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entitled 'District of Columbia's Drinking Water: Agencies Have Improved
Coordination, but Key Challenges Remain in Protecting the Public from
Elevated Lead Levels' which was released on May 5, 2005.
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Report to the Chairman, Subcommittee on Environment and Hazardous
Materials, Committee on Energy and Commerce, House of Representatives:
March 2005:
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:
GAO Highlights:
Highlights of GAO-05-344, a report to the Chairman, Subcommittee on
Environment and Hazardous Materials, Committee on Energy and Commerce,
House of Representatives:
Why GAO Did This Study:
Media reports on elevated lead in the District of Columbia’s drinking
water raised concern about how local and federal agencies are carrying
out their responsibilities. The Lead and Copper Rule requires water
systems to protect drinking water from lead. The U.S. Army Corps of
Engineers’ Washington Aqueduct treats and sells water to the District
Water and Sewer Authority (WASA), which delivers it to District
residents. The Environmental Protection Agency’s (EPA) Region III
Office oversees these agencies.
GAO examined (1) what agencies implementing the rule in the District
are doing to improve their coordination and reduce lead levels, (2) the
extent to which WASA and other agencies are identifying populations at
greatest risk of exposure to lead in drinking water and reducing their
exposure, (3) how other drinking water systems that exceed EPA’s action
level for lead conduct public education, and (4) the state of research
on lead exposure and how it applies to drinking water.
What GAO Found:
WASA and other government agencies have improved their coordination,
but significant challenges remain. According to EPA officials, WASA has
thus far met the terms of a June 2004 consent order by enhancing its
coordination with EPA and the D.C. Department of Health. For example,
WASA developed a plan to improve its public education efforts and
collaborated with the department to set priorities for replacing lead
service lines. EPA expects the August 2004 addition of a corrosion
inhibitor to eventually reduce lead in drinking water, though it may
take more than one year for full improvements to be observed. Tap water
test results reported in January 2005 show that D.C. drinking water
still exceeds the standard for lead.
WASA is identifying those customers most at risk from exposure to lead
in drinking water and reducing their exposure. WASA is focusing on lead
service lines as the primary source of lead in drinking water. It is
updating its inventory of lead service lines, accelerating its rate of
service line replacement, and providing priority replacement for
customers most vulnerable to lead’s health effects. However, questions
remain about the success of the replacement program because, by law,
WASA can only pay to replace the portion of the service line that it
owns. Homeowners may pay to replace their portion of the service line,
but few homeowners chose to do so in 2003 and 2004.
Other water systems use innovative methods to educate their customers
and to judge the effectiveness of their efforts. These practices
include using a variety of media to inform the public, forming
partnerships with government and nonprofit agencies, and targeting and
adapting information to the audiences most susceptible to lead exposure
through drinking water. Many of these practices go well beyond the
requirements of the Lead and Copper Rule. In this connection, water
industry representatives and others noted several shortcomings with the
rule’s public education provisions, including confusing language and
the lack of a requirement to notify homeowners of the specific lead
levels in their drinking water. Additionally, EPA has not evaluated
water systems’ public education efforts on lead in drinking water since
the rule was established more than a decade ago.
Much is known about the health effects of lead exposure, particularly
its impact on brain development and functioning in young children.
However, limited studies have been conducted on the health effects of
exposure to low levels of lead in drinking water. EPA plans to prepare
a health advisory document to help utilities explain the risks of lead
exposure to the public, and a paper summarizing lead research conducted
since the Lead and Copper Rule was published in 1991. However, the
timetable for these projects is not clear, and it is also not clear how
this work will fit into a broader research agenda, or if this effort
needs to involve other key organizations, such as the Centers for
Disease Control and Prevention.
What GAO Recommends:
GAO recommends that EPA (1) identify and publish best practices that
water systems use to educate their customers about lead in drinking
water and (2) develop a strategy for closing information gaps in the
health effects of lead in drinking water. EPA generally agreed with the
report.
www.gao.gov/cgi-bin/getrpt?GAO-05-344.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact John Stephenson at (202)
512-3841 or stephensonj@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Agencies Have Improved Coordination, but Challenges Remain in Reducing
Lead Levels:
WASA and Other Agencies Are Taking Steps to Identify At-Risk
Populations and Reduce Their Lead Exposure:
Experiences of Other Water Systems Highlight Ways to Better Educate the
Public:
Although Lead Exposure Causes Serious Health Effects, Research on Low-
Level Exposure to Lead in Drinking Water Is Limited:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Environmental Protection Agency:
Tables:
Table 1: Summary of Selected June 2004 Consent Order Requirements and
Compliance Activities:
Table 2: WASA's Priority Lead Service Line Replacement Program:
Table 3: Portland's Targeted Lead Education Program:
Figures:
Figure 1: Inventory of WASA Service Lines:
Figure 2: Lead Service Line Configuration:
Abbreviations:
CDC: Centers for Disease Control and Prevention:
EPA: Environmental Protection Agency:
IEUBK: Integrated Exposure Uptake Biokinetic Model for Lead:
MCL: maximum contaminant level:
MCLG: maximum contaminant level goal:
MOU: memorandum of understanding:
MWRA: Massachusetts Water Resources Authority:
ppb: parts per billion:
WASA: District of Columbia Water and Sewer Authority:
WIC: Women, Infants, and Children:
Letter March 31, 2005:
The Honorable Paul Gillmor:
Chairman:
Subcommittee on Environment and Hazardous Materials:
Committee on Energy and Commerce:
House of Representatives:
Dear Mr. Chairman:
In January 2004, local media reported that the District of Columbia
Water and Sewer Authority (WASA) had found elevated lead levels in the
drinking water of more than 4,000 homes in the city--the results of
tests conducted during the summer of 2003. The lack of timely
disclosure of this problem and the subsequent confused effort by
government agencies to inform the public on steps to protect itself
resulted in numerous congressional hearings and ongoing Environmental
Protection Agency (EPA) efforts to review the adequacy of federal
regulations on lead in drinking water. In July 2004 testimony before
your subcommittee,[Footnote 1] we made preliminary observations on
issues surrounding the elevated levels of lead found in Washington,
D.C.'s drinking water and highlighted areas for further examination.
This letter discusses our findings and recommendations from that
further review.
Although rarely the sole cause of lead poisoning, lead in drinking
water can significantly increase a person's total lead exposure. EPA
estimates that drinking water is the source of up to 20 percent of
Americans' lead exposure, and recent research suggests that drinking
water may provide as much as 60 percent of total lead exposure for
infants who drink baby formula and concentrated juices that are mixed
with water. Adults exposed to high levels of lead could develop kidney
problems or high blood pressure. Developing fetuses, infants, and young
children are more vulnerable to lead from all sources, including
drinking water. Their exposure to lead may harm their physical or
mental development.
Lead is unusual among drinking water contaminants because it generally
does not come from source water supplies like rivers and lakes. Rather,
lead enters drinking water primarily from the corrosion of materials
containing lead in the water distribution system and in household
plumbing. These materials include lead service lines that connect a
house to the water main, lead-based solder used in a house to join
copper pipe, and brass plumbing fixtures such as faucets. The 1986
Amendments to the Safe Drinking Water Act limited the amount of lead
used in solder, faucets, pipes, and other plumbing components. However,
older leaded components are still present in many homes, and many new
components still contain some lead.
The Safe Drinking Water Act is the key federal law protecting public
water supplies from harmful contaminants.[Footnote 2] Its 1991 Lead and
Copper Rule requires water systems to protect consumers against
exposure to elevated levels of lead in drinking water by chemically
treating water to reduce its corrosiveness and by collecting water
samples from consumer taps and testing them for evidence of lead
corrosion.[Footnote 3] Because lead contamination generally occurs
after water leaves the treatment plant, the Lead and Copper Rule
requires testing for lead at consumer taps. Large water systems, like
WASA's, generally must take 100 samples in a 6-month period. EPA
considers lead to be over the "action level" when lead levels are
higher than 15 parts per billion in over 10 percent of tap water
samples taken. If a water system exceeds the action level, it must
notify and educate the public about ways to reduce exposure. If lead
levels exceed the action level after treatment to minimize water's
corrosiveness, the water system must annually replace 7 percent of the
lead service lines that it owns.
Implementation and enforcement of the Lead and Copper Rule in the
District of Columbia is complicated because of the number and nature of
the entities involved. The Washington Aqueduct, owned and operated by
the U.S. Army Corps of Engineers, treats the water (including
controlling for corrosion). WASA purchases water from the Washington
Aqueduct and delivers it to District residents, and is responsible for
monitoring tap water samples for lead. EPA Region III in Philadelphia
has oversight and enforcement authority for the District's public water
systems.
You asked us to determine (1) what the key government entities that
implement the Safe Drinking Water Act's regulations for lead in the
District of Columbia are doing to increase their level of coordination
and reduce lead levels, (2) to what extent WASA and other agencies are
determining which adult and child populations in the District of
Columbia are at greatest risk of exposure to elevated lead levels in
drinking water and how the agencies are reducing the public's lead
exposure, (3) how other drinking water systems that exceeded EPA's
action level for lead conducted public notification and education, and
(4) the state of research on lead exposure and how this information
could help inform other drinking water utilities of potential problems
in their systems.
To answer the first two questions, we interviewed officials responsible
for the delivery and regulation of drinking water in the District of
Columbia, including WASA, EPA, the Washington Aqueduct, and officials
from community advocacy groups. We also reviewed key documents, such as
the consent orders between WASA and EPA and testimony by the involved
entities. Additionally, we spoke to officials with the D.C. Department
of Health and the Centers for Disease Control and Prevention (CDC), and
reviewed a March 2004 CDC study on lead exposure from drinking water in
the District of Columbia. To answer the third question, we interviewed
officials responsible for the delivery and regulation of drinking water
in several cities around the country, reviewed documents these
officials produced, and observed aspects of their public education
programs. We also spoke with EPA, water industry groups, and public
advocacy groups and reviewed reports these entities produced. Finally,
to answer the fourth question, we interviewed experts on the health
effects of lead exposure, including officials at EPA and CDC, and
reviewed public health studies and medical literature describing the
health effects of lead exposure. We also interviewed EPA officials and
reviewed program documentation to understand EPA's involvement in lead
research.
We conducted our review from April 2004 through February 2005 in
accordance with generally accepted government auditing standards. For a
more detailed discussion of our scope and methodology, see appendix I.
Results in Brief:
WASA and other government agencies implementing the Safe Drinking Water
Act's regulations for lead have taken steps to improve their
coordination, but challenges remain to reduce lead levels. According to
EPA officials, WASA appears to be on track to meet the terms of a June
17, 2004, consent order the two agencies signed. The consent order
required WASA to take a number of corrective actions that, by
necessity, enhanced its coordination with EPA and the D.C. Department
of Health. Among these actions were developing a plan to identify
additional lead service lines, improving the selection of sampling
locations and reporting of water testing results to EPA, developing a
strategy to improve WASA's public education efforts, and collaborating
with the D.C. Department of Health to set priorities for replacing lead
service lines. WASA has also agreed to implement several
recommendations the D.C. Inspector General made in a January 2005
report to improve coordination between EPA, WASA and the D.C.
Department of Health. However, improved coordination has not, and may
not, resolve all problems. EPA and WASA officials remain concerned
about lead levels in drinking water. Tap water test results that WASA
submitted in January 2005 indicate the drinking water WASA provided
still exceeds the action level for lead of 15 parts per billion.
According to EPA, experts have said that it can take 6 months or more
to begin seeing a drop in lead levels and a year or more for the
orthophosphate treatment to reduce lead levels below the EPA action
level.
WASA is taking steps to identify those customers most at risk from
exposure to lead in drinking water and to reduce their exposure. WASA
and EPA are focusing on lead service lines as the primary source of
lead in drinking water in the District of Columbia. Under the consent
order, WASA is identifying those most at risk by updating its inventory
of lead service lines, primarily by determining the composition of
service lines made of unknown materials. In addition, to reduce the
exposure of District residents to lead in drinking water, WASA is
accelerating its rate of lead service line replacement and, consistent
with the consent order, providing priority replacement for populations
particularly vulnerable to the health effects of lead. Locations
eligible for priority replacement of lead service lines include day
care centers and homes housing children up to 6 years old with elevated
blood lead levels. However, questions remain about the success of this
replacement program because WASA often replaces only part of the lead
service line. Generally, ownership of service lines is shared--WASA
owns the portion from the water main to the property line, and
homeowners own the portion from the property line to the home.
Homeowners may pay to replace their portion of the lead service line at
the same time as WASA replaces its portion, but are not required to do
so. Only 2 percent of homeowners replaced their portion of the service
line in fiscal years 2003 and 2004. WASA officials attribute low
homeowner participation to cost concerns, but believe its incentive
program--which includes low-interest loans, grants, and a fixed-fee
structure--is increasing the number of full pipe replacements.
Available data from fiscal year 2005 show that 14 percent of customers
have replaced the private portion of their home's lead service line.
Other water systems use innovative methods to educate their customers
about lead in drinking water and to judge the effectiveness of their
efforts. These practices include using a variety of media to inform the
public, forming partnerships with government and community groups, and
targeting and adapting information to audiences most susceptible to
lead exposure through drinking water. Many of these practices go well
beyond the requirements of the Lead and Copper Rule. Representatives
from the water industry and community groups as well as other experts
have found several shortcomings with the Lead and Copper Rule's public
education requirements. They noted, for example, that the rule's
required notification language is confusing and that a water system has
up to 60 days to notify its customers if the system exceeds the action
level for lead. EPA is both examining water systems' compliance with
the Lead and Copper Rule's public education requirements and
considering changing the rule or its accompanying guidance documents
and training. While we support this effort, the clear deficiencies of
the rule's public education requirements call for more immediate action
to assist water systems in their efforts to educate the public.
Therefore, we recommend that EPA identify and publish best practices
that water systems are using to educate the public about lead in
drinking water.
Much is known about the health effects of lead exposure, particularly
lead's impact on brain development and functioning in young children.
However, according to experts we interviewed, limited studies have been
conducted on the heath effects of exposure to low levels of lead in
drinking water, and these studies are now nearly 20 years old.
Acknowledging the need for improved and up-to-date information,
officials in EPA's Office of Water and its Office of Research and
Development indicate that they are beginning to address certain
information gaps about the health risks of lead in drinking water. For
example, the Office of Water is planning to prepare a health advisory
document for lead to help utilities and state and local officials
explain the risks of lead exposure to the public. Additionally, the
Office of Water is planning to develop a paper summarizing the results
of research conducted on lead exposure since the Lead and Copper Rule
was published in 1991. However, the timetable for completing these
projects is not clear, and it is also not clear how this work will fit
into a broader agency research agenda or if this research needs to
involve other key organizations, such as CDC. To address this issue, we
recommend that EPA develop a strategy for closing information gaps in
the health effects of lead in drinking water that includes timelines,
funding requirements, and any needed coordination with CDC and other
research organizations.
Background:
The Safe Drinking Water Act established a federal-state arrangement in
which states may be delegated primary implementation and enforcement
authority ("primacy") for the drinking water program. Except for
Wyoming and the District of Columbia, all states and territories have
received primacy. For contaminants that are known or anticipated to
occur in public water systems and that the EPA Administrator determines
may have an adverse impact on health, the act requires EPA to set a
nonenforceable maximum contaminant level goal (MCLG) at which no known
or anticipated adverse health effects occur and that allows an adequate
margin of safety. Once the MCLG is established, EPA may set an
enforceable standard for water as it leaves the treatment plant, the
maximum contaminant level (MCL). The MCL generally must be set as close
to the MCLG as is feasible using the best technology or other means
available, taking costs into consideration. Alternatively, EPA can
establish a treatment technique, which requires a treatment procedure
or level of technological performance to reduce the level of the
contaminant.
The fact that lead contamination occurs after water leaves the
treatment facility has complicated efforts to regulate lead in the same
way as most other drinking water contaminants. In 1975, EPA established
an interim MCL for lead of 50 parts per billion (ppb), but did not
require sampling of tap water to show compliance with the standard.
Rather, the standard had to be met at the water system before the water
was distributed. The 1986 amendments to the act directed EPA to issue a
new lead regulation, and in 1991, EPA adopted the Lead and Copper Rule.
Instead of an MCL, the rule established an "action level" of 15 ppb for
lead in drinking water. To reduce the amount of lead entering the water
as it flows through distribution lines and home plumbing to customers'
taps, the rule required that water systems, if needed, treat the water
to limit its corrosiveness. Under the rule, the action level is
exceeded if lead levels are higher than 15 ppb in over 10 percent of
tap water samples.[Footnote 4] Large systems, including WASA's,
generally must take at least 100 tap water samples in a 6-month
monitoring period, though reduced monitoring schedules are also allowed
for some systems. If a water system exceeds the action level, it has 60
days to deliver a public education program that meets EPA requirements,
including a notice in customers' water bills; delivery of public
service announcements to television and radio stations; and the
distribution of information to locations likely to serve populations
vulnerable to lead exposure, including hospitals, clinics, and local
welfare agencies.[Footnote 5] In addition, if lead levels exceed the
action level after treatment to minimize water's corrosiveness, the
water system must annually replace 7 percent of the lead service lines
under its ownership and offer to replace the private portion of the
lead service line (at the owner's expense) until the tap water 90th
percentile lead levels drop below the action level for two consecutive
six month monitoring periods.
Drinking water is provided to District of Columbia residents under a
unique organizational structure:
* The U.S. Army Corps of Engineers' Washington Aqueduct draws water
from the Potomac River that it filters and chemically treats to meet
EPA specifications. The aqueduct produces drinking water and sells it
to utilities that serve approximately 1 million people living or
working in or visiting the District of Columbia; Arlington County,
Virginia; and Falls Church, Virginia. Managed by the Corps of
Engineers' Baltimore District, the aqueduct is a federally owned and
operated public water supply agency that produces an average of 180
million gallons of water per day at two treatment plants located in the
District.
* The District of Columbia Water and Sewer Authority buys its drinking
water from the Washington Aqueduct and distributes it through 1,300
miles of water mains to customers in the District and several federal
facilities in Virginia. From its inception in 1938 until 1996, WASA's
predecessor, the District of Columbia Water and Sewer Utility
Administration, was a part of the District's government. In 1996, WASA
was established by the District of Columbia as a semiautonomous
regional entity.
* EPA's Region III Office in Philadelphia has primary oversight and
enforcement responsibility for public water systems in the District of
Columbia. According to EPA, the regional office's oversight and
enforcement responsibilities include providing technical assistance to
the water suppliers on how to comply with federal regulations; ensuring
the suppliers report monitoring results to EPA by the required
deadlines; taking enforcement actions if violations occur; and using
those enforcement actions to return the system to compliance in a
timely fashion.
* The District's Department of Health, while having no formal role
under the act, has as its mission identifying health risks and
educating the public on those risks.
In August 2002, WASA officially reported to EPA that drinking water in
the District of Columbia exceeded the action level for lead. This
report triggered the Lead and Copper Rule's requirement to deliver a
public education program within 60 days and to replace lead service
lines at a minimum rate of 7 percent per year.[Footnote 6] Because WASA
and property owners in the District share ownership of the water
service lines, the rule required WASA to replace the portion of the
lines that it owns, and to offer to replace the portion of the lines
controlled by the homeowners at the homeowners' expense.
Under the Lead and Copper Rule, water systems get credit for lead
service line replacement either by actually replacing lines or by
finding homes with lead service lines that test under the 15 ppb action
level. For fiscal year 2003, WASA decided to physically replace and
test lead service lines concurrently. WASA reported that it tested
4,613 homes with lead service lines in fiscal year 2003, and found
1,241 homes at or below the 15 ppb action level but another 3,372 homes
with water exceeding the action level.[Footnote 7] Local media made
these results public in January 2004.
EPA began a special audit of WASA's compliance with the Lead and Copper
Rule in February 2004. This audit resulted in a consent order that EPA
and WASA signed on June 17, 2004. Congress held a number of hearings in
2004 to investigate drinking water problems in the District.
Agencies Have Improved Coordination, but Challenges Remain in Reducing
Lead Levels:
WASA and other government agencies implementing the act's regulations
for lead have taken steps to improve their coordination. According to
EPA officials, WASA has thus far met the terms of the order the two
agencies signed that required WASA to take a number of corrective
actions. WASA has also agreed to implement most recommendations that
the D.C. Inspector General made in a January 2005 report to develop
internal policies and procedures at WASA that would improve the
coordination between EPA, WASA, and the D.C. Department of Health.
Improved coordination, however, has not resolved all problems, and EPA
and WASA officials remain concerned that drinking water WASA provides
still exceeds the action level for lead of 15 parts per billion.
WASA Has Improved Coordination with Other Agencies:
Under the June 2004 Consent Order, WASA agreed to take several actions
to improve its compliance with the Lead and Copper Rule and, in so
doing, enhanced its coordination with EPA and the D.C. Department of
Health. The order required WASA to improve its selection of sampling
locations and reporting of water testing results to EPA, create a
strategy to improve its public education efforts, physically replace an
additional 1,615 lead service lines by the end of fiscal year 2006,
develop a plan and a schedule to identify additional lead service
lines, and, in collaboration with the D.C. Department of Health,
develop a plan to set priorities for replacing lead service lines.
According to staff in EPA's Region III, WASA appears to be on track to
meet the terms of the order. Table 1 identifies some principal
requirements of the order and notes the status of WASA's compliance as
of January 18, 2005.
Table 1: Summary of Selected June 2004 Consent Order Requirements and
Compliance Activities:
Required WASA action: Submit tap water sampling plan;
Submitted to EPA: June 25, 2004;
EPA action: Provided comments to plan on July 14, 2004; no approval
required under order.
Required WASA action: Develop a new public education plan;
Submitted to EPA: July 19, 2004;
EPA action: Provided comments to plan on August 2, 2004; no approval
required under order.
Required WASA action: Develop a plan to update inventory of lead
service lines;
Submitted to EPA: August 2, 2004;
EPA action: Approved September 29, 2004.
Required WASA action: With D.C. Department of Health approval, develop
plan for prioritizing replacement of lead service lines;
Submitted to EPA: August 2, 2004;
EPA action: Approved September 29, 2004.
Required WASA action: Develop plan to encourage homeowners to consent
to full replacement of lead service lines;
Submitted to EPA: August 2, 2004;
EPA action: Approved August 10, 2004.
Required WASA action: Develop plan for enhanced database management and
reporting;
Submitted to EPA: August 16, 2004;
EPA action: Provided comments to plan on September 3, 2004; no approval
required under order.
Source: EPA.
[End of table]
WASA also agreed to implement 11 of the 12 recommendations contained in
the D.C. Inspector General's January 2005 report.[Footnote 8] The D.C.
Inspector General found that WASA had not developed or maintained
internal policies or procedures for implementing requirements set forth
in the Lead and Copper Rule, including those for selecting and
reporting lead water sample test results. However, the D.C. Inspector
General concluded that WASA's current initiatives on lead
concentrations in the District's tap water were noteworthy; he also
made 12 recommendations to improve WASA's annual monitoring, lead
service line replacement, and communication.
WASA agreed to all of the Inspector General's recommendations except
one to develop a memorandum of understanding (MOU) with the D.C.
Department of Health that defines both agencies' roles and
responsibilities, the expert advice each agency can provide in the
areas of water quality management, and the frequency and manner of
transmission of information between the agencies. WASA did not agree
that an MOU was necessary to ensure effective cooperation, and noted
that its relationship with the D.C. Department of Health has vastly
improved and reflects a more creative and flexible partnership and that
the range of substantive issues around which WASA and the D.C.
Department of Health must communicate is wide, diverse, and complex.
While we agree that WASA's relationship with the D.C. Department of
Health has improved, we nonetheless agree with the Inspector General's
view that an MOU would serve to define the two agencies' roles and
responsibilities and help improve their coordination and partnership.
Lead Levels Remain Above the Action Level:
Despite improved coordination, the central problem remains: lead in
D.C. drinking water is still over the EPA action level. In February
2004, EPA formed a Technical Expert Working Group made up of
representatives from WASA; EPA; CDC; the Washington Aqueduct; Arlington
and Falls Church, Virginia; the D.C. Department of Health; and industry
consultants. Industry experts traced the likely cause for the increased
lead levels to November 2000. At that time, the Washington Aqueduct
changed its secondary disinfectant treatment from free chlorine to
chloramines to comply with a new EPA regulation that placed strict
limits on disinfection by-products. This change in water treatment may
have had the unintended consequence of making the corrosion control
treatment that was in place no longer adequately protective.[Footnote
9] Therefore, lead levels increased in water exposed to lead-containing
plumbing and fixtures.
The group recommended the introduction of orthophosphate to the
drinking water supply because it concluded that this chemical would
form a protective coating inside lead service lines and fixtures to
prevent lead from leaching into drinking water. In order to assess the
effect of orthophosphate on the water distribution system, in May 2004,
EPA approved the Washington Aqueduct's request to apply the corrosion
inhibitor to a portion of the District of Columbia drinking water
distribution system, and the corrosion inhibitor was introduced June
2004. This portion is called the 4th High Pressure Zone, and it is
hydraulically isolated from the remainder of the system.
In early August 2004, based on the results of the partial system test,
EPA approved the Washington Aqueduct's request for broader use of the
corrosion inhibitor, and on August 23, 2004, the inhibitor was
introduced systemwide. On January 10, 2005, WASA submitted to EPA its
latest tap water sampling results, covering tap water samples taken
from July through December 2004. These results showed that the 90th
percentile sample reached 59 ppb, still substantially over the 15 ppb
action level for lead. However, EPA and WASA officials report that some
reductions of lead levels occurred in the latter half of the monitoring
period. WASA data show that 42 samples taken during July through
September 2004 had a 90th percentile reading of 82 ppb, while 88
samples taken during October through December 2004 had a 90th
percentile reading of 31 ppb. According to EPA, experts have said that
it can take 6 months or more to begin seeing a drop in lead levels and
a year or more for the orthophosphate treatment to reduce lead levels
below the EPA action level.
WASA and Other Agencies Are Taking Steps to Identify At-Risk
Populations and Reduce Their Lead Exposure:
WASA is identifying those most at risk for exposure to lead in drinking
water by updating its inventory of lead service lines. To reduce the
exposure of District residents to lead in drinking water, WASA is
accelerating its rate of lead service line replacement and providing
priority replacement of lead service lines for populations particularly
vulnerable to the health effects of lead. However, questions remain
about the success of the lead service line replacement program, because
WASA is replacing only part of the lead service line unless customers
pay to have their portion replaced.
WASA Is Updating Its Lead Service Line Inventory:
WASA and EPA officials are focusing on lead service lines as the
primary source of lead in drinking water in the District of Columbia.
Locating these lines allows WASA to identify the people most likely to
be exposed. The June 2004 consent order that WASA signed with EPA
Region III requires WASA to update its baseline inventory of lead
service lines each year.[Footnote 10] WASA must use this baseline
inventory to calculate the 7 percent of lines it replaces each year. In
September 2004, WASA revised its baseline inventory to 23,637 lead
service lines and reported this number to EPA. However, at that time
WASA did not know the composition of 31,380 service lines. The order
requires WASA to provide a strategy and timetable for identifying the
composition of these unknown lines. During fiscal year 2005, WASA plans
to determine the composition of 1,200 unknown lines by digging up or
testing a segment of each line. Figure 1 shows the inventory of WASA's
service lines as of October 1, 2004.
Figure 1: Inventory of WASA Service Lines:
[See PDF for image]
[End of figure]
To speed the process of identifying the composition of unknown lines,
WASA is attempting to develop a methodology to identify the composition
without physically digging up the line. WASA plans to statistically
analyze line composition data from test pits dug in 2003 through 2005
along with known quantities about each excavated line: the date of
service line construction, water test result for lead, and size of
service line. WASA hopes that these known quantities can be used to
determine the unknown line composition. WASA plans to complete this
analysis by August 1, 2005.
WASA Is Accelerating Lead Service Line Replacement and Targeting At-
Risk Populations:
To reduce residents' exposure to lead in drinking water, WASA is
accelerating its schedule for replacing lead service lines. WASA's
Board of Directors decided to replace all lead service lines in public
space in the District of Columbia by 2010. The total cost of this
program is estimated at $300 million. In fiscal years 2002 through
2004, WASA replaced 2,229 lead service lines in public space, about 9
percent of the total known lead service line inventory.
In its lead service line replacement program, WASA replaces the
majority of lines on a block-by-block basis. However, to reduce
exposure to lead in drinking water for those residents most vulnerable
to lead's health effects, WASA agreed, as part of the consent order, to
develop in consultation with the D.C. Department of Health a system for
setting priorities for lead service line replacement and to replace
1,000 lead service lines by the end of fiscal year 2006 on a priority
basis. For fiscal year 2005, WASA's first priority for replacement is
homes with children younger than 6 who have elevated blood lead
levels;[Footnote 11] its second priority is day-care centers; and its
third priority is homes that are occupied by children younger than 6,
or pregnant or nursing mothers. WASA identified members of this third
group by sending a letter to all customers in its database who have a
lead service line or a service line of unknown composition. Customers
could return the letter to identify themselves as members of these at
risk groups, as appropriate, and WASA sorted customer responses to
remove those who did not meet the criteria for priority replacement.
WASA worked with the D.C. Department of Health to establish criteria
for priority replacement, and EPA has approved the program. Table 2
shows the number of priority replacements WASA completed in fiscal year
2004 and plans to complete in fiscal year 2005.
Table 2: WASA's Priority Lead Service Line Replacement Program:
Year: Fiscal 2004 (completed);
Number of lead service lines replaced: Children under 6 with elevated
blood lead: 135;
Number of lead service lines replaced: Day-care centers: 46;
Number of lead service lines replaced: Children under 6, or pregnant or
nursing women: 137;
Number of lead service lines replaced: Total priority replacements:
318.
Year: Fiscal 2005 (estimated);
Number of lead service lines replaced: Children under 6 with elevated
blood lead: 289;
Number of lead service lines replaced: Day-care centers: 119;
Number of lead service lines replaced: Children under 6, or pregnant or
nursing women: 592[A];
Number of lead service lines replaced: Total priority replacements:
1,000[B].
Source: WASA.
Notes: WASA priorities for replacement in 2004 were different from the
2005 priorities. WASA's first priority in 2004 was day-care centers,
followed by children with elevated blood lead and high-risk residents
(children under 6, or pregnant or nursing women).
[A] WASA is forwarding 2,097 notices to customers who identified
themselves as members of this group, and customers must provide
verification. Additionally, not all of these homes will actually have a
lead service line, when tested.
[B] The June 2004 consent order requires WASA to replace 1,000 service
lines on a priority basis by the end of fiscal year 2006. WASA
officials plan to meet this deadline by the end of fiscal year 2005.
[End of table]
Questions Remain about the Success of the Lead Service Line Replacement
Program:
WASA is replacing lead service lines in public space--from the water
main to the homeowners' property line. In the District of Columbia,
homeowners own the portion of the service line that runs from the
property line to the home. Homeowners may replace this portion of the
line if they choose, but this replacement is not required.[Footnote 12]
WASA can replace the private portion of a lead service line when it
replaces its portion of the line. Figure 2 shows the configuration of a
service line from the water main to a customer's home.
Figure 2: Lead Service Line Configuration:
[See PDF for image]
[End of figure]
Experts disagree about the effectiveness of removing only part of a
lead service line. Studies that EPA cited in the Lead and Copper Rule
suggest that long-term exposure to lead from drinking water decreases
when a service line is partially replaced. However, after partial
replacement of a lead service line, exposure to lead in drinking water
is likely to increase in the short term because cutting or moving the
pipe can dislodge lead particles and disturb any protective coating on
the inside of the pipe. Some experts believe that lead exposure can
increase after partial service line replacement because of galvanic
corrosion where the dissimilar metals of the old and new pipes meet. A
study at WASA showed that partial lead service line replacement
significantly reduced average lead levels, but that flushing was
necessary to remove lead immediately after replacement. At an EPA
conference on lead service line replacement in October 2004, water
industry officials and others stressed the importance of encouraging or
mandating full replacement of lead service lines.
As the consent order required, WASA has established a program to
encourage homeowners to replace their portion of lead service lines.
This program includes:
* a low-interest loan program for low-income residents, offered through
a local bank;
* grants of up to $5,000 for low-income residents, offered by the
District of Columbia Department of Housing and Community Development;
and:
* a fixed-fee structure for line replacement of $100 per linear foot
plus $500 to connect through the wall of the home, to make pricing
easier for homeowners to understand.
WASA implemented this program in July 2004, and EPA approved the
program on August 10, 2004. Information about these programs is
included in the notice that homeowners receive at least 45 days before
their lead service line is scheduled to be replaced.
Thus far, few homeowners in the District of Columbia have replaced
their portion of lead service lines. In fiscal years 2003 through 2004,
only 2 percent of homeowners (48 of 2,217) replaced the private portion
of their lead service line. WASA officials attribute the low rate of
full line replacement to customers' cost concerns. An EPA Region III
official told us it is too early to determine if the District of
Columbia's program is increasing the number of customers who replace
their portion of the service line, since the program went into place
approximately 2 months before the end of fiscal year 2004. However,
WASA officials told us that the number of full replacements is
increasing since the program was implemented--14 percent of customers
(119 of 841) replaced the private portion of their lead service line
between October 1, 2004, and January 28, 2005. EPA has asked WASA to
report on the number of customers taking advantage of the various
incentive programs in the 2005 annual lead service line replacement
report.
Madison, Wisconsin, provides an alternative example for maximizing full
lead service line replacement. A 1997 study showed that these lines
were the source of elevated lead levels in water, and that fully
replacing them could reduce lead levels to well below the action level.
Madison cannot use orthophosphate corrosion control treatment because
this treatment would degrade surface water quality in local lakes. In
lieu of corrosion control treatment, the water utility is replacing all
lead service lines in the city over 10 years, a total of approximately
6,000 service lines. To ensure that lines are completely replaced,
Madison passed an ordinance in 2000 requiring homeowners to replace
their portion of the lead service line when the utility replaces its
portion. The city reimburses homeowners for half of the cost they incur
in replacing their portion of the line, up to a maximum of $1,000.
Assistance is available for customers who cannot afford the
replacement. A Madison Water Utility official told us that before the
ordinance was passed, less than 1 percent of customers paid to have
their portion of the lead service line replaced.
Experiences of Other Water Systems Highlight Ways to Better Educate the
Public:
Other water systems use innovative methods to educate their customers
about lead in drinking water. These practices include using a variety
of media to inform the public, forming partnerships with government
agencies and community groups, and targeting educational materials to
the audience most susceptible to lead exposure through drinking water.
These practices tend to go well beyond the provisions of the Lead and
Copper Rule, which require public notification language that is
difficult to understand and do not require utilities to notify
individual homeowners of the lead concentrations in their homes'
drinking water.
Other Water Systems Used Innovative Methods to Educate the Public about
Lead in Drinking Water:
WASA's experience highlights the importance of conducting an effective
public education program. In its June 2004 consent order, EPA found
that WASA had committed only a few violations of the public education
requirements of the Lead and Copper Rule.[Footnote 13] However,
community groups and others have criticized WASA for failing to
adequately convey information to its customers about lead in drinking
water and for failing to communicate a sense of urgency in the
materials provided. As we testified in July 2004, EPA acknowledges that
it should have provided better oversight of WASA's public education
program.
Other water systems we contacted have used innovative approaches to
educate the public about lead in drinking water. For example, some
systems used a variety of media to inform the public. Officials from
the Massachusetts Water Resources Authority (MWRA) appear for
interviews on local radio and television talk shows to spread
information about lead in drinking water. The Portland (Oregon) Water
Bureau provides funding for many lead education initiatives, including
materials presented to new parents in hospitals; billboard, movie, and
bus advertisements targeted to neighborhoods with older housing; and
education materials produced by the Community Alliance of Tenants to
educate renters on potential lead hazards. Each of these materials
directs people to call a telephone hotline to get information about all
types of lead hazards. This hotline is operated by the Multnomah County
Health Department and funded by the Portland Water Bureau.
Water industry experts at an EPA conference in September 2004 stressed
the importance of partnerships, particularly with health officials, in
educating the public about lead in drinking water. Some water systems
have already formed partnerships to better educate the public and
provide a unified message. Three examples follow:
* MWRA provides training workshops on drinking water issues, including
lead in drinking water, for local health officials. These officials can
then educate the public about drinking water issues when they arise.
* MWRA also sends the local health department the same drinking water
data that it sends to the state drinking water regulator, so local
health officials are well informed.
* The Portland Water Bureau participates in an integrated program to
educate the public and reduce exposure to all sources of lead,
including drinking water. The water bureau's partners in this program
include the Multnomah County Health Department, the State Lead
Poisoning Prevention Program, the Portland Bureau of Housing and
Community Development, and community nonprofit agencies.
The Lead and Copper Rule requires water systems that exceed the action
level to provide written education materials to facilities and
organizations that serve high-risk segments of the population,
including people more susceptible to the adverse effects of lead and
people at greater risk of exposure to lead in drinking water. Some
water systems have gone beyond this basic requirement to better reach
high-risk populations. For example, in January 2004, the Portland Water
Bureau sent a targeted mailing of approximately 2,600 postcards to the
homes of an age most likely to contain lead solder that it identified
as having a child 6 years old or younger. These postcards encouraged
residents to get their water tested for lead, learn about childhood
blood lead screening, and reduce lead hazards in their homes. Water
bureau officials said that they obtained the information needed to
target the mailing from a commercial marketing company and that the
information was inexpensive and easy to obtain. The rule specifies that
educational materials be delivered to Women, Infants, and Children
(WIC) and Head Start programs, where available. Both Portland and MWRA
have cultivated relationships with these programs. MWRA worked with
local WIC officials to add information about lead in drinking water to
WIC's postpartum program for new mothers, and to prepare an easy-to-
understand brochure explaining how to avoid exposure to lead in
drinking water. Portland funded efforts with Head Start to provide free
blood lead testing and to present puppet shows teaching children how to
avoid lead hazards. Table 3 shows how the Portland Water Bureau targets
its lead education program to community groups.
Table 3: Portland's Targeted Lead Education Program:
Activity: Annual lead brochure;
Targeted population: Homes at high risk for lead in water: Yes;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: Yes;
Targeted population: Home remodels: Yes;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: Yes.
Activity: Annual Consumer Confidence Report;
Targeted population: Homes at high risk for lead in water: Yes;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: Yes;
Targeted population: Home remodels: Yes;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: Yes.
Activity: Postcard outreach to homes built between 1970-1985, with
children 6 and under;
Targeted population: Homes at high risk for lead in water: Yes;
Targeted population: Older homes: No;
Targeted population: Low-income residents: No;
Targeted population: Child-oriented services: No;
Targeted population: Home remodels: No;
Targeted population: Specific populations: No;
Targeted population: Broad population: No.
Activity: Childcare outreach;
Targeted population: Homes at high risk for lead in water: Yes;
Targeted population: Older homes: No;
Targeted population: Low-income residents: No;
Targeted population: Child-oriented services: Yes;
Targeted population: Home remodels: No;
Targeted population: Specific populations: No;
Targeted population: Broad population: No.
Activity: Lead education and LeadLine brochure distribution;
Targeted population: Homes at high risk for lead in water: Yes;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: Yes;
Targeted population: Home remodels: Yes;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: Yes.
Activity: Lead education video;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: Yes;
Targeted population: Home remodels: No;
Targeted population: Specific populations: No;
Targeted population: Broad population: Yes.
Activity: Outreach to health providers;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: No;
Targeted population: Low-income residents: No;
Targeted population: Child-oriented services: Yes;
Targeted population: Home remodels: No;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: No.
Activity: Landlord training and landlord outreach;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: No;
Targeted population: Low-income residents: No;
Targeted population: Child-oriented services: No;
Targeted population: Home remodels: No;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: No.
Activity: Community forums: African-American, Vietnamese, Russian
communities;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: No;
Targeted population: Home remodels: No;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: No.
Activity: Billboards, bus ads, and theater ads;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: No;
Targeted population: Home remodels: No;
Targeted population: Specific populations: No;
Targeted population: Broad population: Yes.
Activity: Newspaper ads in community newspapers;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: No;
Targeted population: Home remodels: No;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: Yes.
Activity: Home Depot, permit center, and community location displays;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: No;
Targeted population: Child-oriented services: No;
Targeted population: Home remodels: Yes;
Targeted population: Specific populations: No;
Targeted population: Broad population: Yes.
Activity: Location of clinics and workshops;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: No;
Targeted population: Home remodels: No;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: No.
Activity: Head Start outreach;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: No;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: Yes;
Targeted population: Home remodels: No;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: No.
Activity: Canvassing in target areas;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: No;
Targeted population: Home remodels: No;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: No.
Activity: Low-income renters--outreach by Community Alliance of
Tenants;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: Yes;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: No;
Targeted population: Home remodels: No;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: No.
Activity: Blood lead testing for children of migrant workers;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: No;
Targeted population: Low-income residents: Yes;
Targeted population: Child-oriented services: Yes;
Targeted population: Home remodels: No;
Targeted population: Specific populations: Yes;
Targeted population: Broad population: No.
Activity: Mailing to child-care facilities;
Targeted population: Homes at high risk for lead in water: No;
Targeted population: Older homes: No;
Targeted population: Low-income residents: No;
Targeted population: Child-oriented services: Yes;
Targeted population: Home remodels: No;
Targeted population: Specific populations: No;
Targeted population: Broad population: No.
Source: Portland Water Bureau.
[End of table]
Some other water systems measure the impact of their public education
programs. MWRA has conducted focus groups to judge the effectiveness of
its public education program, and routinely refines the information
presented about lead in drinking water. The Portland Water Bureau
tracks calls received by its lead information hotline and surveys
callers to determine their satisfaction with the program and the extent
to which it changed their behavior. An official from St. Paul
(Minnesota) Regional Water Services told us that the utility surveys
its customers about water quality issues. During the time the utility
was conducting public education about lead in drinking water, it
surveyed customers each year to ask if customers believed they were
receiving enough information about the quality of their water.
Lead and Copper Rule Public Education Requirements Have Several
Shortcomings:
Responding to concerns about the Lead and Copper Rule's public
education requirements, EPA conducted a workshop in September 2004 at
which representatives from the water industry and community groups
discussed their views of the rule's requirements. Representatives from
the water industry also told us they went beyond the rule's
requirements to ensure the success of their public education programs.
At the EPA workshop and in interviews, water industry officials,
experts, and community groups identified the following problems:
* The public cannot easily understand the required public education
language. Representatives of several water utilities told us the
required language was too long and the reading level too advanced for
many customers to understand. One expert estimated that understanding
the EPA language required at least an 11th grade reading level, while
approximately half the adult population of the United States reads at
an 8th grade level or lower. Water industry officials suggested
customizing education materials about lead in drinking water for those
who have limited reading ability.
* The rule does not require utilities to send results to homeowners
whose water is sampled for lead compliance. EPA officials told us that
many water systems do provide this information to customers, but in the
past, WASA did not provide this information in a timely fashion. The
consent order requires WASA to provide lead results to homeowners
within 3 days of receiving the results from the laboratory, and
encourages WASA to provide this data within 30 days of collecting the
sample.
* Public notification under the rule is less timely than that required
for other violations of the Safe Drinking Water Act. The rule requires
a water system to notify the public within 60 days if it exceeds the
action level for lead. Other violations of the Safe Drinking Water Act
with the potential to cause serious adverse effects on human health
require public notification within 30 days, including violations of
MCLs and treatment techniques.[Footnote 14]
* EPA has not evaluated the effectiveness of the public education
requirements of the rule since it was implemented in 1991. Water
industry officials at the EPA workshop suggested several methods to
evaluate the effectiveness of public outreach, including surveying the
public to determine its knowledge of lead in drinking water issues and
comparing the level of knowledge in areas where public education has
and has not been conducted. These officials also suggested that EPA
identify public education activities conducted by utilities around the
country that are following EPA guidelines and doing additional
voluntary education work to identify good practices.
In response to elevated lead levels in the District of Columbia, EPA is
conducting a national review of compliance and implementation of the
Lead and Copper Rule, including its public education requirements.
Additionally, EPA conducted the public education expert workshop to
gain information to use in its deliberations about changing the Lead
and Copper Rule and possibly its accompanying guidance documents and
training. We support EPA's efforts in re-evaluating the public
education requirements of the rule, but believe that EPA also needs to
provide more practical assistance that water systems can use when
educating their customers about lead in drinking water.
Although Lead Exposure Causes Serious Health Effects, Research on Low-
Level Exposure to Lead in Drinking Water Is Limited:
Much is known about the health effects of lead exposure, particularly
lead's impact on brain development and functioning in young children.
However, according to experts we interviewed, limited studies have been
conducted on the heath effects of exposure to low levels of lead in
drinking water. Officials in EPA's Office of Water and Office of
Research and Development told us they are beginning to address certain
information gaps about the health risks of lead in drinking water.
However, the timetable for completing this effort is not clear.
Lead Exposure Causes Serious Health Effects, Particularly in Children:
Health experts agree that lead is toxic to almost every organ system,
and much research has documented its adverse health effects. While many
body systems can be severely affected by high chronic and acute lead
exposures, lead is dangerous in large part because moderate to low
chronic exposure can result in adverse health effects.[Footnote 15] The
threshold for harmful effects of lead remains unknown. Over the years,
as new data has become available, CDC has revised its recommendations
on the threshold of blood lead levels that should raise concern and
trigger interventions. In 1975, CDC's blood lead level threshold of
concern stood at 30 micrograms per deciliter. In 1991, CDC lowered the
blood lead level of concern to 10 micrograms per deciliter. Research
conducted since 1991 provides evidence of adverse effects at even lower
levels--at less than 10 micrograms per deciliter among children younger
than 6.
Because of their behavior and physiology, children are more sensitive
than adults to exposure to lead in a given environment. For example,
children generally come into more contact with lead because they spend
more time on the ground, where there may be lead-contaminated soil or
dust. Mouthing and hand-to-mouth behaviors also increase the likelihood
that children may ingest soil or dust. Physiologically, children take
in more food and water per pound of body weight, and their absorption
of lead is estimated to be 5 to 10 times greater than adults. Finally,
children are more sensitive than adults to elevated blood lead levels
because organ systems, including their brain and nervous system, are
still developing. This ongoing development increases the risk of lead's
entry into the brain and nervous system, and can result in prolonged or
permanent neurobehavioral disorders.
In contrast, most adult exposures to lead are occupational and occur in
lead-related industries, such as lead smelting, refining, and
manufacturing. Adults exposed to lead can develop high blood pressure,
anemia, and kidney damage. Lead poses a substantial threat to pregnant
women and their developing fetuses because blood lead readily crosses
the placenta. Pregnant women with elevated blood lead levels may have
an increased chance of miscarriage, premature birth, and newborns with
low birth weight or neurologic problems.
CDC tracks children's blood lead levels in the United States through
the National Health and Nutrition Examination Surveys and state and
local surveillance data.[Footnote 16] The surveys between 1976 and 1980
found evidence of an estimated 88 percent prevalence of lead levels
greater than or equal to 10 micrograms per deciliter in children aged 1
to 5 compared with an estimated prevalence of 2.2 percent in 1999 to
2000.[Footnote 17] Health experts generally attribute this decline to
the elimination of leaded gasoline and lead solder from canned foods,
and a ban on leaded paint used in housing and other consumer products.
Data provided by the District of Columbia to CDC for 2001 show that, of
an estimated 39,356 children younger than 6, 16,036 were tested for
lead. Of those, 437, or 2.73 percent, had blood lead levels greater
than or equal to 10 micrograms per deciliter.
More recently, in response to the discovery of high lead levels in
drinking water in the District of Columbia, CDC and the D.C. Department
of Health studied blood lead levels of residents most at risk for lead
exposure.[Footnote 18] This study was designed to determine the extent
to which lead in drinking water was contributing to blood lead levels
of District residents. One portion of the study focused on residents of
homes with known lead levels in drinking water greater than 300 ppb,
much greater than the EPA action level of 15 ppb. Health officials
attempted to contact nearly all residents of homes with lead
concentrations at this level, and collected blood samples for lead
analysis from residents who agreed to the procedure. Of the 201
residents tested, all were found to have blood lead levels less than
CDC's levels of concern for adults or children, as appropriate.
Another portion of this study examined blood lead data collected by the
District of Columbia Department of Health's blood lead surveillance
system. Results of blood lead tests conducted from January 1998 through
December 2003 were compared for a nonprobability sample of homes with
known lead service lines and homes with nonlead service lines.[Footnote
19] During 2000 through 2003, the period when lead levels in drinking
water increased, the number of people with blood lead levels greater
than 5 micrograms per deciliter decreased for the sample without lead
service lines but did not decrease in a statistically significant way
for the sample with lead service lines. In the District of Columbia,
blood lead levels are generally greater in homes with lead service
lines. In general, the older homes most likely to have lead service
lines are also those most likely to have other lead hazards, such as
lead in paint and dust.
Research on the Health Effects of Lead in Drinking Water Is Limited:
A good deal of research has been conducted on the health effects of
lead associated with certain pathways of contamination, such as the
ingestion of lead paint and the inhalation of dust contaminated with
lead. According to a number of public health experts, drinking water
contributes a relatively minor amount to overall lead exposure in
comparison with other sources. However, the most relevant studies on
the isolated health effects of lead in drinking water date back nearly
20 years--including the Glasgow Duplicate Diet Study on lead levels in
children, upon which the Lead and Copper Rule is partially
based.[Footnote 20]
While lead in drinking water is rarely thought to be the sole cause of
lead poisoning, it can significantly increase a person's total lead
exposure--particularly for infants who drink baby formula or
concentrated juices that are mixed with water from homes with lead
service lines or plumbing systems. For children with high levels of
lead exposure from paint, soil, and dust, drinking water is thought to
contribute a much lower proportion of total exposure. For residents of
dwellings with lead solder or lead service lines, however, drinking
water could be the primary source of exposure. As exposure declines
from sources of lead other than drinking water, such as gasoline and
soldered food cans, drinking water will account for a larger proportion
of total intake. Thus, according to EPA's Lead and Copper Rule, the
total drinking water contribution to overall lead levels may range from
as little as 5 percent to more than 50 percent of a child's total lead
exposure.[Footnote 21]
According to recent medical literature and the public health experts we
contacted, the key uncertainties about the effects of lead in drinking
water requiring clarification include the incremental effects of lead-
contaminated drinking water on people whose blood lead levels are
already elevated from other sources of lead contamination and the
potential health effects of exposure to low levels of lead.
EPA Is Beginning to Address Certain Information Gaps in the Health
Risks of Lead in Drinking Water:
EPA has acknowledged the need to improve health risk information
available to drinking water systems and local governments about lead in
drinking water. According to officials from EPA's Office of Water, one
way to improve this information would be to develop a health advisory
for lead. EPA health advisories are written documents that provide
information on the health effects, analytical methodology, and
treatment technology that would be useful in dealing with the
contamination of drinking water and have been issued for many other
water contaminants, such as cryptosporidium (a water-borne microbe).
The advisories serve as informal technical guidance to assist federal,
state, and local officials responsible for protecting public health
when contamination occurs. For example, a cryptosporidium health
advisory was prompted, in part, by an outbreak of the microbe in 1993
in Milwaukee, Wisconsin, where an estimated 400,000 people became ill.
Office of Water officials note that the agency currently does not have
a health advisory for lead and believe the problems local District
agencies had in communicating the health risks of lead in drinking
water highlight the need for one. Office of Water officials also noted
a health advisory document for lead would be useful for other water
systems and state and local officials in communicating risk if they
identify problems with lead during monitoring under the Lead and Copper
Rule. In 1985, EPA drafted a health advisory for lead, but never issued
it to the public. At present, EPA's Office of Water has drafted a plan
to prepare a lead health advisory and have it reviewed by experts
within EPA and by external peer reviewers. However the anticipated
completion date for the advisory has not been determined.
To ensure that the health advisory for lead is up-to-date, the Office
of Water also plans to produce a "white paper" that documents how
research data were used in setting the action level for lead and
updates that assessment using new data on lead exposure and uptake in
the body. Officials in these offices told us that the white paper
should provide sufficient information to allow health risk at the
action level to be discussed in the lead health advisory. They told us
that data used to develop the 15 ppb action level in the 1991 rule were
based on a small group of studies published before 1989 and on early
models of the agency's Integrated Exposure Uptake Biokinetic Model for
Lead (IEUBK), which predicts blood lead concentrations for children
exposed to different types of lead sources. The Office of Research and
Development is currently developing an "all ages lead model" that
supplements the IEUBK model, and should allow for new predictions of
fetal blood lead levels derived from maternal exposure levels.
According to EPA, the agency plans to have the model peer reviewed
first and any issues from the peer review addressed before the model is
used in regulatory decision making. These predictions may be
incorporated into the white paper being prepared by the Office of
Water. However, a timetable for completing the updated model and the
white paper has not been determined. Current draft plans for the health
advisory and white paper neither discuss how these projects fit into a
broader agency research agenda nor identify how they will be funded or
if they need to be coordinated with CDC or other research
organizations.
Conclusions:
In 2004, poor coordination among local District of Columbia agencies
and EPA aggravated the problems they had in responding to elevated lead
levels and communicating accurate and timely health risk information to
affected District residents. Since that time, local agencies and EPA
have improved their coordination. Nonetheless, these agencies still
face considerable challenges in ensuring the safety of the District's
water supplies. For one thing, while lead levels have come down in
recent months, they still remain well above the Lead and Copper Rule's
15 ppb action level. In addition, only time will tell if or how quickly
WASA's ambitious lead service line replacement program will further
lower lead levels in drinking water.
The District's experience has also exposed weaknesses in the Lead and
Copper Rule's public education requirements. EPA is collecting
information about compliance with the rule and is also considering
changes to the Lead and Copper Rule and its accompanying guidance
documents and training. We support these efforts and believe the clear
deficiencies of the rule's public education requirements--vividly
illustrated in the District of Columbia--call for action to assist
water systems in educating their customers about lead.
The District's experience has also underscored gaps in available
knowledge about health risks associated with lead-contaminated drinking
water. In acknowledging these gaps, EPA has pointed to projects planned
by its Office of Water and its Office of Research and Development as
key steps to address the problem. However, the timetable for completing
these projects is not clear, and it is also not clear how this work
will fit into a broader research agenda or if this agenda will involve
other key organizations such as CDC.
Recommendations for Executive Action:
To provide timely information to communities on how to improve
communication of lead health risks, we recommend, as part of its
comprehensive re-examination of the Lead and Copper Rule's public
education requirements, that the Administrator of EPA direct the Office
of Water to identify and publish best practices that water systems are
using to educate the public about lead in drinking water.
To improve the health risk information on lead available to water
systems and regulatory staff, we recommend that the Administrator of
EPA develop a strategy for closing information gaps in the health
effects of lead in drinking water that includes timelines, funding
requirements, and any needed coordination with CDC and other research
organizations.
Agency Comments and Our Evaluation:
We provided a draft of this report to EPA for comment. In its March 14,
2005, letter (see app. II), EPA expressed appreciation for the
information in the report, identified some of its recent and ongoing
efforts to address the problems we identified, and indicated it will
give full consideration to our recommendations. Of particular note, EPA
agreed with our recommendation that the agency identify and publish
best practices that water systems can use to educate their customers
about lead in drinking water. EPA said it will work with its regions
and water utility associations to identify best practices and
disseminate them to a wide audience, and will work with stakeholders to
change the mandatory language in its regulations to make sure it is
relevant and understandable.
The agency indicated neither agreement nor disagreement with our
recommendation to develop a strategy for closing information gaps on
the health risks of lead in drinking water. EPA noted instead it was
awaiting revision of the agency's exposure model for evaluating the
effects of lead exposure from different media on blood lead levels. It
also said it was "working to prepare a health advisory that would
inform the discussion" and was developing a summary of toxicokinetic
research published since 1991. EPA said these efforts should be
completed later this year or early next year. We note that while EPA's
planned efforts to address information gaps in knowledge of health
risks from lead in drinking water appear to be worthwhile activities,
we continue to believe the agency should commit to the kinds of
planning steps (such as budgeted resources and timetables) that will
help to ensure its planned efforts are addressed in a timely manner and
have their intended effect. We also continue to believe that EPA should
coordinate its efforts with CDC and other parties to ensure that the
most is achieved from all agencies' collective efforts. EPA also
provided technical comments and clarifications that have been
incorporated, as appropriate.
On February 23, 2005, we met with WASA officials to discuss the factual
information we were planning to include in our draft report. At that
time, WASA provided oral comments and technical suggestions. We
subsequently provided the draft report to WASA for formal comment.
WASA, however, did not comment on this draft.
As agreed with your office, unless you publicly release 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 of this report to
the appropriate congressional committees; interested Members of
Congress; the Acting Administrator, Environmental Protection Agency;
and other interested parties. We will also make copies available to
others on request. In addition, the report will be available at no
charge on the GAO Web site at [Hyperlink, http://www.gao.gov] .
Should you or your staff need further information, please contact me at
(202) 512-3841 or [Hyperlink, stephensonj@gao.gov]. Individuals making
key contributions to this report included Steve Elstein, Samantha
Gross, Karen Keegan, Tim Minelli, and Carol Herrnstadt Shulman.
Sincerely yours,
Signed by:
John B. Stephenson,
Director, Natural Resources and Environment:
[End of section]
Appendixes:
Appendix I: Scope and Methodology:
To identify actions that key government entities are taking to improve
coordination, we reviewed key documents, such as the consent decrees
between the District of Columbia Water and Sewer Authority (WASA) and
the Environmental Protection Agency (EPA) and testimony by the involved
agencies, that identified steps each agency agreed to take to improve
coordination, efficiency, and accountability. We then met with
officials of these entities and gathered documentation from them to
gauge the progress of planned changes. Additionally, we reviewed
reports written by various groups about lead in drinking water in the
District of Columbia, including reports by the District of Columbia
Inspector General, the D.C. Appleseed Center for Law and Justice, and
the law firm of Covington and Burling. Finally, to gain perspective on
the issue of coordination, we interviewed officials from other water
systems and their federal and state regulatory agencies and consulted
with industry groups in the drinking water delivery field.
To identify the extent to which WASA and others are gathering
information to determine which adult and child populations are at
greatest risk of exposure to lead, we reviewed WASA's efforts to locate
lead service lines. We also reviewed the plans that WASA has submitted
to EPA to replace lead service lines and materials describing WASA's
program to encourage homeowners to fully replace lead service lines. We
interviewed WASA and EPA staff about the progress of the lead service
line identification and replacement programs, interviewed officials at
other water systems to discuss lead service line replacement, and
reviewed studies on partial lead service line replacement.
To determine how other drinking water systems that have exceeded the
action level for lead conducted public education and outreach, we met
with parties knowledgeable about the Lead and Copper Rule, including
EPA headquarters and regional staff and relevant industry groups, in
part to find water systems with particularly innovative and effective
public education and outreach programs. From this group, we focused on
water systems in large cities with diverse populations that had
exceeded the action level for lead since 2000, according to EPA data.
We then interviewed officials from these water systems and reviewed
documents to learn about their public education efforts, how they
target their efforts, and how they measure success. We also spoke to
officials from government and nongovernment entities that partner with
these water systems in their education programs. To learn about public
education under the Lead and Copper Rule, we attended an EPA workshop
where water system managers, environmental and consumer groups, and
other experts shared their opinions on best practices in the industry
and EPA's current policies. We also reviewed reports and public
testimony pertaining to public education in the District of Columbia
and elsewhere.
To evaluate the state of research on lead exposure, we interviewed
public health officials and academic researchers that representatives
of government and nongovernmental organizations in the fields of
drinking water and public health identified as experts on lead. We
interviewed these experts to get their perspective on lead's health
effects, particularly the health effects of ingestion of low levels of
lead and lead in drinking water. We also discussed data gaps on the
health effects of lead, the research efforts planned and under way to
fill these gaps, and alternative strategies that might better ensure
that these gaps are addressed efficiently and effectively. These
experts also helped us identify the medical and public health
literature we reviewed on the health effects of lead exposure,
particularly through drinking water. To learn about efforts to locate
and monitor the blood lead levels of individuals exposed to elevated
levels of lead in drinking water in the District, we examined a
published study and interviewed officials at the District of Columbia
Department of Health and the Centers for Disease Control and
Prevention. Finally, we interviewed EPA officials and reviewed EPA
strategic plans and other documentation to learn about EPA's plans to
address key information gaps on the health effects of lead exposure.
[End of section]
Appendix II: Comments from the Environmental Protection Agency:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY:
OFFICE OF WATER:
WASHINGTON, D.C. 20460:
MAR 14 2005:
John B. Stephenson:
Director, Natural Resources and the Environment:
Government Accountability Office:
Washington, DC 20548:
Dear John:
Thank you for the opportunity to review the proposed Government
Accountability Office (GAO) Report; The District of Columbia's Drinking
Water: Agencies Have Improved Coordination, But Key Challenges Remain
in Protecting the Public From Elevated Lead Levels. We appreciate the
information in the report and will give full consideration to your
recommendations. We have provided technical comments on specific
elements of the report under separate cover. However, I would like to
take the opportunity to respond to the issues you evaluated and your
specific recommendations.
As you know, we have been working over the past year to better
understand implementation of the Lead and Copper Rule nationwide. On
March 7, 2005, we announced an initial series of efforts we are
undertaking to revise regulations and guidance in order to improve
implementation of the rule. We are continuing to collect and analyze
additional information to help us target areas where implementation
needs to be further improved. We want to ensure that this rule, which
has been critical in lowering exposure to lead in drinking water,
continues to be successful.
Your first charge was to examine haw agencies that implement the LCR in
the District are improving their coordination in an effort to reduce
lead levels. From EPA's perspective, we have seen significant
improvements in coordination between EPA, the DC Water and Sewer
Authority (WASA) and Washington Aqueduct over the past year,
particularly through the Technical Expert Working Group. This group,
which was initially developed to help identify a treatment solution for
D.C., has continued to meet in order to discuss the progress of
treatment and water monitoring results. We have also had more frequent
contact with the D.C. Department of Health regarding drinking water
matters in the District and found it beneficial to maintain a
relationship with the L.E.A.D. (Lead Emergency Action for the District)
Coalition members as one means to keep the community updated on actions
taken, research and sampling results and the status of the WASA's
compliance with our administrative order.
Your second charge was to determine the extent to which WASA and other
entities are identifying populations at the greatest risk of exposure
to lead in drinking water and reducing their exposure. As you noted in
your report, WASA has worked to prioritize lead service line
replacement for homes with children, pregnant women, or which have very
high lead levels. We heard about similar efforts undertaken by
utilities during our expert workshops on lead service line replacement
and public education that were held during 2004. We believe the effort
to prioritize is critical to ensuring that sensitive subpopulations are
addressed promptly and will look to share the experiences of utilities
that have already developed prioritization programs with utilities that
are initiating lead service line replacement to comply with the
regulations.
Your third charge was to evaluate how other drinking water systems that
exceed the EPA action level conduct public education. As part of our
work with WASA, staff from Region 3 and Headquarters likewise surveyed
other utilities to learn more about how they tailor public education
efforts. At our public education workshop last September, we heard
first hand about the specific efforts undertaken by Oregon's Portland
Bureau of Water Works and the Massachusetts Water Resources Authority,
which are highlighted in your report.
We agree with your recommendation that EPA identify and publish best
practices that water systems can use to educate their customers about
lead in drinking water. In addition to promoting use of our existing
Public Education guidance, of which many were unaware, we will work
with Regions and water utility associations to build on the information
collected in response to D.C. to identify best practices and
disseminate them to a wide audience. An additional area of interest for
us is revising the existing public education language in the
regulations. Participants at our public education workshop highlighted
their concerns with the complexity of the mandatory language. We would
like to work with stakeholders to pursue changes to the language to
make sure it is relevant and understandable.
Finally, you were charged with evaluating the state of research on lead
exposure as it relates to drinking water. You also recommended that we
work in coordination with CDC and other research organizations to
develop a strategy for closing information gaps on this issue. Although
the Agency has consistently stated that there is no safe level of lead
exposure, we have been challenged to communicate the specific risks of
lead associated with varying concentrations of lead in drinking water
and to put that risk in context with other sources of lead exposure.
As you know, we are awaiting revision of the Agency's exposure model
for evaluating effects of lead exposure from different media on blood
lead levels, which is key in helping us evaluate potential health
effects. We are presently working to prepare a health advisory that we
hope will inform the discussion and are also developing a paper that
will summarize toxicokinetic research published since the rule was
issued in 1991. We expect efforts on all of these items to be completed
by later this year or early next year.
I appreciate 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 yours,
Signed by:
Benjamin H. Grumbles:
Assistant Administrator:
[End of section]
(360510):
FOOTNOTES
[1] GAO, Drinking Water: Safeguarding the District of Columbia's
Supplies and Applying Lessons Learned to Other Systems, GAO-04-974T
(Washington, D.C.: July 22, 2004).
[2] 42 U.S.C. 300f-300j.
[3] 40 C.F.R. pt. 141, subpart I.
[4] For each monitoring period, a system must report the 90th
percentile lead level of homes monitored. For example, if a system
monitors 100 homes, it sorts its results from the lowest to the highest
concentrations and reports the concentration it observed in the 90th
sample.
[5] The water system must also offer to sample the tap water of any
customer who requests it, though the system is not required to pay for
sample collection or analysis.
[6] Under the rule, a water system can stop replacing lead service
lines if lead concentrations are below the action level for two
consecutive 6-month monitoring periods.
[7] On January 14, 2005, EPA Region III issued a supplemental consent
order stating that WASA used an improper methodology to collect many of
these samples. The order requires WASA to physically replace by the end
of fiscal year 2007 any lines that were deemed "replaced" because they
showed a lead level below 15 ppb in these improper tests.
[8] District of Columbia, Office of the Inspector General, Audit of
Elevated Levels of Lead in the District's Drinking Water, OIG No. 04-2-
17LA (Jan. 5, 2005).
[9] EPA officials believe that the removal of free chlorine, rather
than the addition of chloramines, resulted in the increase in
corrosion.
[10] WASA's baseline inventory is the number of lead service lines
present on June 30, 2001. This baseline number changes over time as
WASA identifies the composition of additional lines.
[11] Elevated blood lead in children younger than 6 is defined as 10
micrograms per deciliter or greater, according to CDC guidelines.
[12] A District of Columbia law prohibits WASA from providing repairs
or maintenance on private property without charge to the owners.
However, according to an EPA official, WASA may use EPA funding to
replace the privately owned portion of a lead service line. D.C. Code
Ann. section 8-205(b).
[13] The June 2004 consent order that WASA signed with EPA describes
some violations of the public notification requirements of the Lead and
Copper Rule, including using language slightly different from that
required by the rule and issuing fewer public service announcements
than required.
[14] Public notification for violations with the potential to have
serious adverse effects on human health as a result of short-term
exposure is required within 24 hours.
[15] The Agency for Toxic Substances and Disease Registry defines acute
exposure as 14 days or fewer, intermediate exposure from 15 to 365
days, and chronic exposure as 365 days or more.
[16] The National Health and Nutrition Examination Surveys represent a
series of cross-sectional surveys, which used stratified, multistage,
cluster samples of households with a target population of civilian,
noninstitutionalized residents of the United States. The analysis of
the surveys was weighted using population estimates obtained from the
U.S. Bureau of the Census.
[17] Given the low prevalence of elevated blood lead levels and a
limited sample size, the CDC estimates that elevated lead levels falls
within the range of 1.0 to 4.3 percent, with a 95 percent confidence
interval, for the surveys in 1999 to 2000.
[18] L. Stokes et al., "Blood Lead Levels in Residents of Homes with
Elevated Lead in Tap Water-District of Columbia, 2004," Morbidity and
Mortality Weekly Report, vol. 53 (Mar. 30, 2004).
[19] Nonprobability samples are not randomly selected from the
population being studied. This means that every member of the
population does not have an equal chance of being selected for the
study. Because this study uses a nonprobability sample, the results of
the study cannot be generalized to the population of District of
Columbia residents.
[20] R.F. Lacey et al., "Lead in Water, Infant Diet and Blood: The
Glasgow Duplicate Diet Study," The Science of the Total Environment,
vol. 41 (Mar. 1, 1985).
[21] U.S. Environmental Protection Agency, Lead and Copper Rule, The
Federal Register, vol. 56, no. 110 (June 1991), 7.
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