EPA’s proposed Lead and Copper Rule

 In the waning days of this administration the White House is preparing to sign the U.S.EPA's first updates to the nation's lead and copper standards for drinking water rules since the lead action level was lowered. The update to the rule is seen as strengthening lead monitoring and notifications, and includes the first-ever requirement for testing of drinking water in schools and day cares. So it looks like it is a win for people.  

 Lead in drinking water is a national problem. That lead is predominately coming from the pipes. Lead does not exist in in most groundwater, rivers and lakes- the source water for most municipal and private water supplies. Instead, lead in drinking water is picked up from the pipes on its journey into a home. In older homes the water service lines delivering water from the water main in the street into each home were commonly made of lead. This practice began to fade by the 1950’s but was legal until 1988. Lead was also used to solder copper pipes together before 1988 (when the 1986 ban on lead in paint and solder went into effect). Also, until very recently (2011 Reduction of Lead in Drinking Water Act) almost all drinking water fixtures were made from brass containing up to 8% lead, even if they were sold as "lead-free." So even homes built with PVC piping in the 2000’s may have some lead in most of the faucets.

 The U.S. EPA regulation to control lead and copper in drinking water known as the Lead and Copper Rule (also referred to as the LCR) has undergone various revisions since it was first passed in 1991, but currently requires that:

• Water utilities optimize their treatment system to control corrosion in customers plumbing;
• Determine the tap water levels of lead and copper for customers who have lead service lines or lead-based solder in their plumbing systems;
• Rule out the source water as the source of significant lead levels;
• If lead levels exceed action levels (0.010 mg/L) the supplier is required to educate their customers about lead and actions they can take to reduce their exposure to lead.
• If corrosion control treatment plan continues to fail to reduce lead below lead action level it must begin replacing the lead service lines under its ownership.
• The cities distribution system usually stops at the property line when the homeowner or building owner becomes responsible. In some cities and communities (like Fairfax, VA) the property owner is responsible for the entire service line from the water main to the house (or other building). 

There are about 75 million homes across the country built before 1980, and are likely to contain some lead plumbing, though homes built until 2011 can contain some lead containing plumbing fixtures. That’s half of the housing. In addition, there are an estimated 7.3 million homes connected to their utility's water mains by individual lead service lines. These homes and buildings are mostly in older cities. These lead service lines are owned in part or whole by the property owner and should have been replaced decades ago. The cities distribution system usually stops at the property line when the homeowner or building owner becomes responsible. In some cities and communities (like Fairfax, VA) the property owner is responsible for the entire service line from the water main to home.

The new rule will tighten the requirements for lead service line replacement. Though the existing rule’s has a 7% replacement rate, it rarely happens because of provisions in the current rule allows partial line replacement which may make lead exposure worse.

Here are some of the changes in the update:

For Large Community Water Systems (serving >10,000 customers)

• Lead Service Line (LSL) removal begins at 10 part per billions (ppb) versus 15 ppb.
• More stringent sampling will better find the high lead levels that compel
• replacement.
• Systems must replace the entire lead service line when doing a replacement. If a customer replaces their portion the water systems must replace the water system-owned portion of a lead service line.
• The replacement rate is reduced to 3%. However, systems will no longer be able to “test out” lines. The current rule allows system to count the line as replaced towards their 7% removal if a sample taken from an individual line is below 15 ppb — even when not replaced. This has been a major problem with the current rule.

Currently, water systems can stop the 7% removal of lead service lines if after one year or less once they are below the action level. The proposed rule requires water systems that fall under the rule’s mandatory 3% replacement program to have lead levels less than the 15 ppb action level for two years prior to ending the replacement program. In addition, water systems must make their LSL inventory publicly available, and must notify occupants of homes with LSL every year about the presence of their LSL. This is to allow neighborhood to be informed and take local action. Hopefully, these two steps will keep water systems in the program and get the lead service lines replaced

Finally, in  Small Community Water Systems (serving <10,000 customers) that select LSL replacement as their compliance option would have to replace LSLs on a schedule not to exceed 15 years if they exceed the action level.

Overall, this appears to be an improvement in the Lead and Copper rule that will better protect our inner city communities that are most impacted by lead in drinking water. However, “testing out” of replacement should be eliminated. All lead service lines should be replaced. Those of us on public water need to push to have all lead service lines in our communities replaced. After that the next step is to address the problem of lead in down well equipment.

Do You Have Lead in Your Drinking Water?

You might have lead in your drinking water, but lead does not exist in in most groundwater, rivers and lakes- the source water for most municipal and private water supplies. In addition, water treatment plants as required by the Safe Drinking Water Act test for lead before the water leaves the plant. It is exceedingly rare to have lead in groundwater or rivers as a result of pesticides that were used decades ago or industrial activity that contaminated soil and groundwater. However, it has been estimated that 20% of urban households and an unknown number of rural household have lead in their drinking water above the 15 parts per million that is the federal Safe Drinking Water standard. So where is the lead coming from?

The lead in drinking water is predominately coming from the pipes. Lead in drinking water is most likely to occur in homes built before the mid-1950s when the water service lines delivering water from the water main in the street into each home were commonly made of lead. Lead was also used to solder copper pipes together before 1988. Also until very recently (after implementation of the 2011 Reduction of Lead in Drinking Water Act) almost all drinking water fixtures were made from brass containing up to 8% lead, even if they carry a plated veneer of chrome, nickel or brushed aluminum. So even a home like mine built with PVC piping in the 2000’s has some lead in most of the faucets.

Over time older pipes and fixtures corrode or simply wear away and the lead and other corrosion material (like rust) is carried to the drinking water. Time and water do cause corrosion, but this can be aggravated by the pH of the water or other changes in water chemistry. The amount of lead corroded from metal plumbing generally increases as water corrosiveness, a factor of the water’s acidity and calcium carbonate content, increases. In general, acidic water that has a pH less than 7 and that is low in calcium carbonate is more corrosive than water that has a pH higher than 7 and that is high in calcium carbonate. Soft water (low in dissolved solids like calcium and magnesium) tends to be more corrosive than hard water (with high concentrations of calcium and magnesium), and warm water is more corrosive than cold water. The common practice of grounding electrical connections to water pipes also can increase lead corrosion in the pipes.

In addition, water that sits for several hours or overnight in a pipe or brass fixture can leach lead from the brass faucet interior which may produce high lead levels in the first draw of drinking water. Though faucets purchased after 1997 contain less lead than previously used, they still can leach some lead -as evidenced by the detectible but extremely low “first draw” lead levels I find each year in my own plumbing. The most recent legislation, the 2011 Reduction of Lead in Drinking Water Act also called “Get the Lead Out,” mandates that after January 4, 2014, all faucets sold in the United States will contain no more than a weighted average of 0.25% lead in relation to wetted surface and can be labeled “lead free.”.

Lead can cause damage to the brain and kidneys, and can interfere with the production of red blood cells that carry oxygen to all parts of your body. The greatest risk of lead exposure is to infants, young children, and pregnant women. Scientists have linked the effects of lead on the brain with lowered IQ in children. If your home was built before 1990 the only way to know if you have lead in your drinking water is to test.

The U. S. EPA limit for lead in drinking water is 15 parts per billion (ppb), but only requires action if limited sample monitoring for lead has not exceeded the 15 ppb action level in more than 10% of the homes tested. Cities are only required to test a very small number of homes monthly and the condition and age of the plumbing in the home really determines if lead levels will be elevated. You need to test your own home.

The true prevalence of lead in public water supplies at the tap is difficult to know because it depends on how corrosive the source water is, whether lead distribution lines are used, and whether a particular building contains leaded plumbing materials. Lead may also originate from the corrosion of brass fittings on certain types of submersible pumps used in private groundwater wells through the mid 1990's.

If you have elevated levels of lead in your home’s water you need to take action to reduce any potential exposure.

• Replace the entire lead water service pipe. Typically water service lines a partially owned by the municipality and the portion on private property is owned by the homeowner. In Fairfax County homeowners are responsible for the entire service line from the water main. Replacing only a portion of the service line may actually make the problem worse. 
• Replace the leaded components in the plumbing system with newer, non-leaded components. This usually requires replacing copper pipes and lead solder with plastic PVC or PEX pipes. 
• Install an end-of-tap water filter. Look for filters certified by the National Sanitation Foundation for lead removal and reduction. Install this filter on the tap you use most often for cooking or for water to drink. Be aware that these small units are limited in the amount of time that the filter is effective in removing lead. Reverse osmosis units and activated alumina filters are very effective in removing lead once it is in the water. These units typically are attached to the kitchen tap and treat only the water from that tap.

Lead Pipes in Our Cities and Communities

The nation’s water infrastructure the pipes, treatment plants and other critical components that deliver drinking water and remove and treat waste water have grown old. In many of our cities water pipes installed when systems were built have only been replaced when they break. The building service lines that connect homes and businesses to the water mains are often the original lines.

The cities distribution system usually stops at the property line when the homeowner or building owner becomes responsible. In some cities and communities (like Fairfax, VA) the property owner is responsible for the entire service line from the water main to the house (or other building). As Flint Michigan has made all of America aware many of our oldest water systems have lead service lines or lead solder in copper lines.

For decades instead of replacing lead pipes urban water companies (especially in poor cities) have used chemicals to control lead and other chemicals from leaching into the water supply. Many at the American Water Works Association and other trade groups have questioned the wisdom of this strategy, there is always some lead leaching and many of us believe that there is no safe level of lead in drinking water.

In 1986 lead pipes were finally banned in new construction and repairs by the federal government, but many cities banned lead pipe use much earlier out of health concerns. Most existing lead pipes are closer to years old, are in the older cities of the east coast and mid-west and should have been replaced in the normal course of preventive maintenance program. Unfortunately, that is not how we operate in the United States. A few cities, including Madison, Wisconsin, and Lansing, Michigan, have taken steps to remove all of their lead pipes. Such projects can cost tens of millions of dollars and have to paid for by including an increase in water bills and also paid by property owners. It was estimated by the American Water Association that there are 6.5 million lead pipes still in service in the United States while the EPA estimates that number at around 10 million. That does not even consider all the homes in America that have copper pipes with lead solder.

In 1991, EPA published a regulation to control lead and copper in drinking water. This regulation is known as the Lead and Copper Rule (also referred to as the LCR). The rule has undergone various revisions, but requires that: (1) water utilities optimize their treatment system to control corrosion in customers plumbing; (2) determine the tap water levels of lead and copper for customers who have lead service lines or lead-based solder in their plumbing systems; (3) rule out the source water as the source of significant lead levels; (4) if lead levels exceed action levels (0.010 mg/L) the supplier is required to educate their customers about lead and actions they can take to reduce their exposure to lead. If a water utilities’ corrosion control treatment plan continues to fail to reduce lead below lead action level it must begin replacing the lead service lines under its ownership.

In the 1990’s and early 2000’s when the lead action level was lowered, water utilities discovered that just as changes in water chemistry can disturb the protective biofilm, removing lead lines improperly, or taking out only a portion of a line ends up disturbing the coating intended to prevent lead leaching inside old pipes. Replacing only a section can induce a chemical reaction from the addition of other metals, like copper, in new sections of pipe. Lawsuits were recently filed in Flint, Michigan and Chicago, Illinois for failure to remove all their lead pipes. Many other utilities could face such lawsuits because we are a nation that waits for system or component failure before we replace something.

WSSC, DC Water, and Fairfax water have had lead testing programs in place since 1990’s. The problems of lead in household drinking water in Washington DC has been previously discussed. In light of the national conversation over concerns of lead in public drinking water, that there have been no problems identified in the Fairfax Water system nor the WSS system. Testing in the Fairfax Water system has not found elevated levels of lead in the drinking water. Since testing began in the early 1990s, Fairfax Water’s levels have tested well within the EPA’s compliance standards. In the most recent Lead and Copper Rule sampling period for Fairfax Water, 100 % of the samples tested were significantly below the EPA action level of 15 ppb. In fact, during the sampling period, 100 % of the Fairfax Water samples contained less than 1.5 ppb of lead. For a fee, concerned homeowners can have Fairfax Water analyze their water sample for lead.

WSSC has an older system that was established in 1918. In 2005, WSSC conducted a search to find and replace any lead pipes in the WSSC system, but the WSSC system extends only to the property line. Recall that in the early 2000’s it was discovered that replacing only a section of a lead service line can induce a chemical reaction from the addition of other metals, like copper, in new sections of pipe. In addition, many homes built before the 1986 EPA ban of lead solder may still contain sources of lead in the solder that was used to connect copper plumbing inside their homes. In accordance with EPA regulations, every three years WSSC conducts random sampling in certain homes built prior to the EPA ban. Based on the latest round of sampling in 2014, results for all homes tested were below 15 parts per billion (ppb) for lead, which is the EPA action level. Ninety-eight percent of those tested were below 2 ppb.

WSSC adds a corrosion inhibitor to their water. This corrosion inhibitor works by creating a coating on pipes that prevents them from leaching lead, but it’s still possible that some homes built prior to 1960 may still have lead service lines on their property. It is the homeowner’s responsibility to test their pipes and replace them. Concerned customers should contact WSSC’s Water Quality Center at 301-206-7575 about having their water tested.

Safely Dispose of Drugs in Prince William County April 27th 2013

The 6th National DEA Prescription Drug Take-Back Day will be held on Saturday, April 27, 2013; from 10:00 am to 2:00 pm.  Prince William County is again participating in the program. Simply bring your prescription drugs to the collection sites at Prince William Hospital, Heathcote Health Center and Sentara Lake Ridge between 10 am to 2:00 pm to safely dispose of unused and old drugs such as powerful narcotic, pain relievers and other controlled substances that carry FDA instructions for flushing the remainder or excess down the toilet to reduce the danger of unintentional use or overdose and illegal abuse. Any other pills or capsules you wish to dispose of will be accepted-prescription and over the counter tablets. Intravenous solutions, injectables such as insulin, and needles will not be accepted. The service is free and anonymous, and though no questions will be asked- Illicit substances such as marijuana or methamphetamine will also not be accepted.

According to the Food and Drug Administration (FDA), most drugs can be thrown in the household trash, but should be taken out of their original containers and mixed with coffee grinds or kitty litter or otherwise made unpalatable. A few drugs should be flushed down the toilet for safety reasons, but may impact our water supplies. Drugs such as powerful narcotic pain relievers and other controlled substances carry instructions for flushing to reduce the danger of unintentional use or overdose and abuse. This nationwide prescription drug “Take-Back” day is to prevent pill abuse and theft. According to the DEA, prescription drug abuse in the United States is increasing, as are the number of accidental poisonings and overdoses. Studies cited by the DEA show that a majority of abused prescription drugs are obtained from family and friends, including from the home medicine cabinet. So now is your chance to clean out your medicine cabinet without damaging the environment.

Despite the safety reasons for flushing some drugs, waste water treatment systems were simply not designed to handle chemicals and drugs. Recent studies have found trace levels of drug residues in surface water, such as rivers and lakes, and in our drinking water supplies coming from the Potomac and Occoquan Reservoir. Waste water treatment systems including septic systems are not designed to remove drug residue and traces of contaminants are being found in some groundwater aquifers nationwide. However, many scientists report that the main way drug residues enter water systems is by human waste-people taking medications which are not complexly metabolized and then naturally allowing the drugs to pass through their bodies.

The technology used for chemical analysis has advanced to the point that it is possible to detect and quantify nearly any compound known to human kind down to less than a nanogram per liter or parts per trillion (1/1,000,000,000,000). This enhanced analytical ability has allowed scientists to discover that trace levels of pharmaceuticals, potential endocrine disrupting compounds (EDC) and other emerging contaminants exist in much of our nation’s surface water and is appearing in some groundwater and persists in the water through conventional and some advanced water treatments to also appear in our drinking water. Fairfax Water that supplies water to parts of Prince William County has examined their drinking water for some of these emerging contaminants and found traces of some contaminants in both their source water and finished water.

The implications of this ubiquitous exposure are unknown, but of concern. The detection of a chemical does not mean that it will cause health effects or disease, but we really do not know. The guiding principal of toxicology is that there is a relationship between a toxic reaction (the response) and the amount of a substance received (the dose). An important assumption in this relationship is that there is almost always a dose below which no response occurs or can be measured. So if the concentration of the contaminant was low enough there would be no toxic reaction, but that principal is being tested with endocrine disruption, and advances in analysis.

 Meanwhile, water utilities and citizens are left not knowing how to address findings of emerging contaminants in their source and finished drinking water. A study conducted by the Water Research Foundation concluded that using a combination of ozone and granular activated carbon in addition to coagulation, sedimentation, filtration and disinfection is effective in removing some of the broad categories of endocrine disrupters, personal care products and pharmaceuticals found in drinking water. Both the Washington Aqueduct and Fairfax water now treat their water supplies with ozone, but it is best to keep drug and other substance out of our groundwater and surface water in the first place. Begin by not flushing chemicals and drugs down the toilet. Bring your unused pills and capsules to the 6th National DEA Prescription Drug Take-Back Day. Dispose of chemicals and household hazardous waste at the Prince William Landfill on Wednesdays and Saturdays. 

Water Contamination From Fracking -Science or Politics?

In late 2010, two homeowners who lived over the Barnett Sale in Parker Texas near the drilling and hydraulic fracturing operations of Range Resources, a Fort Worth based natural gas driller, reported problems with their tap water, complaining that it was bubbling and even flammable. On Dec. 7, 2010, EPA issued an emergency administrative order to Range Resources to take immediate action to protect these homeowners. Now without explanation EPA has withdrawn the administrative order. The tale of this incident is not straightforward. The homeowners drinking water wells had been drilled in 2005 and no historical sampling beyond basic bacteria had ever been performed. However, whether or not I had been diligent in monitoring my private water supply if I suddenly discovered methane in my well, I, too, would want action, but it is possible that the appearance of the methane was not sudden. One of the families, the Lipsky family, sued Range Resources for $6,500,000 in damages.

Under the EPA order, Range Resources was required to provide drinking water to residents of two homes in Parker County whose water wells the agency said had been contaminated with methane by Range Resource’s natural gas drilling. In addition, the Emergency Order directed Range to install explosivity meters in the two houses within 48 hours, perform and submit to the EPA a survey “of all private water wells within 3,000 of each of their well and all of the Lake Country Acres public water supply system wells,” within five days along with a plan to sample air and water at those wells. In addition, Range Resources was to submit to the EPA for approval “a plan to conduct soil gas surveys and indoor air concentration in the homes within 14 days. A dramatic video on U-Tube of what appeared to be flaming water may have contributed to the EPA determination.

The Texas Railroad Commission held hearings on the incident. To those of us not familiar with the Texas regulatory structure, the Railroad Commission of Texas was established in 1891 and is the oldest regulatory agency in the state. For more than 90 years, the Commission has regulated the oil and gas industry. In addition the Railroad Commission has jurisdiction over gas utility, surface mining and pipeline industries. The Railroad Commission has both the expertise and experience to address these concerns. The Commission invited the EPA and the two domestic water well owners to present their evidence at the Commission’s January 19-20, 2011 administrative law hearing. However, neither the EPA nor the water well owners or their representatives appeared to testify.

Evidence presented during the Commission’s hearing included geochemical gas fingerprinting that demonstrated the gas in the domestic water wells came from the shallower Strawn gas field, which begins about 200 to 400 feet below the surface. The natural gas tested did not match the gas produced by Range Resources from the much deeper Barnett Shale field, which is more than 5,000 feet below the surface in that area. Range Resources also presented information to demonstrate that the two Range Resources gas wells were mechanically sound and without any leaks.

The evidence presented at the hearing demonstrated to the satisfaction of the state regulators and the administrative law judge that hydraulic fracturing of gas wells in the area did not result in communication between the Barnett Shale gas field and shallow aquifers from which water wells in the area draw their water and the Railroad Commission voted unanimously to clear the company of the charges last March. Texas Railroad Commission hearing examiners issued a finding that Range Resources two Barnett Shale natural gas wells were not the source of methane-gas contamination of residential water wells in Parker County.

Meanwhile, at the conclusion of the hearing in Texas, on January 20, 2011, Range Resources filed its petition for review of the Administrative Order with the federal Court asserting that EPA acted arbitrarily and capriciously in issuing the Emergency Order and counter sued one of the homeowners. It appears that one of the homeowners, the Lipsky’s created a dramatic video of flames coming from the well by attaching a hose to the water well's gas vent, not the water line as represented in the video and then lit the gas from the hose's nozzle. A Texas Judge found the video to be deceptive and the judge threw out the Lipskys' $6,500,000 lawsuit against Range Resources. The Judge ruled that the couple lacked legal jurisdiction to sue because the Texas Railroad Commission had determined in March that Range's gas wells were not responsible for contaminating their well.

Meanwhile, EPA countered Range Resources motion to dismiss that the endangerment determination was based on its concern that “methane in the levels found by EPA are potentially explosive or flammable, and benzene if ingested or inhaled could cause cancer, anemia, neurological impairment and other adverse health impacts and that this threat two private drinking water wells was a reasonable exercise of EPA’s authority under section 1431 of the Safe Drinking Water Act. ” The benzene levels found were below the regulatory maximum contaminant level, MCL, under the SDWA.

Though the EPA web site states: “The Safe Drinking Water Act gives EPA authority is to abate conditions in the water supply that may present an imminent and substantial endangerment to human health. This authority is generally triggered when a contaminant present in, or likely to enter, a public water system or underground drinking water source, may present an imminent and substantial endangerment to human health, and the state or local authority as not acted.” It is not entirely clear upon reading that the SDWA extends to groundwater beyond Underground Injection Control. Private drinking water wells are clearly not public water supplies.

Range resources’ challenge against the order was pending in the U.S. Court of Appeals for the Fifth Circuit when the EPA withdrew the order on last Thursday and stated that: "EPA and Range will share scientific data and conduct further well monitoring in the area, and Range will also provide useful information and access to EPA in support of EPA's scientific inquiry into the potential impacts of energy extraction on drinking water."

The EPA has also agreed with Wyoming state regulators earlier in March to conduct more tests at a site in Pavillion, where initial results found evidence that fracking contributed to water pollution. State regulators and industry officials questioned those initial results. In Wyoming where the water table is deep and the gas shallow the drinking water aquifer has been impacted. The EPA, announced last December that glycols, alcohols, methane and benzene were found in a well the EPA drilled into the drinking water aquifer in Wyoming within the Pavillion field were consistent with gas production and hydraulic fracturing fluids and likely due to fracking. The oil company responsible for these wells and the state regulators claimed that the results were inconclusive because methane can naturally seep into groundwater wells that provide drinking water. This is a rare occurrence that is usually confined to deeper water wells in the coal-producing areas, but these were deeper wells in a coal producing area. Benzene could have been introduced into the water by previous generations of oil and gas development. EPA appears to be backing off from its previous stance and point of view on fracking and water contamination for the moment. Possibly EPA should deploy fewer lawyers and more scientists and really study hydraulic fracturing or allow the states to develop regulations and controls appropriate to their specific geology.

Bottled Water is Not the Answer

The purity of bottled water cannot be trusted. The Food and Drug Administration (FDA) regulates bottled water as a packaged food under the Federal Food, Drug and Cosmetic Act and has established standards for testing bottled water that are not as stringent as the EPA’s Safe Drinking Water Act (SDWA) standards. While the FDA has established requirements for processing and bottling water to be sold for drinking, the FDA rules do not require disinfection and require only once a year testing for bacteria and other substances. The FDA requires using an approved source of water, but without a definition or control of what an approved source of water that requirement is practically meaningless.

The safest source water is a protected groundwater aquifer with a confining geological layer. When used as the source of the bottled water a protected groundwater aquifer could go a long way to ensuring the water quality, consistency of taste and the absence of cryptosporidium, a microscopic parasite that lives in the intestine of infected animals and humans and occurs mainly in surface water sources, such as lakes, streams and rivers. The safest bottled water like the safest source of any drinking water is from a protected groundwater aquifer or spring, though groundwater aquifers are potentially vulnerable to a wide range of man-made and naturally occurring contaminants, including many that are not regulated in drinking water under the SDWA, or by the FDA for bottled water.

Research performed by the US Geological Survey (USGS) on the quality of the nation’s groundwater found low levels of several chemicals and compounds (at least 10% of the MCL or other human health screening levels). Naturally occurring elements, radionuclides and pesticide compounds were extensively found at these low concentrations. Trace levels of pesticide compounds or VOCs were detected in a slight majority of the groundwater samples from public wells. Pesticides and VOCs were detected in a significantly greater proportion of samples from unconfined aquifers than in samples from confined aquifers. The groundwater with the greatest number of contaminants were consistently from shallower unconfined aquifers demonstrating the natural protection provided by a confining geological layer. Knowing the source of bottled water could provide insight into the quality and safety of the water.

Back in 2007 the Environmental Working Group (EWG) had laboratory analysis performed on bottled water and found that 10 popular brands purchased from grocery stores and other retailers in 9 states and the District of Columbia, contained in total 38 chemical pollutants, with an average of 8 contaminants in each brand. The analyses was conducted by the University of Iowa Hygienic Laboratory and found a wide range of pollutants, including not only disinfection byproducts, but also common urban wastewater pollutants like caffeine and pharmaceuticals (Tylenol); heavy metals and minerals including arsenic and radioactive isotopes; fertilizer residue (nitrate and ammonia); and a broad range of other, tentatively identified industrial chemicals used as solvents, plasticizers, viscosity decreasing agents, and propellants. These are all contaminants that are more characteristic of large system tap water that includes surface water in their water mix rather than a protected groundwater source. In fact, it appeared likely in at least two instances that the water was tap water.

More than one-third of the chemicals identified by the EWG were substances that are not regulated in bottled water by the FDA. Whether a particular contaminant in water is potentially harmful to human health depends on the contaminant’s toxicity and concentration in drinking water. Other factors include the susceptibility of individuals, amount of water consumed, and duration of exposure. Some of the chemicals found are regulated in California in drinking water and exceeded the maximum contaminant level (MCL) under California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). California has one of the most extensive and stringent lists of chemicals with MCLs for drinking water and their list is used as a standard for human exposure of substances not regulated under the FDA or SDWA, but many substance found in the bottled water samples are not regulated in water at all. Some of the bottled water tested by the EWG was found to be contaminated with bacteria. EWG’s report did change the regulatory awareness of the problem, increase public awareness of the problem and ultimately nudged some in the bottled water industry to disclose the source of their water or some indication of the source of the water.

The EWG report was followed by a Governmental Accountability Office (GAO) report criticizing the FDA and by Congressional Hearings. There seems to have been little progress the 2009-2010 EWG survey of 173 unique bottled water products found some improvements in product identification and labeling. Despite California’s bottled water law, SB 220, intended to provide transparency as to source and treatment for bottled water there seemed to be little improvement. The EWG found many popular brands of bottle water stated on their labels that water testing results were available from web sites or customer service numbers only to find that the results were, in fact, not available. The purity of bottled water remains in question yet many continue to buy bottled water. There are two independent certifications that often appear on bottled water. The International Bottled Water Association (IBWA) is a trade organization for water bottlers. IBWA members must meet the organization’s “model code” and are subject to annual inspections by an independent third party. Bottlers belonging to IBWA frequently indicate membership on their labels. NSF International - Bottled water certified by NSF undergoes additional testing by unannounced annual plant inspections. NSF certifications mean that the bottler complies with all applicable FDA requirements, including good manufacturing practices.

People may prefer bottled water because of its taste or simply as a healthier drink choice. The taste of all water has to do with the way it is treated and the quality of its source water, including its natural mineral content. According to the EPA, most bottled water comes from groundwater, where water quality varies less from day to day. The water is treated and immediately bottled. Bottled water from a dedicated source may have a more consistent taste than tap water, which in the large population centers is mixed and predominately comes from surface sources and must travel through pipes to reach homes. One of the key taste differences between tap water and bottled water is due to how the water is disinfected. Tap water may be disinfected with chlorine, chloramine, ozone, or ultraviolet light to kill disease-causing germs. Water systems use these disinfectants chlorine and chloramine because they are effective and inexpensive, and they continue to disinfect as water travels through the system pipes and pumps. There is often a residual taste. There are many groundwater sources that do not need to be disinfected and when necessary or desirable the bottled water industry typically uses ozone or ultraviolet light to disinfect the water. These methods leave no residual taste.

EWG and Good Housekeeping recommend that consumers drink filtered tap water or well water that has also been tested and filtered. Though there are no home filters that are certified to remove pharmaceuticals and certain other (emerging) contaminants, Good Housekeeping found some home filters do a great job of removing contaminants. The GH Research Institute, working with the Arizona Laboratory for Emerging Contaminants at the University of Arizona, tested the effectiveness of a group of filters at removing a group of these emerging contaminants. The water was spiked with low levels of Atrazine (herbicide), BPA (bisphenol A, used in production of plastics and in resins in many metal can liners), Carbamazepine (anticonvulsant), DEET (insect repellent), Estrone (hormone), Fluoxetine (Prozac, an antidepressant), Ibuprofen (pain reliever), PFOA (perfluorooctanoic acid, used to make nonstick-cookware coatings and other products), PFOS (perfluorooctanesulfonic acid, a key ingredient in stain repellents), Primidone (anticonvulsant), Sucralose (artificial sweetener), Sulfamethoxazole (antibiotic), TCEP (flame retardant), Tonalide (fragrance), and Trimethoprim (antibiotic) and the effective removal of contaminants by various commercially available home filters was measured. They found that many were very effective, but the best was the Whirlpool Filter 1 Refrigerator Filter which removed more than 92% for all contaminants over the life of the filter. ZeroWater 8-Cup Pitcher, $35 was found to be the best pitcher type filter. See http://www.goodhousekeeping.com/product-reviews/health-products/water-filters#slide-5 for the full report.

Filtering your tap water and using your own stainless steel bottle saves money, it’s purer than tap water and it helps shrink the global glut of discarded plastic bottles. If your home’s water comes from a public water system, the best way to learn more about your water quality is to read your water supplier’s annual water quality report which should be sent to you annually. If your water comes from a private drinking water well, EPA recommends testing the water regularly for bacteria, nitrates, and other contaminants. At a minimum you should test your drinking water for the 90 SDWA primary contaminants at least every few years and for a shorter list of contaminants including bacteria and nitrates annually.

Fracking Contaminated a Drinking Water Well

Fracking or hydraulic fracturing as it is more properly known is the pressurized injection of water with chemical additives into a geologic formation. The pressure used exceeds the rock strength and the fluid cracks open or enlarges fractures in the rocks and shale. As the formation is fractured, a “propping agent,” such as sand or ceramic beads, is pumped into the fractures to keep them from closing when the pumping stops and the pressure is released. Natural gas will flow from the fractures in the rock and shale into the wells increasing the recovery of the methane.

Historically, shale wells had been drilled vertically and then hydraulically fractured with 80,000 gallons or less of water and sometimes water and diesel. Diesel use is no longer allowed. However, today the most efficient method for developing the vast low-permeability Marcellus shale reservoirs is high-volume hydraulic fracturing. Wells used for hydraulic fracturing are drilled vertically, vertically and horizontally, or directionally and may extend more than 8,000 feet below ground surface or less than 1,000 feet. The wells can extend several thousand feet horizontally, potentially allowing impact to properties and water supplies far away from the well heads. Fifty thousand to 350,000 gallons of water may be required to fracture one well in a coalbed formation while two to five million gallons of water may be necessary to fracture one horizontal well in a shale formation. Water used for fracturing fluids is acquired from surface water or groundwater in the local area.

No one has ever looked at what the long term implications are for the hydraulic balance and groundwater supply when fracking occurs. The removal of millions of gallons of water, the fracturing of the geological formations, and the high pressure injection of contaminants even at low concentrations into the subsurface could cause significant changes in groundwater flow and quality. Now, the often repeated statement by oil industry executives and the current EPA administration that no documented case of drinking water aquifer being contaminated with fracking fluid has been proven false.

In last Thursday’s New York Times was an article by Ian Urbana outlining information that was part of a 1987 E.P.A. report to congress titled “Management of Wastes from the Exploration, Development and Production of Crude Oil, Natural Gas and Geothermal Energy.” This three volume report was brought to the attention of the New York Times by Carla Greathouse, the study’s lead author. Corroborating documentation was obtained from state archives or from the agency’s library by the New York Times. It appears despite claims to the contrary, EPA has been aware of at least one well documented case of drinking water well contamination from fracking for 25 years. In addition, there are reports from several states noting contamination of drinking water wells in association with fracking. One New York state report reads: “Because of possible underreporting by individuals whose drinking water was contaminated and difficulties in detection, the full extent to which injected brines have contaminated underground sources of drinking water is unknown. However, 23 cases of contamination have been confirmed and 4 are suspected.” http://s3.documentcloud.org/documents/216377/doc-reader-with-epa-report.pdf
http://www.nytimes.com/interactive/us/drilling-down-documents-7.html#document/p1/a27935

In some parts of the country, groundwater is the primary source of drinking water. Residents of 34 of the 100 largest cities in the United States rely on groundwater, as do about 95% of rural households. My own home in the rural crescent would be worthless without my well. Groundwater needs to be protected from anything that can contaminate, damage the water table or impair well production potential. Groundwater hydrology is not fully understood and impairment is not easily seen, only slowly experienced. Groundwater contamination is a particular concern to many of the most vocal opponents of fracking, and although earth’s cleansing capacity is limited, impairment to groundwater storage, flow and well productive capacity should be of equal or greater concern. .

About half the population of the United States depends on groundwater for a significant portion of its drinking water. To help protect these supplies from contamination, the Congress passed Part C of the Safe Drinking Water Act in 1974. This law requires the Environmental Protection Agency (EPA) to establish an underground injection control (LJIC) program. Through this program, EPA, directly or through delegation to states, regulates the design, construction, and operation of underground injection wells, which inject wastes and other fluids below underground drinking water sources. It is time that EPA make their first priority the protection of groundwater.

Fracking and Drinking Water Problems

On July 28th 2011 the EPA proposed standards that would require oil and gas well operators to cut emissions of volatile organic compounds, VOCs, (including methane) with fracking projects required to reduce VOC emissions by 95%. This is the second step EPA has taken in reexamining fracking. The documentary film “Gasland” created a groundswell of support for EPA to reexamine the impact of fracking on drinking water supplies and EPA announced in March 2010 that it will study the potential adverse impact that fracking may have on drinking water and developed a study plan with advise from their independent Science Advisory Board Environment Engineering Committee. Most of the Marcellus Shale hydraulic fracturing controversy has been focused on Pennsylvania and New York, but the Marcellus Shale runs through Maryland to Virginia. http://yosemite.epa.gov/sab/sabproduct.nsf/02ad90b136fc21ef85256eba00436459/d3483ab445ae61418525775900603e79!OpenDocument&TableRow=2.1#2

Fracking or hydraulic fracturing as it is more properly known involves the pressurized injection of fluids commonly made up of mostly water and chemical additives into a geologic formation. The pressure used exceeds the rock strength and the fluid opens or enlarges fractures in the rock. As the formation is fractured, a “propping agent,” such as sand or ceramic beads, is pumped into the fractures to keep them from closing as the pumping pressure is released. The fracturing fluids (water and chemical additives) are partially recovered and returned to the surface or deep well injected. Natural gas will flow from pores and fractures in the rock into the wells allowing for enhanced access to the methane reserve.

Wells used for hydraulic fracturing are drilled vertically, vertically and horizontally, or directionally and may extend more than 8,000 feet below ground surface or less than 1,000 feet, and horizontal sections of a well may extend several thousands of feet away from the production pad on the surface. This allows potential impact to properties and water supplies far away from the well heads. Over the past few years, the use of hydraulic fracturing for gas extraction has increased and has expanded over a wider diversity of geographic regions and geologic formations beyond its original use in old oil and gas fields to revitalize them. It is projected that shale gas will comprise over 20% of the total U.S. gas supply in the next 20-35 years. http://water.epa.gov/type/groundwater/uic/class2/hydraulicfracturing/index.cfm

Given expansion in the use of fracking it seems appropriate to reexamine the potential consequences. The 2005 energy law exempts fracking from the Safe Drinking Water Act. It has been suggested by some that particular “loophole” was created for Halliburton, a company once headed by former Vice President Cheney and one of the companies that helped pioneer fracking and is a supplier of fracking fluids. A more likely explanation is that the energy industry managed once more to be exempted from regulation. The 2004 EPA study “Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs” states that EPA reviewed 11 major coal basins mined for coalbed methane and saw no conclusive evidence that water quality degradation on underground drinking water supplies had occurred as a direct result of the injection of hydraulic fracturing fluids.

The report goes on to state that “Although potentially hazardous chemicals may be introduced into USDW (underground source of drinking water) the risk posed to USDW by introduction of these chemicals is reduced significantly by groundwater production and injected fluid recovery, combined with the mitigation effects of dilution and dispersion, adsorption and potentially biodegradation. Additionally, EPA has reached an agreement with the major service companies to voluntarily eliminate diesel fuel from hydraulic fracturing fluids that are injected directly into USDW for coalbed methane production.” http://water.epa.gov/type/groundwater/uic/class2/hydraulicfracturing/wells_coalbedmethanestudy.cfm

However, the Marcellus Shale covers an area in Pennsylvania where the coal and gas rights were separated from the land title generations ago so that many people live on land where they do not own the gas and coal rights and fracking can occur adjacent to or beneath their homes. Much of the concern with fracking has been direct contamination of drinking water supplies with methane and the additives in the fracking water, but serious study should be given to the potential to impact groundwater flow and reservoirs through the fracking process.
Fracturing fluids can be up to 99% water. The volume of water needed for hydraulic fracturing varies by site and type of formation. Fifty thousand to 350,000 gallons of water may be required to fracture one well in a coalbed formation while two to five million gallons of water may be necessary to fracture one horizontal well in a shale formation. Water used for fracturing fluids is acquired from surface water or groundwater in the local area. Wastewaters from the hydraulic fracturing process may be disposed in several ways. The water that flows back after fracturing may be returned underground using injection well, discharged to surface waters after treatment to remove contaminants, or applied to land surfaces. Not all fracturing fluids injected into the geologic formation during hydraulic fracturing are recovered. The EPA estimates that the fluids recovered range from 15-80% of the volume injected depending on the site. No one has ever looked at what the long term implications are for the hydraulic balance when fracking occurs. The removal of millions of gallons of water, the fracturing of the geological formations, and the injection of contaminants even at low concentrations into the subsurface could cause significant changes in groundwater flow and quality. I jealously guard my groundwater supply and would be outraged if fracking or for that matter even massive pumping of that quantity of groundwater would occur anywhere within 5 miles of here (which covers the recharge zone up Bull Run mountain and the hydraulic barrier of the river. The water is a valuable resource and should be guarded and protected. http://www.epa.gov/safewater/uic/pdfs/hfresearchstudyfs.pdf