Tuesday, March 31, 2009

Is WASA's Definition of "Accurate and Useful Information" Different from the Public's?

On February 10, 2009, DC Council Members Mary Cheh and Jim Graham held a joint public hearing to address new revelations about the harm that was done from the District's lead-at-the-tap contamination of 2001-2004, and the quality of our drinking water today. In his testimony, WASA General Manager Jerry Johnson mentioned the intense scrutiny to which WASA has been subjected since 2004, and assured the DC Council that all past investigations into his agency's handling of the lead-in-water problem have helped WASA "continue" its efforts to provide "accurate and useful information" to the public.

One of the eight investigations Mr. Johnson mentioned was a 2005 audit by the DC Office of the Inspector General (OIG) that was carried out in response to a 2004 request by then DC Council Member Carol Schwartz for an "independent corroboration" of WASA's lead-in-water data. Written on February 27, 2004 -- only weeks after DC residents learned that for two and a half years the city's drinking water dispensed hazardous levels of lead -- Ms. Schwartz's letter to the DC OIG explained that such corroboration was necessary because the public had "lost faith" in the utility's credibility. In contrast to the other seven investigations -- which exposed gross breaches of responsibility and management deficiencies -- the DC OIG's 2005 audit seemed to redeem WASA. In the words of Mr. Johnson, it "affirmed [the] Authority's lead water sample findings."

Indeed, the DC OIG report stated that only 6% (as opposed to 21% in 2004) of 272 homes had lead-in-water concentrations above the Environmental Protection Agency (EPA) action level of 15 parts per billion. These findings were hailed by WASA as proof that its much questioned water sampling methodology was sound, and that its claim about declining lead-in-water levels due to the new chemical "orthophosphate" were correct. "Report Supports Integrity of DC WASA Testing Program," declared WASA's press release of June 20, 2005, days after the announcement of the DC OIG findings.

The water utility's press release quoted Mr. Johnson saying:
"We're extremely pleased with the Inspector General's findings, as it validates the hard work that this agency and its partners have done to address this issue. [...] Moreover, this report affirms our recent announcements of declining lead levels, as well as the integrity of our test sampling process."
Turns out this wasn't the last we were going to hear about the DC OIG audit. WASA brought it up again on February 20, 2009, this time at a DC Department of the Environment (DDOE) meeting about the District's latest effort to evaluate independently our drinking water for lead. At this meeting, a WASA board member asserted that WASA's lead-in-water monitoring practices -- which continue to be questioned by independent experts as well as public health and environmental organizations -- were validated by the DC OIG in 2005. This validation, the board member suggested, freed the DDOE of any need to focus its current investigation on the integrity of WASA's monitoring methods.

In our work on lead in the District's drinking water we have learned that you cannot trust WASA's statements without triple-checking the facts. Prompted by the assertions of WASA's board member, we decided to take a closer look at the DC OIG 2005 audit.

The DC OIG 2005 audit, which was supposed to detect the presence of lead in DC's drinking water by re-sampling "high risk" homes in WASA's own testing pool, used a water-sampling methodology that departs significantly from the standard EPA protocol and, by design, is not able to capture normally available lead at the tap. The methodology is rendered useless by the following inexplicable instructions:

1. No first-draw samples. A first-draw sample represents the water that is collected immediately after a minimum stagnation period of 6 hours. Compliance with federal regulations necessitates that 90% or above of first-draw samples at "high-risk" homes measure below 15 parts per billion of lead.

2. "Second-draw" samples after 4 minutes of flushing.
Second-draw samples are not required for compliance with federal regulations, but they can provide useful information about lead that is released from lead service lines outside many homes. For single-family residences EPA suggests collecting second-draw samples by "allowing the water to run until there is a significant change in temperature which would be indicative of water that has been standing in the lead service line." Water corrosion expert at Virginia Tech and 2007 MacArthur Fellow Marc Edwards says that, in practice, EPA's guidance translates to a flush of approximately 30 seconds to 1 minute. A 4-minute flush, Dr. Edwards told us, "is completely worthless in assessing any aspect of corrosion control, water safety, or veracity of prior EPA monitoring data. Whoever wrote that instruction guaranteed that the results obtained would be favorable to DC WASA, because the collected samples had no chance of detecting a lead hazard even if it were present."

What DC residents have painfully learned in the last few years is that there are sampling protocols that find lead problems when they exist, and there are sampling protocols that miss lead problems when they exist. The DC OIG 2005 audit, which comprised the first independent evaluation of DC's drinking water for lead following the two-and-a-half years when WASA kept the contamination under wraps, used a sampling protocol that misses lead problems. It is noteworthy that the DC OIG findings directly contradicted concurrent research in Washington DC by a University of California, Berkeley team, which in the Fall of 2005 reported that:
"Despite reports that lead levels have fallen significantly over the past year, 63% of all homes tested during the second year of our study [2005] still contained lead levels that exceeded the EPA limit. In addition, drinking water collected from a well-used fountain at an elementary school site that a local government reported as lead free contained lead concentrations greater than 5 times the EPA action limit two years in a row."
Indeed, the fact that 16 of the 272 homes sampled for the DC OIG investigation were found to have elevated levels of lead after 4 minutes of flushing (and during cold months of the year, when lead-in-water levels are not at their peak) suggests that in 2005 DC had a much more serious lead-in-water problem than the DC OIG data revealed. Contrary to WASA's claims, therefore, the DC OIG audit affirmed neither declining lead levels, nor the integrity of WASA's sampling methods.

One, of course, has to wonder how the DC OIG came up with the flawed sampling protocol. The DC OIG told us that it was given the impression that this protocol was what WASA was using at the time and that it complied with EPA requirements. If this is what the DC OIG was told, then it was led astray.

The protocol WASA was using in 2004 included a first draw sample, as EPA requires for compliance with federal regulations and the DC OIG report's comparison table demonstrates (pp. 10-16). Moreover, to our knowledge, it instructed homeowners to take a second draw sample after feeling a significant change in the temperature of the water, which is the language recommended by EPA. Excessive flushing prior to second draw sampling does not meet EPA requirements, and WASA knew this long before DC OIG began its investigation.

Although we haven't yet confirmed who exactly gave DC OIG the flawed sampling protocol, we know that improper flushing prior to testing -- either on the eve of sampling or immediately before collecting a sample -- is one of WASA's signature practices:
  • Prior to July 2003 and as part of its water monitoring program for compliance with federal regulations, WASA did in fact instruct homeowners to run the water for five minutes before collecting a second draw sample (Covington & Burling report, p. 108). In July 2003, however, WASA realized that excessive flushing prior to second-draw sampling was not included in EPA's guidelines. As a result, it changed its protocol to reflect EPA's language (i.e., allowing the water to run until there is a significant change in temperature). But it did not tell EPA that 400+ lead-in-water measurements below 15 parts per billion it had submitted for compliance with federal regulations had been obtained with the illegal sampling method. EPA Region III learned about WASA's erroneous methodology from a different investigation one year later. In January 2005, the federal agency issued an administrative order requiring WASA to, among other things, notify the residents in those 400+ homes about the unreliability of their 2004 water test results and the need to use lead-removing water filters.
  • In February 2004, two weeks after the Washington Post broke the story about the two-and-a-half year contamination, WASA tested DC public schools (DCPS) by running all taps for 10 minutes immediately before collecting first draw samples -- another version of the flushing practice that lowers lead at the tap and goes against the standard EPA protocol. The water utility's press release declared that "the vast majority of the DCPS and facilities have extremely low levels of lead in the water." Indeed, 98.94% of the taps tested measured below 15 parts per billion for lead. Following complaints by safe water activists and an official admission by WASA that 10 minutes of flushing gets rid of much of the lead, then Mayor Anthony Williams pressed WASA to repeat the school testing without the 10-minute flush. Lead-in-water levels this time came back markedly higher. Later, however, it was discovered that this time again WASA had recommended another pre-sampling flush. Rather than letting the water run immediately before sampling, WASA advised DCPS to flush all buildings for 10 minutes the night before. "If I did not want to find a lead problem where a serious problem existed, this is the protocol I would write," said Dr. Edwards. Another engineer commented, "They flushed the devil out of those schools." Three years later, in 2007, WASA instructed DCPS to flush all schools for 45 minutes and all taps for 5-15 minutes the night before sampling. Still, results showed that 3/4 of DC schools had at least one tap with lead levels that exceeded 15 parts per billion.
  • Similarly, from 2005-2008, WASA instructed homeowners in its water monitoring pool to flush their taps for 10 minutes the night before sampling for compliance with federal regulations, and refused to admit this to inquiring members of the public until asked by the Washington Post in mid-2008. Despite the objections of public health and environmental organizations and EPA's September 2008 determination that flushing on the eve of sampling goes against the intent of the law, WASA continues to recommend running the tap on the eve of sampling, albeit now for 2 minutes instead of 10. This, despite data from Virginia Tech that a 2-minute flush on the eve of sampling eliminates almost as much lead as a flush that lasts for 10 minutes.
When a water utility makes claims about water quality or the integrity of their data they have an obligation to base their statements on good science and verifiable facts. The 2005 DC OIG audit is yet another example of the type of deception we have come to expect from WASA. "Accurate and useful information" is nearly always just "smoke and mirrors" when the issue is lead in DC's drinking water.

Sunday, March 22, 2009

A New Congressional Inquiry into Scientific Integrity Highlights Lead in DC Drinking Water

On Thursday, March 12, 2009, the US House Subcommittee on Investigations and Oversight held a hearing on the federal Agency for Toxic Substances and Disease Registry (ATSDR) -- an agency under the aegis of the Centers for Disease Control and Prevention (CDC). The staff report for this hearing -- which argues that ATSDR is doing an abysmal job of fulfilling its mission to prevent human harm from toxic substances through reliable science, proper public health actions, and accurate information -- discusses, among other cases, lead in DC's drinking water. In its introduction, the report paints a grim picture of ATSDR:
"[A]cross the nation local community groups believe that ATSDR has failed to protect them from toxic exposures and independent scientists are often aghast at the lack of scientific rigor in its health consultations and assessments. The studies lack the ability to properly attribute illness to toxic exposures and the methodologies used by the agency to identify suspected environmental exposures to hazardous chemicals are doomed from the start. [...] [T]ime and time again ATSDR appears to avoid clearly and directly confronting the most obvious toxic culprits that harm the health of local communities throughout the nation. Instead, they deny, delay, minimize, trivialize or ignore legitimate concerns and health considerations of local communities and well respected scientists and medical professionals" (pp. 1-2; emphasis added).
One might wonder what ATSDR has to do with the District's lead-in-water problems.

Think CDC 2004. Actually, think CDC 2004-2009.

On March 30, 2004, exactly two months after the Washington Post informed District residents that for two and a half years the drinking water in thousands of DC homes had been contaminated with lead, the CDC's National Center for Environmental Health (NCEH) published a report with the DC Department of Health (DOH) that flew in the face of prior scientific knowledge about the health effects of lead in drinking water on the most vulnerable populations: infants and young children (see, Edwards et al. 2009 and our 2/25/09 blog entry). CDC/DOH's conclusion was the following:
"The findings in this report, indicate that although lead in tap water contributed to a small increase in BLLs [blood lead levels] in DC, no children were identified with BLLs [equal to or greater than] 10 ug/dL, even in homes with the highest water lead levels."
10 ug/dL is the CDC's "level of concern" for children aged 6 months-15 years. The report's take-away message was that two and a half years of exposure to lead-contaminated drinking water resulted in no measurable harm.

The CDC/DOH report was quoted ad nauseam by local and federal government officials (see select quotes). WASA, which used it in its 2008 campaign to convince the public that it was time to terminate its accelerated lead service line replacement program, cites the CDC/DOH findings on its website even today (e.g., 2006 news release, 2008 press release & fact sheet). The relief that the CDC/DOH publication brought to all those responsible for the safety of DC's drinking water was most powerfully expressed at a 9/22/04 oversight hearing on WASA by then City Council Member Carol Schwartz, Chair of the Committee on Public Works and the Environment. Responding to the assertion by Lynette Stokes, PhD, MPH, a DOH employee and one of the report's co-authors, that even those residents in homes with the worst lead-in-water levels were left essentially unscathed by the contamination, Ms. Schwartz rejoiced: "That is a marvelously, enormously, encouraging thing" (see video excerpt below).

Dr. Stokes was a former employee of the ATSDR (see our 2/25/09 and 1/31/09 blog entries). NCEH, the Center at the CDC that co-authored the CDC/DOH report is a sister agency to ATSDR. NCEH and ATSDR are managed by the same director, Howard Frumkin, MD, MPH, DrPH. According to the US House Subcommittee on Investigations and Oversight, Dr. Frumkin (and his predecessors) has displayed a persistent lack of concern about the scientific integrity of the reports produced by ATSDR. The Subcommittee's staff report for the March 12, 2009 hearing says:
"[T]he local communities that the ATSDR was created to help protect often believe the agency does more harm than good by offering them reassuring but unfounded and unsound advice and analysis which simply creates an artificial perception of safety to the public that is not supported by scientific inquiry or independent examination" (p. 4).
Today we know that the 2004 CDC/DOH report contradicted not only previous scientific research, but also evidence based on data collected in Washington DC. In April 2004, the Environmental Protection Agency's (EPA) National Center for Environmental Assessment used biokinetic modeling, which when extrapolated to the DC population predicted at least 600-700 cases of elevated blood lead levels (equal to or greater than 10 ug/dL) for children under 6 in 2003 (Edwards et al. 2009, Supporting Information). In 2004 and 2006, media reports featured cases of individual children who experienced elevated blood lead levels from DC's lead-contaminated water. In 2006, Virginia Tech water corrosion expert and MacArthur Fellow Marc Edwards, PhD discovered that -- contrary to public claims by DOH -- several WASA-funded environmental assessments at the homes of children with elevated blood lead levels pointed to drinking water as the sole or a contributing source of lead in 2004. In January 2009, Virginia Tech and the Children's National Medical Center showed that, consistent with the EPA models, in 2001-2004 hundreds if not thousands of DC infants and toddlers experienced elevated blood lead levels (equal to or greater than 10 ug/dL) as a result of high lead at the tap (Edwards et al. 2009).

The true facts about the harm done to DC residents from the 2001-2004 lead-in-water crisis were neither "marvelously" nor "enormously" encouraging. They were not encouraging at all.

The CDC's NCEH and DOH arrived at their misleading conclusions through some of the same flawed research methods characterizing many of ATSDR's reports:
  • Posing the wrong questions: The CDC/DOH study asked whether DC residents as a whole were harmed from chronic exposure to lead-contaminated water, rather than whether infants and toddlers were harmed from this exposure. By asking the broader question, CDC and DOH failed to look carefully at the age groups known to be most vulnerable to adverse health effects from lead at the tap. Infants are especially prone to harm from high lead in water due to their small body weight and heavy reliance on water as a major component of their diet via consumption of reconstituted formula.
  • Relying on inadequate or flawed data: The CDC/DOH study relied on blood lead data from DOH. According to Dr. Edwards, DOH's 2003 dataset was riddled with errors and inaccuracies, and thousands of blood lead records are unaccounted for.
  • Overlooking exposed people: The CDC/DOH study did not take into account individual cases of DC children whose elevated blood lead levels were linked to lead-contaminated drinking water. The story of at least one such case was featured in the Washington Post almost 4 weeks before the report's publication.
  • Diluting exposed populations with unexposed populations: The CDC/DOH study lumped all blood lead measurements from DC together (i.e., infants, toddlers, children under 6, children over 6, and adults) and conducted a citywide analysis, an approach that can mask population groups or geographical areas disproportionately affected from a given exposure.
  • Using inappropriate comparisons: In the CDC/DOH study there was a delay of months to a year between the time residents in homes with the worst lead-in-water problems were informed that their water was contaminated (and took measures to protect themselves from exposure) and the time their blood was tested for lead. Because the half-life of lead in blood is 28-36 days, blood lead levels tend to drop relatively quickly when the exposure source is eliminated. Moreover, all 17 children included in this analysis were using bottled or filtered water at the time of their blood test. As a result, this study had no chance of detecting the harm done to DC residents from excessively high lead-in-water levels, contrary to the public presentation of the data as "worst case."
In 2007, Dr. Edwards submitted to the CDC two 20-page letters detailing possible scientific misconduct in connection with the 2004 CDC/DOH report. The CDC dismissed his allegation without rebutting any of his specific facts. Then, in January 2009, when the Virginia Tech/Children's National Medical Center study contradicting the CDC/DOH report made front page news in the Washington Post, Dr. Frumkin publicly defended his agency's misleading report and minimized the seriousness of the new revelations (see the US House Subcommittee staff report, science reporter Rebecca Renner's 1/29/09 blog entry, and our 2/5/09 blog entry). In February 2009, Parents for Nontoxic Alternatives and our colleagues at the Alliance for Healthy Homes and Lead Safe DC wrote to Dr. Frumkin to suggest that he correct the record with a letter to the Washington Post stating clearly and accurately what the new findings actually mean. Here's what we suggested as one example of a more appropriate message:
The recent study demonstrates that the 2001-2004 lead-in-water crisis had many more adverse impacts and affected far more children than previously believed. There is no medical intervention that can help children already exposed, but we can and must continue working to understand the causes and extent of this problem and prevent further exposures. We know that exposure to lead at the levels reported are likely to cause a population decrease in IQ and educational performance. The presence of this toxin in our water supply has a negative impact on children in DC.

Since questions remain about the quality of DC water, we encourage residents, particularly those with children or who are pregnant, to carefully follow the advice issued by DC WASA, the DC Department of Health, and the Centers for Disease Control and Prevention. This includes never using hot tap water for cooking or drinking and running the tap for 2 minutes before use for cooking and drinking, if water has been stagnant for several hours. Commercially available water filters recognized by the National Sanitation Foundation for filtering lead are also effective. These precautions are even more important when tap water is used for mixing infant formula, powdered milk, or juices.
In his response, Dr. Frumkin did not address our suggestion. Instead, he remarked that WASA's "persistent misstatement" that CDC/DOH identified no harm from the 2001-2004 lead-in-water crisis was "regrettable." And he closed with one last defending statement about his agency's misleading report: that it concluded with the clear message that "public health interventions should focus on eliminating all lead exposure in children."

What a marvelous truism...

Video excerpt: 9/22/04, former DC Council Member Carol Schwartz, then Chair of the Committee on Public Works and the Environment that oversaw WASA, responds with jubilation to the news that none of the residents living in homes with the highest lead-in-water levels were harmed from the 2001-2004 contamination. Today we know that this CDC/DOH "study" had no chance of detecting harm from the years of high lead. Its first author, Mary Jean Brown, ScD, RN, Chief of the CDC's Lead Poisoning Prevention Branch has now admitted that the work was "clearly" not scientific.

Sunday, March 15, 2009

Four Things WASA Misled Us About on the Kojo Nnamdi Show

On March 2, WASA's General Manager Jerry Johnson was featured on WAMU's Kojo Nnamdi Show to answer questions about the safety of our drinking water. Mr. Johnson made several statements that require correction, because they give false assurances about the safety of our drinking water:

Misstatement #1: Lead in your drinking water could be a problem only if you have a lead service line.

Mr. Johnson argued and implied repeatedly -- and his co-guest, Mr. Tom Jacobus, General Manager of the Washington Aqueduct, made the point too -- that unless you have a lead service line (that's the pipe that carries water from the water main on the street to your home), you do not have to worry about lead in your drinking water. This is not true.

Building on the same erroneous premise, Mr. Johnson also asserted that health authorities recommend precautions against lead in water only for pregnant women, nursing mothers, and infants living in homes with lead service lines. This is also not true.

In reality: Although lead service lines are an important source of lead in DC's drinking water, and about 30,000 DC homes have them, lead solder and leaded brass fixtures can leach hazardous concentrations of lead as well. One thing to remember is that DC public schools are free of lead service lines, but they have a long history of lead-in-water problems. Virtually all DC plumbing systems have leaded brass, and lead solder was very common in homes built before 1987. This means that the majority of District homes have some lead in their plumbing. If you are concerned about lead at the tap you might want to take precautions, whether your home has a lead service line or not.

The Centers for Disease Control and Prevention (CDC) states clearly that "for homes with children or pregnant women and with water lead levels exceeding EPA's action level of 15 [parts per billion], CDC recommends using only bottled water for cooking, drinking, and baby formula preparation." Neither the CDC, nor any other agency of which we are aware limits this advice to populations with lead service lines.

An interesting note:

Through Freedom of Information Act requests, water corrosion expert and 2007 MacArthur Fellow Marc Edwards traced WASA's exclusive focus on lead service lines back to February 2004. Days after the Washington Post broke the story about the unprecedented lead-in-water levels in the District's drinking water, the director of the DC Department of Health water quality division e-mailed his colleagues that presenting the problem as isolated to homes with lead service lines would help calm down the public. The reasoning was that the majority of District homes do not have a lead service line. WASA embraced the idea, despite their own data that showed serious lead-in-water problems in many non-lead-service-line homes. Science reporter Rebecca Renner wrote, "A day later, WASA mailed an information letter on the lead crisis, which emphasized the problem of lead service lines, briefly mentioned lead solder, and ignored brass plumbing components." WASA proceeded to offer special health warnings, bottled water, and lead filters only to the 23,000 households known at the time to have a lead service line. Their outreach excluded not only non-lead-service-line homes, but also over 12,000 residences with a lead service line that WASA did not know about at the time. According to Edwards et al. (2009), simple predictive modeling suggests that in 2003 more DC children experienced elevated blood lead levels from contaminated water in homes without a lead service line than in homes with a lead service line (Supporting Information, p. 22).

Misstatement #2: If you want to prevent exposure to lead at the tap, and your water has been sitting unused for more than 6 hours, flush for 2 (or more) minutes any tap in your home prior to drinking or cooking.

These were Mr. Johnson's words:

"We do offer some advice, and that advice is: if the water has been stagnating, if it's been sitting in the house, inside the pipes, for more than 6 hours, we recommend a person comes home, when they come home, you should have some water use that involves about 2 minutes of flushing. You can come in and use the bathroom, you can wash a load of clothes, you can run the water for 2 minutes, and that then removes that stagnant water from anything that it's been in contact with over that period of time, and brings fresh water in from the water main in the street to the individual household."

This recommendation will not always protect you from high levels of lead in water.

In reality: Although running the water is a good way to reduce lead at the tap, flushing a tap other than the one you use for drinking and cooking (e.g., bathroom tap, laundry tap) will not always protect you from exposure to high lead in water. Here's why: the lead that ends up in your glass or cooking pot sometimes sits near or inside the tap you use to drink/cook, and is ready to flow out as soon as you turn on the water. It may have traveled from plumbing materials far from your faucet, or it may have leached from plumbing materials near or inside your faucet, but either way this lead will not go away by flushing a different tap. If you want to use flushing as a precautionary measure, make sure you also flush the tap you use for drinking and/or cooking. If you want to be especially cautious, flush routinely before every use.

Misstatement #3: The chemical "orthophosphate," which was added to our drinking water in 2004 and helps control the release of lead from plumbing materials, has solved DC's lead-in-water problem.

These were Mr. Johnson's words:

"What we found through a great deal of study and through significant research was that the orthophosphate addition that was mentioned by Tom [Jacobus] a little earlier has in fact worked. We have licked the lead problem with a chemical solution. Therefore the dollars that were originally slated for expenditure for replacing the public side of lead service lines has been primarily moved to other, more demanding needs within the system."

The unqualified statement that orthophosphate has addressed DC's lead-in-water problem, and that WASA can now turn its attention to "more demanding" issues is both false and irresponsible.

In reality: WASA assesses the state of lead in our drinking water through the agency's water-monitoring program that they carry out semi-annually for compliance with federal law. Since 2005, the first year after the 2001-2004 crisis that WASA claimed they met EPA requirements once again, WASA has been sampling DC's drinking water with methods known to miss lead at the tap. For example, they have been asking homeowners to run their tap for 10 minutes on the eve of sampling -- a practice called "pre-flushing" that temporarily reduces lead in water and that EPA Headquarters determined goes against the intent of the law -- and they have avoided sampling in the 7-8 weeks of the year when lead-in-water levels in DC are known to peak.

Even though everyone agrees that the District no longer faces the extreme lead-in-water problem of 2001-2004, the serious questions that remain about WASA's monitoring practices render unqualified statements about orthophosphate's success unsubstantiated. Additional evidence suggests that lead-in-water problems persist. For example:
  • In 2006, 2007, and 2008, an average of 4.2% of the homes monitored by WASA exceeded the EPA Lead Action Level (LAL) of 15 parts per billion in the 1st draw sample, and an average of 7% exceeded the LAL in the 2nd draw (or "flush") sample. Federal law regulates only 1st draw water samples. 2nd draw samples, which are more representative of the water we use to drink and cook, do not count. If 2nd draw samples counted, WASA’s 2006 and 2007 compliance monitoring data would have rendered the agency in exceedance of the LAL, and would have triggered public education, corrosion control, and lead service line replacement requirements. These data strongly suggest that lead in the water of thousands of District homes will frequently be elevated above the LAL.
  • According to WASA's own data, lead-in-water levels after partial lead service line replacement often spike for an undetermined duration. In 2008, WASA tested the water at 75 homes that had undergone partial lead service line replacement in 2006 and found a 1st and/or 2nd draw LAL exceedance in 13% of cases. This percentage of long-term problems is conservative, because in this testing round WASA once again instructed homeowners to pre-flush their taps for 10 minutes on the eve of sampling. WASA has conducted over 9,000 partial lead service line replacements throughout DC. This means, that well over 1,000 homes might have hazardous levels of lead at the tap today, as a result.
  • In 2006-2007, testing at DC Public Schools (DCPS) showed that 3/4 of the buildings had lead-at-the-tap problems. In several schools more than 60% of the sampled taps dispensed water with over 15 parts per billion lead. In a couple of cases, the water measured over 5,000 parts per billion, which qualifies as "hazardous waste." In 2008, Parents for Nontoxic Alternatives, in collaboration with Virginia Tech, the Washington International School, Cesar Chavez Public Charter School, and DCPS, sampled 6 high-risk schools. Overall, lead-in-water levels showed a dramatic drop from 2006-2007, probably due to the new coolers, fountains, and lead filters that were finally installed system-wide as part of Mayor Fenty's school Safe Water Initiative. Problems, however, remain in some taps without filters. This data proves that the orthophosphate is far from the cure it is professed to be, and that filters and/or other protective measures are still necessary for drinking water safety in DC.
  • From 2007 to the present, drinking water has been implicated as either the only or a contributing environmental source of lead for 9% of DC children under 6 who had elevated blood lead levels and whose home tap water was analyzed. No water samples were even collected in 30% of cases, and the sampling protocol used did not ensure a 6-hour stagnation prior to water collection, which can miss normally available lead at the tap. In 2006 and 2007, the parents of 5 of these children with elevated blood lead reported that WASA had done a partial lead service line replacement at their home in 2005. In 2008, independent testing by Parents for Nontoxic Alternatives and Virginia Tech at the home of another child with lead poisoning revealed that 3 out of the 9 taps dispensed excessive levels of lead. One of the 3 taps, which is used by the child for drinking, measured at 947 parts per billion for the 1st draw, and 51.99 parts per billion for the 2nd draw. This too was a residence with a recent partial lead service line replacement. Although the interior was also severely contaminated with lead dust, regular consumption of the water alone could have easily caused lead poisoning.
Misstatement #4: Pre-flushing pipes on the eve of sampling for federal water-monitoring requirements is a necessary practice that has been approved by EPA.

These were Mr. Johnson's words:

"Until several months ago we had used a protocol that called on people using a 10-minute flush. The 10-minute flush was to give us an apples-to-apples comparison. So we're asking everybody to do the same thing before they participate in the testing program. This is a program where we call on individual residents in the city to fill up liter-bottles of water and leave them for us to do certain kinds of testing. The [federal Lead and Copper] Rule calls for a 6-hour stagnation period, and in order to accomplish that, some people may have been out of the house for a week, some people may have been gone for a day, others may have just come home that evening, so that was the effort -- and it was an approved method by the US Environmental Protection Agency. They have since instructed us to come back to something that's more common to regular use within the household, so what we've been advising people now is doing a 2-minute flush. We must have a 6-hour stagnation period."

In reality: This is the third year in a row that WASA is claiming publicly that they obtained EPA's approval for pre-flushing pipes on the eve of sampling for lead in DC water. WASA made this claim in 2007, when Parents for Nontoxic Alternatives uncovered that the agency had instructed DC public schools to flush all buildings for 45 minutes and every tap for 5-15 minutes the night before sampling for lead, and again in 2008, when residents finally got a hold of WASA's 2005-2008 sampling protocol for compliance with federal standards and learned that it included a 10-minute pre-flush at every sampled home.

EPA Region III, the agency that oversees DC's drinking water, has repeatedly said on the record, both to Parents for Nontoxic Alternatives and to the Washington Post, that they never actually "approved" WASA's pre-flush. Moreover, in September 2008, EPA Headquarters determined that pre-flushing goes against the intent of the law, because it alters homeowners' normal water use patterns. A month later, at EPA's long-term issues stakeholder meeting, EPA Headquarters also confirmed that pre-flushing artificially caps stagnation time (which is not supposed to be capped) and removes particulate lead at the tap (thus missing "worst case" lead-in-water levels, which is precisely what a water utility's monitoring is supposed to capture).

Contrary to Mr. Johnson's statement, federal law requires a minimum 6-hour stagnation prior to sample collection, but there is no upper bound to stagnation time. The intent of the law is to determine the effectiveness of corrosion control measures and assess public safety in a set of "worst case" for risk of lead homes, based on actual resident water use. It is not to compare one home to another under artificially controlled conditions.

In November 2008, when we heard that WASA was negotiating with EPA to replace their 10-minute pre-flush with a 2-minute pre-flush, rather than give up pre-flushing all together, a member of WASA's Board of Directors e-mailed us a quote from Mr. Johnson saying, "DCWASA is not negotiating with the EPA to allow a 2-minute pre flush on the instructions used for LCR [federal Lead and Copper Rule] testing. WASA accepted the changes from EPA Region 3 in their entirety based on EPA Headquarters response to Ralph Scott's letter."

We do not know why WASA's revised 2009 sampling protocol continues to recommend a pre-flush. We have asked both EPA Region III and Mr. Johnson and are waiting to hear back.

Sunday, March 8, 2009

"All Ok": WASA's Hazardous Public Messages

There is a strange thing about WASA's public messages on lead in our drinking water. Often completely divorced from reality, these messages are dumped on us in reassuring sound bites and give a disincentive to take simple actions that would protect fetuses, infants, and young children from exposure to lead at the tap. To many of our leaders and to WASA's Board of Directors, WASA's confident messages that the city's water is unequivocally lead-safe seem to have a comforting effect, even when WASA's own data (and that from independent sources) show just the opposite.

Here are some examples of the hazardous public messages to which we have been subjected in the past:
  • In June 2003, while in the middle of an unprecedented lead-in-water contamination, the cover page of WASA's 2002 Water Quality Report to customers declared, "Your Drinking Water is Safe" (WASA has since removed this page of the report from their website). The truth is that in October 2002, the Environmental Protection Agency (EPA) had officially deemed WASA in exceedance of the federal Lead Action Level. This means that the tap water in over 10% of DC homes monitored by WASA dispensed more than 15 parts per billion lead. In actuality, WASA's data showed that 49% of homes had a lead-in-water problem. This exceedance had triggered public education, lead pipe replacement, and corrosion control requirements that are built into federal law to protect public health from lead-in-water hazards (see Eric H. Holder, Jr. Report, 2004, p. 76).
  • In February 2004, just weeks after the Washington Post broke the story about excessively high levels of lead at the tap throughout the District, WASA declared that drinking water at DC public schools had "extremely low levels of lead" -- only 7 of 154 schools had a problem. Soon after, it was discovered that WASA had flushed school taps for 10 minutes immediately before collecting samples, a practice that goes against EPA sampling standards, and that WASA later bragged was a good protective measure that residents could use to eliminate 95% of the lead at their tap. In April 2004, WASA conceded to public pressure and went back to test schools again. This time, 29 of 137 schools had a problem. Several taps dispensed lead concentrations that exceeded EPA's Lead Action Level of 15 parts per billion by hundreds and thousands of times. Free blood lead testing was offered only to students at those 29 schools. The message to the public was that children in other schools were safe. What was discovered years later was that WASA's second round of tests included the removal of aerators and flushing all schools for 10 minutes the night before sampling. Both of these actions hide lead at the tap. Testing in 2006-2007 showed some "hazardous waste" levels of lead in school water, 3/4 of schools with lead-at-the-tap problems, and several schools with more than 60% of the sampled taps dispensing over 15 parts per billion lead. Always at least a year or two behind WASA's innovations to hide lead-in-water problems, it took until 2006 before EPA essentially banned aerator removal, and until 2008 to determine that flushing on the eve of sampling for lead goes against the intent of federal regulations. In the end, we will never know how many DC children were needlessly exposed to lead in school drinking water between 2001 and 2007, when lead filters were finally installed system-wide as part of Mayor Fenty's school Safe Water Initiative.
  • In January 2008, WASA initiated a series of community meetings to try and begin reneging on their 2004 pledge to replace quickly all the lead service lines they own in the city. In their factsheet, and at their first public presentation of the issue in Anacostia, WASA declared that the partial lead service line replacements they had conducted in over 9,000 DC homes between 2004 and 2007 had shown "only small decreases in lead levels at the tap." What WASA failed to mention was that their data actually showed lead-in-water spikes for weeks and months after partial replacement in many homes. As shown in the video below, participants at the Anacostia meeting who had obtained WASA's data previously and knew about the spikes demanded answers. After intense questioning, WASA finally admitted that the spikes can last "for weeks" but could not recall how severe they are. Subsequently, DC Council member Jim Graham ordered WASA to conduct testing that would shed light on the long-term duration of post-partial-replacement spikes. In July 2008, WASA reported to Council member Graham that all was good: they tested homes that had their lead pipe partially replaced in 2006 and confirmed that the lead-in-water spikes following partial replacement were only a "short-term occurrence." In truth, 13% of the homes WASA tested continued to have lead-in-water problems in 2008 (i.e., they had a 1st and/or 2nd draw lead level over 15 parts per billion). This percentage is conservative, because in this testing round WASA once again instructed all homeowners to flush their taps for 10 minutes on the eve of sampling.
Today we know that despite WASA's repeated reassurances that our water is safe, in 2001-2003 hundreds, if not thousands, of DC infants and toddlers experienced elevated blood lead levels as a result of lead-contaminated drinking water. Moreover, in the last 3 years, children with elevated blood lead levels were identified in homes with a recent partial lead service line replacement.

WASA's public messages about lead in our water can be hazardous to our health. Unfortunately, correcting these messages, or erasing the misperceptions is extremely difficult. Because WASA rarely responds to Freedom of Information Act requests, it often takes years to discover what unethical manipulations went behind their latest "all ok" message.


Video excerpt: 1/30/08 "public education" meeting in Anacostia where WASA officials presented the utility's lead pipe replacement program. At this meeting, WASA was unprepared to discuss with the public the lead-in-water spikes that, according to WASA's own data, often follow partial lead pipe replacement for an undetermined duration. To date, WASA has done a partial lead pipe replacement in over 9,000 DC homes.

Sunday, March 1, 2009

Are You Concerned About Lead in Your Drinking Water? Here's Some Things You Can Do

This entry was updated on May 23, 2010:

DC drinking water should be lead-free (or close to it) if your plumbing has no lead-bearing components. But if you have:
  • A lead service line (full or partial)
  • Lead solder connecting your pipes
  • Leaded brass fixtures, or
  • Galvanized iron pipes (and your home has or had a full or partial lead service line)
your tap water may dispense lead. Virtually all DC plumbing systems have leaded brass. Lead solder was very common in homes built before 1987. And more than 30,000 DC residents have lead pipes (intact or partially replaced) in front of their homes.

The lead in our drinking water can come in two forms:
  • Soluble (like dissolved sugar), and
  • Particulate (small pieces of lead solder or detaching lead rust)
Orthophosphate, the chemical treatment that was added in DC water in 2004 to control lead leaching, helps control soluble lead, but its effect on lead particles is uncertain.

For children or pregnant women, the Centers for Disease Control and Prevention (CDC) recommends using only bottled water for cooking, drinking, and baby formula preparation, if water lead concentrations exceed 15 parts per billion.

If you are concerned about lead in your drinking water, you can:

1. Have your water tested by an independent EPA-accredited lab

Look for an NLLAP lab that does water testing.

Make sure that the test kit sent to you includes two bottles, for both a 1st and 2nd draw sample. The bottles should be large enough (1/4 of a liter) and their opening should be wide enough to allow sampling at a flow rate that resembles the way you usually fill a glass of water or a pan for cooking. Water corrosion expert at Virginia Tech, Marc Edwards, recommends that when you mail bottles back to the lab, you request that they use 2% nitric acid in the first step (prior to the mandatory holding time of the acidified bottles), instead of the specified 0.15% nitric acid (pH less than 2). Use of a stronger acid is allowed by EPA and makes it more likely that lead particles will not be missed.

One thing to keep in mind: the release of lead particles tends to be erratic. If your plumbing releases lead particles, you may or may not capture any in the two samples you take for analysis. This means that if you are really concerned about lead in your water, you may want to take precautions even if your test results indicate water lead levels below 15 parts per billion.

2. Take precautions

To reduce lead in water, EPA recommends the following:
  • When a tap has not been used for several hours, run the water until you feel the temperature change before cooking, drinking, or brushing teeth
  • Use only cold water for cooking and drinking
  • Never cook or mix infant formula with hot tap water
Additionally, you can use bottled water, or a water treatment device that is certified by the National Sanitation Foundation to reduce lead. NSF Standard 53 certification for lead reduction means that the certified device reduces 150 parts per billion lead to 10 parts per billion or less for the product's stated service cycle in gallons. For lead reduction, NSF certifies three different types of devices:
  • Distillation
  • Filtration
  • Reverse osmosis
At this time, the only pitcher-style filter certified by NSF to remove both soluble and particulate lead is ZP-001 by Zero Technologies. The Zero Technologies website says that this filter is sold at Target and Walgreens. It costs approximately $40.