Drinking Water: Safeguarding the District of Columbia's Supplies 
and Applying Lessons Learned to Other Systems (22-JUL-04,	 
GAO-04-974T).							 
                                                                 
Concerns have been raised about lead in District of Columbia	 
drinking water and how those charged with ensuring the safety of 
this water have carried out their responsibilities. The 1991 Lead
and Copper Rule (LCR) requires water systems to protect drinking 
water from lead by, among other things, chemically treating it to
reduce its corrosiveness and by monitoring tap water samples for 
evidence of lead corrosion. If enough samples show corrosion,	 
water systems officials are required to notify and educate the	 
public on lead health risks and undertake additional efforts. The
Washington Aqueduct, owned and operated by the U.S. Army Corps of
Engineers, treats and sells water to the District of Columbia	 
Water and Sewer Authority (WASA), which delivers water to D.C.	 
residents. EPA's Philadelphia Office is charged with overseeing  
these agencies. GAO is examining (1) the current structure and	 
level of coordination among key government entities that	 
implement the Safe Drinking Water Act's regulations for lead in  
the District of Columbia, (2) how other drinking water systems	 
conducted public notification and outreach, (3) the availability 
of data necessary to determine which adult and child populations 
are at greatest risk of exposure to elevated lead levels, and	 
what information WASA is gathering to help track their health,	 
and (4) the state of research on the health effects of lead	 
exposure. The testimony discusses preliminary results of GAO's	 
work. GAO will report in full at a later date.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-974T					        
    ACCNO:   A11097						        
  TITLE:     Drinking Water: Safeguarding the District of Columbia's  
Supplies and Applying Lessons Learned to Other Systems		 
     DATE:   07/22/2004 
  SUBJECT:   Environmental monitoring				 
	     Hazardous substances				 
	     Health hazards					 
	     Municipal governments				 
	     Potable water					 
	     Reporting requirements				 
	     Strategic planning 				 
	     Water pollution					 
	     Water pollution control				 
	     Water treatment					 

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GAO-04-974T

United States Government Accountability Office

GAO Testimony

Before the Subcommittee on Environment and Hazardous Materials, Committee
on Energy and Commerce, House of Representatives

For Release on Delivery

Expected at 9:30 a.m. DST DRINKING WATER

Thursday, July 22, 2004

Safeguarding the District of Columbia's Supplies and Applying Lessons Learned to
                                 Other Systems

Statement of John B. Stephenson, Director Natural Resources and Environment

GAO-04-974T

Highlights of GAO-04-974T, a statement to the Subcommittee on Environment
and Hazardous Materials, Committee on Energy and Commerce, House of
Representatives

Concerns have been raised about lead in District of Columbia drinking
water and how those charged with ensuring the safety of this water have
carried out their responsibilities. The 1991 Lead and Copper Rule (LCR)
requires water systems to protect drinking water from lead by, among other
things, chemically treating it to reduce its corrosiveness and by
monitoring tap water samples for evidence of lead corrosion. If enough
samples show corrosion, water systems officials are required to notify and
educate the public on lead health risks and undertake additional efforts.
The Washington Aqueduct, owned and operated by the U.S. Army Corps of
Engineers, treats and sells water to the District of Columbia Water and
Sewer Authority (WASA), which delivers water to D.C. residents. EPA's
Philadelphia Office is charged with overseeing these agencies.

GAO is examining (1) the current structure and level of coordination among
key government entities that implement the Safe Drinking Water Act's
regulations for lead in the District of Columbia, (2) how other drinking
water systems conducted public notification and outreach, (3) the
availability of data necessary to determine which adult and child
populations are at greatest risk of exposure to elevated lead levels, and
what information WASA is gathering to help track their health, and (4) the
state of research on the health effects of lead exposure.

The testimony discusses preliminary results of GAO's work. GAO will report
in full at a later date.

July 2004

DRINKING WATER

Safeguarding the District of Columbia's Supplies and Applying Lessons Learned to
Other Systems

This statement discusses GAO's preliminary observations and highlights
areas of further examination.

One of the key relationships in the effort to ensure the safety of the
District's drinking water is the one between WASA, the deliverer of water,
and EPA's Philadelphia Office, which oversees WASA's compliance with
drinking water regulations. Recent public statements and corrective
actions by these parties clearly indicate that coordination and
communication between them could have been better in the years preceding
the current lead controversy. GAO's future work will examine (to the
extent appropriate) the interrelationships among other key agencies (such
as the Aqueduct and the D.C. Department of Health); how other water
systems in similar situations interacted with federal, state, and local
agencies; and what the experiences of these other jurisdictions may
suggest concerning how improved coordination can better protect drinking
water in the District of Columbia.

Other water systems facing elevated lead levels used public notification
and education practices that may offer lessons for conducting outreach to
water customers. For example, some of the practices of the two water
systems we have begun to examine - the Massachusetts Water Resources
Authority and the Portland (Oregon) Water Bureau - include tailoring their
communications to varied audiences in their service areas, testing the
effectiveness of their communication materials, and linking demographic
and infrastructure data to identify populations at greatest risk from lead
in drinking water.

WASA faces challenges in collecting the information needed to identify
District citizens at greatest risk from lead in drinking water.
Specifically, WASA has partial information on which of its customers have
lead service lines, and is in the process of obtaining more complete
information. GAO's future work will examine the efforts of other water
systems to go one step further by linking data on at-risk populations
(such as pregnant mothers, infants, and small children) with data on homes
suspected of being served by lead service pipes and other plumbing
fixtures that may leach lead into drinking water.

Nationally, much is known about the hazards of lead once in the body and
how lead from paint, soil, and dust enter the body, but little research
has been done to determine actual lead exposure from drinking water, and
the information that does exist is dated. In our future work, we will
examine the plans of EPA and other organizations to fill this key
information gap.

www.gao.gov/cgi-bin/getrpt?GAO-04-974T.

To view the full product, including the scope and methodology, click on
the link above. For more information, contact John Stephenson at (202)
512-3841 or [email protected].

Mr. Chairman and Members of the Subcommittee:

Thank you for the opportunity to discuss our work to date on the issues
surrounding elevated levels of lead in Washington, D.C. drinking water. At
the request of this Subcommittee, we are examining issues concerning lead
in drinking water generally and the situation in Washington, D.C., in
particular. Our testimony today lays out our preliminary observations on
these issues and highlights areas of further examination.

Although rarely the sole cause of lead poisoning, lead in drinking water
can significantly increase a person's total lead exposure. EPA estimates
that drinking water is the source of about 20 percent of Americans' lead
exposure, but that it may be as high as 60 percent for infants who drink
baby formulas and concentrated juices that are mixed with water. Adults
who drink water with high lead concentrations could develop kidney
problems or high blood pressure. Developing fetuses, infants and young
children are more vulnerable to lead from all sources, including drinking
water. Their exposure to lead may delay their physical or mental
development.

The delivery of safe water to residents requires that water systems and
regulators work cooperatively in fulfilling the requirements of the Safe
Drinking Water Act.1 In most cases, states have primary oversight and
enforcement authority under the Act. Lead in drinking water is regulated
under the Act's 1991 Lead and Copper Rule.2 The rule requires water
systems to treat their water to limit its corrosiveness, monitor tap water
samples for evidence of elevated levels of lead, and report this
information to their state. In addition, drinking water systems may
consult with state health agencies when communicating with their customers
about health risks from drinking water.

The relationship between regulators and water systems is more complicated
in the District of Columbia, where the Washington Aqueduct,

142 U.S.C. 300f-300j.

240 C.F.R. pt. 141, subpart I. The Lead and Copper Rule established an
action level of 15 parts per billion (ppb) for lead in drinking water.
Under the rule, the action level is exceeded if lead levels are higher
than 15 ppb in over 10 percent of tap water samples taken. For each
monitoring period, a system must report the lead level at the 90th
percentile of homes monitored. For example, if a system monitors 100
homes, it sorts its results from the lowest to the highest concentrations
and reports the concentration it observed in the 90th sample.

owned by the U.S. Army Corps of Engineers, draws and treats water
from�the Potomac River. The Aqueduct sells the treated water to the
District of�Columbia Water and Sewer Authority (WASA), which
distributes it to�District residents. The Environmental Protection
Agency's (EPA) �Region III Office in Philadelphia, Pennsylvania,
has primary oversight and �enforcement authority for the District's
public water systems. The District�of Columbia's Department of
Health, while having no formal role under �the Safe Drinking Water
Act, is responsible for educating District residents�on potential
health risks.�

In the District, the Washington Aqueduct treats drinking water and
�monitors for most contaminants, while WASA monitors tap water
samples �for lead and reports these results to EPA's Philadelphia
Office. Tap water �monitoring is important because, unlike most
drinking water �contaminants, lead is not generally introduced to
drinking water supplies �from source water. Rather, lead leaches
into drinking water as it travels �through lead service pipes, over
pipe joints connected with lead-based �solder, and through brass
plumbing fixtures that contain lead. According �to EPA, its
Philadelphia Office is responsible for providing technical
�assistance to the Aqueduct and WASA on how to comply with
federal�regulations; ensuring that they report the monitoring
results to EPA by�required deadlines; taking enforcement actions if
violations occur; and �using those enforcement actions to return
the water systems to�compliance in a timely fashion. �

Significant concerns were raised in early 2004 about how federal and local
�agencies were carrying out their responsibilities under the Safe
Drinking �Water Act. At that time, the local media reported that a
number of tap �water samples showed elevated levels of lead.
�

You asked that we (1) examine the current structure and level of
�coordination among key government entities that implement the Safe
�Drinking Water Act's regulations for lead in the District of
Columbia, and �identify any improvements to increase efficiency and
accountability, (2) �determine how other drinking water systems
that exceeded the EPA �action level for lead have conducted public
notification and outreach, (3) �assess the availability of data
necessary to determine which adult and �child populations are at
greatest risk of exposure to elevated lead levels, �and what
information WASA is gathering to help track their health, (4)
�evaluate the state of research on lead exposure, and how this
information �could help inform other drinking water utilities of
potential problems in�their systems. �

To respond to these questions, we are interviewing key officials and staff
with the federal and local agencies responsible for managing drinking
water and monitoring health for lead exposure in Washington, D.C.,
including officials at EPA's headquarters and in its Philadelphia Office,
WASA, the Washington Aqueduct, and the D.C. Department of Health. We are
also (1) reviewing records documenting key activities and interactions
among these agencies, and examining their current responses to the lead
problem, (2) contacting academic and non-governmental experts in lead
contamination, and (3) examining how other water systems facing similar
circumstances notified and educated their customers on lead health risks,
and how they interacted with federal, state, and local agencies to respond
to the problem. Many of the facts and circumstances surrounding the
District's lead controversy are the subject of active litigation.
Accordingly, we do not take a position on these issues and on how they
bear on the question of interagency coordination and communication, and
instead report them only as stated by the affected parties.

We are here to present our preliminary observations on these issues. We
will report our final findings and any recommendations we may develop at a
later date. In summary:

o  Providing safe drinking water requires that water systems, regulators,
and public health agencies fulfill individual roles, yet work together in
a coordinated fashion. It is particularly important that these entities
report and communicate information to each other in a timely and accurate
manner. Recent public statements and corrective actions by the responsible
entities, particularly EPA and WASA, clearly indicate that coordination
could have been better in the years preceding the current controversy. As
our work continues, we will seek to examine (to the extent appropriate)
specific ways in which improved coordination between EPA and WASA could
help both agencies better fulfill their responsibilities. We will also
examine interrelationships among other key agencies (such as the Aqueduct
and the D.C. Department of Health); how other water systems in similar
situations interacted with federal, state, and local agencies; and what
the experiences of these other jurisdictions may suggest concerning how
improved coordination can better protect drinking water in the District of
Columbia.

o  Other water systems facing elevated lead levels used public
notification and education practices that appear to offer lessons for
conducting outreach to water customers, including those in the District of
Columbia. For example, some of the practices of the two systems we have
begun to examine-the Massachusetts Water Resources Authority and the
Portland

Water Bureau-include tailoring their communications to varied audiences in
their service areas, testing the effectiveness of their communication
materials, and linking demographic and infrastructure data to identify
populations at greatest risk from lead in drinking water.

o  WASA faces challenges in collecting the information needed to identify
District citizens at greatest risk from lead in drinking water.
Specifically, it has partial information on which of its customers have
lead service pipes, although it is currently in the process of obtaining
more complete information. In our future work, we will examine the efforts
of other water systems to go one step further by linking data on at-risk
populations (such as pregnant mothers, infants, and small children) with
data on homes suspected of being served by lead service pipes and other
plumbing fixtures that may leach lead into drinking water.

o  Much is known about the hazards of lead in the human body and about how
lead from paint, soil, and dust enter the body. However, little research
has been done to determine actual lead exposure from drinking water, and
the information that does exist is dated. In our future work, we will
examine the plans of EPA and other organizations to fill this key
information gap.

Background Lead is unusual among drinking water contaminants in that it
seldom occurs naturally in source water supplies like rivers and lakes.
Rather, lead enters drinking water primarily as a result of the corrosion
of materials containing lead in the water distribution system and in
household plumbing. These materials include lead service pipes that
connect a house to the water main, household lead-based solder used to
join copper pipe, and brass plumbing fixtures such as faucets.

The Safe Drinking Water Act is the key federal law protecting public water
supplies from harmful contaminants. The Act established a federal-state
arrangement in which states may be delegated primary implementation and
enforcement authority ("primacy") for the drinking water program. Except
for Wyoming and the District of Columbia, all states and territories have
received primacy. For contaminants that are known or anticipated to occur
in public water systems and that the EPA Administrator determines may have
an adverse impact on health, the Act requires EPA to set a 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 sets an enforceable standard for water
as it leaves the treatment plant, the maximum

contaminant level (MCL). The MCL generally must be set as close to the
MCLG as is "feasible" using the best technology or other means available,
taking costs into consideration.

The fact that lead contamination occurs after water leaves the treatment
plant has complicated efforts to regulate it in the same way as most
contaminants. In 1975, EPA set an interim MCL for lead at 50 parts per
billion (ppb), but did not require sampling of tap water to show
compliance with the standard. Rather, the standard had to be met at the
water system before the water was distributed. The 1986 amendments to the
Act directed EPA to issue a new lead regulation, and in 1991, EPA adopted
the Lead and Copper Rule.

Instead of an MCL, the rule established an "action level" of 15 ppb for
lead in drinking water, and required that water systems take steps to
limit the corrosiveness of their water. Under the rule, the action level
is exceeded if lead levels are higher than 15 ppb in over 10 percent of
tap water samples taken. Large systems, including WASA, generally must
take at least 100 tap water samples in a 6-month monitoring period. Large
systems that do not exceed the action level or that maintain optimal
corrosion control for two consecutive 6-month periods may reduce the
number of sampling sites to 50 sites and reduce collection frequency to
once per year. If a water system exceeds the action level, other
regulatory requirements are triggered. The water system must intensify tap
water sampling, take additional actions to control corrosion, and educate
the public about steps they should take to protect themselves from lead
exposure. If the problem is not abated, the water system must annually
replace 7 percent of the lead service lines under its ownership.

The public notification requirements of the Safe Drinking Water Act are
intended to protect public health, build trust with consumers through open
and honest sharing of information, and establish an ongoing, positive
relationship with the community.3 While public notification provisions
were included in the original Act, concerns have been raised for many
years about the way public water systems notify the public regarding
health threats posed by contaminated drinking water. In 1992, for example,
we reported, among other things, that (1) there were high rates of
noncompliance among water systems with the public notification regulations
in effect at that time and (2) notices often did not clearly

3Public Notification Handbook, EPA Office of Water (EPA 816-R-00-010, June
2000).

convey the appropriate information to the public concerning the health
risks associated with a violation and the preventive action to be taken.4
The 1996 Amendments to the Safe Drinking Water Act attempted to address
many of these concerns by requiring that consumers of public water
supplies be given more accurate and timely information about violations
and that this information be in a form that is more understandable and
useful.

Drinking water is provided to District of Columbia residents under a
unique organizational structure:

o  The U.S. Army Corps of Engineers' Washington Aqueduct draws water from
the Potomac River and filters and chemically treats it to meet EPA
specifications. The Aqueduct produces drinking water for approximately 1
million citizens living, working, or visiting in the District of Columbia,
Arlington County, Virginia, and the City of Falls Church, Virginia.
Managed by the Corps of Engineers' Baltimore District, the Aqueduct is a
federally owned and operated public water supply agency that produces an
average of 180 million gallons of water per day at two treatment plants
located in the District. All funding for operations, maintenance, and
capital improvements comes from revenue generated by selling drinking
water to the District of Columbia, Arlington County, Virginia, and the
City of Falls Church, Virginia.

o  The District of Columbia Water and Sewer Authority buys its drinking
water from the Aqueduct. WASA distributes drinking water through 1,300
miles of water mains under the streets of the District to individual homes
and buildings, as well as to several federal facilities directly across
the Potomac River in Virginia. From its inception in 1938 until 1996,
WASA's predecessor, the District of Columbia Water and Sewer Utility
Administration, was a part of the District's government. In 1996, WASA was
established by District of Columbia law as a semiautonomous regional
entity. WASA develops its own budget, which is incorporated into the
District's budget and then forwarded to Congress. All funding for
operations, improvements, and debt financing come from usage fees, EPA
grants, and the sale of revenue bonds.

o  EPA's Philadelphia Regional Office has primary oversight and
enforcement responsibility for public water systems in the District.

4U.S. General Accounting Office, Drinking Water: Consumers Often Not
Well-Informed of Potentially Serious Violations, GAO/RCED-92-135
(Washington, D.C. June 1992).

According to EPA, the Regional Office's oversight and enforcement
responsibilities include providing technical assistance to the water
suppliers on how to comply with federal regulations; ensuring that the
suppliers report the monitoring results to EPA by the required deadlines;
taking enforcement actions if violations occur; and using those
enforcement actions to return the system to compliance in a timely
fashion.

o  The District's Department of Health, while having no formal role under

  Coordination Among Agencies Is Critical To Ensure Safe Drinking Water

the Act, is responsible for identifying health risks and educating the
public on those risks.

Providing safe drinking water requires that water systems, regulators, and
public health agencies fulfill individual responsibilities yet work
together in a coordinated fashion. It is particularly important that these
entities report and communicate information to each other in a timely and
accurate manner. In the case of drinking water in the District of
Columbia, one of the key relationships is the one between WASA, the
deliverer of water to District customers, and EPA's Philadelphia Office,
the regulator charged with overseeing WASA's compliance with drinking
water regulations. Of particular note, one of WASA's key obligations is to
monitor the water it supplies to District customers through a tap water
sampling program, and to report these results accurately and in a timely
manner to EPA's Philadelphia Office. As EPA itself has noted, one of the
Philadelphia Office's key obligations is to ensure that WASA understands
the reporting requirements and reports monitoring results by required
deadlines.

It is noteworthy that WASA and EPA have taken or agreed to take steps that
are clearly intended to improve communication and coordination between the
agencies. For example:

o  Under the Consent Order signed by EPA and WASA on June 17, 2004, WASA
agreed to improve its format for reporting tap water samples by ensuring
that the reports include tap water sample identification numbers, sample
date and location, lead and copper concentration, service line materials,
and reasons for any deviation from previously sampled locations. The
monitoring reports are also to include the laboratory data sheets, which
contain the raw test data recorded directly by the laboratory. Under the
Order, WASA also agreed to submit to EPA for comment a plan and schedule
for enhanced information, database management, and reporting. The plan is
to describe how monitoring

reports will be generated, maintained, and submitted to EPA in a timely
fashion.

o  EPA's Philadelphia Office has altered the way in which it will handle
compliance data from WASA and the Washington Aqueduct. According to the
office, compliance data from both water systems will now be sent to those
in the Office responsible for enforcing the Safe Drinking Water Act, so as
to separate the enforcement/compliance assurance function from the
municipal assistance function.

Aside from the tap water monitoring issue, EPA's Philadelphia Office
acknowledges that its oversight of WASA public notification and education
efforts could have been better, noting that "In hindsight, EPA should have
asked more questions about the extent, coverage and impact of DC WASA's
public education program, and reacted to fill the public education gaps
where they were evident."5 To address the problem, the Philadelphia Office
reported on its website that it will have to make some improvements in the
way it exercises its own oversight responsibilities.6 Suggested
improvements include obtaining written agreement from WASA to receive
drafts of education materials and a timeline for their submission,
reviewing drafts of public education materials for compliance with
requirements, as well as effectiveness of materials and delivery, and
acquiring outside expertise to assist in evaluating outreach efforts.

As our work continues, we will seek to examine (to the extent it does not
conflict with active litigation) other ways in which improved coordination
between WASA and EPA could help both agencies better fulfill their
responsibilities. We will also examine interrelationships that include
other key agencies, such as the Aqueduct and the D.C. Department of
Health. We will also examine how other water systems in similar situations
interacted with federal, state, and local agencies. These experiences may
offer suggestions on how coordination can be improved among the agencies
responsible for protecting drinking water in the District of Columbia.

5Letter from William C. Early, Regional Counsel, EPA Region III, to Eric
H. Holder, Jr., Covington & Burling (June 25, 2004) attaching EPA's
Response to May 13, 2004, letter from Covington & Burling, Response #26.

6http://www.epa.gov/dclead/pep_recommendations.htm.

  Experiences of Other Water Systems Highlight Effective Ways to Inform and
  Educate the Public

WASA is not the first system to exceed the action level for lead.
According to EPA, when the first round of monitoring results was completed
for large water systems in 1991 pursuant to the Lead and Copper Rule, 130
of the 660 systems serving populations over 50,000 exceeded the action
level for lead. EPA data show that since the monitoring period ending in
2000, 27 such systems have exceeded the action level.7 As part of our
work, we will be examining the innovative approaches some of these systems
have used to notify and educate their customers. I would like to touch on
the activities of two such systems, the Massachusetts Water Resources
Authority and the Portland, Oregon, Water Bureau. Each of these systems
has employed effective notification practices in recent years that may
provide insights into how WASA, and other water systems, could improve
their own practices.

            Massachusetts Water �Resources Authority �

The Massachusetts Water Resources Authority (MWRA) is the wholesale water
provider for approximately 2.3 million customers, mostly in the
metropolitan Boston area. Under an agreement with the Massachusetts
Department of Environmental Protection, monitoring for lead under the Lead
and Copper Rule occurs in each of the communities that MWRA serves and the
results are submitted together. Initial system-wide tap water monitoring
results in 1992 showed a 90th percentile lead concentration of 71 ppb
(meaning 10 percent of its samples scored at this level and above).
According to MWRA, adjustments in corrosion control have led to a
reduction in lead levels, but the 90th percentile lead concentration in
MWRA's service area has still been above the action level in four of the
seven sampling events since early 2000.

According to an MWRA official, the public education program for lead in
drinking water is designed to ensure that all potentially affected parties
within MWRA's service area receive information about lead in drinking
water. He noted, for example, that while the Lead and Copper Rule requires
that information be sent to consumers in their water bills, the large
population of renters living in MWRA's service area often do not receive
water bills. Therefore, MWRA included information about lead in its
consumer confidence report, which is sent to all mailing addresses within
the service area. Additionally, MWRA uses public service

7EPA Office of Ground Water and Drinking Water, Summary: Lead action level
exceedences for medium (3,300-50,000) and large (>50,000) public water
systems

(Updated as of June 1, 2004).

announcements, interviews on radio and television talk shows, appearances
at city councils and other local government agency meetings, and articles
in local newspapers to convey information. MWRA also conducted focus
groups to judge the effectiveness of the public education program and
continually makes changes to refine the information about lead in drinking
water.

An MWRA official also noted that MWRA focuses portions of its lead public
education program on the populations most vulnerable to the health effects
of lead exposure. For example, MWRA worked with officials from the
Massachusetts Women, Infants and Children Supplemental Nutrition Program
(WIC) to design a brochure to help parents understand how to protect their
children from lead in drinking water. Among other things, the brochure
includes the pertinent information in several foreign languages, including
Spanish, Portuguese, and Vietnamese. The WIC program also includes
information on how to avoid lead hazards when preparing formula.

                         Portland Water Bureau�

The Portland Water Bureau provides drinking water to approximately 787,000
people in the Portland metropolitan area, nearly one-fourth of the
population of Oregon. Since 1997, the city has exceeded the lead action
level 6 times in 14 rounds of monitoring. According to Bureau officials,
the problem stems mainly from lead solder used to join copper plumbing and
from lead in home faucets. Portland's system has never had lead service
lines, and the Water Bureau finished removing all lead fittings within the
water system's control in 1998.

The Portland Water Bureau sought flexibility in complying with the Lead
and Copper Rule. The state of Oregon allowed the Water Bureau to implement
a lead hazard reduction program as a substitute for the optimal corrosion
control treatment requirement of the Lead and Copper Rule. Portland's lead
hazard reduction program is a partnership between the Portland Water
Bureau, the Multnomah County and Oregon State health departments, and
community groups. According to Portland Water Bureau officials, the
program consists of four components: (1) water treatment for corrosion
control; (2) free water testing to identify customers who may be at
significant risk from elevated lead levels in drinking water; (3) a home
lead hazard reduction program to prevent children from being exposed to
lead from lead-based paint, dust, and other sources; and (4) education on
how to prevent lead exposure targeted to those at greatest risk from
exposure.

As the components suggest, the program is focused on reducing exposure to
lead through all exposure pathways, not just through drinking water. For
example, the Water Bureau provides funding to the Multnomah County Health
Department's LeadLine-a phone hotline that residents can call to get
information about all types of lead hazards. Callers can get information
about how to flush their plumbing to reduce their lead exposure and can
request a lead sampling kit to determine the lead concentration in the
drinking water in their home. The Water Bureau also provides funding for
lead education materials provided to new parents in hospitals, for
billboards and movie advertisements targeted to neighborhoods with older
housing stock, and to the Community Alliance of Tenants to educate renters
on potential lead hazards. Each of these materials directs people to call
the LeadLine if they need additional information about any lead hazard.
The Water Bureau evaluates the results of the program by tracking the
number of calls to the LeadLine, and by surveying program participants to
determine their satisfaction with the program and the extent to which the
program changed their behavior.

In January 2004, the Portland Water Bureau sent a targeted mailing to
those residents most likely to be affected by lead in drinking water. The
mailing targeted homes of an age most likely to contain lead-leaching
solder where a child 6 years old or younger lived. Approximately 2,600
postcards were sent that encouraged residents to get their water tested
for lead, learn about childhood blood lead screening, and reduce lead
hazards in their homes. Water Bureau officials said that they obtained the
information needed to target the mailing from a commercial marketing
company, and that the commercial information was inexpensive and easy to
obtain.

In an ideal world, a water utility such as WASA would have several
different types of information that would allow it to monitor the health
of individuals most susceptible to the health effects of lead in drinking
water. The utility would know the location of all lead service lines and
homes with leaded plumbing (pipes, solder and/or fixtures) within its
service area. The utility would also know the demographics of the
residents of each of these homes. With this information, the utility could
identify each pregnant woman or child six years old or younger who would
be most likely to be exposed to lead through drinking water. These
individuals could then be educated about how to avoid lead exposure, and
lead exposure for each of these individuals could then be monitored
through water testing and blood lead testing.

  WASA Faces Challenges in Identifying At-Risk Populations

Unfortunately, WASA and other drinking water utilities do not operate in
an ideal world. WASA does have some information on the location of lead
service lines within its distribution area. Its predecessor developed an
inventory of lead service lines in its distribution system in 1990 as part
of an effort to identify sampling locations to comply with the Lead and
Copper Rule. According to WASA officials, identifying the locations of
lead service lines was difficult because many of the records were nearly
100 years old and some of the information was incomplete. According to
this 1990 inventory, there were approximately 22,000 lead service lines.
WASA updated the inventory in September 2003, and estimated that it had
23,071 "known or suspected" lead service lines. WASA subsequently
identified an additional 27,495 service lines in the distribution system
made of "unknown" materials. Consequently, there is some uncertainty over
the actual number and location of the lead service lines in WASA's
distribution system. The administrative order that EPA issued in June 2004
requires WASA to further update its inventory of lead service lines.

Regardless of the information WASA has about the location of lead service
lines, according to WASA officials, WASA has little information about the
location of customers who are particularly vulnerable to the effects of
lead. The District's Department of Health is responsible for monitoring
blood lead levels for children in the District. Officials from the
Department of Health told us that they maintain a database of the results
of all childhood blood lead testing in the District, and have studied the
distribution of blood lead levels in children on a neighborhood basis.
However, according to a joint study by the D.C. Department of Health and
the Centers for Disease Control and Prevention (CDC) published in March
2004, it is difficult to discern any effect of lead in drinking water on
children's blood lead levels because the older homes most likely to have
lead service lines are also those most likely to have other lead hazards,
such as lead in paint and dust. This joint study also described efforts by
the Department of Health and the United States Public Health Service to
conduct blood lead monitoring for residents of homes whose drinking water
test indicated a lead concentration greater than 300 ppb. None of the 201
residents tested were found to have blood lead levels exceeding the levels
of concern for adults or children, as appropriate.

  Researchers Face Gaps in Knowledge Regarding the Risks Posed by Lead in
  Drinking Water

A good deal of research has been conducted on the health effects of lead,
in particular on the effects associated with certain pathways of
contamination, such as ingestion of leaded paint and inhalation of leaded
dust. In contrast, the most relevant studies on the isolated health
effects of lead in drinking water date back nearly 20 years-including the
Glasgow Duplicate Diet Study on lead levels in children upon which the
Lead and Copper Rule is partially based.8 According to recent medical
literature and the public health experts we contacted, the key
uncertainties requiring clarification include the incremental effects of
lead-contaminated drinking water on people whose blood lead levels are
already elevated from other sources of lead contamination and the
potential health effects of exposure to low levels of lead. As we continue
our work, we will examine the plans of EPA and other organizations to fill
these and other key information gaps.

Lead is a naturally occurring element that, according to numerous studies,
can be harmful to humans when ingested or inhaled, particularly to
pregnant and nursing women and children aged six or younger. In children,
for example, lead poisoning has been documented as causing brain damage,
mental retardation, behavioral problems, anemia, liver and kidney damage,
hearing loss, hyperactivity, and other physical and mental problems.
Exposure to lead may also be associated with diminished school
performance, reduced scores on standardized IQ tests, schizophrenia, and
delayed puberty.

Long-term exposure may also have serious effects on adults. Lead ingestion
accumulates in bones, where it may remain for decades. However, stored
lead can be mobilized during pregnancy and passed to the fetus. Other
health effects in adults that may be associated with lead exposure include
irritability, poor muscle coordination and nerve damage, increased blood
pressure, impaired hearing and vision, and reproductive problems.

There are many sources of lead exposure besides drinking water, including
the ingestion of soil, paint chips and dust; inhalation of lead particles
in soil or dust in air; and ingestion of foods that contain lead from soil
or water. Extensive literature is available on the health impacts of lead
exposure, particularly from contaminated air and dust. CDC identified in a

8Lacey R.F., et al. Lead in Water, Infant Diet and Blood: The Glasgow
Duplicate Diet Study. The Science of the Total Environment, 41 (1985)
235-257.

December 2002 Morbidity and Mortality Weekly Report the sources of lead
exposure for adults and their potential health effects.9 In a September
2003 Morbidity and Mortality Weekly Report, CDC identified the most
prevalent sources of lead in the environment for children, and correlated
high blood lead levels in children with race, sex, and income bracket.10
The surveys suggest that Hispanic and African-American children are at
highest risk for lead poisoning, as well as those individuals who are
recipients of Medicaid. Dust and soil contaminated by leaded paint were
documented as the major sources of lead exposure. Children and adults
living in housing built before 1950 are more likely to be exposed to lead
paint and dust and may therefore have higher blood lead levels.

Articles in numerous journals have reported on the physical and
neurological health effects on children of lead in paint, soil, and dust.
The New England Journal of Medicine published an article in April 2003
that associated environmental lead exposure with decreased growth and
delayed puberty in girls.11 In 2000, the Journal of Public Health Medicine
examined the implications of lead-contaminated soil, its effect on
produce, and its potential health effects on consumers.12 Lead can also
enter children's homes if other residents are employed in lead
contaminated workplaces. In 2000, Occupational Medicine found that
children of individuals exposed to lead in the workplace were at higher
risk for elevated blood lead levels.13 The EPA has aided in some similar
research through the use of its Integrated Exposure Uptake Biokinetic
Model for

9Centers for Disease Control and Prevention. Morbidity and Mortality
Weekly Report: Adult Blood Lead Epidemiology and Surveillance - United
States 1998-2001. 13 December 2002.

10Centers for Disease Control and Prevention. Morbidity and Mortality
Weekly Report: Surveillance for Elevated Blood Lead Levels Among Children
- United States 1997-2001. 12 September 2003.

11Sherry G. Selevan, Deborah C. Rice, Karen A. Hogan, Susan Y. Euling, et
al. "Blood lead concentration and delayed puberty in girls." The New
England Journal of Medicine. Boston: Apr 17, 2003. Vol. 348, Iss. 16; pp.
1527-1536.

12Prasad LR, Nazareth B. "Contamination of Allotment Soil with Lead:
Managing Potential Risks to Health." Journal of Public Health Medicine.
22(4) December 2000: 525-30.

13Chan, J, et al. "Predictors of Lead Absorption in Children of Lead
Workers." Occupational Medicine. Vol 50, Issue 6, 398-405, 2000.

Lead in Children (IEUBK). This model predicts blood lead concentrations
for children exposed to different types of lead sources.14

According to a number of public health experts, drinking water contributes
a relatively minor amount to overall lead exposure in comparison to other
sources. However, while lead in drinking water is rarely thought to be the
sole cause of lead poisoning, it can significantly increase a person's
total lead exposure-particularly for infants who drink baby formulas or
concentrated juices that are mixed with water from homes with lead service
lines or plumbing systems. For children with high levels of lead exposure
from paint, soil, and dust, drinking water is thought to contribute a much
lower proportion of total exposure. For residents of dwellings with lead
solder or lead service lines, however, drinking water could be the primary
source of exposure. As exposure declines from sources of lead other than
drinking water, such as gasoline and soldered food cans, drinking water
will account for a larger proportion of total intake. Thus, according to
EPA, the total drinking water contribution to overall lead levels may
range from as little as 5 percent to more than 50 percent of a child's
total lead exposure.15

Mr. Chairman, this completes my prepared statement. I would be happy to
respond to any questions you or other Members of this Subcommittee may
have at this time.

For further information, please contact John B. Stephenson at (202)
5123841. Individuals making key contributions to this testimony included
Steve Elstein, Samantha Gross, Karen Keegan, Jessica Marfurt, and Tim
Minelli.

                              Contact and�

                            Acknowledgments �

14U.S. Environmental Protection Agency. The IEUBK Model
http:www.opa.gov/superfund/programs/lead/ieubk.htm 16 April 2004.

15U.S. Environmental Protection Agency. Lead and Copper Rule. The Federal
Register. Vol. 56 NO. 110, 7 June 1991.

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