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.

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