 1 criteria, such as being served by a
lead service line.) However, when we followed up with state officials,
they said that they had no way of tracking the extent to which water
systems were actually including child care facilities as sampling
sites.
The scope of the targeted testing reported by 12 states varied widely,
from a single school district in Pennsylvania to over 1,300 homes and
child care facilities in Indiana. Several states indicated that they
were focusing on potential high risk locations. EPA regional offices
helped to initiate some limited testing in a few states, including
Massachusetts, New Jersey, New York, and Pennsylvania; the testing
generally focused on a few of the states' largest school districts. The
state-sponsored surveys to determine the status of testing by local
agencies also varied, with some covering all schools within the state
and others focusing on a smaller subset of schools. In Washington, the
state recently set aside $750,000, including $400,000 from its drinking
water state revolving fund, to partially reimburse school districts for
the cost of monitoring for lead in elementary schools' drinking water.
EPA officials attributed the relatively low level of state activity in
recent years to the aftereffects of a 1996 lawsuit brought by the
Association of Community Organizations for Reform Now against the state
of Louisiana for not doing enough to implement the LCCA. The case
resulted in a federal circuit court decision declaring that part of the
LCCA was unconstitutional. Specifically, the court ruled that the
federal government did not have the authority to require states to
establish a remedial action program as outlined in the LCCA.[Footnote
60] While Louisiana reported to EPA that the case "had the unintended
effect of ending the lead program in schools for the state of
Louisiana," none of the 10 states we contacted cited the ruling as a
factor in limiting their efforts.
To obtain more information about testing and remedial actions in
individual cities, we contacted five school districts--Boston, Detroit,
Philadelphia, Seattle, and Syracuse. Table 11 shows the extent and
results of testing within each district, and provides information on
the various approaches school administrators have used to address the
lead contamination.
Table 11: Information on Recent Efforts to Test for and Remediate Lead
in Drinking Water in Five School Districts:
School district: Boston, Mass; Public Schools[A];
Scope and results of testing: Scope: Testing focused on kitchen
facilities used to prepare food and was conducted between 2003 and 2004
at the district's central kitchen facility and 38 schools with on-site
kitchen facilities;
Results: Lead levels in water from 17 kitchen facilities, including the
central kitchen, exceeded 20 ppb; Type and cost of remedial actions:
Actions: Manual flushing for at least 1 minute each day in all kitchens
and an automatic flushing program at the central kitchen and 22 school
buildings with kitchen facilities; Cost: Not available.
School district: Detroit, Mich; Public Schools;
Scope and results of testing: Scope: The district tested 21 water
fountains and other outlets in one middle school as of November 2002.
(Testing was also conducted at one other middle school, but the number
of outlets included was not available.);
Results: Lead levels in water from 16 drinking water outlets in one
middle school exceeded 15 ppb; Type and cost of remedial actions:
Actions: For the short term, shutting off outlets with elevated lead
levels, doing manual flushing, and providing bottled water. For the
long term, installing a water treatment system, replacing lead piping
and fixtures, and re-routing a service line serving the school; Cost:
An estimated $9,000 for bottled water and $5,865 for the water
treatment system, plus $800 in annual maintenance costs.
School district: Philadelphia, Pa; School District[B];
Scope and results of testing: Scope: As a result of consent orders in
1999 and 2000, the school district was required to test all drinking
water outlets at 299 schools and other buildings, or about 30,000
outlets in total.[C];
Results: As of March 2004, the district had detected lead levels over
20 ppb in approximately 4,600, or roughly 15 percent, of the outlets
tested; Type and cost of remedial actions: Actions: For the short term,
shutting off outlets with elevated lead levels and providing bottled
water. For the long term, replacing or removing fixtures; Cost: An
estimated $6 million through February 2005.
School district: Seattle, Wash; Public Schools[B];
Scope and results of testing: Scope: In 2004, the district tested all
interior drinking water outlets considered suitable for use, about
2,400 outlets in total;
Results: Lead levels at 600 of the outlets, or 25 percent, exceeded 20
ppb; Type and cost of remedial actions: Actions: For the short term,
shutting off outlets with elevated lead levels and providing bottled
water. For the long term, fixing or replacing fixtures, installing
filters, and replacing piping for any outlet where lead levels exceeded
10 ppb; Cost: An estimated $15 million upon completion in 2007.
School district: Syracuse, N.Y; City School District;
Scope and results of testing: Scope: The district tested specific
interior drinking water outlets in 50 schools and other buildings,
beginning in August 2003;
Results: 23 of the facilities had at least one drinking water outlet
with lead levels over 20 ppb; Type and cost of remedial actions:
Actions: For the short term, shutting off outlets with elevated lead
levels. For the long term, installing in-line carbon filters at each
outlet with elevated lead levels. (Other measures such as pipe
replacement and removal of fixtures are still under discussion.); Cost:
An estimated $100,000 through March 2005.
Source: EPA and school districts.
[A] Boston officials told us that they focused on kitchen facilities in
their most recent testing because the district had already installed
bottled water at many drinking water outlets after earlier testing had
disclosed elevated lead levels.
[B] Both Philadelphia and Seattle had also conducted some testing prior
to the more recent efforts summarized in this table.
[C] A 2003 modification to the earlier consent orders removed the
requirement to test bathroom faucets.
[End of table]
The cities we contacted differed in the testing protocols they used to
test for lead in school drinking water.[Footnote 61] While three of the
cities (Boston, Philadelphia, and Syracuse) followed EPA's guidance,
using a 250 milliliter sample and a limit of 20 parts per billion for
triggering follow-up action, Seattle took a more conservative approach.
Using the same sample volume, the school board established 10 parts per
billion as its standard for follow-up action. Detroit, on the other
hand, used the same protocol that is required for public water systems-
-a 1 liter sample and 15 parts per billion as the limit.
Some of the remediation measures adopted by the cities we contacted
were effective, including installing in-line filters, replacing pipes,
and removing fixtures at outlets with test results indicating high lead
levels. Other measures required more attention and others inadvertently
created new issues for officials to deal with. For example, a Seattle
school official noted that the district decided against instituting a
flushing program in its schools because it was too difficult to ensure
that staff in individual schools would follow through with the flushing
every day. In Boston, a school official told us that using bottled
water posed a problem because staff had to make sure that replacement
bottles were always available and because it created other issues with
pests, vandalism, and spillage.
The Extent to Which Drinking Water at Schools and Child Care Facilities
Is Contaminated by Lead Is Uncertain, in Part, Because No Clear Focal
Point Exists to Collect Available Data:
While a number of cities have detected elevated lead levels in school
drinking water, and a few states are beginning to collect information
on the status of local testing efforts, little information exists on
the extent to which drinking water at schools and child care facilities
nationwide may contain unacceptable levels of lead. No focal point
exists at the federal or state level to collect and analyze test
results or information on cost-effective remediation strategies. As a
result, it is difficult to get a sense of the pervasiveness of lead
contamination in the drinking water at schools and child care
facilities, and to know whether a more concerted effort to address the
issue--such as mandatory testing--is warranted. In addition,
remediation measures such as providing bottled water, regularly
flushing water lines, installing filters, and replacing fixtures and
internal piping vary widely in cost and complexity, among other
factors. State and local officials have expressed concern about not
having sufficient information on the measures, their pros and cons, and
circumstances in which particular measures might be more appropriate
than others.
At the federal level, EPA's Office of Ground Water and Drinking Water
sets drinking water standards and other requirements for public
drinking water systems, but generally does not have any direct
oversight responsibility for the quality of drinking water in schools
or child care facilities.[Footnote 62] The U.S. Department of Education
(Education) is responsible for, among other things, providing guidance
and financial assistance to state and local education agencies for
elementary and secondary schools. Education's Office of Safe and Drug
Free Schools recently signed a memorandum of understanding with EPA,
the Centers for Disease Control and Prevention, and various water
industry associations with the goal of reducing children's exposure to
lead in drinking water at schools and child care facilities.[Footnote
63] However, according to an Education official, the department does
not have legal authority to compel schools to test for lead in the
drinking water. Officials in Washington state saw a need for closer
coordination between EPA and Education. The officials believe that
local education officials are more likely to respond to guidance on
lead and other environmental health issues if Education were to be
involved in developing it.
At the state level, responsibility for the environmental health of
schools and child care facilities is usually fragmented among multiple
agencies. According to EPA, in most states, the same agency that
administers the drinking water program--generally the state's
department of environmental protection or department of health--is also
responsible for implementing the LCCA. However, we also learned from
EPA that the state agencies responsible for administering education
programs and licensing child care facilities are usually the ones with
the regulatory or oversight authority over environmental conditions in
schools and child care facilities. (As noted earlier, some states also
have lead poisoning prevention programs to monitor blood lead levels in
children and investigate the source of lead exposure when the levels
are elevated.) According to some of the states we contacted, the level
of coordination among state agencies needs to be improved and the lack
of a centralized authority at the state level has complicated efforts
to plan and implement a testing program for lead in water in some
school districts. For example, in Pennsylvania, state drinking water
officials said that several other agencies, including the Departments
of Health, Education, and Public Welfare, have a role in overseeing
schools and child care facilities--but it was unclear which agency
would be best suited to manage a testing program if one were to be
required. In contrast, Connecticut officials said that having both the
drinking water program and the child care licensing program housed
within the same department has been an advantage because it is easier
for the programs to share information and coordinate their activities.
We also contacted several school and child care associations to find
out if they were involved in or aware of efforts to promote testing for
lead in drinking water, collect and analyze the results of testing, or
set standards for the environmental health of the facilities. According
to a representative of the National Child Care Association, until
recently the association had not been aware of any issues regarding
lead in drinking water at child care facilities or involved in any
effort to promote testing.[Footnote 64] The representative commented
that one challenge to distributing information on lead in drinking
water to child care facilities is the fragmented nature of the child
care industry. While the National Head Start Association has been
involved with lead poisoning prevention in general, the organization
has not done anything specifically related to lead in drinking
water.[Footnote 65] The Healthy Schools Network, Inc. promotes the
development of state and national policies, regulations, and funding
for environmentally safe and healthy schools. Although the network has
published some fact sheets that address the potential health risks from
lead exposure, lead in drinking water has not been a priority compared
with other environmental issues. While none of these organizations were
parties to EPA's recent memorandum of understanding, they have been
actively engaged in assisting EPA as the agency revises its guidance
for schools and child care facilities, according to EPA officials.
State and Local Officials Say Addressing Other Environmental Hazards
Takes Priority over Testing for Lead in Drinking Water at Schools and
Child Care Facilities:
According to state and local officials, children may be exposed to a
variety of environmental hazards at schools and child care facilities,
including asbestos, lead in paint or dust, mold, and other substances
that affect indoor air quality. The officials told us that dealing with
such problems often takes priority over checking for lead in drinking
water because, in the case of the other problems, more information is
available on the nature and extent of the potential health risks
involved. For example, many of the officials we interviewed said that
the most significant source of lead exposure--and thus, their primary
concern--was lead in paint. Officials from two states also mentioned
that lead in jewelry, toys, or pottery is a more significant source of
exposure than lead in drinking water. Washington state officials told
us that child care facilities also have many competing priorities and
cited food handling as one of their major concerns.
At the local level, officials talked about dealing with multiple health
and safety issues and the difficulty of prioritizing limited resources.
For example, in Detroit, one official told us that dealing with
asbestos takes priority over all other environmental concerns,
including lead in drinking water. Another Detroit official commented
that indoor air quality is another priority because "issues related to
breathing are very important to educators." In Philadelphia, a school
official noted that a major source of lead in the school district is
dust, a problem that requires continuing attention from the maintenance
staff, which must set aside time to scrub the areas where dust
collects. A Seattle official also mentioned the difficulty posed by
competing needs for limited funds. He indicated that the competition is
not only among environmental issues, such as mold and asbestos, but, on
a broader level, between maintenance and basic classroom expenditures.
Without additional resources--or more compelling evidence that lead in
drinking water should be a higher priority--state and local officials,
as well as representatives of industry groups, were reluctant to
support calls for mandatory testing for lead in drinking water in
schools and child care facilities. Many of the officials we interviewed
said that more research is needed on several aspects of the lead issue.
In addition to wanting more information on the extent to which lead
contamination in schools and child care facilities is a problem, some
officials also wanted more information on the circumstances in which
particular remediation approaches are most effective. Other officials
believe that more research is needed on the relationship between
children's exposure to lead in drinking water and their blood lead
levels.
Conclusions:
Ensuring that the lead rule adequately protects public health and is
fully implemented and enforced should be a high priority for EPA and
the states because the potential consequences of lead exposure,
particularly for infants and young children, can be significant.
However, EPA's hands are tied unless states report complete, accurate,
and timely data on the results of required monitoring, the status of
corrective actions, and the extent of violations. Without such
information, EPA cannot provide effective oversight or target limited
resources where they are most needed. Similarly, inconsistencies among
the states' policies and practices for implementing the lead rule may
lead to uneven levels of public health protection for consumers and
thus need to be examined and corrected, as appropriate.
Given the potential health effects associated with lead contamination,
it is important to minimize any unnecessary exposure as a result of
leaded materials in the water distribution system or household
plumbing. Reevaluating existing standards for the devices used in or
near residential plumbing systems would also enhance the effectiveness
of the treatment provided by local water systems. In the case of
schools and child care facilities, both the vulnerability of the
population served by such facilities and the competition for limited
resources make it essential to have better information on the nature
and extent of lead-contaminated drinking water--and its significance
relative to other environmental hazards.
Recommendations for Executive Action:
We recommend that the Administrator, EPA, take a number of steps to
further protect the American public from elevated lead levels in
drinking water. Specifically, to improve EPA's ability to oversee
implementation of the lead rule and assess compliance and enforcement
activities, EPA should:
* ensure that data on water systems' test results, corrective action
milestones, and violations are current, accurate, and complete and:
* analyze data on corrective actions and violations to assess the
adequacy of EPA and state enforcement efforts.
To expand ongoing efforts to improve implementation and oversight of
the lead rule, EPA should reassess existing regulations and guidance to
ensure the following:
* the sites water systems use for tap monitoring reflect areas of
highest risk for lead corrosion;
* the circumstances in which states approve water systems for reduced
monitoring are appropriate and that systems resume standard monitoring
following a major treatment change;
* homeowners who participate in tap monitoring are informed of the test
results; and:
* states review and approve major treatment changes, as defined by EPA,
to assess their impact on corrosion control before the changes are
implemented.
In addition, EPA should:
* collect and analyze data on the impact of lead service line
replacement on lead levels and conduct other research, as appropriate,
to assess the effectiveness of lead line replacement programs and
whether additional regulations or guidance are warranted;
* collect information on (1) the nature and extent of modified sampling
arrangements within combined distribution systems and (2) differences
in the reporting practices and corrective actions authorized by the
states, using this information to reassess applicable regulations and
guidance; and:
* evaluate existing standards for in-line and endpoint plumbing devices
used in or near residential plumbing systems to determine if the
standards are sufficiently protective to minimize potential lead
contamination.
In order to update its guidance and testing protocols, EPA should
collect and analyze the results of any testing that has been done to
determine whether more needs to be done to protect users from elevated
lead levels in drinking water at schools and child care facilities. In
addition, to assist local agencies in making the most efficient use of
their resources, EPA should assess the pros and cons of various
remediation activities and make the information publicly available.
Agency Comments and Our Evaluation:
We provided a draft of this report to EPA and the Consumer Product
Safety Commission for review and comment. EPA generally agreed with our
findings and recommendations. Regarding the completeness of information
that EPA has to evaluate implementation of the lead rule, the agency
said that it will work with the states to ensure that relevant
information is incorporated into the national database and will use the
information, in part, to assess the adequacy of enforcement efforts. In
addition, EPA agreed that aspects of the regulation need improvement.
EPA said that it will address some of these areas as part of its
package of revisions to the lead rule that it plans to propose early in
2006, including homeowner notification of test results and criteria for
reduced monitoring. EPA also said that it needs additional information
before it can address other areas, such as lead service line
replacement and plumbing standards, that may warrant regulatory
changes. EPA did not comment on our recommendation to reevaluate
existing regulations and guidance to ensure that tap monitoring sites
reflect areas of highest risk for lead corrosion. Finally, EPA did not
address our recommendations regarding lead contamination and remedial
actions at schools and child care facilities. We believe that, given
the particular vulnerability of children to the effects of lead, it is
important for EPA to take full advantage of the results of any tests
that have been done, as well as to identify those remedial activities
that have proven to be most effective. EPA's comments appear in
appendix V. The Consumer Product Safety Commission generally agreed
with our findings as they pertain to the Commission.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to appropriate
congressional committees; the Administrator, EPA; the Chairman,
Consumer Product Safety Commission; and the Director of the Office of
Management and Budget. We will also make copies available to others
upon request. In addition, the report will be available at no charge on
the GAO Web site at [Hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-3841 or [Hyperlink, stephensonj@gao.gov].
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff who
made major contributions to this report are listed in appendix VI.
Signed by:
John B. Stephenson:
Director, Natural Resources and Environment:
Appendixes:
Appendix I: Scope and Methodology:
For information on how the lead rule is being implemented, we obtained
information from the Environmental Protection Agency's (EPA) Office of
Ground Water and Drinking Water and Office of Enforcement and
Compliance Assurance, eight EPA regional offices, and 10 states. We
selected eight of the states--California, Illinois, Iowa,
Massachusetts, Michigan, New York, Pennsylvania, and Washington--
because they either had a relatively high number of water systems with
test results that exceeded or fell just below the lead action level, or
they added to the geographical diversity of our selections. We also
included Connecticut and Florida in our review because they were
identified by EPA as particularly active in addressing potential lead
contamination in water supplies serving child care facilities. At the
local level, we obtained information from eight water systems: the
Chicago Water Department in Illinois, the Boston Water and Sewer
Commission and Massachusetts Water Resources Authority in
Massachusetts, the Detroit Water and Sewerage Department in Michigan,
the Syracuse Water Department in New York, the Portland Bureau of Water
Works in Oregon, the Philadelphia Water Department in Pennsylvania, and
Seattle Public Utilities in Washington. Our criteria for selecting
these systems included test results showing elevated lead levels, lead
service line replacement activity, and/or the use of modified sampling
arrangements for consecutive systems. We reviewed the Safe Drinking
Water Act, the lead rule, EPA's minor revisions to the lead rule, other
pertinent regulations, and applicable guidance to states and water
systems.
To gain a national perspective on the data EPA uses for oversight of
lead rule implementation, including the results of required testing,
the status of corrective actions, and the extent of violations, we
analyzed data from EPA's Safe Drinking Water Information System through
June 2005 for active community water systems. We assessed the
reliability of the data by (1) performing electronic testing of
required data elements, (2) reviewing existing information about the
data and the system that produced them, (3) interviewing agency
officials knowledgeable about the data, and (4) reviewing EPA's own
data verification audits and summaries of data reliability. We
determined that the data on results and frequency of lead testing were
sufficiently reliable to show compliance trends. However, we found that
other data on corrective actions and violations were not sufficiently
reliable to assess the status of efforts to implement and enforce the
lead rule.
For information on experiences in implementing the lead rule and the
need for changes to the regulatory framework, we interviewed EPA,
state, and local officials; analyzed states' responses to an EPA
information request regarding their policies and practices in
implementing the rule; and reviewed other relevant studies and
documents. We reviewed the results of EPA's expert workshops on
monitoring protocols, simultaneous compliance, lead service line
replacement, and public education, and obtained information from
several researchers and other drinking water experts. Among other
things, we identified potential gaps in the regulatory framework,
including oversight, regulations, and guidance, and obtained views on
the modifications to the lead rule now being considered by EPA. To
learn about the development and effectiveness of existing plumbing
standards, we obtained and analyzed information from NSF International
(NSF), the Copper Development Association, the Plumbing Manufacturers
Institute, and relevant articles and studies. To assess the reliability
of NSF's data on lead content and lead leaching of plumbing fittings
and fixtures, we talked with foundation officials about data quality
control procedures. We determined the data were sufficiently reliable
for illustrative purposes.
For information on safeguards against lead-contaminated drinking water
at schools and child care facilities, we interviewed officials from the
Consumer Product Safety Commission, EPA's Office of Ground Water and
Drinking Water, the National Head Start Association, the National Child
Care Association, and the Healthy Schools Network. We also obtained
information from drinking water program offices and public health or
education departments in the 10 states we contacted for the first
objective as well as school districts in Boston, Chicago, Detroit,
Philadelphia, Seattle, and Syracuse. We reviewed the Lead Contamination
Control Act (LCCA) of 1988 and obtained information on the recall of
lead-lined water coolers. For information on other actions taken in
response to the LCCA, we interviewed EPA, state, and local officials;
reviewed relevant studies; and analyzed information collected by EPA.
We used the same information sources to determine (1) the extent of
current testing and remediation activities for lead in school and child
care facility drinking water, (2) the extent to which various entities
have responsibility for overseeing or collecting data on such
activities, and (3) the relative priorities among environmental hazards
common to schools and child care facilities. We also analyzed states'
responses to an EPA information request on state and local efforts to
monitor and protect children from lead exposure and attended an EPA-
sponsored expert workshop on lead in drinking water at schools and
child care facilities. For more detailed information on experiences at
the local level, we collected information from five school districts on
the extent of testing for lead in school drinking water, the results,
and the approaches used to address contamination.
We performed our work between June 2004 and November 2005 in accordance
with generally accepted government auditing standards.
[End of section]
Appendix II: Detailed Analysis of Corrective Action Milestone Data
Reported to EPA, by State, through June 2005:
State: AK;
Large: Number of systems: Total number of systems: 1;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 135,000;
Large: Population of large systems: Population in systems without
milestones: 135,000;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: AL;
Large: Number of systems: Total number of systems: 11;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 1,881,984;
Large: Population of large systems: Population in systems without
milestones: 1,881,984;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: AR;
Large: Number of systems: Total number of systems: 8;
Large: Number of systems: Number of systems with milestones: 8;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 781,325;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: AZ;
Large: Number of systems: Total number of systems: 13;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 3,417,902;
Large: Population of large systems: Population in systems without
milestones: 3,417,902;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: CA;
Large: Number of systems: Total number of systems: 160;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served:
25,224,420;
Large: Population of large systems: Population in systems without
milestones: 25,224,420;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: CO;
Large: Number of systems: Total number of systems: 16;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 2,941,619;
Large: Population of large systems: Population in systems without
milestones: 2,941,619;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: CT;
Large: Number of systems: Total number of systems: 9;
Large: Number of systems: Number of systems with milestones: 9;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 1,586,458;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: DC;
Large: Number of systems: Total number of systems: 1;
Large: Number of systems: Number of systems with milestones: 1;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 595,000;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: DE;
Large: Number of systems: Total number of systems: 3;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 445,504;
Large: Population of large systems: Population in systems without
milestones: 445,504;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: FL;
Large: Number of systems: Total number of systems: 76;
Large: Number of systems: Number of systems with milestones: 3;
Large: Number of systems: Percent of systems without milestones: 96.1;
Large: Population of large systems: Total population served:
12,098,524;
Large: Population of large systems: Population in systems without
milestones: 11,805,584;
Large: Population of large systems: Percent of population in systems
without milestones: 97.6.
State: GA;
Large: Number of systems: Total number of systems: 23;
Large: Number of systems: Number of systems with milestones: 18;
Large: Number of systems: Percent of systems without milestones: 21.7;
Large: Population of large systems: Total population served: 4,544,090;
Large: Population of large systems: Population in systems without
milestones: 507,529;
Large: Population of large systems: Percent of population in systems
without milestones: 11.2.
State: HI;
Large: Number of systems: Total number of systems: 4;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 875,238;
Large: Population of large systems: Population in systems without
milestones: 875,238;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: IA;
Large: Number of systems: Total number of systems: 8;
Large: Number of systems: Number of systems with milestones: 1;
Large: Number of systems: Percent of systems without milestones: 87.5;
Large: Population of large systems: Total population served: 793,026;
Large: Population of large systems: Population in systems without
milestones: 584,383;
Large: Population of large systems: Percent of population in systems
without milestones: 73.7.
State: ID;
Large: Number of systems: Total number of systems: 4;
Large: Number of systems: Number of systems with milestones: 1;
Large: Number of systems: Percent of systems without milestones: 75.0;
Large: Population of large systems: Total population served: 353,151;
Large: Population of large systems: Population in systems without
milestones: 300,800;
Large: Population of large systems: Percent of population in systems
without milestones: 85.2.
State: IL;
Large: Number of systems: Total number of systems: 30;
Large: Number of systems: Number of systems with milestones: 28;
Large: Number of systems: Percent of systems without milestones: 6.7;
Large: Population of large systems: Total population served: 5,367,282;
Large: Population of large systems: Population in systems without
milestones: 123,603;
Large: Population of large systems: Percent of population in systems
without milestones: 2.3.
State: IN;
Large: Number of systems: Total number of systems: 14;
Large: Number of systems: Number of systems with milestones: 14;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 2,106,043;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: KS;
Large: Number of systems: Total number of systems: 6;
Large: Number of systems: Number of systems with milestones: 2;
Large: Number of systems: Percent of systems without milestones: 66.7;
Large: Population of large systems: Total population served: 1,172,516;
Large: Population of large systems: Population in systems without
milestones: 981,341;
Large: Population of large systems: Percent of population in systems
without milestones: 83.7.
State: KY;
Large: Number of systems: Total number of systems: 8;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 1,705,135;
Large: Population of large systems: Population in systems without
milestones: 1,705,135;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: LA;
Large: Number of systems: Total number of systems: 15;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 2,315,098;
Large: Population of large systems: Population in systems without
milestones: 2,315,098;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: MA;
Large: Number of systems: Total number of systems: 29;
Large: Number of systems: Number of systems with milestones: 14;
Large: Number of systems: Percent of systems without milestones: 51.7;
Large: Population of large systems: Total population served: 4,992,887;
Large: Population of large systems: Population in systems without
milestones: 3,629,018;
Large: Population of large systems: Percent of population in systems
without milestones: 72.7.
State: MD;
Large: Number of systems: Total number of systems: 9;
Large: Number of systems: Number of systems with milestones: 7;
Large: Number of systems: Percent of systems without milestones: 22.2;
Large: Population of large systems: Total population served: 4,005,168;
Large: Population of large systems: Population in systems without
milestones: 106,000;
Large: Population of large systems: Percent of population in systems
without milestones: 2.6.
State: ME;
Large: Number of systems: Total number of systems: 1;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 113,560;
Large: Population of large systems: Population in systems without
milestones: 113,560;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: MI;
Large: Number of systems: Total number of systems: 31;
Large: Number of systems: Number of systems with milestones: 28;
Large: Number of systems: Percent of systems without milestones: 9.7;
Large: Population of large systems: Total population served: 3,647,640;
Large: Population of large systems: Population in systems without
milestones: 318,288;
Large: Population of large systems: Percent of population in systems
without milestones: 8.7.
State: MN;
Large: Number of systems: Total number of systems: 14;
Large: Number of systems: Number of systems with milestones: 8;
Large: Number of systems: Percent of systems without milestones: 42.9;
Large: Population of large systems: Total population served: 1,610,382;
Large: Population of large systems: Population in systems without
milestones: 370,533;
Large: Population of large systems: Percent of population in systems
without milestones: 23.0.
State: MO;
Large: Number of systems: Total number of systems: 11;
Large: Number of systems: Number of systems with milestones: 4;
Large: Number of systems: Percent of systems without milestones: 63.6;
Large: Population of large systems: Total population served: 2,586,464;
Large: Population of large systems: Population in systems without
milestones: 2,347,737;
Large: Population of large systems: Percent of population in systems
without milestones: 90.8.
State: MS;
Large: Number of systems: Total number of systems: 2;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 288,257;
Large: Population of large systems: Population in systems without
milestones: 288,257;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: MT;
Large: Number of systems: Total number of systems: 3;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 208,335;
Large: Population of large systems: Population in systems without
milestones: 208,335;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: NC;
Large: Number of systems: Total number of systems: 24;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 3,255,476;
Large: Population of large systems: Population in systems without
milestones: 3,255,476;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: ND;
Large: Number of systems: Total number of systems: 2;
Large: Number of systems: Number of systems with milestones: 2;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 146,131;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: NE;
Large: Number of systems: Total number of systems: 2;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 709,420;
Large: Population of large systems: Population in systems without
milestones: 709,420;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: NH;
Large: Number of systems: Total number of systems: 2;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 213,000;
Large: Population of large systems: Population in systems without
milestones: 213,000;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: NJ;
Large: Number of systems: Total number of systems: 21;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 4,205,795;
Large: Population of large systems: Population in systems without
milestones: 4,205,795;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: NM;
Large: Number of systems: Total number of systems: 4;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 660,026;
Large: Population of large systems: Population in systems without
milestones: 660,026;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: NV;
Large: Number of systems: Total number of systems: 5;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 1,876,500;
Large: Population of large systems: Population in systems without
milestones: 1,876,500;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: NY;
Large: Number of systems: Total number of systems: 32;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served:
13,079,586;
Large: Population of large systems: Population in systems without
milestones: 13,079,586;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: OH;
Large: Number of systems: Total number of systems: 27;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 5,720,471;
Large: Population of large systems: Population in systems without
milestones: 5,720,471;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: OK;
Large: Number of systems: Total number of systems: 9;
Large: Number of systems: Number of systems with milestones: 7;
Large: Number of systems: Percent of systems without milestones: 22.2;
Large: Population of large systems: Total population served: 1,538,179;
Large: Population of large systems: Population in systems without
milestones: 679,000;
Large: Population of large systems: Percent of population in systems
without milestones: 44.1.
State: OR;
Large: Number of systems: Total number of systems: 11;
Large: Number of systems: Number of systems with milestones: 8;
Large: Number of systems: Percent of systems without milestones: 27.3;
Large: Population of large systems: Total population served: 1,424,645;
Large: Population of large systems: Population in systems without
milestones: 278,000;
Large: Population of large systems: Percent of population in systems
without milestones: 19.5.
State: PA;
Large: Number of systems: Total number of systems: 31;
Large: Number of systems: Number of systems with milestones: 31;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 5,823,088;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: RI;
Large: Number of systems: Total number of systems: 4;
Large: Number of systems: Number of systems with milestones: 4;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 528,853;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: SC;
Large: Number of systems: Total number of systems: 12;
Large: Number of systems: Number of systems with milestones: 12;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 1,549,312;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: SD;
Large: Number of systems: Total number of systems: 2;
Large: Number of systems: Number of systems with milestones: 2;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 185,983;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: TN;
Large: Number of systems: Total number of systems: 15;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 2,221,020;
Large: Population of large systems: Population in systems without
milestones: 2,221,020;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: TX;
Large: Number of systems: Total number of systems: 56;
Large: Number of systems: Number of systems with milestones: 5;
Large: Number of systems: Percent of systems without milestones: 91.1;
Large: Population of large systems: Total population served:
12,580,122;
Large: Population of large systems: Population in systems without
milestones: 12,268,259;
Large: Population of large systems: Percent of population in systems
without milestones: 97.5.
State: UT;
Large: Number of systems: Total number of systems: 10;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 1,197,900;
Large: Population of large systems: Population in systems without
milestones: 1,197,900;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: VA;
Large: Number of systems: Total number of systems: 22;
Large: Number of systems: Number of systems with milestones: 22;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 3,979,119;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: VT;
Large: Number of systems: Total number of systems: 0;
Large: Number of systems: Number of systems with milestones: N/A;
Large: Number of systems: Percent of systems without milestones: N/A;
Large: Population of large systems: Total population served: 0;
Large: Population of large systems: Population in systems without
milestones: N/A;
Large: Population of large systems: Percent of population in systems
without milestones: N/A.
State: WA;
Large: Number of systems: Total number of systems: 23;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 2,697,616;
Large: Population of large systems: Population in systems without
milestones: 2,697,616;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: WI;
Large: Number of systems: Total number of systems: 13;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 1,666,474;
Large: Population of large systems: Population in systems without
milestones: 1,666,474;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
State: WV;
Large: Number of systems: Total number of systems: 2;
Large: Number of systems: Number of systems with milestones: 2;
Large: Number of systems: Percent of systems without milestones: 0.0;
Large: Population of large systems: Total population served: 246,203;
Large: Population of large systems: Population in systems without
milestones: 0;
Large: Population of large systems: Percent of population in systems
without milestones: 0.0.
State: WY;
Large: Number of systems: Total number of systems: 2;
Large: Number of systems: Number of systems with milestones: 0;
Large: Number of systems: Percent of systems without milestones: 100.0;
Large: Population of large systems: Total population served: 110,108;
Large: Population of large systems: Population in systems without
milestones: 110,108;
Large: Population of large systems: Percent of population in systems
without milestones: 100.0.
Total/AVG;
Large: Number of systems: Total number of systems: 841;
Large: Number of systems: Number of systems with milestones: 241;
Large: Number of systems: Percent of systems without milestones: 71.3;
Large: Population of large systems: Total population served:
151,407,035;
Large: Population of large systems: Population in systems without
milestones: 111,465,519;
Large: Population of large systems: Percent of population in systems
without milestones: 73.6.
Source: GAO analysis of EPA data.
[End of table]
State: AK;
Medium: Number of systems: Total number of systems: 23;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 200,798;
Medium: Population of medium systems: Population in systems without
milestones: 200,798;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: AL;
Medium: Number of systems: Total number of systems: 266;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
2,944,220;
Medium: Population of medium systems: Population in systems without
milestones: 2,944,220;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: AR;
Medium: Number of systems: Total number of systems: 139;
Medium: Number of systems: Number of systems with milestones: 133;
Medium: Number of systems: Percent of systems without milestones: 4.3;
Medium: Population of medium systems: Total population served:
1,190,159;
Medium: Population of medium systems: Population in systems without
milestones: 31,091;
Medium: Population of medium systems: Percent of population in systems
without milestones: 2.6.
State: AZ;
Medium: Number of systems: Total number of systems: 105;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
1,227,834;
Medium: Population of medium systems: Population in systems without
milestones: 1,227,834;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: CA;
Medium: Number of systems: Total number of systems: 478;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
7,476,807;
Medium: Population of medium systems: Population in systems without
milestones: 7,476,807;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: CO;
Medium: Number of systems: Total number of systems: 131;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
1,726,744;
Medium: Population of medium systems: Population in systems without
milestones: 1,726,744;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: CT;
Medium: Number of systems: Total number of systems: 48;
Medium: Number of systems: Number of systems with milestones: 48;
Medium: Number of systems: Percent of systems without milestones: 0.0;
Medium: Population of medium systems: Total population served: 926,493;
Medium: Population of medium systems: Population in systems without
milestones: 0;
Medium: Population of medium systems: Percent of population in systems
without milestones: 0.0.
State: DC;
Medium: Number of systems: Total number of systems: 1;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 11,000;
Medium: Population of medium systems: Population in systems without
milestones: 11,000;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: DE;
Medium: Number of systems: Total number of systems: 24;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 298,763;
Medium: Population of medium systems: Population in systems without
milestones: 298,763;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: FL;
Medium: Number of systems: Total number of systems: 310;
Medium: Number of systems: Number of systems with milestones: 2;
Medium: Number of systems: Percent of systems without milestones: 99.4;
Medium: Population of medium systems: Total population served:
4,684,659;
Medium: Population of medium systems: Population in systems without
milestones: 4,655,307;
Medium: Population of medium systems: Percent of population in systems
without milestones: 99.4.
State: GA;
Medium: Number of systems: Total number of systems: 184;
Medium: Number of systems: Number of systems with milestones: 94;
Medium: Number of systems: Percent of systems without milestones: 48.9;
Medium: Population of medium systems: Total population served:
2,254,876;
Medium: Population of medium systems: Population in systems without
milestones: 1,068,475;
Medium: Population of medium systems: Percent of population in systems
without milestones: 47.4.
State: HI;
Medium: Number of systems: Total number of systems: 33;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 378,964;
Medium: Population of medium systems: Population in systems without
milestones: 378,964;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: IA;
Medium: Number of systems: Total number of systems: 116;
Medium: Number of systems: Number of systems with milestones: 12;
Medium: Number of systems: Percent of systems without milestones: 89.7;
Medium: Population of medium systems: Total population served:
1,173,595;
Medium: Population of medium systems: Population in systems without
milestones: 1,099,226;
Medium: Population of medium systems: Percent of population in systems
without milestones: 93.7.
State: ID;
Medium: Number of systems: Total number of systems: 41;
Medium: Number of systems: Number of systems with milestones: 3;
Medium: Number of systems: Percent of systems without milestones: 92.7;
Medium: Population of medium systems: Total population served: 401,222;
Medium: Population of medium systems: Population in systems without
milestones: 355,215;
Medium: Population of medium systems: Percent of population in systems
without milestones: 88.5.
State: IL;
Medium: Number of systems: Total number of systems: 396;
Medium: Number of systems: Number of systems with milestones: 378;
Medium: Number of systems: Percent of systems without milestones: 4.5;
Medium: Population of medium systems: Total population served:
5,176,451;
Medium: Population of medium systems: Population in systems without
milestones: 192,293;
Medium: Population of medium systems: Percent of population in systems
without milestones: 3.7.
State: IN;
Medium: Number of systems: Total number of systems: 188;
Medium: Number of systems: Number of systems with milestones: 187;
Medium: Number of systems: Percent of systems without milestones: 0.5;
Medium: Population of medium systems: Total population served:
2,025,670;
Medium: Population of medium systems: Population in systems without
milestones: 3,661;
Medium: Population of medium systems: Percent of population in systems
without milestones: 0.2.
State: KS;
Medium: Number of systems: Total number of systems: 81;
Medium: Number of systems: Number of systems with milestones: 75;
Medium: Number of systems: Percent of systems without milestones: 7.4;
Medium: Population of medium systems: Total population served: 836,216;
Medium: Population of medium systems: Population in systems without
milestones: 24,796;
Medium: Population of medium systems: Percent of population in systems
without milestones: 3.0.
State: KY;
Medium: Number of systems: Total number of systems: 231;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
2,657,189;
Medium: Population of medium systems: Population in systems without
milestones: 2,657,189;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: LA;
Medium: Number of systems: Total number of systems: 203;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
1,827,405;
Medium: Population of medium systems: Population in systems without
milestones: 1,827,405;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: MA;
Medium: Number of systems: Total number of systems: 217;
Medium: Number of systems: Number of systems with milestones: 81;
Medium: Number of systems: Percent of systems without milestones: 62.7;
Medium: Population of medium systems: Total population served:
3,788,166;
Medium: Population of medium systems: Population in systems without
milestones: 2,339,423;
Medium: Population of medium systems: Percent of population in systems
without milestones: 61.8.
State: MD;
Medium: Number of systems: Total number of systems: 53;
Medium: Number of systems: Number of systems with milestones: 1;
Medium: Number of systems: Percent of systems without milestones: 98.1;
Medium: Population of medium systems: Total population served: 623,854;
Medium: Population of medium systems: Population in systems without
milestones: 620,429;
Medium: Population of medium systems: Percent of population in systems
without milestones: 99.5.
State: ME;
Medium: Number of systems: Total number of systems: 32;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 339,255;
Medium: Population of medium systems: Population in systems without
milestones: 339,255;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: MI;
Medium: Number of systems: Total number of systems: 249;
Medium: Number of systems: Number of systems with milestones: 204;
Medium: Number of systems: Percent of systems without milestones: 18.1;
Medium: Population of medium systems: Total population served:
3,078,142;
Medium: Population of medium systems: Population in systems without
milestones: 477,742;
Medium: Population of medium systems: Percent of population in systems
without milestones: 15.5.
State: MN;
Medium: Number of systems: Total number of systems: 140;
Medium: Number of systems: Number of systems with milestones: 44;
Medium: Number of systems: Percent of systems without milestones: 68.6;
Medium: Population of medium systems: Total population served:
1,821,460;
Medium: Population of medium systems: Population in systems without
milestones: 1,359,303;
Medium: Population of medium systems: Percent of population in systems
without milestones: 74.6.
State: MO;
Medium: Number of systems: Total number of systems: 173;
Medium: Number of systems: Number of systems with milestones: 166;
Medium: Number of systems: Percent of systems without milestones: 4.0;
Medium: Population of medium systems: Total population served:
1,596,299;
Medium: Population of medium systems: Population in systems without
milestones: 39,249;
Medium: Population of medium systems: Percent of population in systems
without milestones: 2.5.
State: MS;
Medium: Number of systems: Total number of systems: 189;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
1,758,806;
Medium: Population of medium systems: Population in systems without
milestones: 1,758,806;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: MT;
Medium: Number of systems: Total number of systems: 28;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 258,541;
Medium: Population of medium systems: Population in systems without
milestones: 258,541;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: NC;
Medium: Number of systems: Total number of systems: 226;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
2,496,100;
Medium: Population of medium systems: Population in systems without
milestones: 2,496,100;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: ND;
Medium: Number of systems: Total number of systems: 19;
Medium: Number of systems: Number of systems with milestones: 19;
Medium: Number of systems: Percent of systems without milestones: 0.0;
Medium: Population of medium systems: Total population served: 229,025;
Medium: Population of medium systems: Population in systems without
milestones: 0;
Medium: Population of medium systems: Percent of population in systems
without milestones: 0.0.
State: NE;
Medium: Number of systems: Total number of systems: 38;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 403,073;
Medium: Population of medium systems: Population in systems without
milestones: 403,073;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: NH;
Medium: Number of systems: Total number of systems: 34;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 404,279;
Medium: Population of medium systems: Population in systems without
milestones: 404,279;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: NJ;
Medium: Number of systems: Total number of systems: 207;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
3,419,920;
Medium: Population of medium systems: Population in systems without
milestones: 3,419,920;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: NM;
Medium: Number of systems: Total number of systems: 55;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 701,119;
Medium: Population of medium systems: Population in systems without
milestones: 701,119;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: NV;
Medium: Number of systems: Total number of systems: 28;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 229,455;
Medium: Population of medium systems: Population in systems without
milestones: 229,455;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: NY;
Medium: Number of systems: Total number of systems: 294;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
3,698,727;
Medium: Population of medium systems: Population in systems without
milestones: 3,698,727;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: OH;
Medium: Number of systems: Total number of systems: 280;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
3,593,577;
Medium: Population of medium systems: Population in systems without
milestones: 3,593,577;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: OK;
Medium: Number of systems: Total number of systems: 122;
Medium: Number of systems: Number of systems with milestones: 105;
Medium: Number of systems: Percent of systems without milestones: 13.9;
Medium: Population of medium systems: Total population served:
1,225,346;
Medium: Population of medium systems: Population in systems without
milestones: 130,815;
Medium: Population of medium systems: Percent of population in systems
without milestones: 10.7.
State: OR;
Medium: Number of systems: Total number of systems: 94;
Medium: Number of systems: Number of systems with milestones: 28;
Medium: Number of systems: Percent of systems without milestones: 70.2;
Medium: Population of medium systems: Total population served:
1,222,949;
Medium: Population of medium systems: Population in systems without
milestones: 862,909;
Medium: Population of medium systems: Percent of population in systems
without milestones: 70.6.
State: PA;
Medium: Number of systems: Total number of systems: 292;
Medium: Number of systems: Number of systems with milestones: 281;
Medium: Number of systems: Percent of systems without milestones: 3.8;
Medium: Population of medium systems: Total population served:
3,685,523;
Medium: Population of medium systems: Population in systems without
milestones: 139,384;
Medium: Population of medium systems: Percent of population in systems
without milestones: 3.8.
State: RI;
Medium: Number of systems: Total number of systems: 22;
Medium: Number of systems: Number of systems with milestones: 18;
Medium: Number of systems: Percent of systems without milestones: 18.2;
Medium: Population of medium systems: Total population served: 420,039;
Medium: Population of medium systems: Population in systems without
milestones: 43,700;
Medium: Population of medium systems: Percent of population in systems
without milestones: 10.4.
State: SC;
Medium: Number of systems: Total number of systems: 141;
Medium: Number of systems: Number of systems with milestones: 141;
Medium: Number of systems: Percent of systems without milestones: 0.0;
Medium: Population of medium systems: Total population served:
1,666,077;
Medium: Population of medium systems: Population in systems without
milestones: 0;
Medium: Population of medium systems: Percent of population in systems
without milestones: 0.0.
State: SD;
Medium: Number of systems: Total number of systems: 30;
Medium: Number of systems: Number of systems with milestones: 30;
Medium: Number of systems: Percent of systems without milestones: 0.0;
Medium: Population of medium systems: Total population served: 258,637;
Medium: Population of medium systems: Population in systems without
milestones: 0;
Medium: Population of medium systems: Percent of population in systems
without milestones: 0.0.
State: TN;
Medium: Number of systems: Total number of systems: 236;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
2,745,416;
Medium: Population of medium systems: Population in systems without
milestones: 2,745,416;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: TX;
Medium: Number of systems: Total number of systems: 750;
Medium: Number of systems: Number of systems with milestones: 46;
Medium: Number of systems: Percent of systems without milestones: 93.9;
Medium: Population of medium systems: Total population served:
7,370,002;
Medium: Population of medium systems: Population in systems without
milestones: 6,950,037;
Medium: Population of medium systems: Percent of population in systems
without milestones: 94.3.
State: UT;
Medium: Number of systems: Total number of systems: 85;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
1,088,639;
Medium: Population of medium systems: Population in systems without
milestones: 1,088,639;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: VA;
Medium: Number of systems: Total number of systems: 126;
Medium: Number of systems: Number of systems with milestones: 104;
Medium: Number of systems: Percent of systems without milestones: 17.5;
Medium: Population of medium systems: Total population served:
1,783,530;
Medium: Population of medium systems: Population in systems without
milestones: 346,752;
Medium: Population of medium systems: Percent of population in systems
without milestones: 19.4.
State: VT;
Medium: Number of systems: Total number of systems: 30;
Medium: Number of systems: Number of systems with milestones: 8;
Medium: Number of systems: Percent of systems without milestones: 73.3;
Medium: Population of medium systems: Total population served: 266,690;
Medium: Population of medium systems: Population in systems without
milestones: 151,730;
Medium: Population of medium systems: Percent of population in systems
without milestones: 56.9.
State: WA;
Medium: Number of systems: Total number of systems: 170;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
2,217,060;
Medium: Population of medium systems: Population in systems without
milestones: 2,217,060;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: WI;
Medium: Number of systems: Total number of systems: 160;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served:
1,696,466;
Medium: Population of medium systems: Population in systems without
milestones: 1,696,466;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
State: WV;
Medium: Number of systems: Total number of systems: 80;
Medium: Number of systems: Number of systems with milestones: 77;
Medium: Number of systems: Percent of systems without milestones: 3.8;
Medium: Population of medium systems: Total population served: 756,976;
Medium: Population of medium systems: Population in systems without
milestones: 28,025;
Medium: Population of medium systems: Percent of population in systems
without milestones: 3.7.
State: WY;
Medium: Number of systems: Total number of systems: 22;
Medium: Number of systems: Number of systems with milestones: 0;
Medium: Number of systems: Percent of systems without milestones:
100.0;
Medium: Population of medium systems: Total population served: 225,116;
Medium: Population of medium systems: Population in systems without
milestones: 225,116;
Medium: Population of medium systems: Percent of population in systems
without milestones: 100.0.
Total/AVG;
Medium: Number of systems: Total number of systems: 7,620;
Medium: Number of systems: Number of systems with milestones: 2,285;
Medium: Number of systems: Percent of systems without milestones: 70.0;
Medium: Population of medium systems: Total population served:
92,487,329;
Medium: Population of medium systems: Population in systems without
milestones: 64,944,835;
Medium: Population of medium systems: Percent of population in systems
without milestones: 70.2.
Source: GAO analysis of EPA data.
[End of table]
State: AK;
Small: Number of systems: Total number of systems: 412;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 128,713;
Small: Population of small systems: Population in systems without
milestones: 128,713;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: AL;
Small: Number of systems: Total number of systems: 342;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 437,400;
Small: Population of small systems: Population in systems without
milestones: 437,400;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: AR;
Small: Number of systems: Total number of systems: 582;
Small: Number of systems: Number of systems with milestones: 548;
Small: Number of systems: Percent of systems without milestones: 5.8;
Small: Population of small systems: Total population served: 569,267;
Small: Population of small systems: Population in systems without
milestones: 23,567;
Small: Population of small systems: Percent of population in systems
without milestones: 4.1.
State: AZ;
Small: Number of systems: Total number of systems: 675;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 334,986;
Small: Population of small systems: Population in systems without
milestones: 334,986;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: CA;
Small: Number of systems: Total number of systems: 2,488;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 995,796;
Small: Population of small systems: Population in systems without
milestones: 995,796;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: CO;
Small: Number of systems: Total number of systems: 684;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 378,345;
Small: Population of small systems: Population in systems without
milestones: 378,345;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: CT;
Small: Number of systems: Total number of systems: 529;
Small: Number of systems: Number of systems with milestones: 443;
Small: Number of systems: Percent of systems without milestones: 16.3;
Small: Population of small systems: Total population served: 160,534;
Small: Population of small systems: Population in systems without
milestones: 16,676;
Small: Population of small systems: Percent of population in systems
without milestones: 10.4.
State: DC;
Small: Number of systems: Total number of systems: 1;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 0;
Small: Population of small systems: Population in systems without
milestones: 0;
Small: Population of small systems: Percent of population in systems
without milestones: N/A.
State: DE;
Small: Number of systems: Total number of systems: 202;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 92,110;
Small: Population of small systems: Population in systems without
milestones: 92,110;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: FL;
Small: Number of systems: Total number of systems: 1,503;
Small: Number of systems: Number of systems with milestones: 9;
Small: Number of systems: Percent of systems without milestones: 99.4;
Small: Population of small systems: Total population served: 799,213;
Small: Population of small systems: Population in systems without
milestones: 793,025;
Small: Population of small systems: Percent of population in systems
without milestones: 99.2.
State: GA;
Small: Number of systems: Total number of systems: 1,484;
Small: Number of systems: Number of systems with milestones: 660;
Small: Number of systems: Percent of systems without milestones: 55.5;
Small: Population of small systems: Total population served: 601,723;
Small: Population of small systems: Population in systems without
milestones: 324,449;
Small: Population of small systems: Percent of population in systems
without milestones: 53.9.
State: HI;
Small: Number of systems: Total number of systems: 78;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 72,007;
Small: Population of small systems: Population in systems without
milestones: 72,007;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: IA;
Small: Number of systems: Total number of systems: 1,019;
Small: Number of systems: Number of systems with milestones: 64;
Small: Number of systems: Percent of systems without milestones: 93.7;
Small: Population of small systems: Total population served: 614,789;
Small: Population of small systems: Population in systems without
milestones: 562,918;
Small: Population of small systems: Percent of population in systems
without milestones: 91.6.
State: ID;
Small: Number of systems: Total number of systems: 707;
Small: Number of systems: Number of systems with milestones: 81;
Small: Number of systems: Percent of systems without milestones: 88.5;
Small: Population of small systems: Total population served: 211,117;
Small: Population of small systems: Population in systems without
milestones: 182,893;
Small: Population of small systems: Percent of population in systems
without milestones: 86.6.
State: IL;
Small: Number of systems: Total number of systems: 1,367;
Small: Number of systems: Number of systems with milestones: 1,216;
Small: Number of systems: Percent of systems without milestones: 11.0;
Small: Population of small systems: Total population served: 1,071,477;
Small: Population of small systems: Population in systems without
milestones: 92,176;
Small: Population of small systems: Percent of population in systems
without milestones: 8.6.
State: IN;
Small: Number of systems: Total number of systems: 638;
Small: Number of systems: Number of systems with milestones: 628;
Small: Number of systems: Percent of systems without milestones: 1.6;
Small: Population of small systems: Total population served: 503,685;
Small: Population of small systems: Population in systems without
milestones: 4,818;
Small: Population of small systems: Percent of population in systems
without milestones: 1.0.
State: KS;
Small: Number of systems: Total number of systems: 824;
Small: Number of systems: Number of systems with milestones: 649;
Small: Number of systems: Percent of systems without milestones: 21.2;
Small: Population of small systems: Total population served: 560,103;
Small: Population of small systems: Population in systems without
milestones: 115,971;
Small: Population of small systems: Percent of population in systems
without milestones: 20.7.
State: KY;
Small: Number of systems: Total number of systems: 179;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 259,090;
Small: Population of small systems: Population in systems without
milestones: 259,090;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: LA;
Small: Number of systems: Total number of systems: 893;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 743,960;
Small: Population of small systems: Population in systems without
milestones: 743,960;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: MA;
Small: Number of systems: Total number of systems: 278;
Small: Number of systems: Number of systems with milestones: 83;
Small: Number of systems: Percent of systems without milestones: 70.1;
Small: Population of small systems: Total population served: 161,166;
Small: Population of small systems: Population in systems without
milestones: 110,437;
Small: Population of small systems: Percent of population in systems
without milestones: 68.5.
State: MD;
Small: Number of systems: Total number of systems: 440;
Small: Number of systems: Number of systems with milestones: 271;
Small: Number of systems: Percent of systems without milestones: 38.4;
Small: Population of small systems: Total population served: 217,804;
Small: Population of small systems: Population in systems without
milestones: 87,464;
Small: Population of small systems: Percent of population in systems
without milestones: 40.2.
State: ME;
Small: Number of systems: Total number of systems: 366;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 165,359;
Small: Population of small systems: Population in systems without
milestones: 165,359;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: MI;
Small: Number of systems: Total number of systems: 1,158;
Small: Number of systems: Number of systems with milestones: 971;
Small: Number of systems: Percent of systems without milestones: 16.1;
Small: Population of small systems: Total population served: 716,406;
Small: Population of small systems: Population in systems without
milestones: 173,559;
Small: Population of small systems: Percent of population in systems
without milestones: 24.2.
State: MN;
Small: Number of systems: Total number of systems: 811;
Small: Number of systems: Number of systems with milestones: 143;
Small: Number of systems: Percent of systems without milestones: 82.4;
Small: Population of small systems: Total population served: 531,720;
Small: Population of small systems: Population in systems without
milestones: 395,653;
Small: Population of small systems: Percent of population in systems
without milestones: 74.4.
State: MO;
Small: Number of systems: Total number of systems: 1,281;
Small: Number of systems: Number of systems with milestones: 1,168;
Small: Number of systems: Percent of systems without milestones: 8.8;
Small: Population of small systems: Total population served: 739,179;
Small: Population of small systems: Population in systems without
milestones: 38,519;
Small: Population of small systems: Percent of population in systems
without milestones: 5.2.
State: MS;
Small: Number of systems: Total number of systems: 980;
Small: Number of systems: Number of systems with milestones: 1;
Small: Number of systems: Percent of systems without milestones: 99.9;
Small: Population of small systems: Total population served: 1,032,244;
Small: Population of small systems: Population in systems without
milestones: 1,031,729;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: MT;
Small: Number of systems: Total number of systems: 647;
Small: Number of systems: Number of systems with milestones: 2;
Small: Number of systems: Percent of systems without milestones: 99.7;
Small: Population of small systems: Total population served: 206,237;
Small: Population of small systems: Population in systems without
milestones: 203,914;
Small: Population of small systems: Percent of population in systems
without milestones: 98.9.
State: NC;
Small: Number of systems: Total number of systems: 1,924;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 726,326;
Small: Population of small systems: Population in systems without
milestones: 726,326;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: ND;
Small: Number of systems: Total number of systems: 299;
Small: Number of systems: Number of systems with milestones: 284;
Small: Number of systems: Percent of systems without milestones: 5.0;
Small: Population of small systems: Total population served: 177,573;
Small: Population of small systems: Population in systems without
milestones: 8,747;
Small: Population of small systems: Percent of population in systems
without milestones: 4.9.
State: NE;
Small: Number of systems: Total number of systems: 566;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 304,924;
Small: Population of small systems: Population in systems without
milestones: 304,924;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: NH;
Small: Number of systems: Total number of systems: 662;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 200,898;
Small: Population of small systems: Population in systems without
milestones: 200,898;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: NJ;
Small: Number of systems: Total number of systems: 381;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 257,045;
Small: Population of small systems: Population in systems without
milestones: 257,045;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: NM;
Small: Number of systems: Total number of systems: 586;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 251,374;
Small: Population of small systems: Population in systems without
milestones: 251,374;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: NV;
Small: Number of systems: Total number of systems: 220;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 106,349;
Small: Population of small systems: Population in systems without
milestones: 106,349;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: NY;
Small: Number of systems: Total number of systems: 2,492;
Small: Number of systems: Number of systems with milestones: 1;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 1,131,590;
Small: Population of small systems: Population in systems without
milestones: 1,131,240;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: OH;
Small: Number of systems: Total number of systems: 1,014;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 739,441;
Small: Population of small systems: Population in systems without
milestones: 739,441;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: OK;
Small: Number of systems: Total number of systems: 1,004;
Small: Number of systems: Number of systems with milestones: 378;
Small: Number of systems: Percent of systems without milestones: 62.4;
Small: Population of small systems: Total population served: 679,858;
Small: Population of small systems: Population in systems without
milestones: 332,062;
Small: Population of small systems: Percent of population in systems
without milestones: 48.8.
State: OR;
Small: Number of systems: Total number of systems: 769;
Small: Number of systems: Number of systems with milestones: 108;
Small: Number of systems: Percent of systems without milestones: 86.0;
Small: Population of small systems: Total population served: 324,386;
Small: Population of small systems: Population in systems without
milestones: 251,660;
Small: Population of small systems: Percent of population in systems
without milestones: 77.6.
State: PA;
Small: Number of systems: Total number of systems: 1,813;
Small: Number of systems: Number of systems with milestones: 1,670;
Small: Number of systems: Percent of systems without milestones: 7.9;
Small: Population of small systems: Total population served: 960,679;
Small: Population of small systems: Population in systems without
milestones: 50,135;
Small: Population of small systems: Percent of population in systems
without milestones: 5.2.
State: RI;
Small: Number of systems: Total number of systems: 57;
Small: Number of systems: Number of systems with milestones: 40;
Small: Number of systems: Percent of systems without milestones: 29.8;
Small: Population of small systems: Total population served: 26,914;
Small: Population of small systems: Population in systems without
milestones: 10,630;
Small: Population of small systems: Percent of population in systems
without milestones: 39.5.
State: SC;
Small: Number of systems: Total number of systems: 506;
Small: Number of systems: Number of systems with milestones: 483;
Small: Number of systems: Percent of systems without milestones: 4.5;
Small: Population of small systems: Total population served: 270,387;
Small: Population of small systems: Population in systems without
milestones: 8,152;
Small: Population of small systems: Percent of population in systems
without milestones: 3.0.
State: SD;
Small: Number of systems: Total number of systems: 435;
Small: Number of systems: Number of systems with milestones: 382;
Small: Number of systems: Percent of systems without milestones: 12.2;
Small: Population of small systems: Total population served: 216,413;
Small: Population of small systems: Population in systems without
milestones: 12,348;
Small: Population of small systems: Percent of population in systems
without milestones: 5.7.
State: TN;
Small: Number of systems: Total number of systems: 430;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 417,026;
Small: Population of small systems: Population in systems without
milestones: 417,026;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: TX;
Small: Number of systems: Total number of systems: 3,683;
Small: Number of systems: Number of systems with milestones: 165;
Small: Number of systems: Percent of systems without milestones: 95.5;
Small: Population of small systems: Total population served: 2,724,725;
Small: Population of small systems: Population in systems without
milestones: 2,554,606;
Small: Population of small systems: Percent of population in systems
without milestones: 93.8.
State: UT;
Small: Number of systems: Total number of systems: 356;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 208,654;
Small: Population of small systems: Population in systems without
milestones: 208,654;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: VA;
Small: Number of systems: Total number of systems: 1,117;
Small: Number of systems: Number of systems with milestones: 874;
Small: Number of systems: Percent of systems without milestones: 21.8;
Small: Population of small systems: Total population served: 482,223;
Small: Population of small systems: Population in systems without
milestones: 95,023;
Small: Population of small systems: Percent of population in systems
without milestones: 19.7.
State: VT;
Small: Number of systems: Total number of systems: 405;
Small: Number of systems: Number of systems with milestones: 42;
Small: Number of systems: Percent of systems without milestones: 89.6;
Small: Population of small systems: Total population served: 172,502;
Small: Population of small systems: Population in systems without
milestones: 138,701;
Small: Population of small systems: Percent of population in systems
without milestones: 80.4.
State: WA;
Small: Number of systems: Total number of systems: 2,084;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 693,052;
Small: Population of small systems: Population in systems without
milestones: 693,052;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: WI;
Small: Number of systems: Total number of systems: 913;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 517,366;
Small: Population of small systems: Population in systems without
milestones: 517,366;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
State: WV;
Small: Number of systems: Total number of systems: 455;
Small: Number of systems: Number of systems with milestones: 432;
Small: Number of systems: Percent of systems without milestones: 5.1;
Small: Population of small systems: Total population served: 413,870;
Small: Population of small systems: Population in systems without
milestones: 10,363;
Small: Population of small systems: Percent of population in systems
without milestones: 2.5.
State: WY;
Small: Number of systems: Total number of systems: 252;
Small: Number of systems: Number of systems with milestones: 0;
Small: Number of systems: Percent of systems without milestones: 100.0;
Small: Population of small systems: Total population served: 103,403;
Small: Population of small systems: Population in systems without
milestones: 103,403;
Small: Population of small systems: Percent of population in systems
without milestones: 100.0.
Total/AVG;
Small: Number of systems: Total number of systems: 42,991;
Small: Number of systems: Number of systems with milestones: 11,796;
Small: Number of systems: Percent of systems without milestones: 72.6;
Small: Population of small systems: Total population served:
24,411,408;
Small: Population of small systems: Population in systems without
milestones: 16,895,059;
Small: Population of small systems: Percent of population in systems
without milestones: 69.2.
Source: GAO analysis of EPA data.
[End of table]
[End of section]
Appendix III: Number of Lead Rule Violations Reported to EPA Between
1995 and June 2005 (by State):
State: AK;
Number of systems: 436;
Number of violations: TT: 4;
Number of violations: MR: 586;
Number of violations: Total: 590;
Number of systems with violations: TT: 3;
Number of systems with violations: Percent of total systems with TT
violations: 0.7;
Number of systems with violations: MR: 252;
Number of systems with violations: Percent of total systems with MR
violations: 57.8;
Number of systems with violations: Total: 254;
Number of systems with violations: Percent of total systems with
violations: 58.3.
State: AL;
Number of systems: 619;
Number of violations: TT: 0;
Number of violations: MR: 91;
Number of violations: Total: 91;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 65;
Number of systems with violations: Percent of total systems with MR
violations: 10.5;
Number of systems with violations: Total: 65;
Number of systems with violations: Percent of total systems with
violations: 10.5.
State: AR;
Number of systems: 729;
Number of violations: TT: 28;
Number of violations: MR: 38;
Number of violations: Total: 66;
Number of systems with violations: TT: 23;
Number of systems with violations: Percent of total systems with TT
violations: 3.2;
Number of systems with violations: MR: 32;
Number of systems with violations: Percent of total systems with MR
violations: 4.4;
Number of systems with violations: Total: 50;
Number of systems with violations: Percent of total systems with
violations: 6.9.
State: AZ;
Number of systems: 793;
Number of violations: TT: 0;
Number of violations: MR: 1,100;
Number of violations: Total: 1,100;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 419;
Number of systems with violations: Percent of total systems with MR
violations: 52.8;
Number of systems with violations: Total: 419;
Number of systems with violations: Percent of total systems with
violations: 52.8.
State: CA;
Number of systems: 3,126;
Number of violations: TT: 0;
Number of violations: MR: 144;
Number of violations: Total: 144;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 136;
Number of systems with violations: Percent of total systems with MR
violations: 4.4;
Number of systems with violations: Total: 136;
Number of systems with violations: Percent of total systems with
violations: 4.4.
State: CO;
Number of systems: 831;
Number of violations: TT: 28;
Number of violations: MR: 262;
Number of violations: Total: 290;
Number of systems with violations: TT: 10;
Number of systems with violations: Percent of total systems with TT
violations: 1.2;
Number of systems with violations: MR: 195;
Number of systems with violations: Percent of total systems with MR
violations: 23.5;
Number of systems with violations: Total: 201;
Number of systems with violations: Percent of total systems with
violations: 24.2.
State: CT;
Number of systems: 586;
Number of violations: TT: 29;
Number of violations: MR: 232;
Number of violations: Total: 261;
Number of systems with violations: TT: 25;
Number of systems with violations: Percent of total systems with TT
violations: 4.3;
Number of systems with violations: MR: 168;
Number of systems with violations: Percent of total systems with MR
violations: 28.7;
Number of systems with violations: Total: 176;
Number of systems with violations: Percent of total systems with
violations: 30.0.
State: DE;
Number of systems: 229;
Number of violations: TT: 0;
Number of violations: MR: 3;
Number of violations: Total: 3;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 3;
Number of systems with violations: Percent of total systems with MR
violations: 1.3;
Number of systems with violations: Total: 3;
Number of systems with violations: Percent of total systems with
violations: 1.3.
State: FL;
Number of systems: 1,889;
Number of violations: TT: 10;
Number of violations: MR: 74;
Number of violations: Total: 84;
Number of systems with violations: TT: 10;
Number of systems with violations: Percent of total systems with TT
violations: 0.5;
Number of systems with violations: MR: 68;
Number of systems with violations: Percent of total systems with MR
violations: 3.6;
Number of systems with violations: Total: 76;
Number of systems with violations: Percent of total systems with
violations: 4.0.
State: GA;
Number of systems: 1,691;
Number of violations: TT: 8;
Number of violations: MR: 1,927;
Number of violations: Total: 1,935;
Number of systems with violations: TT: 8;
Number of systems with violations: Percent of total systems with TT
violations: 0.5;
Number of systems with violations: MR: 1,015;
Number of systems with violations: Percent of total systems with MR
violations: 60.0;
Number of systems with violations: Total: 1,016;
Number of systems with violations: Percent of total systems with
violations: 60.1.
State: HI;
Number of systems: 115;
Number of violations: TT: 0;
Number of violations: MR: 0;
Number of violations: Total: 0;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 0;
Number of systems with violations: Percent of total systems with MR
violations: 0.0;
Number of systems with violations: Total: 0;
Number of systems with violations: Percent of total systems with
violations: 0.0.
State: IA;
Number of systems: 1,143;
Number of violations: TT: 1;
Number of violations: MR: 100;
Number of violations: Total: 101;
Number of systems with violations: TT: 1;
Number of systems with violations: Percent of total systems with TT
violations: 0.1;
Number of systems with violations: MR: 85;
Number of systems with violations: Percent of total systems with MR
violations: 7.4;
Number of systems with violations: Total: 86;
Number of systems with violations: Percent of total systems with
violations: 7.5.
State: ID;
Number of systems: 752;
Number of violations: TT: 9;
Number of violations: MR: 866;
Number of violations: Total: 875;
Number of systems with violations: TT: 9;
Number of systems with violations: Percent of total systems with TT
violations: 1.2;
Number of systems with violations: MR: 269;
Number of systems with violations: Percent of total systems with MR
violations: 35.8;
Number of systems with violations: Total: 274;
Number of systems with violations: Percent of total systems with
violations: 36.4.
State: IL;
Number of systems: 1,793;
Number of violations: TT: 292;
Number of violations: MR: 670;
Number of violations: Total: 962;
Number of systems with violations: TT: 170;
Number of systems with violations: Percent of total systems with TT
violations: 9.5;
Number of systems with violations: MR: 330;
Number of systems with violations: Percent of total systems with MR
violations: 18.4;
Number of systems with violations: Total: 423;
Number of systems with violations: Percent of total systems with
violations: 23.6.
State: IN;
Number of systems: 840;
Number of violations: TT: 90;
Number of violations: MR: 279;
Number of violations: Total: 369;
Number of systems with violations: TT: 54;
Number of systems with violations: Percent of total systems with TT
violations: 6.4;
Number of systems with violations: MR: 127;
Number of systems with violations: Percent of total systems with MR
violations: 15.1;
Number of systems with violations: Total: 138;
Number of systems with violations: Percent of total systems with
violations: 16.4.
State: KS;
Number of systems: 911;
Number of violations: TT: 62;
Number of violations: MR: 105;
Number of violations: Total: 167;
Number of systems with violations: TT: 44;
Number of systems with violations: Percent of total systems with TT
violations: 4.8;
Number of systems with violations: MR: 83;
Number of systems with violations: Percent of total systems with MR
violations: 9.1;
Number of systems with violations: Total: 119;
Number of systems with violations: Percent of total systems with
violations: 13.1.
State: KY;
Number of systems: 418;
Number of violations: TT: 0;
Number of violations: MR: 200;
Number of violations: Total: 200;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 147;
Number of systems with violations: Percent of total systems with MR
violations: 35.2;
Number of systems with violations: Total: 147;
Number of systems with violations: Percent of total systems with
violations: 35.2.
State: LA;
Number of systems: 1,111;
Number of violations: TT: 0;
Number of violations: MR: 132;
Number of violations: Total: 132;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 132;
Number of systems with violations: Percent of total systems with MR
violations: 11.9;
Number of systems with violations: Total: 132;
Number of systems with violations: Percent of total systems with
violations: 11.9.
State: MA;
Number of systems: 524;
Number of violations: TT: 81;
Number of violations: MR: 219;
Number of violations: Total: 300;
Number of systems with violations: TT: 60;
Number of systems with violations: Percent of total systems with TT
violations: 11.5;
Number of systems with violations: MR: 137;
Number of systems with violations: Percent of total systems with MR
violations: 26.1;
Number of systems with violations: Total: 189;
Number of systems with violations: Percent of total systems with
violations: 36.1.
State: MD;
Number of systems: 502;
Number of violations: TT: 69;
Number of violations: MR: 231;
Number of violations: Total: 300;
Number of systems with violations: TT: 40;
Number of systems with violations: Percent of total systems with TT
violations: 8.0;
Number of systems with violations: MR: 156;
Number of systems with violations: Percent of total systems with MR
violations: 31.1;
Number of systems with violations: Total: 165;
Number of systems with violations: Percent of total systems with
violations: 32.9.
State: ME;
Number of systems: 399;
Number of violations: TT: 63;
Number of violations: MR: 188;
Number of violations: Total: 251;
Number of systems with violations: TT: 44;
Number of systems with violations: Percent of total systems with TT
violations: 11.0;
Number of systems with violations: MR: 88;
Number of systems with violations: Percent of total systems with MR
violations: 22.1;
Number of systems with violations: Total: 107;
Number of systems with violations: Percent of total systems with
violations: 26.8.
State: MI;
Number of systems: 1,438;
Number of violations: TT: 9;
Number of violations: MR: 116;
Number of violations: Total: 125;
Number of systems with violations: TT: 8;
Number of systems with violations: Percent of total systems with TT
violations: 0.6;
Number of systems with violations: MR: 101;
Number of systems with violations: Percent of total systems with MR
violations: 7.0;
Number of systems with violations: Total: 107;
Number of systems with violations: Percent of total systems with
violations: 7.4.
State: MN;
Number of systems: 965;
Number of violations: TT: 3;
Number of violations: MR: 104;
Number of violations: Total: 107;
Number of systems with violations: TT: 3;
Number of systems with violations: Percent of total systems with TT
violations: 0.3;
Number of systems with violations: MR: 76;
Number of systems with violations: Percent of total systems with MR
violations: 7.9;
Number of systems with violations: Total: 77;
Number of systems with violations: Percent of total systems with
violations: 8.0.
State: MO;
Number of systems: 1,465;
Number of violations: TT: 2;
Number of violations: MR: 420;
Number of violations: Total: 422;
Number of systems with violations: TT: 2;
Number of systems with violations: Percent of total systems with TT
violations: 0.1;
Number of systems with violations: MR: 330;
Number of systems with violations: Percent of total systems with MR
violations: 22.5;
Number of systems with violations: Total: 332;
Number of systems with violations: Percent of total systems with
violations: 22.7.
State: MS;
Number of systems: 1,171;
Number of violations: TT: 0;
Number of violations: MR: 35;
Number of violations: Total: 35;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 32;
Number of systems with violations: Percent of total systems with MR
violations: 2.7;
Number of systems with violations: Total: 32;
Number of systems with violations: Percent of total systems with
violations: 2.7.
State: MT;
Number of systems: 678;
Number of violations: TT: 8;
Number of violations: MR: 590;
Number of violations: Total: 598;
Number of systems with violations: TT: 8;
Number of systems with violations: Percent of total systems with TT
violations: 1.2;
Number of systems with violations: MR: 225;
Number of systems with violations: Percent of total systems with MR
violations: 33.2;
Number of systems with violations: Total: 228;
Number of systems with violations: Percent of total systems with
violations: 33.6.
State: NC;
Number of systems: 2,174;
Number of violations: TT: 233;
Number of violations: MR: 411;
Number of violations: Total: 644;
Number of systems with violations: TT: 143;
Number of systems with violations: Percent of total systems with TT
violations: 6.6;
Number of systems with violations: MR: 269;
Number of systems with violations: Percent of total systems with MR
violations: 12.4;
Number of systems with violations: Total: 356;
Number of systems with violations: Percent of total systems with
violations: 16.4.
State: ND;
Number of systems: 320;
Number of violations: TT: 7;
Number of violations: MR: 36;
Number of violations: Total: 43;
Number of systems with violations: TT: 6;
Number of systems with violations: Percent of total systems with TT
violations: 1.9;
Number of systems with violations: MR: 16;
Number of systems with violations: Percent of total systems with MR
violations: 5.0;
Number of systems with violations: Total: 20;
Number of systems with violations: Percent of total systems with
violations: 6.3.
State: NE;
Number of systems: 606;
Number of violations: TT: 59;
Number of violations: MR: 4;
Number of violations: Total: 63;
Number of systems with violations: TT: 58;
Number of systems with violations: Percent of total systems with TT
violations: 9.6;
Number of systems with violations: MR: 4;
Number of systems with violations: Percent of total systems with MR
violations: 0.7;
Number of systems with violations: Total: 62;
Number of systems with violations: Percent of total systems with
violations: 10.2.
State: NH;
Number of systems: 698;
Number of violations: TT: 18;
Number of violations: MR: 107;
Number of violations: Total: 125;
Number of systems with violations: TT: 14;
Number of systems with violations: Percent of total systems with TT
violations: 2.0;
Number of systems with violations: MR: 91;
Number of systems with violations: Percent of total systems with MR
violations: 13.0;
Number of systems with violations: Total: 100;
Number of systems with violations: Percent of total systems with
violations: 14.3.
State: NJ;
Number of systems: 609;
Number of violations: TT: 3;
Number of violations: MR: 108;
Number of violations: Total: 111;
Number of systems with violations: TT: 3;
Number of systems with violations: Percent of total systems with TT
violations: 0.5;
Number of systems with violations: MR: 79;
Number of systems with violations: Percent of total systems with MR
violations: 13.0;
Number of systems with violations: Total: 81;
Number of systems with violations: Percent of total systems with
violations: 13.3.
State: NM;
Number of systems: 645;
Number of violations: TT: 0;
Number of violations: MR: 54;
Number of violations: Total: 54;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 49;
Number of systems with violations: Percent of total systems with MR
violations: 7.6;
Number of systems with violations: Total: 49;
Number of systems with violations: Percent of total systems with
violations: 7.6.
State: NV;
Number of systems: 253;
Number of violations: TT: 1;
Number of violations: MR: 113;
Number of violations: Total: 114;
Number of systems with violations: TT: 1;
Number of systems with violations: Percent of total systems with TT
violations: 0.4;
Number of systems with violations: MR: 84;
Number of systems with violations: Percent of total systems with MR
violations: 33.2;
Number of systems with violations: Total: 84;
Number of systems with violations: Percent of total systems with
violations: 33.2.
State: NY;
Number of systems: 2,818;
Number of violations: TT: 62;
Number of violations: MR: 451;
Number of violations: Total: 513;
Number of systems with violations: TT: 52;
Number of systems with violations: Percent of total systems with TT
violations: 1.8;
Number of systems with violations: MR: 327;
Number of systems with violations: Percent of total systems with MR
violations: 11.6;
Number of systems with violations: Total: 362;
Number of systems with violations: Percent of total systems with
violations: 12.8.
State: OH;
Number of systems: 1,321;
Number of violations: TT: 38;
Number of violations: MR: 767;
Number of violations: Total: 805;
Number of systems with violations: TT: 35;
Number of systems with violations: Percent of total systems with TT
violations: 2.6;
Number of systems with violations: MR: 421;
Number of systems with violations: Percent of total systems with MR
violations: 31.9;
Number of systems with violations: Total: 436;
Number of systems with violations: Percent of total systems with
violations: 33.0.
State: OK;
Number of systems: 1,135;
Number of violations: TT: 2;
Number of violations: MR: 311;
Number of violations: Total: 313;
Number of systems with violations: TT: 1;
Number of systems with violations: Percent of total systems with TT
violations: 0.1;
Number of systems with violations: MR: 120;
Number of systems with violations: Percent of total systems with MR
violations: 10.6;
Number of systems with violations: Total: 120;
Number of systems with violations: Percent of total systems with
violations: 10.6.
State: OR;
Number of systems: 874;
Number of violations: TT: 138;
Number of violations: MR: 94;
Number of violations: Total: 232;
Number of systems with violations: TT: 94;
Number of systems with violations: Percent of total systems with TT
violations: 10.8;
Number of systems with violations: MR: 65;
Number of systems with violations: Percent of total systems with MR
violations: 7.4;
Number of systems with violations: Total: 127;
Number of systems with violations: Percent of total systems with
violations: 14.5.
State: PA;
Number of systems: 2,136;
Number of violations: TT: 75;
Number of violations: MR: 800;
Number of violations: Total: 875;
Number of systems with violations: TT: 72;
Number of systems with violations: Percent of total systems with TT
violations: 3.4;
Number of systems with violations: MR: 528;
Number of systems with violations: Percent of total systems with MR
violations: 24.7;
Number of systems with violations: Total: 572;
Number of systems with violations: Percent of total systems with
violations: 26.8.
State: RI;
Number of systems: 83;
Number of violations: TT: 1;
Number of violations: MR: 4;
Number of violations: Total: 5;
Number of systems with violations: TT: 1;
Number of systems with violations: Percent of total systems with TT
violations: 1.2;
Number of systems with violations: MR: 4;
Number of systems with violations: Percent of total systems with MR
violations: 4.8;
Number of systems with violations: Total: 4;
Number of systems with violations: Percent of total systems with
violations: 4.8.
State: SC;
Number of systems: 659;
Number of violations: TT: 92;
Number of violations: MR: 365;
Number of violations: Total: 457;
Number of systems with violations: TT: 60;
Number of systems with violations: Percent of total systems with TT
violations: 9.1;
Number of systems with violations: MR: 218;
Number of systems with violations: Percent of total systems with MR
violations: 33.1;
Number of systems with violations: Total: 238;
Number of systems with violations: Percent of total systems with
violations: 36.1.
State: SD;
Number of systems: 467;
Number of violations: TT: 4;
Number of violations: MR: 431;
Number of violations: Total: 435;
Number of systems with violations: TT: 4;
Number of systems with violations: Percent of total systems with TT
violations: 0.9;
Number of systems with violations: MR: 211;
Number of systems with violations: Percent of total systems with MR
violations: 45.2;
Number of systems with violations: Total: 213;
Number of systems with violations: Percent of total systems with
violations: 45.6.
State: TN;
Number of systems: 681;
Number of violations: TT: 0;
Number of violations: MR: 36;
Number of violations: Total: 36;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 19;
Number of systems with violations: Percent of total systems with MR
violations: 2.8;
Number of systems with violations: Total: 19;
Number of systems with violations: Percent of total systems with
violations: 2.8.
State: TX;
Number of systems: 4,489;
Number of violations: TT: 46;
Number of violations: MR: 54;
Number of violations: Total: 100;
Number of systems with violations: TT: 29;
Number of systems with violations: Percent of total systems with TT
violations: 0.6;
Number of systems with violations: MR: 54;
Number of systems with violations: Percent of total systems with MR
violations: 1.2;
Number of systems with violations: Total: 81;
Number of systems with violations: Percent of total systems with
violations: 1.8.
State: UT;
Number of systems: 451;
Number of violations: TT: 0;
Number of violations: MR: 315;
Number of violations: Total: 315;
Number of systems with violations: TT: 0;
Number of systems with violations: Percent of total systems with TT
violations: 0.0;
Number of systems with violations: MR: 186;
Number of systems with violations: Percent of total systems with MR
violations: 41.2;
Number of systems with violations: Total: 186;
Number of systems with violations: Percent of total systems with
violations: 41.2.
State: VA;
Number of systems: 1,265;
Number of violations: TT: 52;
Number of violations: MR: 253;
Number of violations: Total: 305;
Number of systems with violations: TT: 47;
Number of systems with violations: Percent of total systems with TT
violations: 3.7;
Number of systems with violations: MR: 185;
Number of systems with violations: Percent of total systems with MR
violations: 14.6;
Number of systems with violations: Total: 221;
Number of systems with violations: Percent of total systems with
violations: 17.5.
State: VT;
Number of systems: 435;
Number of violations: TT: 8;
Number of violations: MR: 135;
Number of violations: Total: 143;
Number of systems with violations: TT: 7;
Number of systems with violations: Percent of total systems with TT
violations: 1.6;
Number of systems with violations: MR: 108;
Number of systems with violations: Percent of total systems with MR
violations: 24.8;
Number of systems with violations: Total: 114;
Number of systems with violations: Percent of total systems with
violations: 26.2.
State: WA;
Number of systems: 2,277;
Number of violations: TT: 4;
Number of violations: MR: 1,548;
Number of violations: Total: 1,552;
Number of systems with violations: TT: 4;
Number of systems with violations: Percent of total systems with TT
violations: 0.2;
Number of systems with violations: MR: 1,272;
Number of systems with violations: Percent of total systems with MR
violations: 55.9;
Number of systems with violations: Total: 1,276;
Number of systems with violations: Percent of total systems with
violations: 56.0.
State: WI;
Number of systems: 1,086;
Number of violations: TT: 10;
Number of violations: MR: 210;
Number of violations: Total: 220;
Number of systems with violations: TT: 8;
Number of systems with violations: Percent of total systems with TT
violations: 0.7;
Number of systems with violations: MR: 129;
Number of systems with violations: Percent of total systems with MR
violations: 11.9;
Number of systems with violations: Total: 134;
Number of systems with violations: Percent of total systems with
violations: 12.3.
State: WV;
Number of systems: 537;
Number of violations: TT: 3;
Number of violations: MR: 335;
Number of violations: Total: 338;
Number of systems with violations: TT: 3;
Number of systems with violations: Percent of total systems with TT
violations: 0.6;
Number of systems with violations: MR: 153;
Number of systems with violations: Percent of total systems with MR
violations: 28.5;
Number of systems with violations: Total: 154;
Number of systems with violations: Percent of total systems with
violations: 28.7.
State: WY;
Number of systems: 276;
Number of violations: TT: 1;
Number of violations: MR: 98;
Number of violations: Total: 99;
Number of systems with violations: TT: 1;
Number of systems with violations: Percent of total systems with TT
violations: 0.4;
Number of systems with violations: MR: 80;
Number of systems with violations: Percent of total systems with MR
violations: 29.0;
Number of systems with violations: Total: 80;
Number of systems with violations: Percent of total systems with
violations: 29.0.
State: Total;
Number of systems: 51,449;
Number of violations: TT: 1,653;
Number of violations: MR: 15,752;
Number of violations: Total: 17,405;
Number of systems with violations: TT: 1,165;
Number of systems with violations: Percent of total systems with TT
violations: 2.3;
Number of systems with violations: MR: 9,343;
Number of systems with violations: Percent of total systems with MR
violations: 18.2;
Number of systems with violations: Total: 10,041;
Number of systems with violations: Percent of total systems with
violations: 19.5.
Legend: TT = treatment technique violations, including failure to
install optimal corrosion control treatment, failure to meet water
quality control parameters, failure to replace lead service lines, and
failure to meet public education requirements, among other things.
MR = monitoring and reporting violations, including the failure to
conduct required testing and failure to report the results.
Source: GAO analysis of EPA data.
Note: The total number of systems with violations, and the numbers of
systems with TT and MR violations do not add to the total numbers of
violations because in some cases, systems have more than one type of
violation.
[End of table]
[End of section]
Appendix IV: Information on Selected EPA and State Enforcement Actions,
by Type, from 1995 to June 2005[A]:
Public notification requested:
Type of Action: State;
Year: 1995: 1,359;
Year: 1996: 1,070;
Year: 1997: 1,190;
Year: 1998: 1,223;
Year: 1999: 1,097;
Year: 2000: 791;
Year: 2001: 988;
Year: 2002: 934;
Year: 2003: 1,136;
Year: 2004: 940;
Year: 2005: 1,174;
Totals: 11,902.
Type of Action: Federal;
Year: 1995: 277;
Year: 1996: 28;
Year: 1997: 15;
Year: 1998: 5;
Year: 1999: 6;
Year: 2000: 8;
Year: 2001: 3;
Year: 2002: 9;
Year: 2003: 1;
Year: 2004: 1;
Year: 2005: 3;
Totals: 356.
Type of Action: Formal notice of violation:
Type of Action: State;
Year: 1995: 969;
Year: 1996: 700;
Year: 1997: 526;
Year: 1998: 452;
Year: 1999: 499;
Year: 2000: 602;
Year: 2001: 606;
Year: 2002: 581;
Year: 2003: 649;
Year: 2004: 549;
Year: 2005: 647;
Totals: 6,780.
Type of Action: Federal;
Year: 1995: 614;
Year: 1996: 273;
Year: 1997: 83;
Year: 1998: 177;
Year: 1999: 73;
Year: 2000: 39;
Year: 2001: 91;
Year: 2002: 4;
Year: 2003: 8;
Year: 2004: 22;
Year: 2005: 6;
Totals: 1,390.
Type of Action: Bilateral compliance agreement:
Type of Action: State;
Year: 1995: 52;
Year: 1996: 119;
Year: 1997: 79;
Year: 1998: 87;
Year: 1999: 60;
Year: 2000: 40;
Year: 2001: 69;
Year: 2002: 91;
Year: 2003: 99;
Year: 2004: 89;
Year: 2005: 24;
Totals: 837.
Type of Action: Federal;
Year: 1995: 0;
Year: 1996: 5;
Year: 1997: 1;
Year: 1998: 2;
Year: 1999: 0;
Year: 2000: 0;
Year: 2001: 0;
Year: 2002: 0;
Year: 2003: 1;
Year: 2004: 0;
Year: 2005: 0;
Totals: 9.
Type of Action: Administrative orders:
Type of Action: State (without penalties);
Year: 1995: 107;
Year: 1996: 93;
Year: 1997: 89;
Year: 1998: 114;
Year: 1999: 83;
Year: 2000: 45;
Year: 2001: 89;
Year: 2002: 68;
Year: 2003: 71;
Year: 2004: 78;
Year: 2005: 21;
Totals: 837.
Type of Action: State (with penalties);
Year: 1995: 84;
Year: 1996: 67;
Year: 1997: 42;
Year: 1998: 319;
Year: 1999: 97;
Year: 2000: 52;
Year: 2001: 52;
Year: 2002: 56;
Year: 2003: 49;
Year: 2004: 57;
Year: 2005: 5;
Totals: 880.
Type of Action: Federal (proposed);
Year: 1995: 561;
Year: 1996: 153;
Year: 1997: 4;
Year: 1998: 1;
Year: 1999: 0;
Year: 2000: 0;
Year: 2001: 0;
Year: 2002: 3;
Year: 2003: 0;
Year: 2004: 0;
Year: 2005: 0;
Totals: 272.
Type of Action: Federal (final);
Year: 1995: 145;
Year: 1996: 146;
Year: 1997: 197;
Year: 1998: 64;
Year: 1999: 29;
Year: 2000: 13;
Year: 2001: 9;
Year: 2002: 10;
Year: 2003: 24;
Year: 2004: 17;
Year: 2005: 5;
Totals: 659.
Type of Action: Administrative penalties assessed:
Type of Action: State;
Year: 1995: 11;
Year: 1996: 28;
Year: 1997: 19;
Year: 1998: 21;
Year: 1999: 26;
Year: 2000: 10;
Year: 2001: 41;
Year: 2002: 31;
Year: 2003: 33;
Year: 2004: 30;
Year: 2005: 3;
Totals: 253.
Type of Action: Complaint for penalty issued[B]:
Type of Action: Federal;
Year: 1995: 9;
Year: 1996: 0;
Year: 1997: 10;
Year: 1998: 10;
Year: 1999: 8;
Year: 2000: 3;
Year: 2001: 0;
Year: 2002: 3;
Year: 2003: 0;
Year: 2004: 0;
Year: 2005: 0;
Totals: 43.
Type of Action: Civil cases referred:
Type of Action: State (to attorney general);
Year: 1995: 10;
Year: 1996: 15;
Year: 1997: 21;
Year: 1998: 13;
Year: 1999: 10;
Year: 2000: 3;
Year: 2001: 3;
Year: 2002: 1;
Year: 2003: 9;
Year: 2004: 9;
Year: 2005: 3;
Totals: 97.
Type of Action: Federal (to Department of Justice);
Year: 1995: 0;
Year: 1996: 0;
Year: 1997: 4;
Year: 1998: 1;
Year: 1999: 0;
Year: 2000: 0;
Year: 2001: 0;
Year: 2002: 0;
Year: 2003: 0;
Year: 2004: 54;
Year: 2005: 0;
Totals: 59.
Type of Action: Criminal cases filed:
Type of Action: State;
Year: 1995: 1;
Year: 1996: 2;
Year: 1997: 1;
Year: 1998: 0;
Year: 1999: 3;
Year: 2000: 0;
Year: 2001: 0;
Year: 2002: 0;
Year: 2003: 0;
Year: 2004: 0;
Year: 2005: 0;
Totals: 7.
Type of Action: Federal;
Year: 1995: 0;
Year: 1996: 0;
Year: 1997: 0;
Year: 1998: 0;
Year: 1999: 0;
Year: 2000: 0;
Year: 2001: 0;
Year: 2002: 0;
Year: 2003: 0;
Year: 2004: 0;
Year: 2005: 0;
Totals: 0.
Source: GAO analysis of EPA data.
Notes:
[A] We included the most commonly used enforcement actions in this
table and excluded miscellaneous actions and activities unrelated to
enforcement or the lead rule.
[B] EPA files a "complaint for penalty" when the terms of an
administrative order are violated.
[End of table]
[End of section]
Appendix V: Comments from the Environmental Protection Agency:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY:
OFFICE OF WATER:
WASHINGTON, D.C. 20460:
NOV 18 2006:
John B. Stephenson:
Director, Natural Resources and the Environment:
Government Accountability Office:
Washington, DC 20548:
Dear Mr. Stephenson:
Thank you for the opportunity to review the proposed Government
Accountability Office (GAO) Report; Drinking Water: EPA Should
Strengthen Ongoing Efforts to Ensure that Consumers are Protected from
Lead Contamination. We appreciate the information in the report and are
fully committed to strengthening consumer protections from lead
contamination.
As your report acknowledges, the Environmental Protection Agency (EPA)
has been working since early 2004 to better understand implementation
of the Lead and Copper Rule nationwide. On March 7, 2005, we announced
the Drinking Water Lead Reduction Plan, a series of efforts we are
undertaking to revise regulations and guidance in order to improve
implementation of the rule. We will continue to collect and analyze
information to help us target areas where implementation needs to be
further improved. We want to ensure this rule, which has been critical
in lowering exposure to lead in drinking water, continues to be
successful.
Your staff evaluated (1) the completeness of information that EPA has
to evaluate implementation, (2) areas of the rule where modifications
could strengthen public health protection, and (3) the availability of
information to assess the quality of drinking water in schools and
child care facilities with respect to lead. I would like to respond to
your findings in each of these areas.
Lead Compliance Information:
Your report fairly represents the challenges that we faced in working
to understand the effectiveness of the rule in reducing exposure to
lead in drinking water. In initiating our review, our focus was on
understanding the extent to which utilities were currently exceeding
the 15 ppb action level. While states were responsive to our immediate
request, your report correctly indicates that many have not continued
to focus on adding new data reported by utilities to the database. We
will continue to emphasize to states the importance of having this data
to understand national implementation and will work with our Office of
Enforcement and Compliance Assurance to assess the adequacy of
enforcement efforts.
Your report stresses that information on how utilities have met
milestones associated with taking steps to meet the rule is important
in determining the effectiveness of implementation. As you noted, our
Safe Drinking Water Information System (SDWIS) has incomplete data for
milestones that were effective with revisions to the rule in 2000.
However, while your report accurately characterizes the incompleteness
of new milestones, we believe it is important to note that an absence
of new milestone data does not necessarily mean that utilities did not
take steps to implement corrosion control. Many states failed to update
their data to convert the older milestones that were used with the 1991
rule into the new milestones for individual systems. For example, in
Wisconsin, although none of the 13 large systems have the new DEEM or
DONE milestones in SDWIS, 9 did have a milestone under the old data
structure to indicate that optimal corrosion control treatment had been
installed. However, notwithstanding that difference, it is accurate to
state that data for milestones - under both the old and new structures
- is incomplete. We will work with states over the coming year to
ensure that relevant information is loaded into SDWIS.
Reassessment of the Regulation:
Your report describes several areas where you believe there are
opportunities to improve the effectiveness of the rule. We agree with
GAO that these areas warrant additional attention and we are addressing
some of them (e.g., criteria for reducing monitoring, customer
notification, management of treatment changes) as part of our package
of revisions to the Lead and Copper Rule that we will be proposing
early in the new year. Our decision to revise several provisions in the
rule was based on a review of our information request to states asking
how they were implementing provisions of the rule and feedback we heard
from stakeholders during the expert workshops we conducted during 2004.
However, we need additional information before we can address several
of the other issues discussed in the report, including data on the
effectiveness of lead service line replacement programs and analysis to
determine appropriate monitoring requirements for combined distribution
systems. Ongoing research projects being funded by the American Water
Works Association Research Foundation should help inform efforts on
lead service line replacement and the sufficiency of existing
requirements related to lead content and leaching potential of devices
used in residential plumbing.
Programs to Control Lead in Drinking Water at School and Child Care
Facilities:
We take seriously the issue of lead in schools and child care
facilities, as children are more vulnerable to the negative effects of
lead. We agree with you that there is insufficient information to
determine whether there are widespread problems with lead in school
drinking water. However, we understand the concerns that water
utilities have about being considered the responsible party for
drinking water quality within specific facilities. Although some water
utilities are working with local communities to facilitate testing,
ultimately they have no authority over conditions within a specific
facility. We believe that approaches such as that in Connecticut, which
requires testing of drinking water to be conducted as part of the
licensing process for child care facilities, represent a more
commonsense approach to ensuring that children are protected. We also
acknowledge the concerns of state administrators about balancing risks
of exposure to lead in drinking water with other environmental
exposures within school environments.
Because there are no federal requirements for testing drinking water in
schools that are not already a public water system, we are strongly
advocating a voluntary program to encourage school districts to test
drinking water. As your report notes, we have entered into a memorandum
of understanding with the Department of Education, Centers for Disease
Control and Prevention, Association of State Drinking Water
Administrators and associations representing drinking water utilities.
We are committed to work with these organizations and other
organizations representing schools and child care facilities to
encourage greater consideration of drinking water quality. We are
working to release a revised guidance document for testing drinking
water in schools and additional products over the next several months.
Our experience with the lead rule reminds us that a regulation is only
effective if it is effectively implemented. We understand that EPA
regional staff, state staff, and utility managers face challenges in
carrying out federal requirements in addition to their other duties.
But the experience of Washington, DC reminds us of the importance of
maintaining public confidence in the safety of drinking water. We
believe that improvements are already happening due to the renewed
emphasis on rule. Many states have begun efforts to review their
programs and have already made changes to improve oversight and
reporting. However, staff at local, state and federal levels must
continue to carry out implementation and oversight activities to ensure
that public confidence is maintained.
I appreciated the opportunity to coordinate with your staff on this
project. Should you need additional information or have further
questions, please contact me or Cynthia C. Dougherty, Director of the
Office of Ground Water and Drinking Water at (202) 564-3750.
Sincerely,
Signed by:
Benjamin H. Grumbles:
Assistant Administrator:
Appendix VI: GAO Contact and Staff Acknowledgments:
GAO Contact:
John B. Stephenson (202) 512-3841:
Staff Acknowledgments:
In addition to the individual named above, Ellen Crocker, Nancy
Crothers, Sandra Edwards, Maureen Driscoll, Benjamin Howe, Julian
Klazkin, Jean McSween, Chris Murray, and George Quinn, Jr. made key
contributions to this report.
(360478):
FOOTNOTES
[1] For purposes of this report, we are referring to day care centers,
nursery schools or pre-schools, and school-based after school programs
as child care facilities.
[2] Because this report examines only those requirements and activities
applicable to lead, we will henceforth refer to this rule as the "lead
rule." See 40 C.F.R. § 141.80 et. seq.
[3] 42 U.S.C. § 300f et. seq.
[4] Under the lead rule, high risk sites include single-family homes
that contain copper pipes with lead solder installed after 1982 or lead
pipes--or that are served by lead service lines.
[5] Generally, schools and child care facilities that operate their own
water systems are required to test their drinking water under EPA's
lead rule. EPA estimates that there are approximately 10,000 such
systems in the United States.
[6] GAO, District of Columbia's Drinking Water: Agencies Have Improved
Coordination, but Key Challenges Remain in Protecting the Public from
Elevated Lead Levels, GAO-05-344 (Washington, D.C.: Mar. 31, 2005).
[7] In addition, all systems that have installed corrosion control
treatment and consistently meet water quality control parameters
specified by the state may also qualify for reduced monitoring.
[8] If testing indicates that the source water is contributing to
elevated lead levels, then water systems may be required to install
additional treatment.
[9] Large water systems exceeding the action level must install
corrosion control treatment unless (1) they already had such treatment
in place prior to the effective date of the lead rule and have
conducted related activities equivalent to those specified in the lead
rule or (2) they can demonstrate that their source water is minimally
corrosive, thereby reducing the likelihood that lead will be introduced
into the drinking water from corrosion of lead-bearing plumbing
materials.
[10] 42 U.S.C. § 300g-6(d).
[11] 42 U.S.C. § 300j-21 et seq.
[12] Coolers are considered "lead-free" if any parts or components that
may come in contact with drinking water have no more than 8 percent
lead or include solder, flux, or interior surfaces with no more than
0.2 percent lead. 42 U.S.C. § 300j-21(2).
[13] EPA provided us with a data run as of August 9, 2005. According to
EPA, these data represent, for the most part, compliance information
reported through June 30, 2005; however, states may have made a limited
number of additions or corrections to the data through the run date.
[14] EPA issued minor revisions to the lead rule, including changes to
the reporting requirements, in January 2000. While the revisions
generally took effect as of April 2000, one exception was the reporting
requirements. Although states were encouraged to begin meeting the new
requirements sooner, they did not officially take effect until January
2002. See 65 Fed. Reg. 1991 (Jan. 12, 2000).
[15] Our analysis included active community water systems. Of the water
systems lacking data, 157 are large and 2,457 are medium-sized systems.
[16] For the purposes of this report, we are using the term "corrective
action milestones" although, in some instances, water systems can be
reported as meeting a milestone without taking or completing a
corrective action. For example, water systems do not necessarily have
to install treatment to be deemed to have optimized corrosion control.
They may be eligible for a DEEM designation because their lead levels
are consistently low or they can demonstrate that they have minimally
corrosive water.
[17] EPA, Drinking Water Data Reliability Analysis and Action Plan
(2003), EPA 816-R-03-021 (Washington, D.C., March 2004). The report's
estimates of data quality have an 80 percent confidence level and a 7.5
percent margin of error.
[18] EPA includes several types of violations in its treatment
technique category, including failure to install optimal corrosion
control treatment, failure to meet water quality control parameters,
failure to replace lead service lines, and failure to meet public
education requirements, among other things.
[19] 65 Fed. Reg. 1991 (Jan. 12, 2000).
[20] 63 Fed. Reg. 20043 (Apr. 22, 1998).
[21] EPA, Data Reliability Analysis of the EPA Safe Drinking Water
Information System/Federal Version (SDWIS/FED), EPA 816-R-00-020
(Washington, D.C.: Oct. 2000). EPA found that from 1993 to 1998, 1
state had not reported any lead monitoring violations and 21 states had
not reported any treatment technique violations related to the lead
rule.
[22] If a water system does not have a sufficient number of Tier 1
sites in its sampling pool, the system may use Tier 2 sites, which are
buildings (including multi-family residences) that meet the Tier 1
criteria. If necessary, the system may obtain samples from Tier 3
sites, which are single-family structures that contain copper pipes
with lead solder installed before 1983.
[23] For example, homeowners may drop out of the sampling program,
homes may be torn down or become vacant, or homeowners may install
water softeners or other treatment devices that reduce lead levels.
[24] Under the lead rule, systems that qualify for reducing the
frequency of monitoring because of consistently good test results may
also reduce the number of samples they test (and accordingly, the
number of locations from which they collect samples). Except for the
smallest systems, which serve populations of 100 or fewer (and are only
required to take 5 samples), water systems can cut the number of
samples they collect by half. This means, for example, that the largest
systems, serving populations of over 100,000, can reduce the number of
sampling locations from 100 to 50.
[25] Specifically, if the test results are at or below the action level
in two consecutive 6-month monitoring periods, the systems may reduce
the frequency of monitoring to once a year. Further, systems that test
below the action level in three consecutive annual monitoring periods
may be allowed to conduct testing only once every 3 years. Small
systems may be eligible to reduce their monitoring frequency to once
every 9 years if (1) they can demonstrate that their distribution
system, service lines, and drinking water supply plumbing (including
the plumbing conveying drinking water within all residences and other
buildings connected to the system) is lead-free and (2) all applicable
test results do not exceed 5 parts per billion at the 90th percentile.
[26] When systems install corrosion control treatment, states must
evaluate tap and water quality parameter samples to determine whether
the system has properly installed and operated the treatment.
[27] When systems submit new monitoring or treatment data, or when
other relevant data become available, states are required to review
and, where appropriate, revise their determinations.
[28] In analyzing these data, we compared the most recent test results
reported during the 2002 to June 2005 time frame and data on water
systems' current monitoring frequency.
[29] Although the lead rule states that test results must "meet" the
action level (i.e., be at or below the action level) for a water system
to be eligible for reduced monitoring, 10 states reported that reduced
monitoring is allowed only when the test results are "below" the action
level. We did not follow up with these states to determine whether they
actually differ from the federal rule or their response was in error.
[30] In some of these instances, the states' responses implied--but did
not specify--additional criteria. Otherwise, two states (Louisiana and
South Dakota) reported that water systems would be approved for
triennial monitoring if their 90th percentile test results were less
than half of the action level. Michigan limits reductions in the number
of sampling locations in the case of "combined distribution systems,"
in which systems that purchase water are interconnected with a water
wholesaler.
[31] 40 C.F.R. § 142.10(b)(5).
[32] 40 C.F.R. § 141.90(a)(3).
[33] Information provided by the remaining 19 states was unclear,
generally because their responses were limited or based on a literal
interpretation of EPA's question (e.g., states responded "in writing,"
when asked how systems notified the state about treatment changes).
[34] Overall, 65 water systems with lead service lines were included in
the survey. Although a total of 41 systems responded to the survey, the
number of responses to individual questions varied.
[35] In addition, nine states reported that one or more of their water
systems were replacing lead service lines voluntarily (including one
state that also reported requiring systems to replace lead lines). Two
more states reported that systems with lead goosenecks, which connect
water mains to the service lines, have either replaced the goosenecks
or are doing so as they are discovered.
[36] Another two states said that they issued regulations or provided
guidance instructing systems to comply with the testing requirements;
three states indicated that they review a system's replacement program
during periodic inspections; and six states did not provide any
information regarding their oversight of lead service line testing.
[37] Under EPA's proposed definitions, a "water wholesaler" is a water
system that sells or otherwise delivers treated water to another system
on a regular basis (at least 60 days per year); a "consecutive system"
is a system that buys or otherwise receives some or all of its treated
water from another water system at least 60 days per year. EPA defines
the totality of the distribution systems of all interconnected
wholesale and consecutive systems as a combined distribution system.
[38] We were unable to confirm the actual number of community water
systems in EPA's estimate. According to EPA, they are in the process of
developing better data on the number and type of water systems involved
in combined distribution systems.
[39] 40 C.F.R. § 141.29. EPA must concur with modified monitoring
arrangements.
[40] According to a Massachusetts Water Resources Authority official,
the 30 communities receive corrosion control from the Authority and are
part of the modified sampling arrangement approved by the Massachusetts
Department of Environmental Protection. The Authority also provides
more limited services to 17 other systems, including water that is
mixed with local supplies in some cases and emergency water supplies in
other cases. Each of these other systems has its own lead rule
compliance program.
[41] In this case, the individual communities did notify their
customers of the 90th percentile results for the applicable consecutive
system. However, EPA's database does not contain this information so it
is not readily available to the public at large.
[42] 42 U.S.C. § 300g-6(a),(d),(e).
[43] See NSF, ANSI/NSF Standard 61: Drinking Water System Components -
Health Effects (Ann Arbor, Mich.: 1997). NSF focuses on food, water,
indoor air, and the environment. NSF is accredited by the American
National Standards Institute (ANSI) to provide third-party
certification to NSF Standard 61.
[44] Dudi, A., Schock, M., Murray, N., and Edwards, M., Lead Leaching
from Inline Brass Devices: A Critical Evaluation of the Existing
Standard, Journal AWWA (August 2005).
[45] McLellan, C., Purkiss, D., and Greiner, P., Interim Report on
Extraction Results on Leaded Products Submitted for Evaluation Under
NSF/ANSI 61, NSF International (Ann Arbor, Mich.: June 2005).
[46] Model plumbing codes include the International Plumbing Code and
the United Plumbing Code.
[47] See Cal. Safety & Health Code § 25249.5 (part of the initiative
known as Proposition 65 adopted by popular vote in 1986).
[48] Under the lead rule, water systems are not required to replace an
individual lead service line if the lead concentration in all service
line samples from that line is less than or equal to 15 parts per
billion. This is sometimes referred to as the "test-out" provision.
[49] See ACORN v. Edwards, 81 F.3d 1387 (5th Air. 1996).
[50] 55 Fed. Reg. 22387 (June 1, 1990).
[51] Under the terms of the recall order, the manufacturer was required
to (1) provide periodic reports to the Commission for 3 years,
including information on the number of replacements shipped and refunds
mailed, and (2) maintain records related to the recall for 5 years.
[52] Natural Resources Defense Council, The Lead Contamination Control
Act: A Study in Non-Compliance (June 1991). Because this study is used
for context purposes, we did not assess its reliability.
[53] EPA published the first guidance document in 1989. See EPA Office
of Water, Lead in School's Drinking Water, EPA 570-9-89-001
(Washington, D.C.: Jan. 1989). EPA updated the guidance in 1994. See
EPA Office of Water, Lead in Drinking Water in Schools and Non-
Residential Buildings, EPA 812-8-94-002 (Washington, D.C.: Apr. 1994).
Also in 1994, EPA published a separate guidance document to address
child care facilities. See EPA Office of Water, Sampling for Lead in
Drinking Water in Nursery Schools and Day Care Facilities, EPA 812-B-
94-003 (Washington, D.C.: Apr. 1994).
[54] GAO, Toxic Substances: The Extent of Lead Hazards in Child Care
Facilities and Schools Is Unknown, GAO/RCED-93-197 (Washington, D.C.:
Sept. 14, 1993).
[55] EPA Office of the Inspector General, Report of Audit on the Lead
in Drinking Water Program, Report No. E1HWF9-03-0316-0100508
(Washington, D.C.: Sept. 28, 1990).
[56] The Lead Contamination Control Act: A Study in Non-Compliance, pp.
6-7.
[57] EPA, Controlling Lead in Drinking Water for Schools and Day Care
Facilities: A Summary of State Programs, EPA-810-R-04-001 (Washington,
D.C.: July 2004).
[58] Although not reported in response to EPA's information request,
Washington state also conducted a survey of school testing shortly
after the LCCA was enacted and found that 25 percent of 121 schools
that conducted testing detected unacceptable levels of lead in one or
more drinking water outlets.
[59] In New Hampshire, the testing requirement applies only to
facilities that care for 24 or fewer children and have their own
independent water supply.
[60] See ACORN v. Edwards, 81 F.3d 1387 (5th Cir. 1996).
[61] In EPA's guidance for schools and child care facilities, the
agency recommends using a sample volume of 250 milliliters and
establishes lead concentrations greater than 20 parts per billion as
the trigger for follow-up action. In contrast, the testing protocol for
public water supplies requires a sample volume of 1 liter and follow-up
action if lead levels at the 90th percentile exceed 15 parts per
billion. According to EPA, the testing protocol for water systems is
designed to assess lead levels for the system as a whole, using a
representative number of households; if applicable, the testing also
serves as a means of determining the effectiveness of corrosion control
treatment. The protocol for schools and child care facilities is
slightly more stringent than that used in water systems, and is
designed to determine lead levels at specific outlets.
[62] Some schools and child care facilities have their own water
sources and are subject to Safe Drinking Water Act requirements, such
as the lead rule. Such systems are defined as non-transient,
noncommunity water systems, which serve at least 25 people for more
than 6 months in a year. According to EPA estimates, about 10,000
schools and child care facilities are regulated as non-transient,
noncommunity systems but, according to one official, these data are
incomplete.
[63] Specifically, the parties agreed to encourage schools and child
care facilities to test drinking water for lead, disseminate the
results to the public, and take appropriate actions to correct
problems.
[64] The National Child Care Association is active in 26 states and
represents about 8,000 private, licensed child care facilities that are
based outside the home. The association does not represent the family
home care industry, which consists of an estimated 3,000 individually-
owned family homes that offer child care services.
[65] The National Head Start Association represents more than 1 million
children, 200,000 staff, including teachers and family service workers,
and 2,700 Head Start programs in the U.S.
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