Regional Administrator Welsh Letter

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
1650 Arch Street
Philadelphia, Pennsylvania 19103-2029

March 4, 2004

Mr. Robert C. Bobb
City Administrator and Deputy Mayor
Government of the District of Columbia
John A. Wilson Building
1350 Pennsylvania Avenue, N.W.
Suite 310
Washington, DC 20004

Dear Mr. Bobb:

This is a followup to our meeting on March 2, and my call today with Edward Reiskin, your Chief of Staff, where we discussed our concerns about the lead in drinking water issue within the District of Columbia (D.C.) and the appropriate governmental response.

During our discussions, you indicated your intention to undertake appropriate actions to require the D.C. Water and Sewer Authority (WASA) to provide a safe, alternate supply of water to D.C. residents among other short-term actions. You also instructed us to make further contact with the Emergency Management Agency officials you have designated to lead the City's response effort in this area. In our subsequent meetings and discussions with these individuals, we are not satisfied that the requisite actions to address this urgent concern are being implemented.

Listed below are specific interim actions which EPA believes WASA must undertake to respond to the immediate threat:

1. Make available as soon as feasible, but within 30 days, an interim alternative supply of drinking water to all users supplied by WASA who are believed to receive their water through known or suspected lead service lines. The goal is to provide an alternate water source or filters to the 23,000 homes with lead service lines.

2. A plan describing the implementation of this provision must be provided to the District of Columbia and EPA within 3 days. Bottled water and/or filters must be certified by the appropriate certifying organizations.

3. Report progress on this distribution plan periodically to EPA and the District of Columbia.
4. A plan for sampling and analysis of homes and other buildings – including schools and day care centers – in the District that are not known or suspected to be served by lead service lines to determine whether homes and other buildings not served by lead service lines may also be experiencing excessive concentrations of lead in the water. Sampling must follow EPA protocol.

5. Inform all residents affected (not just bill paying customers) of the program for providing alternate water and periodically reissue notices of the availability of alternate water.

6. Periodically offer maintenance or re-supply the alternate water source (replacement filters e.g.) per standards certified by NSF or other appropriate certifying agencies.

7. Ensure that Point-of-Use filter devices, if used, are certified as effective at the higher levels detected in D.C. (> 150ppb); NSF International testing only applies to <150 ppb.
8. Test all lead service line locations during 2004 and accelerate the physical replacement of lead service lines to the maximum extent possible.

9. Expedite notification to customers of the results of water sampling at their residences.

10. Develop a public education plan that will successfully convey a sense of urgency in all communications with the public about the lead issue.

To provide EPA with adequate assurance that the District will take action to protect public health, I am requesting that you provide me with a written statement of your commitment to require WASA to undertake the actions noted above. It is vitally important that we receive your response no later than 2:00 pm on Friday, March 5. In the event you are not able to make such a commitment, EPA is prepared to exercise its authorities to address these issues discussed earlier.

Should you have questions or wish to discuss this further, feel free to contact me or
Thomas C. Voltaggio, Deputy Regional Administrator at 215-814-2908. My fax number is (215) 814-2901.

Sincerely,

Donald S. Welsh
Regional Administrator

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Regional Administrator Welsh Letter

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