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Ensure That Consumers Are Protected from Lead Contamination' which was 
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Report to Congressional Requesters: 

January 2006: 

Drinking Water: 

EPA Should Strengthen Ongoing Efforts to Ensure That Consumers Are 
Protected from Lead Contamination: 

GAO-06-148: 

GAO Highlights: 

Highlights of GAO-06-148, a report to congressional requesters: 

Why GAO Did This Study: 

Elevated lead levels in the District of Columbia’s tap water in 2003 
prompted questions about how well consumers are protected nationwide. 
The Environmental Protection Agency (EPA), states, and local water 
systems share responsibility for providing safe drinking water. Lead 
typically enters tap water as a result of the corrosion of lead in the 
water lines or household plumbing. EPA’s lead rule establishes testing 
and treatment requirements. This report discusses (1) EPA’s data on the 
rule’s implementation; (2) what implementation of the rule suggests 
about the need for changes to the regulatory framework; and (3) the 
extent to which drinking water at schools and child care facilities is 
tested for lead. 

What GAO Found: 

EPA’s data suggest that the number of drinking water systems with 
elevated lead levels has dropped significantly since testing began in 
the early 1990s. However, EPA’s database does not contain recent test 
results for over 30 percent of large and medium-sized community water 
systems and lacks data on the status of water systems’ efforts to 
implement the lead rule for over 70 percent of all community systems, 
apparently because states have not met reporting requirements. In 
addition, EPA’s data on water systems’ violations of testing and 
treatment requirements are questionable because some states have 
reported few or no violations. As a result, EPA does not have 
sufficient data to gauge the rule’s effectiveness. 

Implementation experiences to date have revealed weaknesses in the 
regulatory framework for the lead rule. For example, most states do not 
require their water systems to notify homeowners that volunteer for 
periodic lead monitoring of the test results. In addition, corrosion 
control can be impaired by changes to other treatment processes, and 
controls that would help avoid such impacts may not be adequate. 
Finally, because testing indicates that some “lead-free” products leach 
high levels of lead into drinking water, existing standards for 
plumbing materials may not be sufficiently protective. According to EPA 
officials, the agency is considering some changes to the lead rule. 

On the basis of the limited data available, it appears that few schools 
and child care facilities have tested their water for lead, either in 
response to the Lead Contamination Control Act of 1988 or as part of 
their current operating practices. In addition, no focal point exists 
at either the national or state level to collect and analyze test 
results. Thus, the pervasiveness of lead contamination in the drinking 
water at schools and child care facilities—and the need for more 
concerted action—is unclear. 

Water Distribution System from the Treatment Plant to Household 
Plumbing: 

[See PDF for image] 

[End of table] 

What GAO Recommends: 

Among other things, GAO recommends that EPA improve its data on key 
aspects of lead rule implementation, strengthen certain regulatory 
requirements and oversight, and assess the problem of lead in drinking 
water at schools and child care facilities. In commenting on a draft of 
this report, EPA generally agreed with our findings and 
recommendations. 

www.gao.gov/cgi-bin/getrpt?GAO-06-148. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact John B. Stephenson at 
(202) 512-3841 or stephensonj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Inadequate Data Impair EPA's Ability to Oversee Implementation of the 
Lead Rule: 

Weaknesses in the Regulatory Framework for the Lead Rule May Undermine 
Public Health Protection: 

Limited Data Indicate Few Schools and Child Care Facilities Test or 
Take Other Measures to Control Lead in Their Water Supplies: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendixes: 

Appendix I: Scope and Methodology: 

Appendix II: Detailed Analysis of Corrective Action Milestone Data 
Reported to EPA, by State, through June 2005: 

Appendix III: Number of Lead Rule Violations Reported to EPA Between 
1995 and June 2005 (by State): 

Appendix IV: Information on Selected EPA and State Enforcement Actions, 
by Type, from 1995 to June 2005: 

Appendix V: Comments from the Environmental Protection Agency: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Corrective Action Milestone Data Reported by the States 
through June 2005, by System Size and Type of Milestone: 

Table 2: Differences in Reported Information on Lead Service Line 
Replacement, as of June 2004: 

Table 3: Percentage of Systems with Violations from 1995 to June 2005: 

Table 4: State Activities to Ensure that Water Systems Are Taking Lead 
Samples at Appropriate Sites: 

Table 5: State Role in Selecting Sites for Reduced Monitoring: 

Table 6: States That Require More Frequent Monitoring to Evaluate the 
Effects of Treatment Changes: 

Table 7: State Views on Extent to Which Water Systems Are Notifying 
Homeowners of the Results of Lead Testing: 

Table 8: Examples of Different Reporting Practices for Lead Testing in 
Combined Water Distribution Systems as of June 2005: 

Table 9: Applicability of Standards for Lead-Free Plumbing Products: 

Table 10: Summary of NSF Test Results Regarding Lead Content of 
Plumbing Products Voluntarily Submitted to NSF for Certification: 

Table 11: Information on Recent Efforts to Test for and Remediate Lead 
in Drinking Water in Five School Districts: 

Figures: 

Figure 1: Water Distribution System from the Treatment Plant to 
Household Plumbing: 

Figure 2: Process Drinking Water Systems Follow to Comply with EPA's 
Lead Rule: 

Figure 3: Number of Community Water Systems That Exceeded the Lead 
Action Level During the Initial Monitoring Period (1992-1994) and Their 
Most Recently Completed Monitoring (2002-June 2005), by System Size: 

Figure 4: Summary of State Efforts to Address Lead in Drinking Water at 
Schools and Child Care Facilities: 

Abbreviations: 

ANSI: American National Standards Institute: 

EPA: Environmental Protection Agency: 

LCCA: Lead Contamination Control Act: 

NSF: NSF International: 

Letter January 4, 2006: 

The Honorable James M. Jeffords: 
Ranking Minority Member: 
Committee on Environment and Public Works: 
United States Senate: 

The Honorable John D. Dingell: 
Ranking Minority Member: 
Committee on Energy and Commerce:
House of Representatives: 

The Honorable Hilda L. Solis: 
Ranking Minority Member: 
Subcommittee on Environment and Hazardous Materials: 
Committee on Energy and Commerce: 
House of Representatives: 

When testing in the District of Columbia during 2003 revealed that over 
4,000 households had elevated levels of lead in their drinking water, 
the ensuing publicity prompted questions about how well local drinking 
water systems are protecting consumers from lead contamination 
nationwide. The adverse health effects associated with exposure to lead 
can be severe, including delays in normal physical and mental 
development in infants and young children, and damage to kidneys and 
reproductive systems for the population at large. Although rarely the 
sole cause of lead poisoning, lead in drinking water can be a 
significant contributor to a person's total exposure--and can account 
for as much as 60 percent of the exposure for infants who drink baby 
formula or concentrated juices mixed with water. Because children are 
most vulnerable to adverse health effects from lead exposure, the 
adequacy of controls over lead in water supplies serving schools and 
child care facilities is particularly important.[Footnote 1] In 
response to the discovery of lead contamination in the District of 
Columbia, the Environmental Protection Agency (EPA) launched a broad 
examination of the implementation of drinking water regulations it 
issued in 1991--known as the Lead and Copper Rule--to determine whether 
elevated lead levels are a national problem.[Footnote 2] EPA issued the 
rule as part of its efforts in implementing the Safe Drinking Water 
Act, and established testing and treatment requirements to control lead 
and copper in public water supplies.[Footnote 3] 

Responsibility for ensuring safe drinking water is shared by EPA, the 
states, and, most importantly, local water systems. In general, EPA 
sets standards to protect drinking water quality and to ensure the 
proper operation and maintenance of public water systems. EPA also 
oversees state implementation of the Safe Drinking Water Act and 
applicable regulations where states have assumed primary responsibility 
for enforcement. The states ensure that local water systems meet EPA 
and state requirements, provide technical assistance, and take 
enforcement action, as necessary. In addition, the states collect 
information on the results of drinking water monitoring, among other 
things, and report the information to EPA. At the local level, public 
water systems operate and maintain their facilities in accordance with 
federal and state requirements, periodically test the drinking water to 
ensure that it meets quality standards, install needed treatments, and 
report required information to the states. 

In contrast to most drinking water contaminants, lead is rarely found 
in the source water used for public water supplies. Instead, lead 
enters tap water as a result of the corrosion that takes place over 
time when materials containing lead in the water distribution system or 
household plumbing come into contact with water. For example, lead can 
leach out of service lines, pipes, brass and bronze fixtures, solders, 
or other materials, and contaminate drinking water. To address this 
problem, EPA established requirements for corrosion control treatment, 
source water treatment, lead service line replacement, and public 
education. The lead rule requires water systems to test the tap water 
at a specified number of locations that are at high risk of lead 
contamination.[Footnote 4] In general, if lead concentrations exceed 15 
parts per billion in more than 10 percent of the samples, a water 
system has exceeded the action level and must (1) provide public 
education materials to its customers and (2) conduct additional testing 
to determine if treating lead contamination from the water's source may 
be necessary. Water systems that exceed the action level may also be 
required to install corrosion control treatment to reduce the water's 
corrosiveness. When treatment is not effective in controlling lead 
levels, a water system must annually replace at least 7 percent of any 
lead service lines it owns. To further address the problem of lead in 
household plumbing, the Congress amended the Safe Drinking Water Act in 
1986 and 1996 to, among other things, ban the use of lead solder and 
plumbing materials that are not "lead-free." 

In addition, under the Lead Contamination Control Act of 1988, the 
Congress required the recall of drinking water coolers with lead-lined 
tanks, banned the manufacture and sale of water coolers that were not 
lead-free, and required states to establish programs to assist local 
agencies in testing and correcting for lead in water supplies in 
schools and child care facilities.[Footnote 5] While the Consumer 
Product Safety Commission was responsible for managing the recall, EPA 
was responsible for distributing a list of banned coolers and 
publishing and distributing guidance on detecting and remediating lead 
contamination in school drinking water supplies. 

In March 2005, we issued a report that focused on the lead 
contamination problem in the District of Columbia's drinking water 
supplies.[Footnote 6] For a national perspective on controlling lead in 
drinking water, you asked us to determine (1) the extent to which EPA 
has sufficient data to oversee implementation of the lead rule, (2) 
what implementation of the rule to date suggests about the need for 
changes to the regulatory framework, and (3) the extent to which 
drinking water supplies at schools and child care facilities are tested 
for lead and their users protected from elevated lead levels. For 
information on the data EPA uses for oversight of lead rule 
implementation, we analyzed EPA data on the results and frequency of 
lead testing, the status of corrective actions, and violations. We 
determined that the data on results and frequency of testing were 
sufficiently reliable to show compliance trends. However, we found that 
other data on corrective actions and violations were not sufficiently 
reliable to assess the status of efforts to implement and enforce the 
lead rule. For information on experiences in implementing the lead rule 
and the need for changes to the regulatory framework, we analyzed the 
responses to a 2004 EPA information request on states' implementation 
policies and practices, the results of EPA-sponsored expert workshops, 
and relevant documents. We also obtained test results from NSF 
International on lead content and lead leaching of plumbing fittings 
and fixtures. To assess data reliability, we obtained information on 
NSF International's procedures for data quality control and determined 
that the data were sufficiently reliable for illustrative purposes. For 
information on efforts to control lead in drinking water at schools and 
child care facilities, we analyzed the results of a 2004 50-state 
information request by EPA, an EPA workshop that focused specifically 
on schools and child care facilities, and relevant documents. 

We supplemented the information collected under each objective by 
contacting state and local drinking water officials in 10 states. We 
selected eight of the states--California, Illinois, Iowa, 
Massachusetts, Michigan, New York, Pennsylvania, and Washington-- 
because they either had a relatively high number of water systems with 
test results that exceeded or fell just below the lead action level, or 
they added to the geographical diversity of our selections. We also 
obtained information from Connecticut and Florida, two states that EPA 
identified as particularly active in addressing potential lead 
contamination in water supplies serving child care facilities. In all 
10 states, we obtained information from state drinking water program 
managers, state public health or education officials, and local school 
districts that have efforts under way to test for and remediate lead 
contamination. (App. I contains a detailed description of our scope and 
methodology.) We performed our work between June 2004 and November 2005 
in accordance with generally accepted government auditing standards. 

Results in Brief: 

While EPA's data suggest that the number of drinking water systems with 
elevated lead levels has declined significantly since the early 1990s, 
the agency does not have a complete picture of how states and water 
systems are implementing the lead rule because data on key aspects of 
water systems' compliance with regulatory requirements are incomplete 
or questionable. According to EPA's data, the number of systems 
exceeding the lead action level dropped by nearly 75 percent from the 
initial monitoring conducted during 1992 to 1994--shortly after the 
lead rule took effect--and the period from 2002 to June 2005. However, 
our analysis disclosed that EPA's database does not contain recent test 
results on over 30 percent of the community water systems, apparently 
because states have not met reporting requirements. EPA's data on the 
status of water systems' efforts to implement the lead rule are 
similarly incomplete. The agency requires the states to report certain 
"milestones" to indicate whether a water system's lead levels are 
acceptable or whether the system is implementing required corrective 
actions, such as installing corrosion control treatment and replacing 
lead service lines. Through June 2005, however, EPA's database did not 
contain any milestone information on more than 70 percent of the 
nation's community water systems. Finally, because some states reported 
few or no violations of lead rule testing and treatment requirements 
over multiple years, the completeness of these data is questionable. 
EPA has been slow to take action on these data problems and, as a 
result, lacks the information it needs to evaluate how effectively the 
lead rule is being implemented and enforced nationwide. 

The experiences of EPA, states, and water systems in implementing the 
lead rule have revealed weaknesses in the regulatory framework, 
including both oversight and the regulations themselves, which may be 
undermining the intended level of public health protection. 
Consequently, some changes to the regulatory framework are necessary. 
First, the sites used for lead testing may no longer represent the 
sites with the highest risk of contamination. For example, when the 
sampling locations approved initially are no longer available or 
appropriate, water systems identify new sites and states may not be 
tracking the changes to ensure that new sites meet high risk criteria. 
Another concern is that most states do not require their water systems 
to notify the homeowners who volunteer for periodic lead monitoring of 
the test results and do not know the extent to which such notifications 
are actually occurring. In addition, the effectiveness of corrosion 
control can be impaired by changes to other treatment processes and, in 
some states, testing and other controls that would help avoid such 
impacts may not be adequate. Finally, existing standards for plumbing 
fixtures and devices may not be protective enough, according to some 
experts, because testing has determined that some of the products 
defined as "lead-free" under the Safe Drinking Water Act can still 
contribute high levels of lead to drinking water. To improve 
implementation of the lead rule, EPA is considering a number of changes 
to its regulations, such as requiring advance notice of treatment 
modifications that could affect corrosion control. EPA is also 
considering changes to its guidance to improve and clarify specific 
aspects of the lead rule. 

Although data are limited, it appears that few schools and child care 
facilities have tested their water supplies for lead--or adopted other 
measures to protect users from lead contamination--either in response 
to the Lead Contamination Control Act of 1988 or as part of their 
current operating practices. Little data are available to assess (1) 
the scope and effectiveness of the effort to recall water coolers or 
(2) the extent and results of any testing. In addition, although the 
act required states to establish programs to assist local agencies in 
addressing potential lead contamination at schools and child care 
facilities, this provision was declared unconstitutional in 1996 and 
state efforts were generally limited. Current efforts to detect and 
remediate lead in drinking water at schools and child care facilities 
appear limited, based on the results of EPA's 50-state information 
request and our discussions with 10 states. In recent years, some of 
these facilities have tested voluntarily, and school districts in some 
cities such as Boston, Philadelphia, and Seattle, have detected 
elevated lead levels at some drinking water outlets. However, little 
information exists on the pervasiveness of the problem nationwide 
because no focal point exists at the national or state level to collect 
and analyze the test results or share information on effective 
remediation strategies. State and local officials say that dealing with 
other environmental problems in their facilities--including lead paint, 
asbestos, and mold--is a higher priority because more information is 
available on the nature and extent of these hazards. 

We are making a series of recommendations to improve oversight and 
implementation of the lead rule. Among other things, we are 
recommending that EPA take steps to ensure that data on key aspects of 
lead rule implementation are timely and complete so that the agency is 
better able to assess the effectiveness of the rule and state oversight 
and enforcement efforts. Other recommendations focus on strengthening 
aspects of the regulatory framework, such as lead monitoring 
requirements, review of treatment changes that could affect corrosion 
control, and standards for plumbing fittings and fixtures. Finally, we 
are recommending that EPA collect and analyze existing data to assess 
the extent of lead contamination in drinking water at schools and child 
care facilities and appropriate remedial actions. In commenting on a 
draft of this report, EPA generally agreed with our findings and 
recommendations. In particular, EPA acknowledged that it needs better 
data to assess the effectiveness of lead rule implementation and 
enforcement. In addition, EPA agreed that the aspects of the regulation 
that we identified as needing improvement warrant additional attention 
and noted its plans to address most of these areas by modifying the 
rule or collecting additional information. EPA did not address our 
recommendations regarding lead contamination and remedial actions at 
schools and child care facilities. 

Background: 

Under the Safe Drinking Water Act, EPA is responsible for regulating 
contaminants that may pose a public health risk and that are likely to 
be present in public water supplies. EPA may establish an enforceable 
standard--called a maximum contaminant level--that limits the amount of 
a contaminant that may be present in drinking water. However, if it is 
not economically or technically feasible to ascertain the level of a 
contaminant, EPA may instead establish a treatment technique to prevent 
known or anticipated health effects. In the case of lead, EPA 
established a treatment technique--including corrosion control 
treatment--because the agency believed that the variability of lead 
levels measured at the tap, even after treatment, makes it 
technologically infeasible to establish an enforceable standard. EPA 
noted that lead in drinking water occurs primarily as a byproduct of 
the corrosion of materials in the water distribution system or 
household plumbing, some of which is outside the control of the water 
systems. Figure 1 illustrates the distribution system for drinking 
water and potential sources of lead contamination. 

Figure 1: Water Distribution System from the Treatment Plant to 
Household Plumbing: 

[See PDF for image] 

[End of figure] 

EPA's lead rule also established a 15-parts-per-billion lead action 
level, which is based on the 90th percentile level of water samples 
taken at the tap. Water systems must sample tap water at locations that 
are at high risk of lead contamination, generally because they are 
served by lead service lines or are likely to contain lead solder in 
the household plumbing. The number of samples that must be collected 
varies depending on the size of the water system and the results of 
earlier testing. Small or medium-sized systems whose test results are 
consistently below the action level may be allowed to reduce the 
frequency of monitoring and the number of samples collected.[Footnote 
7] 

To determine their test results at the 90th percentile level, water 
systems must multiply the number of samples taken during a monitoring 
period by 0.9 and identify the result at that level, after ranking the 
results of the individual samples they collected in ascending order. 
For example, a water system required to take 50 samples would rank the 
results from 1 (for the lowest result) to 50 (for the highest result); 
the 90th percentile level is the 45th result, 5 below the highest test 
result for that monitoring period. When the 90th percentile results for 
a water system are above 15 parts per billion, the system has exceeded 
the lead action level and must meet requirements for public education 
and source water treatment. Under the public education requirements, 
water systems must inform the public about the health effects and 
sources of lead contamination, along with ways to reduce exposure. 
Source water responsibilities include, at a minimum, water monitoring 
to determine if the lead contamination is from the water source rather 
than--or in addition to--service lines or plumbing fixtures.[Footnote 
8] 

Water systems that exceed the action level may also be required to 
install corrosion control treatment, except for large systems that may 
qualify as having optimized corrosion control based on other 
criteria.[Footnote 9] When either corrosion control or source water 
treatment are not effective in controlling lead levels, the lead rule 
calls for water systems with lead service lines to begin replacing them 
at a rate of 7 percent annually (unless the state requires a higher 
rate). 

Figure 2: Process Drinking Water Systems Follow to Comply with EPA's 
Lead Rule: 

[See PDF for image] 

[End of figure] 

The states play an important role in ensuring that the lead rule is 
implemented and enforced at the local level. Among other things, they 
are responsible for (1) ensuring that water systems conduct required 
monitoring and (2) reporting the results to EPA. If the systems must 
take corrective action to address elevated lead levels, the states are 
responsible for approving or determining the nature of the treatment or 
other activities that will be required, ensuring that they are 
implemented, and periodically reporting relevant information to EPA. 
The Safe Drinking Water Act authorizes the states to assume primary 
responsibility for enforcing the drinking water program--including the 
lead rule--if they meet certain requirements, such as adopting drinking 
water regulations at least as stringent as EPA's and having adequate 
procedures to carry out and enforce the program's requirements. All 
states except Wyoming have assumed primacy for managing their drinking 
water programs. 

In addition to requiring the regulation of lead in public water 
supplies, the Safe Drinking Water Act also contains provisions to limit 
the extent to which materials in the water distribution system and 
household plumbing contribute to lead levels at the tap. Specifically, 
the act banned the use of solder and other materials in the 
installation or repair of public water systems or plumbing that are not 
lead-free. In this regard, the act established a material standard by 
defining "lead-free" to mean solders and flux containing no more than 
0.2 percent lead, and pipes and pipe fittings containing no more than 
8.0 percent lead.[Footnote 10] In addition, the act called for 
development of voluntary performance standards and testing protocols 
for the leaching of lead from new plumbing fittings and fixtures by a 
qualified third party certifier or, if necessary, promulgated by EPA. A 
third party certifier set such a standard in 1997, limiting the amount 
of lead that the fittings and fixtures may contribute to water to 11 
parts per billion. 

To address the potential risks of lead contamination in water supplies 
serving schools and child care facilities, Congress passed the Lead 
Contamination Control Act of 1988.[Footnote 11] Among other things, the 
act banned the manufacture and sale of drinking water coolers 
containing lead-lined tanks and other water coolers that are not lead- 
free and required (1) EPA to publish a list of such coolers and 
distribute it to the states, (2) the Consumer Product Safety Commission 
to issue an order requiring manufacturers and importers to repair or 
replace lead-lined coolers or recall and provide a refund for them, and 
(3) the states to establish programs to assist local agencies in 
addressing potential lead contamination.[Footnote 12] In 1990, EPA 
identified six models of water coolers from one manufacturer that 
contained lead-lined tanks, but the agency was unable to obtain 
information on the number of units produced. Regarding water coolers 
that were not lead-free, EPA identified three manufacturers that 
produced coolers containing lead solder that could contaminate drinking 
water. The manufacturers reported producing at least 1 million of the 
coolers. 

Following the discovery of elevated lead levels in the District of 
Columbia's drinking water, EPA undertook a year-long evaluation to gain 
insight into how states and local communities are implementing the lead 
rule and to determine whether the problems identified in the District 
of Columbia are occurring elsewhere. EPA's activities included: 

* a series of expert workshops on key aspects of the rule (monitoring 
protocols, simultaneous compliance, lead service line replacement, 
public education, and lead in plumbing fittings and fixtures), 

* a review of state policies and practices for implementing the lead 
rule, 

* data verification audits that covered the collection and reporting of 
compliance data for the lead rule in 10 states, and: 

* an expert workshop and a review of state efforts to monitor for lead 
in drinking water at schools and child care facilities. 

Participants in EPA's expert workshops included representatives of 
federal and state regulatory agencies, drinking water systems, 
researchers, public interest groups, and others. 

Inadequate Data Impair EPA's Ability to Oversee Implementation of the 
Lead Rule: 

Although EPA's data on the results of testing indicate that the lead 
rule has largely been successful in reducing lead levels, the reporting 
of these data has not been timely or complete. In addition, key data on 
the status of water systems' efforts to implement the lead rule, 
including required corrective actions, are incomplete. EPA's data on 
lead rule violations are also questionable because of potential 
underreporting by the states. The lack of data on key elements of lead 
rule implementation makes it difficult for EPA and others to gauge the 
effectiveness of efforts to meet and enforce the rule's requirements. 

Although EPA's Data Suggest a Decline in Lead Levels, States' Reporting 
on the Results of Lead Testing Has Not Been Timely or Complete: 

When the lead rule was first implemented, initial monitoring disclosed 
that several thousand water systems had elevated lead levels--that is, 
more than 10 percent of the samples taken at these systems exceeded the 
15-parts-per-billion action level. EPA's most recent data indicate that 
the number of water systems that exceed the lead action level has 
declined by nearly 75 percent since the early 1990s. The systems that 
currently have a problem with elevated lead levels represent about 2 
percent of all water systems and serve approximately 4.6 million 
people. Figure 3 shows the results (by system size) of the initial lead 
monitoring, conducted from 1992 to 1994, and more recent testing from 
2002 through the quarter ending in June 2005.[Footnote 13] 

Figure 3: Number of Community Water Systems That Exceeded the Lead 
Action Level During the Initial Monitoring Period (1992-1994) and Their 
Most Recently Completed Monitoring (2002-June 2005), by System Size: 

[See PDF for image] 

Notes: (1) Figure 3 includes data on active community water systems in 
the 50 states and the District of Columbia. The size categories for the 
water systems are based on population served, with large systems 
serving populations of greater than 50,000, medium systems from 3,301 
to 50,000, and small systems less than or equal to 3,300. 

(2) Data for initial monitoring under the lead rule cover the period 
from 1992 to 1994 because the testing was phased in by system size. 
Large water systems began monitoring in January 1992, medium systems in 
July 1992, and small systems in July 1993. 

(3) Many water systems have obtained approval to reduce the frequency 
with which they are required to monitor for lead from every 6 months to 
once a year or once every 3 years. Thus, to capture the most recent 
round of testing for all water systems, we included data from 2002 
through June 2005, the most recent data available at the time of our 
analysis. A few small systems have received approval to reduce their 
monitoring to once every 9 years and may not be included in these 
statistics. 

(4) Some water systems may have tested their lead levels multiple times 
during the periods covered in this analysis; however, we included only 
the results of the initial monitoring and the most recent test result 
for each system. 

(5) We determined that the data are sufficiently reliable for the 
purposes of examining trends in lead action levels. 

[End of figure] 

EPA, state, and water industry officials generally see the decline in 
the number of systems with elevated lead levels as evidence that the 
lead rule has been effective and point to corrosion control treatment 
as the primary reason. Another indicator of success is the number of 
water systems approved for reduced monitoring. Under the lead rule, 
water systems can obtain state approval to reduce both the frequency of 
monitoring and the number of samples included in the testing when test 
results show lead levels consistently below the action level. According 
to EPA's data, nearly 90 percent of all water systems have qualified 
for reduced monitoring. 

After several years of experience with the lead rule, in January 2000, 
EPA made significant changes to the information states were required to 
report for inclusion in the agency's database. Among other things, EPA 
added a requirement for states to report, for large and medium-sized 
systems, all 90th percentile test results, not just the results for 
systems that exceed the action level. EPA said that it planned to use 
these test results to show how levels of lead at the tap have changed 
over time for large and medium systems and, by extrapolation, for small 
systems. 

Although the new reporting requirements took effect in January 2002, 
EPA's database contained 90th percentile test results for only 23 
percent of the large and medium systems by January 2004.[Footnote 14] 
EPA officials explained that states were still having difficulty 
updating their information systems to accommodate the new reporting 
requirements and, for EPA, obtaining the data was not a priority at 
that time. Following the detection of elevated lead levels in the 
District of Columbia, however, EPA made a concerted effort to obtain 
more complete information from the states, and, as of June 2004, EPA 
reported that it had data for nearly 89 percent of the large and medium 
systems (based on an analysis of test results submitted from January 
2000 through May 2004). However, we also analyzed data on the results 
of lead testing and found that EPA's database does not contain current 
information for a much larger percentage of large and medium water 
systems. Specifically, we found that for the period from January 2002 
through June 2005, EPA's database lacks any test results for nearly 31 
percent of the large and medium water systems.[Footnote 15] We could 
not determine whether the data are missing because states have not 
reported the results or because testing has not occurred. When asked 
whether states have been updating test results in a timely manner since 
2004, an official representing EPA said that the timeliness of recent 
test data is unknown; the agency has not been tracking whether states 
are adequately maintaining data on the results of lead testing. 

Regarding the information required for small water systems--which is 
limited to test results exceeding the action level--officials from both 
the Office of Ground Water and Drinking Water and the Office of 
Enforcement and Compliance Assurance indicated that some data are 
probably missing but could not provide specific estimates. An official 
from the Office of Ground Water and Drinking Water commented that EPA's 
database likely includes most of the required small system data because 
action level exceedances trigger follow-up activities and states are 
more likely to pay attention to those cases. 

EPA Does Not Have Complete Information on the Status of Water Systems' 
Efforts to Implement Lead Rule: 

As part of EPA's efforts to improve its indicators of lead rule 
implementation, the agency restructured its reporting requirements and 
reduced the number of "milestones" that states are required to report 
from 11 to 3. EPA established three corrective action milestones, 
including (1) a DEEM milestone, meaning that the system is deemed to 
have optimized corrosion control; (2) an LSLR milestone, meaning that 
the system is required to begin replacing its lead service lines; and 
(3) a DONE milestone, meaning that the system has completed all 
applicable requirements for corrosion control, source water treatment, 
and lead service line replacement.[Footnote 16] 

EPA officials told us that the vast majority of water systems should 
have at least one milestone in the database. They indicated that in 
most instances, systems should have a DEEM designation because they 
have installed corrosion control or qualify for meeting the milestone 
otherwise. However, we found that, overall, EPA has information on 
corrective action milestones for only 28 percent of the community water 
systems nationwide--and lacks any milestone data on the remaining 72 
percent. Table 1 summarizes the results of our analysis. 

Table 1: Corrective Action Milestone Data Reported by the States 
through June 2005, by System Size and Type of MilestoneA: 

System size: Large; 
Number of water systems: 841; 
Systems without any milestone data: Number: 600; 
Systems without any milestone data: Percent: 71.3; 
Systems with milestones: DEEM[B]: 202; 
Systems with milestones: LSLR: 7; 
Systems with milestones: DONE: 206; 
Systems with milestones: Total systems with one or more milestones[C]: 
Number: 241; 
Systems with milestones: Total systems with one or more milestones[C]: 
Percent: 28.7. 

System size: Medium; 
Number of water systems: 7,620; 
Systems without any milestone data: Number: 5,335; 
Systems without any milestone data: Percent: 70.0; 
Systems with milestones: DEEM[B]: 2,122; 
Systems with milestones: LSLR: 15; 
Systems with milestones: DONE: 1,850; 
Systems with milestones: Total systems with one or more milestones[C]: 
Number: 2,285; 
Systems with milestones: Total systems with one or more milestones[C]: 
Percent: 30.0. 

System size: Small; 
Number of water systems: 42,991; 
Systems without any milestone data: Number: 31,195; 
Systems without any milestone data: Percent: 72.6; 
Systems with milestones: DEEM[B]: 11,254; 
Systems with milestones: LSLR: 21; 
Systems with milestones: DONE: 8,838; 
Systems with milestones: Total systems with one or more milestones[C]: 
Number: 11,796; 
Systems with milestones: Total systems with one or more milestones[C]: 
Percent: 27.4. 

System size: Total; 
Number of water systems: 51,452; 
Systems without any milestone data: Number: 37,130; 
Systems without any milestone data: Percent: 72.2; 
Systems with milestones: DEEM[B]: 13,578; 
Systems with milestones: LSLR: 43; 
Systems with milestones: DONE: 10,894; 
Systems with milestones: Total systems with one or more milestones[C]: 
Number: 14,322; 
Systems with milestones: Total systems with one or more milestones[C]: 
Percent: 27.8. 

Source: GAO analysis of EPA data. 

[A] This table reflects the milestone data that states reported for 
active community water systems. 

[B] In the case of the DEEM milestone, states are required to report 
the basis for their determinations that systems have optimized 
corrosion control and EPA established three reason codes for that 
purpose. We found that EPA's database contained the required reason 
codes for 100 percent of the 13,578 systems with a DEEM milestone. 

[C] Because individual water systems may have multiple milestones in 
EPA's database, this column represents the number of unique systems 
with one or more milestones to avoid "double counting." 

[End of table] 

The extent to which milestone data were reported to EPA varied from 
state to state. We found that 22 states had not reported milestones for 
any of their water systems and another 8 states had reported data on 
about 10 percent of their systems. (See app. II for a state-by-state 
breakdown of reported milestone data.) 

EPA officials believe that most water systems have actually taken the 
steps necessary to meet the criteria for the DEEM milestone, at a 
minimum, and attribute the lack of milestone data to non-reporting by 
the states rather than noncompliance by the water systems. They also 
suggested that some of the 22 states we identified as having reported 
no milestone data, based on our analysis of EPA's current data, may 
have reported corrective actions prior to 2000, when EPA modified the 
number and type of milestones. However, we reviewed archived data in 
EPA's database and found that 8 of the 22 states had also not reported 
any milestones prior to 2000, and another 11 states had reported data 
on no more than 10 percent of their systems. Overall, the 50 states had 
reported milestone data for only 5.7 percent of their community water 
systems prior to 2000. 

Moreover, some information in EPA's database is inconsistent with other 
reported data. Specifically, we found differences between the 
information on lead service line replacement in EPA's database--systems 
having an LSLR milestone--and the information states reported in the 
agency's 50-state review of lead rule implementation policies and 
practices. As table 2 shows, seven states reported requiring lead 
service line replacement in response to EPA's June 2004 query but did 
not have any LSLR milestones in EPA's database in the same time frame. 

Table 2: Differences in Reported Information on Lead Service Line 
Replacement, as of June 2004: 

States reporting required lead service line replacement activity in 
EPA’s June 2004 information request[A]: 

Arizona; 
Connecticut; 
Illinois; 
Iowa; 
Massachusetts; 
Michigan; 
Minnesota; 
Montana; 
New York; 
Pennsylvania; 
Utah; 
Wisconsin. 

12 states. 

States reporting LSLR milestone in EPA’s database as of June 2004[B]: 

Illinois; 
Massachusetts; 
Minnesota; 
Montana; 
Pennsylvania; 
Virginia. 

6 states. 

Source: GAO analysis of EPA data. 

[A] In response to EPA's information request, 11 states reported that 
some water systems were voluntarily replacing lead service lines--or, 
in two instances, the "goosenecks" connecting the water main to a 
service line. The 11 states included one state (Michigan) that also 
reported requiring one or more systems to replace lead service lines. 

[B] The District of Columbia was also identified in EPA's database with 
an LSLR milestone. 

[End of table] 

In addition, after following up with state officials, we found that 
EPA's database did not contain accurate data on the number of water 
systems required to replace lead service lines because the states were 
not providing timely updates or correcting erroneous information. 

Data on Lead Rule Violations Are Questionable Because of Potential 
Underreporting by the States: 

Periodic audits by EPA--and our own analyses--raise questions about the 
completeness of EPA's data on lead rule violations. To assess the 
reliability of its drinking water data, EPA regularly conducts data 
verification audits that evaluate state compliance decisions and the 
adequacy of states' reporting to the national database. In addition, 
EPA prepares a national summary evaluation of the reliability of 
drinking water data every 3 years. While past data verification audits 
have not assessed compliance decisions under the lead rule, to the 
extent that states' reporting practices are relatively consistent 
across regulations, the audits may shed some light on the types of 
problems likely to be found in the reporting of lead rule data. 
According to the most recent national summary of data 
reliability,[Footnote 17] which covered audits conducted from 1999 to 
2001, the estimated error rate for health-based violations--involving 
maximum contaminant level or treatment technique requirements--was 35 
percent, down from 60 percent in the prior national report, which 
covered audits conducted from 1996 to 1998. For monitoring and 
reporting violations, the estimated error rate was 77 percent, down 
from 91 percent in the prior report. The March 2004 report said that 
most violation errors resulted from incorrect compliance determinations 
by the states, meaning that the state should have cited a violation but 
did not. Other problems included "data flow" errors (when the state 
correctly identified a violation but did not report it to EPA) and 
errors in EPA's database (such as violations that were incorrectly 
reported or not removed when rescinded). 

Another analysis from EPA's March 2004 report did include the lead rule 
and the results also raise questions about the completeness of EPA's 
data on lead rule violations. The report states that by means of a tool 
that tracks the number of violations reported in each state over a 
period of several years, EPA determined that 14 states had not reported 
any treatment technique violations under the lead rule during a 6-year 
period from 1997 to 2002.[Footnote 18] The report noted that this 
potential non-reporting should be evaluated further and recommended 
that EPA and the states conduct annual evaluations of all instances of 
potential non-reporting. EPA's Office of Ground Water and Drinking 
Water asked the regional offices to follow up with the states regarding 
the potential underreporting, as recommended in the March 2004 report 
on data reliability. For the most part, however, the regions' responses 
did not address the lack of treatment technique violations under the 
lead rule in the applicable states; two of the regional offices did not 
provide written responses. Officials from EPA's Office of Enforcement 
and Compliance Assurance were not aware of the violations analysis. The 
officials told us that because of limited resources, they focus their 
efforts on helping to ensure that states address the worst compliance 
problems--water systems identified as significant noncompliers as a 
result of the frequency or severity of their violations. 

A lack of violations--or a relatively low number of water systems with 
violations--does not necessarily mean that states are not meeting 
reporting requirements, or that their compliance monitoring and 
enforcement efforts are inadequate. However, analyzing the violations 
data and following up on the results could provide some useful insights 
into the reasons for differences among the states; it could also help 
identify problem areas and best practices. We updated EPA's analysis of 
violations and, as table 3 shows, the percentage of water systems that 
have had one or more violations over the past 10 years varies from 
state to state, particularly in the case of monitoring violations. 

Table 3: Percentage of Systems with Violations from 1995 to June 
2005[A]: 

Monitoring violations: Percent of systems with violations[B]: 0; 
Monitoring violations: Number of states: 1; 
Treatment technique violations: Percent of systems with violations[B]: 
0; 
Treatment technique violations: Number of states: 11. 

Monitoring violations: Percent of systems with violations[B]: > 0 to 5; 
Monitoring violations: Number of states: 10; 
Treatment technique violations: Percent of systems with violations[B]: 
> 0 to 1; 
Treatment technique violations: Number of states: 16. 

Monitoring violations: Percent of systems with violations[B]: > 5 to 
10; 
Monitoring violations: Number of states: 6; 
Treatment technique violations: Percent of systems with violations[B]: 
> 1 to 5; 
Treatment technique violations: Number of states: 14. 

Monitoring violations: Percent of systems with violations[B]: > 10 to 
20; 
Monitoring violations: Number of states: 11; 
Treatment technique violations: Percent of systems with violations[B]: 
> 5 to 10; 
Treatment technique violations: Number of states: 6. 

Monitoring violations: Percent of systems with violations[B]: > 20 to 
30; 
Monitoring violations: Number of states: 9; 
Treatment technique violations: Percent of systems with violations[B]: 
> 10; 
Treatment technique violations: Number of states: 3. 

Monitoring violations: Percent of systems with violations[B]: > 30 to 
40; 
Monitoring violations: Number of states: 7. 

Monitoring violations: Percent of systems with violations[B]: > 40; 
Monitoring violations: Number of states: 6. 

Monitoring violations: Percent of systems with violations[B]: Total; 
Monitoring violations: Number of states: 50; 
Treatment technique violations: Percent of systems with violations[B]: 
Total; 
Treatment technique violations: Number of states: 50. 

Source: GAO analysis of EPA data. 

[A] We used 1995 as the starting point for our analysis because all 
water systems should have completed their initial monitoring by the end 
of 1994. 

[B] Some water systems in EPA's database have multiple violations. To 
avoid double counting, we identified the percent of unique systems with 
one or more violations. 

[End of table] 

Appendix III contains a state-by-state analysis of lead rule violations 
reported from 1995 to June 2005. 

More recently, EPA conducted data verification audits during the fall 
of 2004, which focused exclusively on states' compliance determinations 
under the lead rule in five states and included the lead rule as part 
of the audit in another five states. However, the results are not yet 
available. EPA officials have been analyzing the data and obtaining 
comments on the preliminary findings from the states; they expect to 
issue a final report by the end of calendar year 2005. 

Lack of Data Affects EPA's Ability to Evaluate the Effectiveness of 
Lead Rule Implementation and Enforcement: 

In changing its reporting requirements in January 2000, EPA recognized 
that it needed better indicators of the lead rule's implementation. 
Regarding the 90th percentile results of lead monitoring, EPA noted 
that in terms of routine reporting, these data are the only measure it 
has for showing the lead rule's effectiveness and said that, without 
such data, the agency would have no way to measure progress.[Footnote 
19] Similarly, EPA maintained that having information on water systems' 
corrective action milestones, along with quarterly violation and follow-
up information, would provide data on the status of lead rule 
implementation and allow the targeting of compliance and enforcement 
activities.[Footnote 20] Given the reduced number of milestones, EPA 
indicated that it would be critical for states to report the 
information completely and in a timely manner, and that the agency 
would be following up with the states to ensure that such reporting was 
occurring. 

Despite the importance of the 90th percentile results and corrective 
action milestones to evaluating the lead rule's implementation, our 
analyses confirmed or identified significant and longstanding gaps in 
the amount of information available. Although EPA attempted to ensure 
that it had complete data on the results of lead testing, following the 
publicity surrounding the incidence of lead contamination in the 
District of Columbia, the problems with incomplete test result data 
have continued and the agency has not followed up on the missing 
milestone data. EPA has also been slow to take action on the potential 
underreporting of violations. As noted earlier, following its March 
2004 report on data reliability, EPA did not determine the reasons for 
the lack of violations reported by some states. EPA's previous summary 
evaluation, which was issued in October 2000, identified similar 
indications of underreporting and called for targeted attention to the 
applicable states and regions to address the issues and develop action 
plans.[Footnote 21] 

EPA needs complete, accurate, and timely data to monitor water systems' 
progress in implementing the lead rule, identify potential problem 
areas and best practices, and take appropriate action. In particular, 
not having complete or reliable data on corrective action milestones or 
violations makes it difficult to assess the adequacy of EPA and state 
enforcement efforts. However, officials from EPA's Office of 
Enforcement and Compliance Assurance told us that the amount of 
enforcement resources devoted to the drinking water program--including 
enforcement of the lead rule--has declined in recent years. They also 
told us that while they hold monthly meetings with their counterparts 
in EPA's regional offices and state officials to discuss the more 
significant violators, the officials have not systematically evaluated 
state enforcement efforts with regard to the lead rule. See appendix IV 
for information on EPA and state enforcement actions, by type, from 
1995 to June 2005. 

EPA and state officials attribute the problems with lead rule data to 
the complicated nature of the rule, the incompatibility of EPA and 
state information management systems, and resource constraints. For 
example, EPA officials noted that it is difficult to ensure that the 
database contains complete information--and includes data on every 
system that is required to test for lead in a particular period-- 
because the frequency of required testing can vary depending on whether 
a system has qualified for reduced monitoring (and maintains that 
status in future periods). The same circumstances also make it 
difficult to develop trend data. EPA and state officials indicated that 
the January 2000 minor revisions to the lead rule, which made 
significant changes in states' reporting requirements, exacerbated 
existing problems with the transfer of accurate and timely data from 
the states to EPA. For that and other reasons, modifying the states' 
data systems to incorporate the new reporting milestones has been 
delayed. In addition to problems with the structure of the information 
systems--and technical problems in actually transferring data from the 
states to EPA--EPA and state officials acknowledge that reporting water 
systems' milestone data has been a low priority. The officials 
explained that since January 2004, states have been focusing their 
limited resources on reporting the 90th percentile test results for 
large and medium water systems. 

EPA and the Association of State Drinking Water Administrators have 
been working on a Safe Drinking Water Information System modernization 
effort that should address at least some of current data problems, 
according to EPA officials. Among other things, the modernization will 
make it easier to transfer data between states and EPA so EPA's data 
will be more timely. To improve the accuracy of the data, EPA's system 
will have a component designed to validate state data before it is 
entered into the federal database. As of October 2005, EPA had 
completed the transition to its modernized system for the entry of new 
data. 

Weaknesses in the Regulatory Framework for the Lead Rule May Undermine 
Public Health Protection: 

Based on their experiences in implementing the lead rule, EPA, state, 
and water system officials have identified six aspects of the rule for 
which oversight could be improved or the requirements modified to 
increase public health protection. Specifically, their experiences 
indicate that (1) the sampling sites used for lead testing may no 
longer reflect areas of highest risk, (2) reduced monitoring may not be 
appropriate in some instances, (3) the homeowners who participate in 
tap monitoring may not be informed of the test results, (4) controls 
over when and how treatment changes are implemented may not be 
adequate, (5) data on the effectiveness of lead service line 
replacement programs are limited, and (6) states vary in how they apply 
the lead rule when water systems sell drinking water to other systems. 
In addition, some of the officials responsible for implementing the 
lead rule and other drinking water experts believe that existing 
standards for plumbing fixtures may be outdated. EPA is considering 
modifications to the lead rule that will address some of the problems 
we identified. 

Sampling Sites May No Longer Reflect Areas of Highest Risk: 

Under the lead rule, water systems must select sampling sites that are 
considered to be at high risk for contamination. The rule defines Tier 
1 sites as single-family structures served by lead service lines, 
and/or containing lead pipes (or copper pipes with lead solder 
installed after 1982).[Footnote 22] According to participants in EPA's 
workshop on monitoring protocols and state officials we interviewed, 
one problem is that EPA has never updated its site selection criteria 
and at least one of the criteria is outdated. Specifically, enough time 
has elapsed so that lead solder in plumbing installed from 1983 to 1986 
is no longer "fresh" (lead solder was banned in 1986). Experts believe 
that, by now, solder from that period has been coated by a naturally 
occurring film that prevents lead leaching. Moving the sampling sites 
to other Tier 1 locations--for example, homes served by lead service 
lines--could be problematic. In the preamble to the lead rule, issued 
in 1991, EPA cited a survey by the American Water Works Association 
which estimated that only about 20 percent of the nation's community 
water systems have lead service lines. Moreover, although the lead rule 
required water systems to do a "materials evaluation" to identify an 
adequate pool of high risk sampling sites, according to EPA the 
evaluation did not assess pipe materials system-wide, and many systems 
do not have a complete inventory of their service lines. 

A related problem is that sampling locations have likely changed over 
time as sites are no longer available or appropriate, and states may 
not have procedures in place to ensure that these locations continue to 
represent the highest risk sites.[Footnote 23] In this regard, EPA 
requested information from the states on how they "ensure that site 
locations were correctly followed during system sampling rounds." As 
table 4 shows, a significant number of states may not be tracking 
changes in water systems' sampling locations. 

Table 4: State Activities to Ensure that Water Systems Are Taking Lead 
Samples at Appropriate Sites: 

Activity: State uses tracking mechanisms such as special forms or 
unique codes to control sampling sites; 
Number of states: 14. 

Activity: State reported a less rigorous or less defined means of 
oversight[A]; 
Number of states: 11. 

Activity: State requires notification when systems change sampling 
locations but does not otherwise track sampling; 
Number of states: 5. 

Activity: State does not review or track sampling[B]; 
Number of states: 8. 

Activity: State did not answer question or provided information that 
was nonresponsive; 
Number of states: 12. 

Source: GAO analysis of EPA's information request on state 
implementation policies and practices. 

[A] For example, some states reported comparing the actual sampling 
locations with the sampling plans, some said that they advise their 
systems to continue sampling at the locations used during the initial 
sampling rounds, and others reported "reviewing" each round of sampling 
but did not mention comparing the sites to the sampling plans. 

[B] Two of these states (California and Vermont) reported that they 
lacked the resources to ensure that their water systems are taking 
samples at the correct locations. 

[End of table] 

Another uncertainty is whether systems that are on reduced monitoring-
-and have been allowed to reduce the number of samples they collect-- 
are taking samples from locations that represent the highest risk sites 
based on previous testing.[Footnote 24] According to the lead rule, 
these water systems must take their samples from sites included in the 
pool of high risk sampling sites identified initially. Although the 
systems have some indication of which sites within the pool have 
historically tested at higher or lower lead levels, the rule is silent 
on how sites within the pool are to be selected for reduced monitoring, 
except that they must be "representative" of the sites required for 
standard monitoring. In addition, the rule provides that states may 
specify the sampling locations. EPA requested information from the 
states on what role they play in selecting the sites used for reduced 
monitoring. We analyzed the states' responses and found that, in most 
instances, the states' role is limited; table 5 summarizes the results 
of our analysis. 

Table 5: State Role in Selecting Sites for Reduced Monitoring: 

Activity: State requires that highest risk sites, based on previous 
test results, are selected; 
Number of states: 3. 

Activity: State policy ensures that some of the highest risk sites, 
based on previous test results, are selected[A]; 
Number of states: 9. 

Activity: State provides general guidance and may review the water 
systems' selections[B]; 
Number of states: 19. 

Activity: State plays no role in selecting sites for reduced 
monitoring; 
Number of states: 12. 

Activity: State did not answer question or provided information that 
was nonresponsive; 
Number of states: 7. 

Activity: Total; 
Number of states: 50. 

Source: GAO analysis of EPA's information request on state 
implementation policies and practices. 

[A] Among other things, some states require systems to select every 
other sampling site after ranking the sites by result from prior 
testing or alternate sites in each round of sampling. 

[B] For example, many of these states instruct their water systems to 
focus on Tier 1 sites first (if their sampling pool also contains Tier 
2 or Tier 3 sites) or say that the sites must be representative of 
those in the pool or of the distribution system. 

[End of table] 

Reduced Monitoring May Not Be Appropriate in Some Instances: 

According to EPA's lead rule, small and medium-sized water systems 
whose test results are consistently at or below the action level may 
reduce the frequency of monitoring from once every 6 months to annually 
and, if acceptable results continue, to once every 3 years.[Footnote 
25] In addition, systems of any size that operate within water quality 
control parameters reflecting optimal corrosion control treatment, as 
specified by the state, may reduce the frequency of monitoring under 
the same schedule.[Footnote 26] The rule also lays out conditions under 
which water systems must return to standard monitoring--for example, 
small and medium-sized systems that have exceeded the action level. In 
addition, states have the flexibility to require systems to resume 
standard monitoring if the state deems it to be appropriate.[Footnote 
27] We analyzed EPA's compliance data and found some instances that 
raise questions about the states' decisions to allow reduced 
monitoring. Specifically, we found that 49 large and medium water 
systems were exceeding the 15-parts-per-billion action level and 
appeared to be on reduced monitoring schedules.[Footnote 28] In 
addition, our analysis indicates that 104 large and medium systems with 
lead levels of 13-15 parts per billion also appear to be on reduced 
monitoring schedules. Although this is allowable under EPA's 
regulations, according to some state officials, systems with lead 
levels just below the action level should be subject to closer scrutiny 
and, thus, may not be good candidates for reduced monitoring. 

To determine how states exercised their discretion with regard to 
monitoring frequency, we reviewed their responses to EPA's information 
request, which asked the states to describe how they determine if 
reduced monitoring is appropriate. According to their responses, the 
states by and large adhere to the requirements of the lead rule and 
allow reduced monitoring whenever a water system's test results are at 
or below the action level in consecutive monitoring periods.[Footnote 
29] Specifically, 40 states reported that they follow the federal 
regulation, 6 states indicated that they may be using some additional 
criteria for their reduced monitoring determinations,[Footnote 30] and 
4 states did not answer or provided information that was nonresponsive. 
EPA did not ask for the states' views on whether reduced monitoring is 
appropriate when a water system's test results are at or just below the 
action level or on circumstances in which states might determine that 
previously approved reduced monitoring is no longer appropriate--and 
the states did not volunteer such information. None of the states 
reported using other criteria, such as test results that are at or just 
below the action level, to delay or rescind approval for reduced 
monitoring. 

A key issue is whether water systems should be required to resume 
standard monitoring following a major treatment change so that the 
potential effects of the change can be evaluated. Given the 
circumstances in which lead contamination became a problem in the 
District of Columbia, when a change in the system's disinfection 
treatment impaired the effectiveness of corrosion control, such 
decisions can be critical. In its information request on state 
implementation policies and practices, EPA asked the states whether 
they had ever required a system to conduct more frequent monitoring to 
evaluate the potential effects of a treatment change. It would have 
been useful to know more about the states' policies and practices in 
this regard, including how often the states required additional 
monitoring and the criteria they used in making such determinations. 
However, EPA's question was limited in scope and, as table 6 shows, the 
states often did not elaborate. 

Table 6: States That Require More Frequent Monitoring to Evaluate the 
Effects of Treatment Changes: 

State policy: States answered yes without elaborating on the frequency 
of--or criteria for--such decisions; 
Number of states: 11. 

State policy: States answered yes and included some indication of how 
often they required additional monitoring (7 states) or the criteria 
used for these decisions (5 states)[A]; 
Number of states: 12. 

State policy: State answer was ambiguous; it is unclear whether state 
has ever required more frequent monitoring after a treatment change[B]; 
Number of states: 7. 

State policy: States answered no, generally without elaboration[C]; 
Number of states: 16. 

State policy: States did not answer question or provided information 
that was nonresponsive[D]; 
Number of states: 4. 

State policy: Total; 
Number of states: 50. 

Source: GAO analysis of EPA's information request on state 
implementation policies and practices. 

[A] For example, two states indicated that requiring more frequent 
monitoring was relatively common, while others reported that it was 
required in certain instances or occasionally. Examples of criteria for 
more frequent monitoring include (1) test results following a treatment 
change that are close to the lead action level and (2) installing 
treatment that is designed or expected to change water quality. 

[B] Responses from these states referred to state regulations or policy 
(e.g., "this is embedded in the approval process") but did not directly 
answer the question of whether the state had ever required a system to 
conduct more frequent monitoring. In several instances, it seems likely 
that water systems have been required to monitor following a treatment 
change. 

[C] Several states indicated that additional monitoring was recommended 
or encouraged following a treatment change but not required. 

[D] Two states did not answer the question and the responses from the 
other two states only addressed monitoring requirements following 
changes to corrosion control treatment. 

[End of table] 

In our discussions with 10 states, we found a variety of policies and 
practices regarding reduced monitoring. For example, officials from 
California and New York told us that they do not approve reduced 
monitoring--or are reluctant to do so--when water systems' test results 
are close to the lead action level. On the other hand, Connecticut and 
Massachusetts officials indicated that they have systems that are on 
reduced monitoring despite test results close to the action level. 
Several other states indicated that, in the case of large water 
systems, approval for reduced monitoring is linked to whether the 
systems are meeting their water quality parameters--not the results of 
lead monitoring. On the issue of monitoring following a major treatment 
change, some participants at EPA's monitoring workshop stated that 
standard compliance monitoring does not adequately evaluate the impact 
of treatment changes and that monitoring immediately after major 
changes should be required. Several of the states we contacted also 
favor increased monitoring under these circumstances; Florida and New 
York, for example, require systems to return to semi-annual monitoring 
following a treatment change. Pennsylvania officials agree that the 
state and water system should revisit the treatment approach when 
monitoring results indicate that a treatment change is affecting water 
chemistry. However, the officials acknowledged that they may not find 
out about the impact of treatment changes in a timely manner when water 
systems are on a triennial monitoring schedule. 

Homeowners Who Participate in Periodic Tap Sampling May Not Be Notified 
of the Test Results: 

According to EPA's information request on state implementation policies 
and practices, only two states require their water systems to notify 
homeowners of the results of lead testing--Texas (only when results 
exceed the action level) and Wisconsin. At least 17 other states 
indicated that notification may be occurring voluntarily to varying 
degrees. Table 7 summarizes the results of our analysis. 

Table 7: State Views on Extent to Which Water Systems Are Notifying 
Homeowners of the Results of Lead Testing: 

Extent of notification: All systems notify homeowners; 
Number of states: 1. 

Extent of notification: Some systems notify homeowners[A]; 
Number of states: 15. 

Extent of notification: Test results are provided only on request; 
Number of states: 2. 

Extent of notification: State is not aware of any systems that notify 
homeowners; 
Number of states: 6. 

Extent of notification: State does not know what systems are doing[B]; 
Number of states: 18. 

Extent of notification: State apparently misinterpreted EPA's 
question[C]; 
Number of states: 8. 

Extent of notification: Total; 
Number of states: 50. 

Source: GAO analysis of EPA's information request on state 
implementation policies and practices. 

[A] The states' answers varied considerably. For example, some states 
indicated that their larger water systems are providing results to 
homeowners and some indicated that homeowners got the results only if 
they exceeded the action level. 

[B] In a few instances, the states indicated that they recommended that 
their water systems provide homeowners with test results. For example, 
Hawaii recommends notifying the homeowner if test results exceed 100 
parts per billion, both to alert the homeowner and to verify that the 
sampling protocol was followed correctly. However, the states in this 
category did not have information on whether homeowners were actually 
getting test results. 

[C] EPA asked if water systems provide homeowners with the lead 
sampling results derived from "any volunteer sampling program." Based 
on their answers, it appears that these states may have believed that 
EPA was asking about any testing above and beyond the regular sampling 
program involving residential tap samples. For example, several states 
said that they were not aware of any systems performing volunteer 
sampling programs and others indicated that their systems will conduct 
lead testing for homeowners on request. 

[End of table] 

Controls over When and How Treatment Changes Are Implemented May Not Be 
Adequate: 

In some instances, changes to other treatment processes can make 
corrosion control less effective. According to EPA, state, and industry 
officials, one of the biggest challenges in implementing the lead rule 
is achieving "simultaneous compliance" with other rules, including, in 
particular, rules related to total coliform bacteria, surface water 
treatment, and disinfection by-products. Changing the type of 
disinfectant a system uses to control bacteria, for example, can impair 
the effectiveness of a system's corrosion control treatment to prevent 
lead contamination. Among other things, states assuming primary 
enforcement responsibility must have a process for ensuring that the 
design and construction of new or substantially modified water system 
facilities will be capable of meeting drinking water regulations, 
including the lead rule.[Footnote 31] In addition, in its minor 
revisions to the lead rule, EPA added a requirement that certain water 
systems must notify the state no later than 60 days after making a 
change in water treatment.[Footnote 32] However, the responses to EPA's 
information request raise questions about the nature and extent of 
states' reviews of treatment changes. On the one hand, 31 states 
indicated that they had some type of proactive process to review or 
evaluate treatment changes, before or after the treatment was 
installed, including 15 states that reported requiring some or all of 
the affected water systems to provide information on the potential 
effects of treatment changes on corrosion control.[Footnote 33] On the 
other hand, it appears that in at least 15 states, the plan review 
process may be limited, or the states may not be receiving 
notifications from all their water systems. For example, some states 
indicated that their review process only covers changes to a system's 
physical infrastructure--or specifically excludes changes in the 
chemicals used in a process. Other states reported that they are not 
learning of some treatment changes until they conduct comprehensive 
inspections of the water systems, or that small systems in particular 
are not notifying the state when they change their treatment processes. 

Some of the participants in EPA's May 2004 workshop on simultaneous 
compliance cited a need for additional regulations or guidance to help 
ensure that the effectiveness of corrosion control is maintained when 
water systems make changes to other treatment processes. For example, 
some participants suggested that the lead rule should better define or 
even specify the types of treatment changes that (1) should be reported 
to the state and (2) trigger additional monitoring or analysis. Along 
those lines, Washington state officials told us that certain changes, 
such as switching the disinfectant from chlorine to chloramines or 
making adjustments that affect the water's pH or alkalinity, may 
warrant closer review because of the potential impact on corrosion 
control. The officials also noted that additional guidance from EPA on 
these matters would be helpful. Others believe that small water 
systems, in particular, need more guidance on the potential effects of 
various treatment changes, and that operator certification and training 
programs should be updated to address these topics. 

Data on the Effectiveness of Lead Service Line Replacement Programs Are 
Limited: 

Under the lead rule, drinking water systems may be required to replace 
lead service lines if test results exceed the action level after 
installing corrosion control and/or source water treatment. Some of the 
participants in an EPA workshop on lead service line replacement and 
state officials we contacted raised questions about the effectiveness 
of replacement programs, in part because such programs often result in 
partial replacement only. Water systems are responsible for replacing 
only the portion of the service lines they own. While residential 
customers may, at their option, pay the cost of replacing the rest of 
the service line--typically, the portion running from the curb stop or 
property line to the household plumbing system--some evidence suggests 
that customer participation in such programs is generally low. 

According to workshop participants, little conclusive information is 
available on the extent to which removing lead service lines lowers 
lead levels at the tap. In a survey of water systems conducted for the 
American Water Works Association, 18 of 27 respondents indicated that 
lead service lines were not responsible for the highest levels of lead 
in drinking water, and 20 of 29 respondents reported no observed 
linkage between lead service lines and lead levels in drinking 
water.[Footnote 34] However, the survey did not include information on 
test results before and after replacement of lead service lines. The 
American Water Works Association Research Foundation is sponsoring a 
study of the relative contributions of service lines and plumbing 
fixtures to lead levels at the tap; the projected completion is fall 
2008. 

The limited data on the extent and results of lead service line 
replacement programs make it difficult to draw conclusions about the 
programs' effectiveness or the need for additional regulations or 
guidance. As noted earlier, EPA's data on corrective action milestones-
-including the LSLR milestone--are incomplete. Moreover, few states 
reported requiring systems to replace lead service lines in response to 
EPA's information request on state implementation policies and 
practices. Specifically, when asked if they have any systems that have 
been required to do lead service line replacement, five states answered 
"yes" without elaborating and seven states reported a total of 27 water 
systems that are (or were) replacing lead lines.[Footnote 35] In 
addition, although the lead rule requires testing following partial 
service line replacement, it appears that neither the states nor EPA 
are collecting and analyzing these test results. EPA asked states to 
describe the process they use to ensure that water systems are 
following the requirements for lead service line replacement. Among 
other things, the lead rule requires systems to collect samples within 
72 hours following partial replacement and to notify homeowners and 
occupants of the results. States may waive the requirement that these 
test results also be provided to the states. Of the 12 states that 
reported requiring one or more water systems to replace lead service 
lines, only one indicated that its water systems might be required to 
report the results of service line testing to the state.[Footnote 36] 

Some of the officials we contacted raised concerns about whether the 
benefits of replacement are enough to justify what can be a significant 
investment. For example, Iowa drinking water officials commented that 
partial replacement is not a good use of resources because it disturbs 
the line, releasing lead particulate matter into the water, and still 
leaves half the lead line in place. In addition, officials from the 
Syracuse Water Department told us that they are planning to replace 
lead service lines at a cost of $5.3 million, although they are 
skeptical that the effort will significantly reduce lead levels, citing 
the age of the housing stock and lead contributions from internal 
residential plumbing. The officials attribute the city's problem with 
elevated lead levels to a simultaneous compliance issue. Specifically, 
adding a phosphate-based corrosion inhibitor to further reduce the 
corrosiveness of the drinking water solves one problem but creates 
another: excessive phosphates in the system's discharges to a local 
lake. 

Participants at EPA's workshop on lead service line replacement and 
some of the state and water industry officials we contacted suggested 
measures to help ensure that water systems maximize the potential 
benefits of replacement efforts. For example, some workshop 
participants called for EPA guidance on strategies to encourage full 
service line replacement and motivate customers to have their portion 
of the line removed. Such strategies might include subsidizing a 
portion of the replacement cost, offering low interest loans or 
property tax relief, requiring disclosure of lead service lines in 
property sales, or providing more information on the health effects of 
exposure to lead in drinking water. Others suggested that prioritizing 
the replacement of lead service lines would help ensure that 
replacement activities focus on the populations most at risk from 
exposure to elevated lead levels. Some utilities are already 
prioritizing service line replacement using criteria such as locations 
with vulnerable populations, including schools and child care 
facilities, locations where test results have exceeded the action 
level, and lines serving 20 or more people in an 8-hour day. 

States Vary in How They Apply the Lead Rule When Water Systems Sell 
Drinking Water to Other Systems: 

We found some differences among the states in how interconnected water 
systems--generally comprising a system that sells drinking water along 
with one or more systems that buy the water--are required to monitor 
for lead and report the results. According to EPA's proposed 
definitions, these interconnected water systems are known as "combined 
water distribution systems."[Footnote 37] The variations in state 
implementation practices create differences in the level of public 
information and, potentially, public health protection. Combined 
distribution systems account for a large and growing share of the 
nation's community water systems so differences in how they implement 
the lead rule could have broad implications for public health 
protection. Overall, EPA estimates that there are currently about 2,800 
combined distribution systems that encompass about 13,900 individual 
systems, likely accounting for a significant share of all community 
water systems.[Footnote 38] Under EPA regulations that establish 
general requirements for drinking water monitoring, states may modify 
the monitoring requirements imposed on combined distribution systems-- 
typically by reducing the number of samples required within the 
combined system--"to the extent that the interconnection of the systems 
justifies treating them as a single system for monitoring 
purposes."[Footnote 39] However, in the case of the lead rule, EPA 
strongly discouraged such modifications, commenting that they would not 
be appropriate because the primary source of elevated lead levels at 
the tap is materials within the distribution system. 

At least four of the states we contacted--Massachusetts, Michigan, 
Oregon, and Washington--approved modified sampling arrangements at 
combined distribution systems. For example, the Massachusetts Water 
Resources Authority, which supplies all of the drinking water for 30 
communities,[Footnote 40] currently takes lead samples at 440 locations 
under its modified sampling arrangement--significantly fewer than the 
1,720 samples that would be required if each of the consecutive systems 
tested for lead individually. On the other hand, if the combined 
distribution system represented a single water system, only 100 samples 
would be required. 

EPA does not have comprehensive information on the extent to which 
states are approving modified sampling arrangements at combined 
distribution systems--or the reporting practices used by such systems. 
As table 8 shows, we found differences in how combined distribution 
systems calculated and reported their 90th percentile test results. 

Table 8: Examples of Different Reporting Practices for Lead Testing in 
Combined Water Distribution Systems as of June 2005: 

Water wholesaler: Detroit, MI; 
Number of consecutive systems fully supplied by the wholesaler[A]: 72; 
How the systems are listed in EPA's database: Wholesaler and each 
consecutive system are listed separately; 
How the 90th percentile lead levels are calculated and reported in 
EPA's database: Separate lead level calculations for the wholesaler and 
each consecutive system. 

Water wholesaler: Massachusetts Water Resources Authority (MA); 
Number of consecutive systems fully supplied by the wholesaler[A]: 30; 
How the systems are listed in EPA's database: One listing for the 
combined distribution system (including the wholesaler and the 
consecutive systems); 
How the 90th percentile lead levels are calculated and reported in 
EPA's database: One overall result, reported for the combined 
distribution system. 

Water wholesaler: Philadelphia, PA; 
Number of consecutive systems fully supplied by the wholesaler[A]: 3; 
How the systems are listed in EPA's database: Wholesaler and each 
consecutive system are listed separately; 
How the 90th percentile lead levels are calculated and reported in 
EPA's database: Separate lead level calculations for the wholesaler and 
each consecutive system. 

Water wholesaler: Portland, OR; 
Number of consecutive systems fully supplied by the wholesaler[A]: 15; 
How the systems are listed in EPA's database: Wholesaler and each 
consecutive system are listed separately; 
How the 90th percentile lead levels are calculated and reported in 
EPA's database: One overall result; same 90th percentile reported for 
wholesaler and each consecutive system. 

Water wholesaler: Seattle, WA; 
Number of consecutive systems fully supplied by the wholesaler[A]: 19; 
How the systems are listed in EPA's database: One listing for the 
combined distribution system (including the wholesaler and the 
consecutive systems); 
How the 90th percentile lead levels are calculated and reported in 
EPA's database: One overall result, reported for the combined 
distribution system. 

Source: GAO analysis of data from EPA and the wholesaler water systems. 

[A] The water wholesalers may also partially supply other systems or 
provide emergency supplies, and may sell water to certain non- 
transient, noncommunity water systems--systems that serve at least 25 
people for more than 6 months in a year--and generally are subject to 
the same requirements as community water systems. 

[End of table] 

Not only do the reporting practices approved by the states affect the 
amount of information available to the public--they can also have 
implications for the corrective actions that are taken to reduce lead 
levels. For example, reporting one overall result for lead testing can 
be misleading if the 90th percentile levels at individual consecutive 
systems would have exceeded the action level. In the case of the 
Massachusetts Water Resources Authority, although EPA's database 
contains the overall result for the combined system, authority 
officials calculated the 90th percentile results for each of the 
consecutive systems and determined that lead concentrations at some of 
them exceeded the action level.[Footnote 41] State officials in 
Massachusetts told us that until recently, none of the consecutive 
systems whose individual test results exceeded the action level were 
required to meet public notification or public education requirements 
or to replace lead service lines--as long as the result for the 
combined system met the action level. Although EPA regional officials 
concurred with such arrangements when they were first established, EPA 
is now considering how to ensure that the lead rule requirements will 
be applied to each community within a combined distribution system. 
Based on discussions with EPA regional officials, Massachusetts has 
already changed its policy and will be revisiting agreements with 
combined distribution systems. 

Outdated Plumbing Standards Hinder Efforts to Reduce Exposure to Lead 
in Drinking Water: 

The standards applicable to plumbing products are important to utility 
managers who are responsible for ensuring the quality of water at the 
tap but have little control over household plumbing. However, existing 
standards may not be protective enough, according to some experts, 
because testing has determined that some of the products defined as 
"lead-free" under the Safe Drinking Water Act can still contribute high 
levels of lead to drinking water. For example, although the act 
prohibits the use of solder or other plumbing materials in the 
installation or repair of any public water system if it is not lead- 
free, lead-free is defined to include materials that contain small 
amounts of lead. That is, solders and flux may contain up to 0.2 
percent lead, pipes and pipe fittings may contain up to 8 percent lead. 
In addition, plumbing fittings and fixtures may leach lead up to 11 
parts per billion into drinking water and still be deemed lead-free, 
according to voluntary standards established by an independent 
organization and accepted by EPA.[Footnote 42] 

NSF International (NSF)--a not-for-profit, non-governmental 
organization involved in standards development and product 
certification--established the standard in 1997.[Footnote 43] NSF used 
a voluntary consensus process that included representatives from 
regulatory agencies, industry, water suppliers, consultants, and other 
users of the products governed by the standard. 

One problem with the current regulatory framework is that certain 
devices used in or near residential plumbing systems are not covered by 
all standards for lead-free plumbing. Table 9 shows how the standards 
governing lead content and lead leaching apply to specific categories 
of products. 

Table 9: Applicability of Standards for Lead-Free Plumbing Products: 

Type of plumbing product: Endpoint devices, such as kitchen and 
lavatory faucets, water dispensers, drinking fountains, and residential 
refrigerator ice makers[A]. 
8% limit on lead content; 
11 ppb limit on lead leaching. 

Type of plumbing product: In-line devices, such as meters and 
valves[B]. 
8% limit on lead content. 

Source: EPA and NSF International. 

[A] NSF defines endpoint devices as mechanical plumbing devices, 
components, and materials that are typically installed with the last 
liter of the distribution system and are intended by the manufacturer 
to dispense water for human consumption. 

[B] NSF defines in-line devices as devices installed on a service line 
of building distribution system downstream of the water main and before 
endpoint devices. They include devices in a building used to measure or 
control the flow of water in treatment, transmission, or distribution 
systems and are in contact with drinking water. 

[End of table] 

Some of the products that are not covered by the voluntary leaching 
standard have been found to contribute high levels of lead to drinking 
water during testing. For example, tests conducted by NSF indicate that 
certain meters and valves may contribute high levels of lead to 
drinking water. At our request, NSF compiled test results for a 
nonprobability sample of water meters and valves that had been 
submitted for evaluation. While all of the products in the sample were 
well below the 8 percent limit on lead content, the test results showed 
that the amount of lead leached from the selected water meters ranged 
from 0.4 parts per billion up to 39 parts per billion and, in the case 
of valves, ranged from a low of 4.1 parts per billion to as much as 530 
parts per billion. An NSF official commented that although these 
products are representative of what is submitted to NSF for testing, 
they are probably not representative of what is available in the 
marketplace because some manufacturers have two product lines--a low- 
lead line for buyers who specify products that meet NSF Standard 61 and 
a higher-leaded line for other buyers. 

Another issue is that NSF's testing protocol for lead leaching may not 
accurately reflect actual conditions and may need to be modified. One 
recent study identified several aspects of NSF's testing protocol that 
should be reevaluated, including, for example, the chemistry of the 
water in which tests are conducted. After demonstrating that 
potentially unsafe devices could pass NSF's test, the study concluded 
that the protocol "lacks the rigor necessary to prevent installation of 
devices that pose an obvious public health hazard."[Footnote 44] NSF 
officials told us that they are aware of the concerns and have already 
made some clarifications and changes to the protocol. NSF has also 
established a task force, the Drinking Water Additives Joint Committee, 
which will be reviewing the protectiveness of NSF Standard 61 and 
related testing. 

Representatives of NSF, water utilities, and researchers also took 
issue with the standard for lead content, noting that it has not been 
updated to reflect current manufacturing capabilities and practices. 
According to the American Water Works Association, manufacturing 
technology in the plumbing industry has improved since the lead-free 
definition was established nearly 20 years ago, and today's plumbing 
products contain less lead as a result. Data on the lead content of 
plumbing products voluntarily submitted to NSF for evaluation, shown in 
table 10, suggest that manufacturers can produce products with lead 
levels well below the 8 percent standard. 

Table 10: Summary of NSF Test Results Regarding Lead Content of 
Plumbing Products Voluntarily Submitted to NSF for Certification: 

Lead content: 1.0% or less; 
Results of testing on faucets: Cumulative number: 2,069; 
Results of testing on faucets: Cumulative percent: 37.3; 
Results of testing on meters and valves: Cumulative number: 930; 
Results of testing on meters and valves: Cumulative percent: 75.1. 

Lead content: 3.7% or less; 
Results of testing on faucets: Cumulative number: 5,495; 
Results of testing on faucets: Cumulative percent: 99.0; 
Results of testing on meters and valves: Cumulative number: 1,104; 
Results of testing on meters and valves: Cumulative percent: 89.1. 

Lead content: 8.0% or less; 
Results of testing on faucets: Cumulative number: 5,551; 
Results of testing on faucets: Cumulative percent: 100.0; 
Results of testing on meters and valves: Cumulative number: 1,236; 
Results of testing on meters and valves: Cumulative percent: 99.8. 

Total products tested; 
Results of testing on faucets: Cumulative number: 5,551; 
Results of testing on faucets: Cumulative percent: 100.0; 
Results of testing on meters and valves: Cumulative number: 1,239; 
Results of testing on meters and valves: Cumulative percent: 100.0. 

Source: NSF. 

Note: This table contains cumulative data on the number and percent 
lead content of faucets, meters, and valves voluntarily submitted to 
NSF for certification. The data should not be generalized beyond this 
group. 

[End of table] 

According to NSF, the extent to which lead leaches from products 
containing lead is not directly proportional to the level of lead used 
in any one alloy contained in the product.[Footnote 45] NSF identified 
several factors that contribute to the level of leaching, including the 
corrosiveness of the water, lead content, the extent of the leaded 
surface area, and the process used to manufacture the product. However, 
the state regulators, water industry representatives, and other experts 
we interviewed generally agreed that lowering the existing standard for 
lead content is feasible and would provide an extra margin of safety. 
Both the Copper Development Association and the Plumbing Manufacturers 
Institute acknowledged that most plumbing products are below the 8 
percent limit on lead content but prefer that plumbing standards focus 
on performance--the leaching of lead--rather than content. 

We did not attempt to determine the extent to which the standards for 
lead-free plumbing products are enforced. According to NSF, the use of 
plumbing products within a building is generally regulated at the 
state, county, and city levels through plumbing codes. NSF 
representatives also said that all model plumbing codes reference NSF 
Standard 61 for pipes, fittings, and faucets.[Footnote 46] NSF reports 
that most faucets sold at the retail and wholesale level are certified 
to meet Standard 61, but fewer valves and other in-line devices are 
certified to the standard because it is not required in model plumbing 
codes. 

State efforts to implement more stringent standards for plumbing 
products appear limited, based on our discussions with federal and 
state regulators and representatives of the water industry and plumbing 
manufacturers. We identified two states in which such activities have 
occurred: 

* In California, the Attorney General sued 16 manufacturers and 
distributors of kitchen and bathroom faucets in the early 1990s, 
alleging that lead leaching from brass components of their faucets 
violated California law.[Footnote 47] The suit resulted in settlement 
agreements with the companies and a related court decision in which 
they agreed to reduce leaching levels. According to an official with 
the California Attorney General's Office, the limit on lead leaching is 
5 parts per billion for residential kitchen faucets and 11 parts per 
billion for all other faucets. 

* According to officials with the Massachusetts Board of State 
Examiners of Plumbers and Gas Fitters, in 1995 the board established a 
3 percent limit on the lead content of endpoint and in-line devices 
installed inside the home. Board officials acknowledge that enforcement 
of the standard is difficult because products containing more than 3 
percent lead may be sold in Massachusetts stores as long as the 
products are not installed in Massachusetts homes. Moreover, the 
packaging does not indicate lead content or certification to the state 
standard. 

At the local level, some water systems are installing no-lead meters-- 
which contain less than 0.25 percent lead--because of concerns about 
the potential impact of leaded brass meters on lead levels at the tap. 
In some instances, the water systems are targeting their meter 
replacement to buildings housing schools and child care facilities. 

EPA Is Considering Modifications to the Lead Rule to Address Some 
Problem Areas: 

Based on its year-long evaluation of the lead rule and how it is being 
implemented, EPA concluded that the conditions that led to elevated 
lead levels in the District of Columbia were not indicative of the 
conditions nationwide. However, in November 2004, while its evaluation 
was still ongoing, EPA issued a guidance memorandum to reiterate and 
clarify specific regulatory requirements after the agency's review of 
state programs and some press reports identified inconsistencies in how 
drinking water systems and the states were carrying out the regulation. 
The memorandum focused on requirements related to collecting samples 
and calculating compliance. In addition, in March 2005, EPA announced a 
Drinking Water Lead Reduction Plan to improve and clarify specific 
areas of the rule and the agency's guidance materials. The plan 
identifies nine targeted revisions of the regulations and updates to 
two guidance documents. 

Specifically, EPA's lead reduction plan calls for regulatory revisions 
to the following: 

* Monitoring requirements. These revisions would (1) clarify the number 
of samples required, (2) clarify the number of locations from which 
samples should be collected, (3) modify definitions of "monitoring 
period" and "compliance period," (4) clarify the requirement to take 
all samples within the same calendar year, and (5) reconsider allowing 
large water systems that exceed the lead action level to qualify for 
reduced monitoring as long as their test results for water quality 
parameters are within acceptable limits. 

* Treatment requirements. These revisions would require water systems 
to notify the state of treatment changes 60 days prior to the change 
rather than within 60 days following the change. 

* Customer awareness requirements. These revisions would (1) require 
water systems to disclose test results to homeowners and occupants who 
participate in tap monitoring programs and (2) permit states to allow 
water systems to modify flushing instructions--the amount of time that 
homeowners are advised to run water before using it--to address local 
circumstances. 

* Lead service line replacement requirements. These revisions would 
require water systems to reevaluate lead service lines that previously 
"tested out" of the replacement program as a result of low lead levels 
if a subsequent treatment change causes the systems to exceed the 
action level.[Footnote 48] 

In addition, EPA is considering updating its 1994 guidance on lead in 
drinking water in schools and non-residential buildings, along with its 
1999 guidance on simultaneous compliance. 

So far, EPA has not released additional details on the nature of the 
changes being considered in some areas (e.g., number of samples and 
sampling locations) or what prompted its determination that revisions 
to the lead rule and related guidance might be warranted. An EPA 
workgroup, which was established when the lead reduction plan was 
issued, is developing the proposed rule for the regulatory changes, 
with a goal of releasing a proposal in late 2005 or early 2006. 
Revisions to the guidance documents are scheduled to be completed about 
the same time. 

While the exact nature of some changes has yet to be defined, we asked 
the 10 states we contacted for their views on whether the proposed 
revisions would improve implementation of the lead rule. For the most 
part, state officials were in favor of the proposed changes involving 
the monitoring protocols. Although they wanted more details on how the 
requirements would be revised, they believed the changes to be 
relatively minor. In particular, most state officials agreed that large 
water systems that exceed the action level should not be allowed to 
reduce the frequency of lead monitoring based solely on their ability 
to meet water quality parameters. 

Regarding earlier notification of treatment changes, officials from all 
10 states we contacted supported such a revision, particularly for 
major treatment changes. The officials indicated that the notification 
requirement would not have a significant impact on their own practices 
because each of the states already had some type of process in place to 
permit or review treatment changes. Five of the states questioned 
whether 60 days advance notice would be sufficient to allow an adequate 
review. Several states suggested that EPA should require expedited 
monitoring of lead levels following major treatment changes--or issue 
guidance on when it would be appropriate for states to require such 
monitoring--and that EPA should issue guidance on what constitutes a 
major treatment change. In addition, officials from two states 
commented that EPA should require state approval of the treatment 
changes in addition to advance notification. 

On the proposed revisions involving customer awareness, all 10 states 
agreed that homeowners that participate in the tap sampling program 
should be informed of the test results--particularly if the results for 
individual homeowners exceed the lead action level--whether or not the 
90th percentile result for the entire system exceeds the action level. 
One state was concerned about the additional resources that would be 
required to track the water systems' actions. Nearly all of the states 
also endorsed the proposal to give states and water systems more 
flexibility in determining what flushing instructions are appropriate 
in particular situations. Some states suggested that EPA guidance on 
making such determinations would be useful. 

Regarding the proposed reevaluation of lead service lines that tested 
out of a replacement program, the states' views were mixed. Although 
five states generally endorsed the idea, the other five states raised 
several concerns, including the potential cost to local drinking water 
systems, the administrative burden that such a requirement would impose 
on states, and the need for more specific information on the types of 
treatment changes that would trigger a reevaluation of lead service 
lines. 

Over the long term, EPA plans to examine other issues related to lead 
rule implementation that may need to be addressed through regulation or 
guidance. EPA officials have indicated that, in some instances, they 
need more information to determine whether changes are warranted, and 
they are in the process of collecting and analyzing data, or have 
relevant research projects underway. According to EPA officials, some 
of the issues they plan to review include the sampling protocol, 
monitoring and reporting requirements for consecutive systems, the 
impact of disinfection treatment on corrosion control, and the 
requirements for lead service line replacement. 

Limited Data Indicate Few Schools and Child Care Facilities Test or 
Take Other Measures to Control Lead in Their Water Supplies: 

Little information exists on the results of activities initiated after 
enactment of the Lead Contamination Control Act (LCCA) of 1988, 
including the recall of lead-lined water coolers from schools and child 
care facilities. More recent efforts to detect and remediate lead in 
the drinking water at such facilities also appear limited. As a result, 
the extent to which drinking water may contain unacceptable levels of 
lead at schools and child care facilities nationwide is uncertain. In 
addition, no clear focal point exists at the federal or state level to 
collect and analyze the results of testing and remediation efforts. 
Moreover, state and local officials say that addressing other 
environmental hazards at schools and child care facilities takes 
priority over testing for lead in drinking water. 

Little Information Exists on the Results of the Recall of Lead-Lined 
Water Coolers and Other Activities Prompted by the LCCA: 

The LCCA, enacted in 1988, laid out a number of requirements for EPA, 
the Consumer Product Safety Commission, and the states to address the 
potential risks of lead contamination in water supplies serving schools 
and child care facilities. Among other things, the act: 

* banned the manufacture and sale of drinking water coolers containing 
lead-lined tanks and other water coolers that are not lead-free, 

* required EPA to publish a list of such coolers and distribute it to 
the states along with guidance on testing for and remedying lead 
contamination in drinking water, and: 

* required the Consumer Product Safety Commission to issue an order 
requiring manufacturers and importers to (1) repair or replace the 
coolers or (2) recall and provide a refund for them because coolers 
containing lead-lined tanks were deemed to be imminently hazardous 
consumer products. 

In addition, the LCCA required states to establish programs to assist 
local agencies in addressing potential lead contamination. While the 
nature and extent of state activities varied widely, the program was 
never funded, according to EPA officials. In 1996, the requirement was 
determined to be unconstitutional.[Footnote 49] 

To support the required recall, EPA identified six models of water 
coolers containing lead-lined tanks, all produced by one company and 
manufactured prior to April 1979. EPA could not obtain information on 
the number of units produced. The Consumer Product Safety Commission 
broadened the recall order to include all tank-type models of drinking 
water coolers manufactured by the company, whether or not the models 
were included on EPA's list.[Footnote 50] Under the terms of the order, 
the manufacturer established a process under which qualified owners of 
the affected coolers could request a refund or replacement. The 
manufacturer was also required to notify appropriate officials and 
organizations, including state and school officials and day care 
centers, about the recall and the availability of refunds and 
replacements. 

Little information is available to determine the effectiveness of the 
recall effort in removing lead-lined water coolers from 
service.[Footnote 51] Not only is the number of coolers affected by the 
recall unknown, but the Consumer Product Safety Commission did not have 
summary data on the results of the recall. An agency official confirmed 
information in a 1991 Natural Resources Defense Council report that, as 
of 1990, the Commission had received approximately 1,200 inquiries 
about the recall, 1,373 coolers had been determined to be eligible for 
replacement, 514 had been replaced, and 105 refunds had been mailed to 
customers.[Footnote 52] However, the official also said that many more 
coolers were replaced after that date and that by 1993, the 
manufacturer had received approximately 11,000 inquiries about the 
recall. The official believed that the actual number of replacements 
was potentially 10 times greater than those reported in 1991 and the 
refunds four to five times greater. In addition, the recall order did 
not specify an end date for filing a refund or replacement request so 
an unknown number of coolers could have been taken out of service 
without the knowledge of the manufacturer or the Commission subsequent 
to 1993. 

According to several state and school officials we interviewed, 
virtually all of the water coolers affected by the recall have been 
replaced or removed, either as a result of the publicity surrounding 
the recall or because they had already been taken out of service. Some 
of the six models covered by the recall were manufactured in the 1950s 
and 1960s and are likely to have been retired because of their age or 
maintenance problems. 

Beyond the recall effort, little or no data are available to assess the 
effectiveness of other actions taken in response to the LCCA. For 
example, little information is available on the extent to which schools 
and child care facilities were inspected to check potential lead 
contamination from water coolers that were not lead-free. While the act 
did not require EPA or the states to track or report on the results of 
testing, EPA was responsible for publishing guidance and a testing 
protocol to assist schools in determining the source and degree of lead 
contamination in school drinking water supplies and remedying such 
contamination. EPA published guidance for both schools and child care 
facilities in 1989 and 1994, respectively.[Footnote 53] 

We found no information indicating how pervasive lead-contaminated 
drinking water in such facilities nationwide or within particular 
states might be, but several studies conducted in the early 1990s 
contained some limited information on testing efforts: 

* In 1993, we reported on the results of a survey of 57 school 
districts in 10 states.[Footnote 54] We found that 47 districts were 
able to provide data on the results of testing, which showed that about 
15 percent of the 2,272 schools tested had drinking water containing 
levels of lead considered unacceptable by EPA. We also contacted child 
care licensing agencies in 16 states to obtain information on their 
activities for addressing lead hazards and found that none of the 
agencies routinely inspected child care facilities for such hazards. 

* A 1990 report by EPA's Inspector General found that, of the 13 school 
districts surveyed, 10 conducted some testing for lead in drinking 
water and 8 detected contamination, with some results exceeding 
acceptable levels by a wide margin.[Footnote 55] 

* According to the Natural Resources Defense Council's 1991 
study,[Footnote 56] 47 states reported some testing of school drinking 
water supplies, including 16 states that tested in "a few" to 25 
percent of their schools, 27 states that tested from 25 percent to 82 
percent of the schools, and 4 states that tested 95 percent or more of 
their schools. The study also found that 17 states reported testing at 
child care facilities. 

In addition to these earlier studies, in 2004 EPA asked the states to 
provide information on current state and local efforts to monitor and 
protect children from lead exposure in drinking water at schools and 
child care facilities.[Footnote 57] As part of that effort, seven 
states also reported on the results of local testing following passage 
of the LCCA, stating that elevated lead levels were found in at least 
some of the locations tested.[Footnote 58] However, the states differed 
significantly in the extent of their testing and how they summarized 
the results. In five of the states, the results generally ranged from 
about 1 percent to 27 percent of samples, facilities, or districts with 
lead levels considered unacceptable by EPA--but the other two states 
finding elevated lead levels used a different assessment measure. 

Current Efforts to Detect and Remediate Lead in Drinking Water at 
Schools and Child Care Facilities Also Appear Limited: 

The extent of current testing and remediation activities for lead in 
school and child care facility drinking water appears limited. The LCCA 
does not require states to track or report such activities and, based 
on the information that EPA collected from the states in 2004 and our 
own contacts in 10 states, few states have comprehensive programs to 
detect and remediate lead in drinking water at schools and child care 
facilities. Figure 4 shows the nature and extent of these activities; 
about half the states reported no current efforts. 

Figure 4: Summary of State Efforts to Address Lead in Drinking Water at 
Schools and Child Care Facilities: 

[See PDF for image] 

Notes: (1) All states but Colorado responded to EPA's information 
request; about half the states submitted multiple responses, generally 
because responsibility for addressing lead issues at schools and child 
care facilities is shared by both health and environmental agencies. 

(2) The figure summarizes the most frequently reported activities by 
the states. While nearly half the states reported no activities, others 
reported activities in more than one of the categories we used. In 
addition to the activities summarized in figure 4, 26 states reported 
having lead poisoning prevention programs that include testing blood 
lead levels of children and investigating the source of any problems 
identified. We did not include these programs in our summary because 
the investigations usually focus initially on a child's home 
environment and the presence of lead paint. However, they could 
ultimately involve testing the drinking water at schools or child care 
facilities. 

(3) Some states reported testing for lead at schools or child care 
facilities that have their own water systems. We did not include this 
activity in figure 4 because such testing is required under the Safe 
Drinking Water Act. 

[End of figure] 

Of the five states that reported having testing requirements, four-- 
Connecticut, New Hampshire, South Carolina, and Vermont--require child 
care facilities to test their drinking water for lead contamination 
when obtaining or renewing their licenses.[Footnote 59] In the fifth 
state (Massachusetts), the testing requirement focuses on schools. 
Water systems must include two schools among their sampling sites in 
each round of lead testing, although the school data are not included 
in the 90th percentile calculation to determine whether lead levels 
exceed the action level. Massachusetts officials told us that, although 
the testing requirement has been in place since 1992, it has not 
received much attention until recently. The officials acknowledged that 
most water systems repeatedly used the same schools as sampling sites 
for the sake of convenience and said that the state has never 
summarized the results of the school testing. Given the renewed 
concerns about lead contamination following the detection of lead in 
the District of Columbia's drinking water, Massachusetts now requires 
water systems to rotate testing among schools and child care facilities 
and plans to issue a summary report at the end of 2005. 

In addition to these requirements, Florida's Department of 
Environmental Protection reported to EPA that it had established a 
voluntary program. Specifically, the state designated child care 
facilities as Tier 1, high risk sites and gave water systems the option 
of using the facilities as lead sampling sites and including them in 
the calculation of the 90th percentile lead level. (According to a 
Florida official, to be included as a sampling site, the child care 
facility must meet other Tier 1 criteria, such as being served by a 
lead service line.) However, when we followed up with state officials, 
they said that they had no way of tracking the extent to which water 
systems were actually including child care facilities as sampling 
sites. 

The scope of the targeted testing reported by 12 states varied widely, 
from a single school district in Pennsylvania to over 1,300 homes and 
child care facilities in Indiana. Several states indicated that they 
were focusing on potential high risk locations. EPA regional offices 
helped to initiate some limited testing in a few states, including 
Massachusetts, New Jersey, New York, and Pennsylvania; the testing 
generally focused on a few of the states' largest school districts. The 
state-sponsored surveys to determine the status of testing by local 
agencies also varied, with some covering all schools within the state 
and others focusing on a smaller subset of schools. In Washington, the 
state recently set aside $750,000, including $400,000 from its drinking 
water state revolving fund, to partially reimburse school districts for 
the cost of monitoring for lead in elementary schools' drinking water. 

EPA officials attributed the relatively low level of state activity in 
recent years to the aftereffects of a 1996 lawsuit brought by the 
Association of Community Organizations for Reform Now against the state 
of Louisiana for not doing enough to implement the LCCA. The case 
resulted in a federal circuit court decision declaring that part of the 
LCCA was unconstitutional. Specifically, the court ruled that the 
federal government did not have the authority to require states to 
establish a remedial action program as outlined in the LCCA.[Footnote 
60] While Louisiana reported to EPA that the case "had the unintended 
effect of ending the lead program in schools for the state of 
Louisiana," none of the 10 states we contacted cited the ruling as a 
factor in limiting their efforts. 

To obtain more information about testing and remedial actions in 
individual cities, we contacted five school districts--Boston, Detroit, 
Philadelphia, Seattle, and Syracuse. Table 11 shows the extent and 
results of testing within each district, and provides information on 
the various approaches school administrators have used to address the 
lead contamination. 

Table 11: Information on Recent Efforts to Test for and Remediate Lead 
in Drinking Water in Five School Districts: 

School district: Boston, Mass; Public Schools[A]; 
Scope and results of testing: Scope: Testing focused on kitchen 
facilities used to prepare food and was conducted between 2003 and 2004 
at the district's central kitchen facility and 38 schools with on-site 
kitchen facilities; 
Results: Lead levels in water from 17 kitchen facilities, including the 
central kitchen, exceeded 20 ppb; Type and cost of remedial actions: 
Actions: Manual flushing for at least 1 minute each day in all kitchens 
and an automatic flushing program at the central kitchen and 22 school 
buildings with kitchen facilities; Cost: Not available. 

School district: Detroit, Mich; Public Schools; 
Scope and results of testing: Scope: The district tested 21 water 
fountains and other outlets in one middle school as of November 2002. 
(Testing was also conducted at one other middle school, but the number 
of outlets included was not available.); 
Results: Lead levels in water from 16 drinking water outlets in one 
middle school exceeded 15 ppb; Type and cost of remedial actions: 
Actions: For the short term, shutting off outlets with elevated lead 
levels, doing manual flushing, and providing bottled water. For the 
long term, installing a water treatment system, replacing lead piping 
and fixtures, and re-routing a service line serving the school; Cost: 
An estimated $9,000 for bottled water and $5,865 for the water 
treatment system, plus $800 in annual maintenance costs. 

School district: Philadelphia, Pa; School District[B]; 
Scope and results of testing: Scope: As a result of consent orders in 
1999 and 2000, the school district was required to test all drinking 
water outlets at 299 schools and other buildings, or about 30,000 
outlets in total.[C]; 
Results: As of March 2004, the district had detected lead levels over 
20 ppb in approximately 4,600, or roughly 15 percent, of the outlets 
tested; Type and cost of remedial actions: Actions: For the short term, 
shutting off outlets with elevated lead levels and providing bottled 
water. For the long term, replacing or removing fixtures; Cost: An 
estimated $6 million through February 2005. 

School district: Seattle, Wash; Public Schools[B]; 
Scope and results of testing: Scope: In 2004, the district tested all 
interior drinking water outlets considered suitable for use, about 
2,400 outlets in total; 
Results: Lead levels at 600 of the outlets, or 25 percent, exceeded 20 
ppb; Type and cost of remedial actions: Actions: For the short term, 
shutting off outlets with elevated lead levels and providing bottled 
water. For the long term, fixing or replacing fixtures, installing 
filters, and replacing piping for any outlet where lead levels exceeded 
10 ppb; Cost: An estimated $15 million upon completion in 2007. 

School district: Syracuse, N.Y; City School District; 
Scope and results of testing: Scope: The district tested specific 
interior drinking water outlets in 50 schools and other buildings, 
beginning in August 2003; 
Results: 23 of the facilities had at least one drinking water outlet 
with lead levels over 20 ppb; Type and cost of remedial actions: 
Actions: For the short term, shutting off outlets with elevated lead 
levels. For the long term, installing in-line carbon filters at each 
outlet with elevated lead levels. (Other measures such as pipe 
replacement and removal of fixtures are still under discussion.); Cost: 
An estimated $100,000 through March 2005. 

Source: EPA and school districts. 

[A] Boston officials told us that they focused on kitchen facilities in 
their most recent testing because the district had already installed 
bottled water at many drinking water outlets after earlier testing had 
disclosed elevated lead levels. 

[B] Both Philadelphia and Seattle had also conducted some testing prior 
to the more recent efforts summarized in this table. 

[C] A 2003 modification to the earlier consent orders removed the 
requirement to test bathroom faucets. 

[End of table] 

The cities we contacted differed in the testing protocols they used to 
test for lead in school drinking water.[Footnote 61] While three of the 
cities (Boston, Philadelphia, and Syracuse) followed EPA's guidance, 
using a 250 milliliter sample and a limit of 20 parts per billion for 
triggering follow-up action, Seattle took a more conservative approach. 
Using the same sample volume, the school board established 10 parts per 
billion as its standard for follow-up action. Detroit, on the other 
hand, used the same protocol that is required for public water systems-
-a 1 liter sample and 15 parts per billion as the limit. 

Some of the remediation measures adopted by the cities we contacted 
were effective, including installing in-line filters, replacing pipes, 
and removing fixtures at outlets with test results indicating high lead 
levels. Other measures required more attention and others inadvertently 
created new issues for officials to deal with. For example, a Seattle 
school official noted that the district decided against instituting a 
flushing program in its schools because it was too difficult to ensure 
that staff in individual schools would follow through with the flushing 
every day. In Boston, a school official told us that using bottled 
water posed a problem because staff had to make sure that replacement 
bottles were always available and because it created other issues with 
pests, vandalism, and spillage. 

The Extent to Which Drinking Water at Schools and Child Care Facilities 
Is Contaminated by Lead Is Uncertain, in Part, Because No Clear Focal 
Point Exists to Collect Available Data: 

While a number of cities have detected elevated lead levels in school 
drinking water, and a few states are beginning to collect information 
on the status of local testing efforts, little information exists on 
the extent to which drinking water at schools and child care facilities 
nationwide may contain unacceptable levels of lead. No focal point 
exists at the federal or state level to collect and analyze test 
results or information on cost-effective remediation strategies. As a 
result, it is difficult to get a sense of the pervasiveness of lead 
contamination in the drinking water at schools and child care 
facilities, and to know whether a more concerted effort to address the 
issue--such as mandatory testing--is warranted. In addition, 
remediation measures such as providing bottled water, regularly 
flushing water lines, installing filters, and replacing fixtures and 
internal piping vary widely in cost and complexity, among other 
factors. State and local officials have expressed concern about not 
having sufficient information on the measures, their pros and cons, and 
circumstances in which particular measures might be more appropriate 
than others. 

At the federal level, EPA's Office of Ground Water and Drinking Water 
sets drinking water standards and other requirements for public 
drinking water systems, but generally does not have any direct 
oversight responsibility for the quality of drinking water in schools 
or child care facilities.[Footnote 62] The U.S. Department of Education 
(Education) is responsible for, among other things, providing guidance 
and financial assistance to state and local education agencies for 
elementary and secondary schools. Education's Office of Safe and Drug 
Free Schools recently signed a memorandum of understanding with EPA, 
the Centers for Disease Control and Prevention, and various water 
industry associations with the goal of reducing children's exposure to 
lead in drinking water at schools and child care facilities.[Footnote 
63] However, according to an Education official, the department does 
not have legal authority to compel schools to test for lead in the 
drinking water. Officials in Washington state saw a need for closer 
coordination between EPA and Education. The officials believe that 
local education officials are more likely to respond to guidance on 
lead and other environmental health issues if Education were to be 
involved in developing it. 

At the state level, responsibility for the environmental health of 
schools and child care facilities is usually fragmented among multiple 
agencies. According to EPA, in most states, the same agency that 
administers the drinking water program--generally the state's 
department of environmental protection or department of health--is also 
responsible for implementing the LCCA. However, we also learned from 
EPA that the state agencies responsible for administering education 
programs and licensing child care facilities are usually the ones with 
the regulatory or oversight authority over environmental conditions in 
schools and child care facilities. (As noted earlier, some states also 
have lead poisoning prevention programs to monitor blood lead levels in 
children and investigate the source of lead exposure when the levels 
are elevated.) According to some of the states we contacted, the level 
of coordination among state agencies needs to be improved and the lack 
of a centralized authority at the state level has complicated efforts 
to plan and implement a testing program for lead in water in some 
school districts. For example, in Pennsylvania, state drinking water 
officials said that several other agencies, including the Departments 
of Health, Education, and Public Welfare, have a role in overseeing 
schools and child care facilities--but it was unclear which agency 
would be best suited to manage a testing program if one were to be 
required. In contrast, Connecticut officials said that having both the 
drinking water program and the child care licensing program housed 
within the same department has been an advantage because it is easier 
for the programs to share information and coordinate their activities. 

We also contacted several school and child care associations to find 
out if they were involved in or aware of efforts to promote testing for 
lead in drinking water, collect and analyze the results of testing, or 
set standards for the environmental health of the facilities. According 
to a representative of the National Child Care Association, until 
recently the association had not been aware of any issues regarding 
lead in drinking water at child care facilities or involved in any 
effort to promote testing.[Footnote 64] The representative commented 
that one challenge to distributing information on lead in drinking 
water to child care facilities is the fragmented nature of the child 
care industry. While the National Head Start Association has been 
involved with lead poisoning prevention in general, the organization 
has not done anything specifically related to lead in drinking 
water.[Footnote 65] The Healthy Schools Network, Inc. promotes the 
development of state and national policies, regulations, and funding 
for environmentally safe and healthy schools. Although the network has 
published some fact sheets that address the potential health risks from 
lead exposure, lead in drinking water has not been a priority compared 
with other environmental issues. While none of these organizations were 
parties to EPA's recent memorandum of understanding, they have been 
actively engaged in assisting EPA as the agency revises its guidance 
for schools and child care facilities, according to EPA officials. 

State and Local Officials Say Addressing Other Environmental Hazards 
Takes Priority over Testing for Lead in Drinking Water at Schools and 
Child Care Facilities: 

According to state and local officials, children may be exposed to a 
variety of environmental hazards at schools and child care facilities, 
including asbestos, lead in paint or dust, mold, and other substances 
that affect indoor air quality. The officials told us that dealing with 
such problems often takes priority over checking for lead in drinking 
water because, in the case of the other problems, more information is 
available on the nature and extent of the potential health risks 
involved. For example, many of the officials we interviewed said that 
the most significant source of lead exposure--and thus, their primary 
concern--was lead in paint. Officials from two states also mentioned 
that lead in jewelry, toys, or pottery is a more significant source of 
exposure than lead in drinking water. Washington state officials told 
us that child care facilities also have many competing priorities and 
cited food handling as one of their major concerns. 

At the local level, officials talked about dealing with multiple health 
and safety issues and the difficulty of prioritizing limited resources. 
For example, in Detroit, one official told us that dealing with 
asbestos takes priority over all other environmental concerns, 
including lead in drinking water. Another Detroit official commented 
that indoor air quality is another priority because "issues related to 
breathing are very important to educators." In Philadelphia, a school 
official noted that a major source of lead in the school district is 
dust, a problem that requires continuing attention from the maintenance 
staff, which must set aside time to scrub the areas where dust 
collects. A Seattle official also mentioned the difficulty posed by 
competing needs for limited funds. He indicated that the competition is 
not only among environmental issues, such as mold and asbestos, but, on 
a broader level, between maintenance and basic classroom expenditures. 

Without additional resources--or more compelling evidence that lead in 
drinking water should be a higher priority--state and local officials, 
as well as representatives of industry groups, were reluctant to 
support calls for mandatory testing for lead in drinking water in 
schools and child care facilities. Many of the officials we interviewed 
said that more research is needed on several aspects of the lead issue. 
In addition to wanting more information on the extent to which lead 
contamination in schools and child care facilities is a problem, some 
officials also wanted more information on the circumstances in which 
particular remediation approaches are most effective. Other officials 
believe that more research is needed on the relationship between 
children's exposure to lead in drinking water and their blood lead 
levels. 

Conclusions: 

Ensuring that the lead rule adequately protects public health and is 
fully implemented and enforced should be a high priority for EPA and 
the states because the potential consequences of lead exposure, 
particularly for infants and young children, can be significant. 
However, EPA's hands are tied unless states report complete, accurate, 
and timely data on the results of required monitoring, the status of 
corrective actions, and the extent of violations. Without such 
information, EPA cannot provide effective oversight or target limited 
resources where they are most needed. Similarly, inconsistencies among 
the states' policies and practices for implementing the lead rule may 
lead to uneven levels of public health protection for consumers and 
thus need to be examined and corrected, as appropriate. 

Given the potential health effects associated with lead contamination, 
it is important to minimize any unnecessary exposure as a result of 
leaded materials in the water distribution system or household 
plumbing. Reevaluating existing standards for the devices used in or 
near residential plumbing systems would also enhance the effectiveness 
of the treatment provided by local water systems. In the case of 
schools and child care facilities, both the vulnerability of the 
population served by such facilities and the competition for limited 
resources make it essential to have better information on the nature 
and extent of lead-contaminated drinking water--and its significance 
relative to other environmental hazards. 

Recommendations for Executive Action: 

We recommend that the Administrator, EPA, take a number of steps to 
further protect the American public from elevated lead levels in 
drinking water. Specifically, to improve EPA's ability to oversee 
implementation of the lead rule and assess compliance and enforcement 
activities, EPA should: 

* ensure that data on water systems' test results, corrective action 
milestones, and violations are current, accurate, and complete and: 

* analyze data on corrective actions and violations to assess the 
adequacy of EPA and state enforcement efforts. 

To expand ongoing efforts to improve implementation and oversight of 
the lead rule, EPA should reassess existing regulations and guidance to 
ensure the following: 

* the sites water systems use for tap monitoring reflect areas of 
highest risk for lead corrosion; 

* the circumstances in which states approve water systems for reduced 
monitoring are appropriate and that systems resume standard monitoring 
following a major treatment change; 

* homeowners who participate in tap monitoring are informed of the test 
results; and: 

* states review and approve major treatment changes, as defined by EPA, 
to assess their impact on corrosion control before the changes are 
implemented. 

In addition, EPA should: 

* collect and analyze data on the impact of lead service line 
replacement on lead levels and conduct other research, as appropriate, 
to assess the effectiveness of lead line replacement programs and 
whether additional regulations or guidance are warranted; 

* collect information on (1) the nature and extent of modified sampling 
arrangements within combined distribution systems and (2) differences 
in the reporting practices and corrective actions authorized by the 
states, using this information to reassess applicable regulations and 
guidance; and: 

* evaluate existing standards for in-line and endpoint plumbing devices 
used in or near residential plumbing systems to determine if the 
standards are sufficiently protective to minimize potential lead 
contamination. 

In order to update its guidance and testing protocols, EPA should 
collect and analyze the results of any testing that has been done to 
determine whether more needs to be done to protect users from elevated 
lead levels in drinking water at schools and child care facilities. In 
addition, to assist local agencies in making the most efficient use of 
their resources, EPA should assess the pros and cons of various 
remediation activities and make the information publicly available. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to EPA and the Consumer Product 
Safety Commission for review and comment. EPA generally agreed with our 
findings and recommendations. Regarding the completeness of information 
that EPA has to evaluate implementation of the lead rule, the agency 
said that it will work with the states to ensure that relevant 
information is incorporated into the national database and will use the 
information, in part, to assess the adequacy of enforcement efforts. In 
addition, EPA agreed that aspects of the regulation need improvement. 
EPA said that it will address some of these areas as part of its 
package of revisions to the lead rule that it plans to propose early in 
2006, including homeowner notification of test results and criteria for 
reduced monitoring. EPA also said that it needs additional information 
before it can address other areas, such as lead service line 
replacement and plumbing standards, that may warrant regulatory 
changes. EPA did not comment on our recommendation to reevaluate 
existing regulations and guidance to ensure that tap monitoring sites 
reflect areas of highest risk for lead corrosion. Finally, EPA did not 
address our recommendations regarding lead contamination and remedial 
actions at schools and child care facilities. We believe that, given 
the particular vulnerability of children to the effects of lead, it is 
important for EPA to take full advantage of the results of any tests 
that have been done, as well as to identify those remedial activities 
that have proven to be most effective. EPA's comments appear in 
appendix V. The Consumer Product Safety Commission generally agreed 
with our findings as they pertain to the Commission. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to appropriate 
congressional committees; the Administrator, EPA; the Chairman, 
Consumer Product Safety Commission; and the Director of the Office of 
Management and Budget. We will also make copies available to others 
upon request. In addition, the report will be available at no charge on 
the GAO Web site at [Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or [Hyperlink, stephensonj@gao.gov]. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. GAO staff who 
made major contributions to this report are listed in appendix VI. 

Signed by: 

John B. Stephenson: 
Director, Natural Resources and Environment: 

Appendixes: 

Appendix I: Scope and Methodology: 

For information on how the lead rule is being implemented, we obtained 
information from the Environmental Protection Agency's (EPA) Office of 
Ground Water and Drinking Water and Office of Enforcement and 
Compliance Assurance, eight EPA regional offices, and 10 states. We 
selected eight of the states--California, Illinois, Iowa, 
Massachusetts, Michigan, New York, Pennsylvania, and Washington-- 
because they either had a relatively high number of water systems with 
test results that exceeded or fell just below the lead action level, or 
they added to the geographical diversity of our selections. We also 
included Connecticut and Florida in our review because they were 
identified by EPA as particularly active in addressing potential lead 
contamination in water supplies serving child care facilities. At the 
local level, we obtained information from eight water systems: the 
Chicago Water Department in Illinois, the Boston Water and Sewer 
Commission and Massachusetts Water Resources Authority in 
Massachusetts, the Detroit Water and Sewerage Department in Michigan, 
the Syracuse Water Department in New York, the Portland Bureau of Water 
Works in Oregon, the Philadelphia Water Department in Pennsylvania, and 
Seattle Public Utilities in Washington. Our criteria for selecting 
these systems included test results showing elevated lead levels, lead 
service line replacement activity, and/or the use of modified sampling 
arrangements for consecutive systems. We reviewed the Safe Drinking 
Water Act, the lead rule, EPA's minor revisions to the lead rule, other 
pertinent regulations, and applicable guidance to states and water 
systems. 

To gain a national perspective on the data EPA uses for oversight of 
lead rule implementation, including the results of required testing, 
the status of corrective actions, and the extent of violations, we 
analyzed data from EPA's Safe Drinking Water Information System through 
June 2005 for active community water systems. We assessed the 
reliability of the data by (1) performing electronic testing of 
required data elements, (2) reviewing existing information about the 
data and the system that produced them, (3) interviewing agency 
officials knowledgeable about the data, and (4) reviewing EPA's own 
data verification audits and summaries of data reliability. We 
determined that the data on results and frequency of lead testing were 
sufficiently reliable to show compliance trends. However, we found that 
other data on corrective actions and violations were not sufficiently 
reliable to assess the status of efforts to implement and enforce the 
lead rule. 

For information on experiences in implementing the lead rule and the 
need for changes to the regulatory framework, we interviewed EPA, 
state, and local officials; analyzed states' responses to an EPA 
information request regarding their policies and practices in 
implementing the rule; and reviewed other relevant studies and 
documents. We reviewed the results of EPA's expert workshops on 
monitoring protocols, simultaneous compliance, lead service line 
replacement, and public education, and obtained information from 
several researchers and other drinking water experts. Among other 
things, we identified potential gaps in the regulatory framework, 
including oversight, regulations, and guidance, and obtained views on 
the modifications to the lead rule now being considered by EPA. To 
learn about the development and effectiveness of existing plumbing 
standards, we obtained and analyzed information from NSF International 
(NSF), the Copper Development Association, the Plumbing Manufacturers 
Institute, and relevant articles and studies. To assess the reliability 
of NSF's data on lead content and lead leaching of plumbing fittings 
and fixtures, we talked with foundation officials about data quality 
control procedures. We determined the data were sufficiently reliable 
for illustrative purposes. 

For information on safeguards against lead-contaminated drinking water 
at schools and child care facilities, we interviewed officials from the 
Consumer Product Safety Commission, EPA's Office of Ground Water and 
Drinking Water, the National Head Start Association, the National Child 
Care Association, and the Healthy Schools Network. We also obtained 
information from drinking water program offices and public health or 
education departments in the 10 states we contacted for the first 
objective as well as school districts in Boston, Chicago, Detroit, 
Philadelphia, Seattle, and Syracuse. We reviewed the Lead Contamination 
Control Act (LCCA) of 1988 and obtained information on the recall of 
lead-lined water coolers. For information on other actions taken in 
response to the LCCA, we interviewed EPA, state, and local officials; 
reviewed relevant studies; and analyzed information collected by EPA. 
We used the same information sources to determine (1) the extent of 
current testing and remediation activities for lead in school and child 
care facility drinking water, (2) the extent to which various entities 
have responsibility for overseeing or collecting data on such 
activities, and (3) the relative priorities among environmental hazards 
common to schools and child care facilities. We also analyzed states' 
responses to an EPA information request on state and local efforts to 
monitor and protect children from lead exposure and attended an EPA- 
sponsored expert workshop on lead in drinking water at schools and 
child care facilities. For more detailed information on experiences at 
the local level, we collected information from five school districts on 
the extent of testing for lead in school drinking water, the results, 
and the approaches used to address contamination. 

We performed our work between June 2004 and November 2005 in accordance 
with generally accepted government auditing standards. 

[End of section] 

Appendix II: Detailed Analysis of Corrective Action Milestone Data 
Reported to EPA, by State, through June 2005: 

State: AK; 
Large: Number of systems: Total number of systems: 1; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 135,000; 
Large: Population of large systems: Population in systems without 
milestones: 135,000; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: AL; 
Large: Number of systems: Total number of systems: 11; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 1,881,984; 
Large: Population of large systems: Population in systems without 
milestones: 1,881,984; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: AR; 
Large: Number of systems: Total number of systems: 8; 
Large: Number of systems: Number of systems with milestones: 8; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 781,325; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: AZ; 
Large: Number of systems: Total number of systems: 13; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 3,417,902; 
Large: Population of large systems: Population in systems without 
milestones: 3,417,902; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: CA; 
Large: Number of systems: Total number of systems: 160; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 
25,224,420; 
Large: Population of large systems: Population in systems without 
milestones: 25,224,420; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: CO; 
Large: Number of systems: Total number of systems: 16; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 2,941,619; 
Large: Population of large systems: Population in systems without 
milestones: 2,941,619; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: CT; 
Large: Number of systems: Total number of systems: 9; 
Large: Number of systems: Number of systems with milestones: 9; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 1,586,458; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: DC; 
Large: Number of systems: Total number of systems: 1; 
Large: Number of systems: Number of systems with milestones: 1; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 595,000; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: DE; 
Large: Number of systems: Total number of systems: 3; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 445,504; 
Large: Population of large systems: Population in systems without 
milestones: 445,504; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: FL; 
Large: Number of systems: Total number of systems: 76; 
Large: Number of systems: Number of systems with milestones: 3; 
Large: Number of systems: Percent of systems without milestones: 96.1; 
Large: Population of large systems: Total population served: 
12,098,524; 
Large: Population of large systems: Population in systems without 
milestones: 11,805,584; 
Large: Population of large systems: Percent of population in systems 
without milestones: 97.6. 

State: GA; 
Large: Number of systems: Total number of systems: 23; 
Large: Number of systems: Number of systems with milestones: 18; 
Large: Number of systems: Percent of systems without milestones: 21.7; 
Large: Population of large systems: Total population served: 4,544,090; 
Large: Population of large systems: Population in systems without 
milestones: 507,529; 
Large: Population of large systems: Percent of population in systems 
without milestones: 11.2. 

State: HI; 
Large: Number of systems: Total number of systems: 4; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 875,238; 
Large: Population of large systems: Population in systems without 
milestones: 875,238; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: IA; 
Large: Number of systems: Total number of systems: 8; 
Large: Number of systems: Number of systems with milestones: 1; 
Large: Number of systems: Percent of systems without milestones: 87.5; 
Large: Population of large systems: Total population served: 793,026; 
Large: Population of large systems: Population in systems without 
milestones: 584,383; 
Large: Population of large systems: Percent of population in systems 
without milestones: 73.7. 

State: ID; 
Large: Number of systems: Total number of systems: 4; 
Large: Number of systems: Number of systems with milestones: 1; 
Large: Number of systems: Percent of systems without milestones: 75.0; 
Large: Population of large systems: Total population served: 353,151; 
Large: Population of large systems: Population in systems without 
milestones: 300,800; 
Large: Population of large systems: Percent of population in systems 
without milestones: 85.2. 

State: IL; 
Large: Number of systems: Total number of systems: 30; 
Large: Number of systems: Number of systems with milestones: 28; 
Large: Number of systems: Percent of systems without milestones: 6.7; 
Large: Population of large systems: Total population served: 5,367,282; 
Large: Population of large systems: Population in systems without 
milestones: 123,603; 
Large: Population of large systems: Percent of population in systems 
without milestones: 2.3. 

State: IN; 
Large: Number of systems: Total number of systems: 14; 
Large: Number of systems: Number of systems with milestones: 14; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 2,106,043; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: KS; 
Large: Number of systems: Total number of systems: 6; 
Large: Number of systems: Number of systems with milestones: 2; 
Large: Number of systems: Percent of systems without milestones: 66.7; 
Large: Population of large systems: Total population served: 1,172,516; 
Large: Population of large systems: Population in systems without 
milestones: 981,341; 
Large: Population of large systems: Percent of population in systems 
without milestones: 83.7. 

State: KY; 
Large: Number of systems: Total number of systems: 8; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 1,705,135; 
Large: Population of large systems: Population in systems without 
milestones: 1,705,135; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: LA; 
Large: Number of systems: Total number of systems: 15; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 2,315,098; 
Large: Population of large systems: Population in systems without 
milestones: 2,315,098; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: MA; 
Large: Number of systems: Total number of systems: 29; 
Large: Number of systems: Number of systems with milestones: 14; 
Large: Number of systems: Percent of systems without milestones: 51.7; 
Large: Population of large systems: Total population served: 4,992,887; 
Large: Population of large systems: Population in systems without 
milestones: 3,629,018; 
Large: Population of large systems: Percent of population in systems 
without milestones: 72.7. 

State: MD; 
Large: Number of systems: Total number of systems: 9; 
Large: Number of systems: Number of systems with milestones: 7; 
Large: Number of systems: Percent of systems without milestones: 22.2; 
Large: Population of large systems: Total population served: 4,005,168; 
Large: Population of large systems: Population in systems without 
milestones: 106,000; 
Large: Population of large systems: Percent of population in systems 
without milestones: 2.6. 

State: ME; 
Large: Number of systems: Total number of systems: 1; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 113,560; 
Large: Population of large systems: Population in systems without 
milestones: 113,560; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: MI; 
Large: Number of systems: Total number of systems: 31; 
Large: Number of systems: Number of systems with milestones: 28; 
Large: Number of systems: Percent of systems without milestones: 9.7; 
Large: Population of large systems: Total population served: 3,647,640; 
Large: Population of large systems: Population in systems without 
milestones: 318,288; 
Large: Population of large systems: Percent of population in systems 
without milestones: 8.7. 

State: MN; 
Large: Number of systems: Total number of systems: 14; 
Large: Number of systems: Number of systems with milestones: 8; 
Large: Number of systems: Percent of systems without milestones: 42.9; 
Large: Population of large systems: Total population served: 1,610,382; 
Large: Population of large systems: Population in systems without 
milestones: 370,533; 
Large: Population of large systems: Percent of population in systems 
without milestones: 23.0. 

State: MO; 
Large: Number of systems: Total number of systems: 11; 
Large: Number of systems: Number of systems with milestones: 4; 
Large: Number of systems: Percent of systems without milestones: 63.6; 
Large: Population of large systems: Total population served: 2,586,464; 
Large: Population of large systems: Population in systems without 
milestones: 2,347,737; 
Large: Population of large systems: Percent of population in systems 
without milestones: 90.8. 

State: MS; 
Large: Number of systems: Total number of systems: 2; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 288,257; 
Large: Population of large systems: Population in systems without 
milestones: 288,257; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: MT; 
Large: Number of systems: Total number of systems: 3; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 208,335; 
Large: Population of large systems: Population in systems without 
milestones: 208,335; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: NC; 
Large: Number of systems: Total number of systems: 24; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 3,255,476; 
Large: Population of large systems: Population in systems without 
milestones: 3,255,476; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: ND; 
Large: Number of systems: Total number of systems: 2; 
Large: Number of systems: Number of systems with milestones: 2; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 146,131; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: NE; 
Large: Number of systems: Total number of systems: 2; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 709,420; 
Large: Population of large systems: Population in systems without 
milestones: 709,420; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: NH; 
Large: Number of systems: Total number of systems: 2; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 213,000; 
Large: Population of large systems: Population in systems without 
milestones: 213,000; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: NJ; 
Large: Number of systems: Total number of systems: 21; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 4,205,795; 
Large: Population of large systems: Population in systems without 
milestones: 4,205,795; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: NM; 
Large: Number of systems: Total number of systems: 4; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 660,026; 
Large: Population of large systems: Population in systems without 
milestones: 660,026; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: NV; 
Large: Number of systems: Total number of systems: 5; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 1,876,500; 
Large: Population of large systems: Population in systems without 
milestones: 1,876,500; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: NY; 
Large: Number of systems: Total number of systems: 32; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 
13,079,586; 
Large: Population of large systems: Population in systems without 
milestones: 13,079,586; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: OH; 
Large: Number of systems: Total number of systems: 27; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 5,720,471; 
Large: Population of large systems: Population in systems without 
milestones: 5,720,471; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: OK; 
Large: Number of systems: Total number of systems: 9; 
Large: Number of systems: Number of systems with milestones: 7; 
Large: Number of systems: Percent of systems without milestones: 22.2; 
Large: Population of large systems: Total population served: 1,538,179; 
Large: Population of large systems: Population in systems without 
milestones: 679,000; 
Large: Population of large systems: Percent of population in systems 
without milestones: 44.1. 

State: OR; 
Large: Number of systems: Total number of systems: 11; 
Large: Number of systems: Number of systems with milestones: 8; 
Large: Number of systems: Percent of systems without milestones: 27.3; 
Large: Population of large systems: Total population served: 1,424,645; 
Large: Population of large systems: Population in systems without 
milestones: 278,000; 
Large: Population of large systems: Percent of population in systems 
without milestones: 19.5. 

State: PA; 
Large: Number of systems: Total number of systems: 31; 
Large: Number of systems: Number of systems with milestones: 31; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 5,823,088; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: RI; 
Large: Number of systems: Total number of systems: 4; 
Large: Number of systems: Number of systems with milestones: 4; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 528,853; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: SC; 
Large: Number of systems: Total number of systems: 12; 
Large: Number of systems: Number of systems with milestones: 12; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 1,549,312; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: SD; 
Large: Number of systems: Total number of systems: 2; 
Large: Number of systems: Number of systems with milestones: 2; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 185,983; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: TN; 
Large: Number of systems: Total number of systems: 15; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 2,221,020; 
Large: Population of large systems: Population in systems without 
milestones: 2,221,020; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: TX; 
Large: Number of systems: Total number of systems: 56; 
Large: Number of systems: Number of systems with milestones: 5; 
Large: Number of systems: Percent of systems without milestones: 91.1; 
Large: Population of large systems: Total population served: 
12,580,122; 
Large: Population of large systems: Population in systems without 
milestones: 12,268,259; 
Large: Population of large systems: Percent of population in systems 
without milestones: 97.5. 

State: UT; 
Large: Number of systems: Total number of systems: 10; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 1,197,900; 
Large: Population of large systems: Population in systems without 
milestones: 1,197,900; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: VA; 
Large: Number of systems: Total number of systems: 22; 
Large: Number of systems: Number of systems with milestones: 22; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 3,979,119; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: VT; 
Large: Number of systems: Total number of systems: 0; 
Large: Number of systems: Number of systems with milestones: N/A; 
Large: Number of systems: Percent of systems without milestones: N/A; 
Large: Population of large systems: Total population served: 0; 
Large: Population of large systems: Population in systems without 
milestones: N/A; 
Large: Population of large systems: Percent of population in systems 
without milestones: N/A. 

State: WA; 
Large: Number of systems: Total number of systems: 23; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 2,697,616; 
Large: Population of large systems: Population in systems without 
milestones: 2,697,616; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: WI; 
Large: Number of systems: Total number of systems: 13; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 1,666,474; 
Large: Population of large systems: Population in systems without 
milestones: 1,666,474; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

State: WV; 
Large: Number of systems: Total number of systems: 2; 
Large: Number of systems: Number of systems with milestones: 2; 
Large: Number of systems: Percent of systems without milestones: 0.0; 
Large: Population of large systems: Total population served: 246,203; 
Large: Population of large systems: Population in systems without 
milestones: 0; 
Large: Population of large systems: Percent of population in systems 
without milestones: 0.0. 

State: WY; 
Large: Number of systems: Total number of systems: 2; 
Large: Number of systems: Number of systems with milestones: 0; 
Large: Number of systems: Percent of systems without milestones: 100.0; 
Large: Population of large systems: Total population served: 110,108; 
Large: Population of large systems: Population in systems without 
milestones: 110,108; 
Large: Population of large systems: Percent of population in systems 
without milestones: 100.0. 

Total/AVG; 
Large: Number of systems: Total number of systems: 841; 
Large: Number of systems: Number of systems with milestones: 241; 
Large: Number of systems: Percent of systems without milestones: 71.3; 
Large: Population of large systems: Total population served: 
151,407,035; 
Large: Population of large systems: Population in systems without 
milestones: 111,465,519; 
Large: Population of large systems: Percent of population in systems 
without milestones: 73.6. 

Source: GAO analysis of EPA data. 

[End of table] 

State: AK; 
Medium: Number of systems: Total number of systems: 23; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 200,798; 
Medium: Population of medium systems: Population in systems without 
milestones: 200,798; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: AL; 
Medium: Number of systems: Total number of systems: 266; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
2,944,220; 
Medium: Population of medium systems: Population in systems without 
milestones: 2,944,220; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: AR; 
Medium: Number of systems: Total number of systems: 139; 
Medium: Number of systems: Number of systems with milestones: 133; 
Medium: Number of systems: Percent of systems without milestones: 4.3; 
Medium: Population of medium systems: Total population served: 
1,190,159; 
Medium: Population of medium systems: Population in systems without 
milestones: 31,091; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 2.6. 

State: AZ; 
Medium: Number of systems: Total number of systems: 105; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
1,227,834; 
Medium: Population of medium systems: Population in systems without 
milestones: 1,227,834; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: CA; 
Medium: Number of systems: Total number of systems: 478; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
7,476,807; 
Medium: Population of medium systems: Population in systems without 
milestones: 7,476,807; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: CO; 
Medium: Number of systems: Total number of systems: 131; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
1,726,744; 
Medium: Population of medium systems: Population in systems without 
milestones: 1,726,744; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: CT; 
Medium: Number of systems: Total number of systems: 48; 
Medium: Number of systems: Number of systems with milestones: 48; 
Medium: Number of systems: Percent of systems without milestones: 0.0; 
Medium: Population of medium systems: Total population served: 926,493; 
Medium: Population of medium systems: Population in systems without 
milestones: 0; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 0.0. 

State: DC; 
Medium: Number of systems: Total number of systems: 1; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 11,000; 
Medium: Population of medium systems: Population in systems without 
milestones: 11,000; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: DE; 
Medium: Number of systems: Total number of systems: 24; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 298,763; 
Medium: Population of medium systems: Population in systems without 
milestones: 298,763; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: FL; 
Medium: Number of systems: Total number of systems: 310; 
Medium: Number of systems: Number of systems with milestones: 2; 
Medium: Number of systems: Percent of systems without milestones: 99.4; 
Medium: Population of medium systems: Total population served: 
4,684,659; 
Medium: Population of medium systems: Population in systems without 
milestones: 4,655,307; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 99.4. 

State: GA; 
Medium: Number of systems: Total number of systems: 184; 
Medium: Number of systems: Number of systems with milestones: 94; 
Medium: Number of systems: Percent of systems without milestones: 48.9; 
Medium: Population of medium systems: Total population served: 
2,254,876; 
Medium: Population of medium systems: Population in systems without 
milestones: 1,068,475; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 47.4. 

State: HI; 
Medium: Number of systems: Total number of systems: 33; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 378,964; 
Medium: Population of medium systems: Population in systems without 
milestones: 378,964; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: IA; 
Medium: Number of systems: Total number of systems: 116; 
Medium: Number of systems: Number of systems with milestones: 12; 
Medium: Number of systems: Percent of systems without milestones: 89.7; 
Medium: Population of medium systems: Total population served: 
1,173,595; 
Medium: Population of medium systems: Population in systems without 
milestones: 1,099,226; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 93.7. 

State: ID; 
Medium: Number of systems: Total number of systems: 41; 
Medium: Number of systems: Number of systems with milestones: 3; 
Medium: Number of systems: Percent of systems without milestones: 92.7; 
Medium: Population of medium systems: Total population served: 401,222; 
Medium: Population of medium systems: Population in systems without 
milestones: 355,215; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 88.5. 

State: IL; 
Medium: Number of systems: Total number of systems: 396; 
Medium: Number of systems: Number of systems with milestones: 378; 
Medium: Number of systems: Percent of systems without milestones: 4.5; 
Medium: Population of medium systems: Total population served: 
5,176,451; 
Medium: Population of medium systems: Population in systems without 
milestones: 192,293; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 3.7. 

State: IN; 
Medium: Number of systems: Total number of systems: 188; 
Medium: Number of systems: Number of systems with milestones: 187; 
Medium: Number of systems: Percent of systems without milestones: 0.5; 
Medium: Population of medium systems: Total population served: 
2,025,670; 
Medium: Population of medium systems: Population in systems without 
milestones: 3,661; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 0.2. 

State: KS; 
Medium: Number of systems: Total number of systems: 81; 
Medium: Number of systems: Number of systems with milestones: 75; 
Medium: Number of systems: Percent of systems without milestones: 7.4; 
Medium: Population of medium systems: Total population served: 836,216; 
Medium: Population of medium systems: Population in systems without 
milestones: 24,796; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 3.0. 

State: KY; 
Medium: Number of systems: Total number of systems: 231; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
2,657,189; 
Medium: Population of medium systems: Population in systems without 
milestones: 2,657,189; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: LA; 
Medium: Number of systems: Total number of systems: 203; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
1,827,405; 
Medium: Population of medium systems: Population in systems without 
milestones: 1,827,405; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: MA; 
Medium: Number of systems: Total number of systems: 217; 
Medium: Number of systems: Number of systems with milestones: 81; 
Medium: Number of systems: Percent of systems without milestones: 62.7; 
Medium: Population of medium systems: Total population served: 
3,788,166; 
Medium: Population of medium systems: Population in systems without 
milestones: 2,339,423; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 61.8. 

State: MD; 
Medium: Number of systems: Total number of systems: 53; 
Medium: Number of systems: Number of systems with milestones: 1; 
Medium: Number of systems: Percent of systems without milestones: 98.1; 
Medium: Population of medium systems: Total population served: 623,854; 
Medium: Population of medium systems: Population in systems without 
milestones: 620,429; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 99.5. 

State: ME; 
Medium: Number of systems: Total number of systems: 32; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 339,255; 
Medium: Population of medium systems: Population in systems without 
milestones: 339,255; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: MI; 
Medium: Number of systems: Total number of systems: 249; 
Medium: Number of systems: Number of systems with milestones: 204; 
Medium: Number of systems: Percent of systems without milestones: 18.1; 
Medium: Population of medium systems: Total population served: 
3,078,142; 
Medium: Population of medium systems: Population in systems without 
milestones: 477,742; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 15.5. 

State: MN; 
Medium: Number of systems: Total number of systems: 140; 
Medium: Number of systems: Number of systems with milestones: 44; 
Medium: Number of systems: Percent of systems without milestones: 68.6; 
Medium: Population of medium systems: Total population served: 
1,821,460; 
Medium: Population of medium systems: Population in systems without 
milestones: 1,359,303; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 74.6. 

State: MO; 
Medium: Number of systems: Total number of systems: 173; 
Medium: Number of systems: Number of systems with milestones: 166; 
Medium: Number of systems: Percent of systems without milestones: 4.0; 
Medium: Population of medium systems: Total population served: 
1,596,299; 
Medium: Population of medium systems: Population in systems without 
milestones: 39,249; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 2.5. 

State: MS; 
Medium: Number of systems: Total number of systems: 189; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
1,758,806; 
Medium: Population of medium systems: Population in systems without 
milestones: 1,758,806; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: MT; 
Medium: Number of systems: Total number of systems: 28; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 258,541; 
Medium: Population of medium systems: Population in systems without 
milestones: 258,541; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: NC; 
Medium: Number of systems: Total number of systems: 226; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
2,496,100; 
Medium: Population of medium systems: Population in systems without 
milestones: 2,496,100; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: ND; 
Medium: Number of systems: Total number of systems: 19; 
Medium: Number of systems: Number of systems with milestones: 19; 
Medium: Number of systems: Percent of systems without milestones: 0.0; 
Medium: Population of medium systems: Total population served: 229,025; 
Medium: Population of medium systems: Population in systems without 
milestones: 0; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 0.0. 

State: NE; 
Medium: Number of systems: Total number of systems: 38; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 403,073; 
Medium: Population of medium systems: Population in systems without 
milestones: 403,073; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: NH; 
Medium: Number of systems: Total number of systems: 34; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 404,279; 
Medium: Population of medium systems: Population in systems without 
milestones: 404,279; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: NJ; 
Medium: Number of systems: Total number of systems: 207; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
3,419,920; 
Medium: Population of medium systems: Population in systems without 
milestones: 3,419,920; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: NM; 
Medium: Number of systems: Total number of systems: 55; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 701,119; 
Medium: Population of medium systems: Population in systems without 
milestones: 701,119; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: NV; 
Medium: Number of systems: Total number of systems: 28; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 229,455; 
Medium: Population of medium systems: Population in systems without 
milestones: 229,455; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: NY; 
Medium: Number of systems: Total number of systems: 294; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
3,698,727; 
Medium: Population of medium systems: Population in systems without 
milestones: 3,698,727; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: OH; 
Medium: Number of systems: Total number of systems: 280; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
3,593,577; 
Medium: Population of medium systems: Population in systems without 
milestones: 3,593,577; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: OK; 
Medium: Number of systems: Total number of systems: 122; 
Medium: Number of systems: Number of systems with milestones: 105; 
Medium: Number of systems: Percent of systems without milestones: 13.9; 
Medium: Population of medium systems: Total population served: 
1,225,346; 
Medium: Population of medium systems: Population in systems without 
milestones: 130,815; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 10.7. 

State: OR; 
Medium: Number of systems: Total number of systems: 94; 
Medium: Number of systems: Number of systems with milestones: 28; 
Medium: Number of systems: Percent of systems without milestones: 70.2; 
Medium: Population of medium systems: Total population served: 
1,222,949; 
Medium: Population of medium systems: Population in systems without 
milestones: 862,909; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 70.6. 

State: PA; 
Medium: Number of systems: Total number of systems: 292; 
Medium: Number of systems: Number of systems with milestones: 281; 
Medium: Number of systems: Percent of systems without milestones: 3.8; 
Medium: Population of medium systems: Total population served: 
3,685,523; 
Medium: Population of medium systems: Population in systems without 
milestones: 139,384; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 3.8. 

State: RI; 
Medium: Number of systems: Total number of systems: 22; 
Medium: Number of systems: Number of systems with milestones: 18; 
Medium: Number of systems: Percent of systems without milestones: 18.2; 
Medium: Population of medium systems: Total population served: 420,039; 
Medium: Population of medium systems: Population in systems without 
milestones: 43,700; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 10.4. 

State: SC; 
Medium: Number of systems: Total number of systems: 141; 
Medium: Number of systems: Number of systems with milestones: 141; 
Medium: Number of systems: Percent of systems without milestones: 0.0; 
Medium: Population of medium systems: Total population served: 
1,666,077; 
Medium: Population of medium systems: Population in systems without 
milestones: 0; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 0.0. 

State: SD; 
Medium: Number of systems: Total number of systems: 30; 
Medium: Number of systems: Number of systems with milestones: 30; 
Medium: Number of systems: Percent of systems without milestones: 0.0; 
Medium: Population of medium systems: Total population served: 258,637; 
Medium: Population of medium systems: Population in systems without 
milestones: 0; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 0.0. 

State: TN; 
Medium: Number of systems: Total number of systems: 236; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
2,745,416; 
Medium: Population of medium systems: Population in systems without 
milestones: 2,745,416; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: TX; 
Medium: Number of systems: Total number of systems: 750; 
Medium: Number of systems: Number of systems with milestones: 46; 
Medium: Number of systems: Percent of systems without milestones: 93.9; 
Medium: Population of medium systems: Total population served: 
7,370,002; 
Medium: Population of medium systems: Population in systems without 
milestones: 6,950,037; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 94.3. 

State: UT; 
Medium: Number of systems: Total number of systems: 85; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
1,088,639; 
Medium: Population of medium systems: Population in systems without 
milestones: 1,088,639; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: VA; 
Medium: Number of systems: Total number of systems: 126; 
Medium: Number of systems: Number of systems with milestones: 104; 
Medium: Number of systems: Percent of systems without milestones: 17.5; 
Medium: Population of medium systems: Total population served: 
1,783,530; 
Medium: Population of medium systems: Population in systems without 
milestones: 346,752; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 19.4. 

State: VT; 
Medium: Number of systems: Total number of systems: 30; 
Medium: Number of systems: Number of systems with milestones: 8; 
Medium: Number of systems: Percent of systems without milestones: 73.3; 
Medium: Population of medium systems: Total population served: 266,690; 
Medium: Population of medium systems: Population in systems without 
milestones: 151,730; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 56.9. 

State: WA; 
Medium: Number of systems: Total number of systems: 170; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
2,217,060; 
Medium: Population of medium systems: Population in systems without 
milestones: 2,217,060; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: WI; 
Medium: Number of systems: Total number of systems: 160; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 
1,696,466; 
Medium: Population of medium systems: Population in systems without 
milestones: 1,696,466; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

State: WV; 
Medium: Number of systems: Total number of systems: 80; 
Medium: Number of systems: Number of systems with milestones: 77; 
Medium: Number of systems: Percent of systems without milestones: 3.8; 
Medium: Population of medium systems: Total population served: 756,976; 
Medium: Population of medium systems: Population in systems without 
milestones: 28,025; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 3.7. 

State: WY; 
Medium: Number of systems: Total number of systems: 22; 
Medium: Number of systems: Number of systems with milestones: 0; 
Medium: Number of systems: Percent of systems without milestones: 
100.0; 
Medium: Population of medium systems: Total population served: 225,116; 
Medium: Population of medium systems: Population in systems without 
milestones: 225,116; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 100.0. 

Total/AVG; 
Medium: Number of systems: Total number of systems: 7,620; 
Medium: Number of systems: Number of systems with milestones: 2,285; 
Medium: Number of systems: Percent of systems without milestones: 70.0; 
Medium: Population of medium systems: Total population served: 
92,487,329; 
Medium: Population of medium systems: Population in systems without 
milestones: 64,944,835; 
Medium: Population of medium systems: Percent of population in systems 
without milestones: 70.2. 

Source: GAO analysis of EPA data. 

[End of table] 

State: AK; 
Small: Number of systems: Total number of systems: 412; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 128,713; 
Small: Population of small systems: Population in systems without 
milestones: 128,713; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: AL; 
Small: Number of systems: Total number of systems: 342; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 437,400; 
Small: Population of small systems: Population in systems without 
milestones: 437,400; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: AR; 
Small: Number of systems: Total number of systems: 582; 
Small: Number of systems: Number of systems with milestones: 548; 
Small: Number of systems: Percent of systems without milestones: 5.8; 
Small: Population of small systems: Total population served: 569,267; 
Small: Population of small systems: Population in systems without 
milestones: 23,567; 
Small: Population of small systems: Percent of population in systems 
without milestones: 4.1. 

State: AZ; 
Small: Number of systems: Total number of systems: 675; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 334,986; 
Small: Population of small systems: Population in systems without 
milestones: 334,986; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: CA; 
Small: Number of systems: Total number of systems: 2,488; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 995,796; 
Small: Population of small systems: Population in systems without 
milestones: 995,796; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: CO; 
Small: Number of systems: Total number of systems: 684; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 378,345; 
Small: Population of small systems: Population in systems without 
milestones: 378,345; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: CT; 
Small: Number of systems: Total number of systems: 529; 
Small: Number of systems: Number of systems with milestones: 443; 
Small: Number of systems: Percent of systems without milestones: 16.3; 
Small: Population of small systems: Total population served: 160,534; 
Small: Population of small systems: Population in systems without 
milestones: 16,676; 
Small: Population of small systems: Percent of population in systems 
without milestones: 10.4. 

State: DC; 
Small: Number of systems: Total number of systems: 1; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 0; 
Small: Population of small systems: Population in systems without 
milestones: 0; 
Small: Population of small systems: Percent of population in systems 
without milestones: N/A. 

State: DE; 
Small: Number of systems: Total number of systems: 202; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 92,110; 
Small: Population of small systems: Population in systems without 
milestones: 92,110; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: FL; 
Small: Number of systems: Total number of systems: 1,503; 
Small: Number of systems: Number of systems with milestones: 9; 
Small: Number of systems: Percent of systems without milestones: 99.4; 
Small: Population of small systems: Total population served: 799,213; 
Small: Population of small systems: Population in systems without 
milestones: 793,025; 
Small: Population of small systems: Percent of population in systems 
without milestones: 99.2. 

State: GA; 
Small: Number of systems: Total number of systems: 1,484; 
Small: Number of systems: Number of systems with milestones: 660; 
Small: Number of systems: Percent of systems without milestones: 55.5; 
Small: Population of small systems: Total population served: 601,723; 
Small: Population of small systems: Population in systems without 
milestones: 324,449; 
Small: Population of small systems: Percent of population in systems 
without milestones: 53.9. 

State: HI; 
Small: Number of systems: Total number of systems: 78; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 72,007; 
Small: Population of small systems: Population in systems without 
milestones: 72,007; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: IA; 
Small: Number of systems: Total number of systems: 1,019; 
Small: Number of systems: Number of systems with milestones: 64; 
Small: Number of systems: Percent of systems without milestones: 93.7; 
Small: Population of small systems: Total population served: 614,789; 
Small: Population of small systems: Population in systems without 
milestones: 562,918; 
Small: Population of small systems: Percent of population in systems 
without milestones: 91.6. 

State: ID; 
Small: Number of systems: Total number of systems: 707; 
Small: Number of systems: Number of systems with milestones: 81; 
Small: Number of systems: Percent of systems without milestones: 88.5; 
Small: Population of small systems: Total population served: 211,117; 
Small: Population of small systems: Population in systems without 
milestones: 182,893; 
Small: Population of small systems: Percent of population in systems 
without milestones: 86.6. 

State: IL; 
Small: Number of systems: Total number of systems: 1,367; 
Small: Number of systems: Number of systems with milestones: 1,216; 
Small: Number of systems: Percent of systems without milestones: 11.0; 
Small: Population of small systems: Total population served: 1,071,477; 
Small: Population of small systems: Population in systems without 
milestones: 92,176; 
Small: Population of small systems: Percent of population in systems 
without milestones: 8.6. 

State: IN; 
Small: Number of systems: Total number of systems: 638; 
Small: Number of systems: Number of systems with milestones: 628; 
Small: Number of systems: Percent of systems without milestones: 1.6; 
Small: Population of small systems: Total population served: 503,685; 
Small: Population of small systems: Population in systems without 
milestones: 4,818; 
Small: Population of small systems: Percent of population in systems 
without milestones: 1.0. 

State: KS; 
Small: Number of systems: Total number of systems: 824; 
Small: Number of systems: Number of systems with milestones: 649; 
Small: Number of systems: Percent of systems without milestones: 21.2; 
Small: Population of small systems: Total population served: 560,103; 
Small: Population of small systems: Population in systems without 
milestones: 115,971; 
Small: Population of small systems: Percent of population in systems 
without milestones: 20.7. 

State: KY; 
Small: Number of systems: Total number of systems: 179; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 259,090; 
Small: Population of small systems: Population in systems without 
milestones: 259,090; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: LA; 
Small: Number of systems: Total number of systems: 893; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 743,960; 
Small: Population of small systems: Population in systems without 
milestones: 743,960; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: MA; 
Small: Number of systems: Total number of systems: 278; 
Small: Number of systems: Number of systems with milestones: 83; 
Small: Number of systems: Percent of systems without milestones: 70.1; 
Small: Population of small systems: Total population served: 161,166; 
Small: Population of small systems: Population in systems without 
milestones: 110,437; 
Small: Population of small systems: Percent of population in systems 
without milestones: 68.5. 

State: MD; 
Small: Number of systems: Total number of systems: 440; 
Small: Number of systems: Number of systems with milestones: 271; 
Small: Number of systems: Percent of systems without milestones: 38.4; 
Small: Population of small systems: Total population served: 217,804; 
Small: Population of small systems: Population in systems without 
milestones: 87,464; 
Small: Population of small systems: Percent of population in systems 
without milestones: 40.2. 

State: ME; 
Small: Number of systems: Total number of systems: 366; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 165,359; 
Small: Population of small systems: Population in systems without 
milestones: 165,359; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: MI; 
Small: Number of systems: Total number of systems: 1,158; 
Small: Number of systems: Number of systems with milestones: 971; 
Small: Number of systems: Percent of systems without milestones: 16.1; 
Small: Population of small systems: Total population served: 716,406; 
Small: Population of small systems: Population in systems without 
milestones: 173,559; 
Small: Population of small systems: Percent of population in systems 
without milestones: 24.2. 

State: MN; 
Small: Number of systems: Total number of systems: 811; 
Small: Number of systems: Number of systems with milestones: 143; 
Small: Number of systems: Percent of systems without milestones: 82.4; 
Small: Population of small systems: Total population served: 531,720; 
Small: Population of small systems: Population in systems without 
milestones: 395,653; 
Small: Population of small systems: Percent of population in systems 
without milestones: 74.4. 

State: MO; 
Small: Number of systems: Total number of systems: 1,281; 
Small: Number of systems: Number of systems with milestones: 1,168; 
Small: Number of systems: Percent of systems without milestones: 8.8; 
Small: Population of small systems: Total population served: 739,179; 
Small: Population of small systems: Population in systems without 
milestones: 38,519; 
Small: Population of small systems: Percent of population in systems 
without milestones: 5.2. 

State: MS; 
Small: Number of systems: Total number of systems: 980; 
Small: Number of systems: Number of systems with milestones: 1; 
Small: Number of systems: Percent of systems without milestones: 99.9; 
Small: Population of small systems: Total population served: 1,032,244; 
Small: Population of small systems: Population in systems without 
milestones: 1,031,729; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: MT; 
Small: Number of systems: Total number of systems: 647; 
Small: Number of systems: Number of systems with milestones: 2; 
Small: Number of systems: Percent of systems without milestones: 99.7; 
Small: Population of small systems: Total population served: 206,237; 
Small: Population of small systems: Population in systems without 
milestones: 203,914; 
Small: Population of small systems: Percent of population in systems 
without milestones: 98.9. 

State: NC; 
Small: Number of systems: Total number of systems: 1,924; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 726,326; 
Small: Population of small systems: Population in systems without 
milestones: 726,326; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: ND; 
Small: Number of systems: Total number of systems: 299; 
Small: Number of systems: Number of systems with milestones: 284; 
Small: Number of systems: Percent of systems without milestones: 5.0; 
Small: Population of small systems: Total population served: 177,573; 
Small: Population of small systems: Population in systems without 
milestones: 8,747; 
Small: Population of small systems: Percent of population in systems 
without milestones: 4.9. 

State: NE; 
Small: Number of systems: Total number of systems: 566; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 304,924; 
Small: Population of small systems: Population in systems without 
milestones: 304,924; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: NH; 
Small: Number of systems: Total number of systems: 662; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 200,898; 
Small: Population of small systems: Population in systems without 
milestones: 200,898; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: NJ; 
Small: Number of systems: Total number of systems: 381; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 257,045; 
Small: Population of small systems: Population in systems without 
milestones: 257,045; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: NM; 
Small: Number of systems: Total number of systems: 586; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 251,374; 
Small: Population of small systems: Population in systems without 
milestones: 251,374; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: NV; 
Small: Number of systems: Total number of systems: 220; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 106,349; 
Small: Population of small systems: Population in systems without 
milestones: 106,349; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: NY; 
Small: Number of systems: Total number of systems: 2,492; 
Small: Number of systems: Number of systems with milestones: 1; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 1,131,590; 
Small: Population of small systems: Population in systems without 
milestones: 1,131,240; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: OH; 
Small: Number of systems: Total number of systems: 1,014; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 739,441; 
Small: Population of small systems: Population in systems without 
milestones: 739,441; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: OK; 
Small: Number of systems: Total number of systems: 1,004; 
Small: Number of systems: Number of systems with milestones: 378; 
Small: Number of systems: Percent of systems without milestones: 62.4; 
Small: Population of small systems: Total population served: 679,858; 
Small: Population of small systems: Population in systems without 
milestones: 332,062; 
Small: Population of small systems: Percent of population in systems 
without milestones: 48.8. 

State: OR; 
Small: Number of systems: Total number of systems: 769; 
Small: Number of systems: Number of systems with milestones: 108; 
Small: Number of systems: Percent of systems without milestones: 86.0; 
Small: Population of small systems: Total population served: 324,386; 
Small: Population of small systems: Population in systems without 
milestones: 251,660; 
Small: Population of small systems: Percent of population in systems 
without milestones: 77.6. 

State: PA; 
Small: Number of systems: Total number of systems: 1,813; 
Small: Number of systems: Number of systems with milestones: 1,670; 
Small: Number of systems: Percent of systems without milestones: 7.9; 
Small: Population of small systems: Total population served: 960,679; 
Small: Population of small systems: Population in systems without 
milestones: 50,135; 
Small: Population of small systems: Percent of population in systems 
without milestones: 5.2. 

State: RI; 
Small: Number of systems: Total number of systems: 57; 
Small: Number of systems: Number of systems with milestones: 40; 
Small: Number of systems: Percent of systems without milestones: 29.8; 
Small: Population of small systems: Total population served: 26,914; 
Small: Population of small systems: Population in systems without 
milestones: 10,630; 
Small: Population of small systems: Percent of population in systems 
without milestones: 39.5. 

State: SC; 
Small: Number of systems: Total number of systems: 506; 
Small: Number of systems: Number of systems with milestones: 483; 
Small: Number of systems: Percent of systems without milestones: 4.5; 
Small: Population of small systems: Total population served: 270,387; 
Small: Population of small systems: Population in systems without 
milestones: 8,152; 
Small: Population of small systems: Percent of population in systems 
without milestones: 3.0. 

State: SD; 
Small: Number of systems: Total number of systems: 435; 
Small: Number of systems: Number of systems with milestones: 382; 
Small: Number of systems: Percent of systems without milestones: 12.2; 
Small: Population of small systems: Total population served: 216,413; 
Small: Population of small systems: Population in systems without 
milestones: 12,348; 
Small: Population of small systems: Percent of population in systems 
without milestones: 5.7. 

State: TN; 
Small: Number of systems: Total number of systems: 430; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 417,026; 
Small: Population of small systems: Population in systems without 
milestones: 417,026; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: TX; 
Small: Number of systems: Total number of systems: 3,683; 
Small: Number of systems: Number of systems with milestones: 165; 
Small: Number of systems: Percent of systems without milestones: 95.5; 
Small: Population of small systems: Total population served: 2,724,725; 
Small: Population of small systems: Population in systems without 
milestones: 2,554,606; 
Small: Population of small systems: Percent of population in systems 
without milestones: 93.8. 

State: UT; 
Small: Number of systems: Total number of systems: 356; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 208,654; 
Small: Population of small systems: Population in systems without 
milestones: 208,654; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: VA; 
Small: Number of systems: Total number of systems: 1,117; 
Small: Number of systems: Number of systems with milestones: 874; 
Small: Number of systems: Percent of systems without milestones: 21.8; 
Small: Population of small systems: Total population served: 482,223; 
Small: Population of small systems: Population in systems without 
milestones: 95,023; 
Small: Population of small systems: Percent of population in systems 
without milestones: 19.7. 

State: VT; 
Small: Number of systems: Total number of systems: 405; 
Small: Number of systems: Number of systems with milestones: 42; 
Small: Number of systems: Percent of systems without milestones: 89.6; 
Small: Population of small systems: Total population served: 172,502; 
Small: Population of small systems: Population in systems without 
milestones: 138,701; 
Small: Population of small systems: Percent of population in systems 
without milestones: 80.4. 

State: WA; 
Small: Number of systems: Total number of systems: 2,084; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 693,052; 
Small: Population of small systems: Population in systems without 
milestones: 693,052; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: WI; 
Small: Number of systems: Total number of systems: 913; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 517,366; 
Small: Population of small systems: Population in systems without 
milestones: 517,366; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

State: WV; 
Small: Number of systems: Total number of systems: 455; 
Small: Number of systems: Number of systems with milestones: 432; 
Small: Number of systems: Percent of systems without milestones: 5.1; 
Small: Population of small systems: Total population served: 413,870; 
Small: Population of small systems: Population in systems without 
milestones: 10,363; 
Small: Population of small systems: Percent of population in systems 
without milestones: 2.5. 

State: WY; 
Small: Number of systems: Total number of systems: 252; 
Small: Number of systems: Number of systems with milestones: 0; 
Small: Number of systems: Percent of systems without milestones: 100.0; 
Small: Population of small systems: Total population served: 103,403; 
Small: Population of small systems: Population in systems without 
milestones: 103,403; 
Small: Population of small systems: Percent of population in systems 
without milestones: 100.0. 

Total/AVG; 
Small: Number of systems: Total number of systems: 42,991; 
Small: Number of systems: Number of systems with milestones: 11,796; 
Small: Number of systems: Percent of systems without milestones: 72.6; 
Small: Population of small systems: Total population served: 
24,411,408; 
Small: Population of small systems: Population in systems without 
milestones: 16,895,059; 
Small: Population of small systems: Percent of population in systems 
without milestones: 69.2. 

Source: GAO analysis of EPA data. 

[End of table] 

[End of section] 

Appendix III: Number of Lead Rule Violations Reported to EPA Between 
1995 and June 2005 (by State): 

State: AK; 
Number of systems: 436; 
Number of violations: TT: 4; 
Number of violations: MR: 586; 
Number of violations: Total: 590; 
Number of systems with violations: TT: 3; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.7; 
Number of systems with violations: MR: 252; 
Number of systems with violations: Percent of total systems with MR 
violations: 57.8; 
Number of systems with violations: Total: 254; 
Number of systems with violations: Percent of total systems with 
violations: 58.3. 

State: AL; 
Number of systems: 619; 
Number of violations: TT: 0; 
Number of violations: MR: 91; 
Number of violations: Total: 91; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 65; 
Number of systems with violations: Percent of total systems with MR 
violations: 10.5; 
Number of systems with violations: Total: 65; 
Number of systems with violations: Percent of total systems with 
violations: 10.5. 

State: AR; 
Number of systems: 729; 
Number of violations: TT: 28; 
Number of violations: MR: 38; 
Number of violations: Total: 66; 
Number of systems with violations: TT: 23; 
Number of systems with violations: Percent of total systems with TT 
violations: 3.2; 
Number of systems with violations: MR: 32; 
Number of systems with violations: Percent of total systems with MR 
violations: 4.4; 
Number of systems with violations: Total: 50; 
Number of systems with violations: Percent of total systems with 
violations: 6.9. 

State: AZ; 
Number of systems: 793; 
Number of violations: TT: 0; 
Number of violations: MR: 1,100; 
Number of violations: Total: 1,100; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 419; 
Number of systems with violations: Percent of total systems with MR 
violations: 52.8; 
Number of systems with violations: Total: 419; 
Number of systems with violations: Percent of total systems with 
violations: 52.8. 

State: CA; 
Number of systems: 3,126; 
Number of violations: TT: 0; 
Number of violations: MR: 144; 
Number of violations: Total: 144; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 136; 
Number of systems with violations: Percent of total systems with MR 
violations: 4.4; 
Number of systems with violations: Total: 136; 
Number of systems with violations: Percent of total systems with 
violations: 4.4. 

State: CO; 
Number of systems: 831; 
Number of violations: TT: 28; 
Number of violations: MR: 262; 
Number of violations: Total: 290; 
Number of systems with violations: TT: 10; 
Number of systems with violations: Percent of total systems with TT 
violations: 1.2; 
Number of systems with violations: MR: 195; 
Number of systems with violations: Percent of total systems with MR 
violations: 23.5; 
Number of systems with violations: Total: 201; 
Number of systems with violations: Percent of total systems with 
violations: 24.2. 

State: CT; 
Number of systems: 586; 
Number of violations: TT: 29; 
Number of violations: MR: 232; 
Number of violations: Total: 261; 
Number of systems with violations: TT: 25; 
Number of systems with violations: Percent of total systems with TT 
violations: 4.3; 
Number of systems with violations: MR: 168; 
Number of systems with violations: Percent of total systems with MR 
violations: 28.7; 
Number of systems with violations: Total: 176; 
Number of systems with violations: Percent of total systems with 
violations: 30.0. 

State: DE; 
Number of systems: 229; 
Number of violations: TT: 0; 
Number of violations: MR: 3; 
Number of violations: Total: 3; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 3; 
Number of systems with violations: Percent of total systems with MR 
violations: 1.3; 
Number of systems with violations: Total: 3; 
Number of systems with violations: Percent of total systems with 
violations: 1.3. 

State: FL; 
Number of systems: 1,889; 
Number of violations: TT: 10; 
Number of violations: MR: 74; 
Number of violations: Total: 84; 
Number of systems with violations: TT: 10; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.5; 
Number of systems with violations: MR: 68; 
Number of systems with violations: Percent of total systems with MR 
violations: 3.6; 
Number of systems with violations: Total: 76; 
Number of systems with violations: Percent of total systems with 
violations: 4.0. 

State: GA; 
Number of systems: 1,691; 
Number of violations: TT: 8; 
Number of violations: MR: 1,927; 
Number of violations: Total: 1,935; 
Number of systems with violations: TT: 8; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.5; 
Number of systems with violations: MR: 1,015; 
Number of systems with violations: Percent of total systems with MR 
violations: 60.0; 
Number of systems with violations: Total: 1,016; 
Number of systems with violations: Percent of total systems with 
violations: 60.1. 

State: HI; 
Number of systems: 115; 
Number of violations: TT: 0; 
Number of violations: MR: 0; 
Number of violations: Total: 0; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 0; 
Number of systems with violations: Percent of total systems with MR 
violations: 0.0; 
Number of systems with violations: Total: 0; 
Number of systems with violations: Percent of total systems with 
violations: 0.0. 

State: IA; 
Number of systems: 1,143; 
Number of violations: TT: 1; 
Number of violations: MR: 100; 
Number of violations: Total: 101; 
Number of systems with violations: TT: 1; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.1; 
Number of systems with violations: MR: 85; 
Number of systems with violations: Percent of total systems with MR 
violations: 7.4; 
Number of systems with violations: Total: 86; 
Number of systems with violations: Percent of total systems with 
violations: 7.5. 

State: ID; 
Number of systems: 752; 
Number of violations: TT: 9; 
Number of violations: MR: 866; 
Number of violations: Total: 875; 
Number of systems with violations: TT: 9; 
Number of systems with violations: Percent of total systems with TT 
violations: 1.2; 
Number of systems with violations: MR: 269; 
Number of systems with violations: Percent of total systems with MR 
violations: 35.8; 
Number of systems with violations: Total: 274; 
Number of systems with violations: Percent of total systems with 
violations: 36.4. 

State: IL; 
Number of systems: 1,793; 
Number of violations: TT: 292; 
Number of violations: MR: 670; 
Number of violations: Total: 962; 
Number of systems with violations: TT: 170; 
Number of systems with violations: Percent of total systems with TT 
violations: 9.5; 
Number of systems with violations: MR: 330; 
Number of systems with violations: Percent of total systems with MR 
violations: 18.4; 
Number of systems with violations: Total: 423; 
Number of systems with violations: Percent of total systems with 
violations: 23.6. 

State: IN; 
Number of systems: 840; 
Number of violations: TT: 90; 
Number of violations: MR: 279; 
Number of violations: Total: 369; 
Number of systems with violations: TT: 54; 
Number of systems with violations: Percent of total systems with TT 
violations: 6.4; 
Number of systems with violations: MR: 127; 
Number of systems with violations: Percent of total systems with MR 
violations: 15.1; 
Number of systems with violations: Total: 138; 
Number of systems with violations: Percent of total systems with 
violations: 16.4. 

State: KS; 
Number of systems: 911; 
Number of violations: TT: 62; 
Number of violations: MR: 105; 
Number of violations: Total: 167; 
Number of systems with violations: TT: 44; 
Number of systems with violations: Percent of total systems with TT 
violations: 4.8; 
Number of systems with violations: MR: 83; 
Number of systems with violations: Percent of total systems with MR 
violations: 9.1; 
Number of systems with violations: Total: 119; 
Number of systems with violations: Percent of total systems with 
violations: 13.1. 

State: KY; 
Number of systems: 418; 
Number of violations: TT: 0; 
Number of violations: MR: 200; 
Number of violations: Total: 200; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 147; 
Number of systems with violations: Percent of total systems with MR 
violations: 35.2; 
Number of systems with violations: Total: 147; 
Number of systems with violations: Percent of total systems with 
violations: 35.2. 

State: LA; 
Number of systems: 1,111; 
Number of violations: TT: 0; 
Number of violations: MR: 132; 
Number of violations: Total: 132; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 132; 
Number of systems with violations: Percent of total systems with MR 
violations: 11.9; 
Number of systems with violations: Total: 132; 
Number of systems with violations: Percent of total systems with 
violations: 11.9. 

State: MA; 
Number of systems: 524; 
Number of violations: TT: 81; 
Number of violations: MR: 219; 
Number of violations: Total: 300; 
Number of systems with violations: TT: 60; 
Number of systems with violations: Percent of total systems with TT 
violations: 11.5; 
Number of systems with violations: MR: 137; 
Number of systems with violations: Percent of total systems with MR 
violations: 26.1; 
Number of systems with violations: Total: 189; 
Number of systems with violations: Percent of total systems with 
violations: 36.1. 

State: MD; 
Number of systems: 502; 
Number of violations: TT: 69; 
Number of violations: MR: 231; 
Number of violations: Total: 300; 
Number of systems with violations: TT: 40; 
Number of systems with violations: Percent of total systems with TT 
violations: 8.0; 
Number of systems with violations: MR: 156; 
Number of systems with violations: Percent of total systems with MR 
violations: 31.1; 
Number of systems with violations: Total: 165; 
Number of systems with violations: Percent of total systems with 
violations: 32.9. 

State: ME; 
Number of systems: 399; 
Number of violations: TT: 63; 
Number of violations: MR: 188; 
Number of violations: Total: 251; 
Number of systems with violations: TT: 44; 
Number of systems with violations: Percent of total systems with TT 
violations: 11.0; 
Number of systems with violations: MR: 88; 
Number of systems with violations: Percent of total systems with MR 
violations: 22.1; 
Number of systems with violations: Total: 107; 
Number of systems with violations: Percent of total systems with 
violations: 26.8. 

State: MI; 
Number of systems: 1,438; 
Number of violations: TT: 9; 
Number of violations: MR: 116; 
Number of violations: Total: 125; 
Number of systems with violations: TT: 8; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.6; 
Number of systems with violations: MR: 101; 
Number of systems with violations: Percent of total systems with MR 
violations: 7.0; 
Number of systems with violations: Total: 107; 
Number of systems with violations: Percent of total systems with 
violations: 7.4. 

State: MN; 
Number of systems: 965; 
Number of violations: TT: 3; 
Number of violations: MR: 104; 
Number of violations: Total: 107; 
Number of systems with violations: TT: 3; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.3; 
Number of systems with violations: MR: 76; 
Number of systems with violations: Percent of total systems with MR 
violations: 7.9; 
Number of systems with violations: Total: 77; 
Number of systems with violations: Percent of total systems with 
violations: 8.0. 

State: MO; 
Number of systems: 1,465; 
Number of violations: TT: 2; 
Number of violations: MR: 420; 
Number of violations: Total: 422; 
Number of systems with violations: TT: 2; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.1; 
Number of systems with violations: MR: 330; 
Number of systems with violations: Percent of total systems with MR 
violations: 22.5; 
Number of systems with violations: Total: 332; 
Number of systems with violations: Percent of total systems with 
violations: 22.7. 

State: MS; 
Number of systems: 1,171; 
Number of violations: TT: 0; 
Number of violations: MR: 35; 
Number of violations: Total: 35; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 32; 
Number of systems with violations: Percent of total systems with MR 
violations: 2.7; 
Number of systems with violations: Total: 32; 
Number of systems with violations: Percent of total systems with 
violations: 2.7. 

State: MT; 
Number of systems: 678; 
Number of violations: TT: 8; 
Number of violations: MR: 590; 
Number of violations: Total: 598; 
Number of systems with violations: TT: 8; 
Number of systems with violations: Percent of total systems with TT 
violations: 1.2; 
Number of systems with violations: MR: 225; 
Number of systems with violations: Percent of total systems with MR 
violations: 33.2; 
Number of systems with violations: Total: 228; 
Number of systems with violations: Percent of total systems with 
violations: 33.6. 

State: NC; 
Number of systems: 2,174; 
Number of violations: TT: 233; 
Number of violations: MR: 411; 
Number of violations: Total: 644; 
Number of systems with violations: TT: 143; 
Number of systems with violations: Percent of total systems with TT 
violations: 6.6; 
Number of systems with violations: MR: 269; 
Number of systems with violations: Percent of total systems with MR 
violations: 12.4; 
Number of systems with violations: Total: 356; 
Number of systems with violations: Percent of total systems with 
violations: 16.4. 

State: ND; 
Number of systems: 320; 
Number of violations: TT: 7; 
Number of violations: MR: 36; 
Number of violations: Total: 43; 
Number of systems with violations: TT: 6; 
Number of systems with violations: Percent of total systems with TT 
violations: 1.9; 
Number of systems with violations: MR: 16; 
Number of systems with violations: Percent of total systems with MR 
violations: 5.0; 
Number of systems with violations: Total: 20; 
Number of systems with violations: Percent of total systems with 
violations: 6.3. 

State: NE; 
Number of systems: 606; 
Number of violations: TT: 59; 
Number of violations: MR: 4; 
Number of violations: Total: 63; 
Number of systems with violations: TT: 58; 
Number of systems with violations: Percent of total systems with TT 
violations: 9.6; 
Number of systems with violations: MR: 4; 
Number of systems with violations: Percent of total systems with MR 
violations: 0.7; 
Number of systems with violations: Total: 62; 
Number of systems with violations: Percent of total systems with 
violations: 10.2. 

State: NH; 
Number of systems: 698; 
Number of violations: TT: 18; 
Number of violations: MR: 107; 
Number of violations: Total: 125; 
Number of systems with violations: TT: 14; 
Number of systems with violations: Percent of total systems with TT 
violations: 2.0; 
Number of systems with violations: MR: 91; 
Number of systems with violations: Percent of total systems with MR 
violations: 13.0; 
Number of systems with violations: Total: 100; 
Number of systems with violations: Percent of total systems with 
violations: 14.3. 

State: NJ; 
Number of systems: 609; 
Number of violations: TT: 3; 
Number of violations: MR: 108; 
Number of violations: Total: 111; 
Number of systems with violations: TT: 3; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.5; 
Number of systems with violations: MR: 79; 
Number of systems with violations: Percent of total systems with MR 
violations: 13.0; 
Number of systems with violations: Total: 81; 
Number of systems with violations: Percent of total systems with 
violations: 13.3. 

State: NM; 
Number of systems: 645; 
Number of violations: TT: 0; 
Number of violations: MR: 54; 
Number of violations: Total: 54; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 49; 
Number of systems with violations: Percent of total systems with MR 
violations: 7.6; 
Number of systems with violations: Total: 49; 
Number of systems with violations: Percent of total systems with 
violations: 7.6. 

State: NV; 
Number of systems: 253; 
Number of violations: TT: 1; 
Number of violations: MR: 113; 
Number of violations: Total: 114; 
Number of systems with violations: TT: 1; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.4; 
Number of systems with violations: MR: 84; 
Number of systems with violations: Percent of total systems with MR 
violations: 33.2; 
Number of systems with violations: Total: 84; 
Number of systems with violations: Percent of total systems with 
violations: 33.2. 

State: NY; 
Number of systems: 2,818; 
Number of violations: TT: 62; 
Number of violations: MR: 451; 
Number of violations: Total: 513; 
Number of systems with violations: TT: 52; 
Number of systems with violations: Percent of total systems with TT 
violations: 1.8; 
Number of systems with violations: MR: 327; 
Number of systems with violations: Percent of total systems with MR 
violations: 11.6; 
Number of systems with violations: Total: 362; 
Number of systems with violations: Percent of total systems with 
violations: 12.8. 

State: OH; 
Number of systems: 1,321; 
Number of violations: TT: 38; 
Number of violations: MR: 767; 
Number of violations: Total: 805; 
Number of systems with violations: TT: 35; 
Number of systems with violations: Percent of total systems with TT 
violations: 2.6; 
Number of systems with violations: MR: 421; 
Number of systems with violations: Percent of total systems with MR 
violations: 31.9; 
Number of systems with violations: Total: 436; 
Number of systems with violations: Percent of total systems with 
violations: 33.0. 

State: OK; 
Number of systems: 1,135; 
Number of violations: TT: 2; 
Number of violations: MR: 311; 
Number of violations: Total: 313; 
Number of systems with violations: TT: 1; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.1; 
Number of systems with violations: MR: 120; 
Number of systems with violations: Percent of total systems with MR 
violations: 10.6; 
Number of systems with violations: Total: 120; 
Number of systems with violations: Percent of total systems with 
violations: 10.6. 

State: OR; 
Number of systems: 874; 
Number of violations: TT: 138; 
Number of violations: MR: 94; 
Number of violations: Total: 232; 
Number of systems with violations: TT: 94; 
Number of systems with violations: Percent of total systems with TT 
violations: 10.8; 
Number of systems with violations: MR: 65; 
Number of systems with violations: Percent of total systems with MR 
violations: 7.4; 
Number of systems with violations: Total: 127; 
Number of systems with violations: Percent of total systems with 
violations: 14.5. 

State: PA; 
Number of systems: 2,136; 
Number of violations: TT: 75; 
Number of violations: MR: 800; 
Number of violations: Total: 875; 
Number of systems with violations: TT: 72; 
Number of systems with violations: Percent of total systems with TT 
violations: 3.4; 
Number of systems with violations: MR: 528; 
Number of systems with violations: Percent of total systems with MR 
violations: 24.7; 
Number of systems with violations: Total: 572; 
Number of systems with violations: Percent of total systems with 
violations: 26.8. 

State: RI; 
Number of systems: 83; 
Number of violations: TT: 1; 
Number of violations: MR: 4; 
Number of violations: Total: 5; 
Number of systems with violations: TT: 1; 
Number of systems with violations: Percent of total systems with TT 
violations: 1.2; 
Number of systems with violations: MR: 4; 
Number of systems with violations: Percent of total systems with MR 
violations: 4.8; 
Number of systems with violations: Total: 4; 
Number of systems with violations: Percent of total systems with 
violations: 4.8. 

State: SC; 
Number of systems: 659; 
Number of violations: TT: 92; 
Number of violations: MR: 365; 
Number of violations: Total: 457; 
Number of systems with violations: TT: 60; 
Number of systems with violations: Percent of total systems with TT 
violations: 9.1; 
Number of systems with violations: MR: 218; 
Number of systems with violations: Percent of total systems with MR 
violations: 33.1; 
Number of systems with violations: Total: 238; 
Number of systems with violations: Percent of total systems with 
violations: 36.1. 

State: SD; 
Number of systems: 467; 
Number of violations: TT: 4; 
Number of violations: MR: 431; 
Number of violations: Total: 435; 
Number of systems with violations: TT: 4; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.9; 
Number of systems with violations: MR: 211; 
Number of systems with violations: Percent of total systems with MR 
violations: 45.2; 
Number of systems with violations: Total: 213; 
Number of systems with violations: Percent of total systems with 
violations: 45.6. 

State: TN; 
Number of systems: 681; 
Number of violations: TT: 0; 
Number of violations: MR: 36; 
Number of violations: Total: 36; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 19; 
Number of systems with violations: Percent of total systems with MR 
violations: 2.8; 
Number of systems with violations: Total: 19; 
Number of systems with violations: Percent of total systems with 
violations: 2.8. 

State: TX; 
Number of systems: 4,489; 
Number of violations: TT: 46; 
Number of violations: MR: 54; 
Number of violations: Total: 100; 
Number of systems with violations: TT: 29; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.6; 
Number of systems with violations: MR: 54; 
Number of systems with violations: Percent of total systems with MR 
violations: 1.2; 
Number of systems with violations: Total: 81; 
Number of systems with violations: Percent of total systems with 
violations: 1.8. 

State: UT; 
Number of systems: 451; 
Number of violations: TT: 0; 
Number of violations: MR: 315; 
Number of violations: Total: 315; 
Number of systems with violations: TT: 0; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.0; 
Number of systems with violations: MR: 186; 
Number of systems with violations: Percent of total systems with MR 
violations: 41.2; 
Number of systems with violations: Total: 186; 
Number of systems with violations: Percent of total systems with 
violations: 41.2. 

State: VA; 
Number of systems: 1,265; 
Number of violations: TT: 52; 
Number of violations: MR: 253; 
Number of violations: Total: 305; 
Number of systems with violations: TT: 47; 
Number of systems with violations: Percent of total systems with TT 
violations: 3.7; 
Number of systems with violations: MR: 185; 
Number of systems with violations: Percent of total systems with MR 
violations: 14.6; 
Number of systems with violations: Total: 221; 
Number of systems with violations: Percent of total systems with 
violations: 17.5. 

State: VT; 
Number of systems: 435; 
Number of violations: TT: 8; 
Number of violations: MR: 135; 
Number of violations: Total: 143; 
Number of systems with violations: TT: 7; 
Number of systems with violations: Percent of total systems with TT 
violations: 1.6; 
Number of systems with violations: MR: 108; 
Number of systems with violations: Percent of total systems with MR 
violations: 24.8; 
Number of systems with violations: Total: 114; 
Number of systems with violations: Percent of total systems with 
violations: 26.2. 

State: WA; 
Number of systems: 2,277; 
Number of violations: TT: 4; 
Number of violations: MR: 1,548; 
Number of violations: Total: 1,552; 
Number of systems with violations: TT: 4; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.2; 
Number of systems with violations: MR: 1,272; 
Number of systems with violations: Percent of total systems with MR 
violations: 55.9; 
Number of systems with violations: Total: 1,276; 
Number of systems with violations: Percent of total systems with 
violations: 56.0. 

State: WI; 
Number of systems: 1,086; 
Number of violations: TT: 10; 
Number of violations: MR: 210; 
Number of violations: Total: 220; 
Number of systems with violations: TT: 8; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.7; 
Number of systems with violations: MR: 129; 
Number of systems with violations: Percent of total systems with MR 
violations: 11.9; 
Number of systems with violations: Total: 134; 
Number of systems with violations: Percent of total systems with 
violations: 12.3. 

State: WV; 
Number of systems: 537; 
Number of violations: TT: 3; 
Number of violations: MR: 335; 
Number of violations: Total: 338; 
Number of systems with violations: TT: 3; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.6; 
Number of systems with violations: MR: 153; 
Number of systems with violations: Percent of total systems with MR 
violations: 28.5; 
Number of systems with violations: Total: 154; 
Number of systems with violations: Percent of total systems with 
violations: 28.7. 

State: WY; 
Number of systems: 276; 
Number of violations: TT: 1; 
Number of violations: MR: 98; 
Number of violations: Total: 99; 
Number of systems with violations: TT: 1; 
Number of systems with violations: Percent of total systems with TT 
violations: 0.4; 
Number of systems with violations: MR: 80; 
Number of systems with violations: Percent of total systems with MR 
violations: 29.0; 
Number of systems with violations: Total: 80; 
Number of systems with violations: Percent of total systems with 
violations: 29.0. 

State: Total; 
Number of systems: 51,449; 
Number of violations: TT: 1,653; 
Number of violations: MR: 15,752; 
Number of violations: Total: 17,405; 
Number of systems with violations: TT: 1,165; 
Number of systems with violations: Percent of total systems with TT 
violations: 2.3; 
Number of systems with violations: MR: 9,343; 
Number of systems with violations: Percent of total systems with MR 
violations: 18.2; 
Number of systems with violations: Total: 10,041; 
Number of systems with violations: Percent of total systems with 
violations: 19.5. 

Legend: TT = treatment technique violations, including failure to 
install optimal corrosion control treatment, failure to meet water 
quality control parameters, failure to replace lead service lines, and 
failure to meet public education requirements, among other things. 

MR = monitoring and reporting violations, including the failure to 
conduct required testing and failure to report the results. 

Source: GAO analysis of EPA data. 

Note: The total number of systems with violations, and the numbers of 
systems with TT and MR violations do not add to the total numbers of 
violations because in some cases, systems have more than one type of 
violation. 

[End of table] 

[End of section] 

Appendix IV: Information on Selected EPA and State Enforcement Actions, 
by Type, from 1995 to June 2005[A]: 

Public notification requested: 

Type of Action: State; 
Year: 1995: 1,359; 
Year: 1996: 1,070; 
Year: 1997: 1,190; 
Year: 1998: 1,223; 
Year: 1999: 1,097; 
Year: 2000: 791; 
Year: 2001: 988; 
Year: 2002: 934; 
Year: 2003: 1,136; 
Year: 2004: 940; 
Year: 2005: 1,174; 
Totals: 11,902. 

Type of Action: Federal; 
Year: 1995: 277; 
Year: 1996: 28; 
Year: 1997: 15; 
Year: 1998: 5; 
Year: 1999: 6; 
Year: 2000: 8; 
Year: 2001: 3; 
Year: 2002: 9; 
Year: 2003: 1; 
Year: 2004: 1; 
Year: 2005: 3; 
Totals: 356. 

Type of Action: Formal notice of violation: 

Type of Action: State; 
Year: 1995: 969; 
Year: 1996: 700; 
Year: 1997: 526; 
Year: 1998: 452; 
Year: 1999: 499; 
Year: 2000: 602; 
Year: 2001: 606; 
Year: 2002: 581; 
Year: 2003: 649; 
Year: 2004: 549; 
Year: 2005: 647; 
Totals: 6,780. 

Type of Action: Federal; 
Year: 1995: 614; 
Year: 1996: 273; 
Year: 1997: 83; 
Year: 1998: 177; 
Year: 1999: 73; 
Year: 2000: 39; 
Year: 2001: 91; 
Year: 2002: 4; 
Year: 2003: 8; 
Year: 2004: 22; 
Year: 2005: 6; 
Totals: 1,390. 

Type of Action: Bilateral compliance agreement: 

Type of Action: State; 
Year: 1995: 52; 
Year: 1996: 119; 
Year: 1997: 79; 
Year: 1998: 87; 
Year: 1999: 60; 
Year: 2000: 40; 
Year: 2001: 69; 
Year: 2002: 91; 
Year: 2003: 99; 
Year: 2004: 89; 
Year: 2005: 24; 
Totals: 837. 

Type of Action: Federal; 
Year: 1995: 0; 
Year: 1996: 5; 
Year: 1997: 1; 
Year: 1998: 2; 
Year: 1999: 0; 
Year: 2000: 0; 
Year: 2001: 0; 
Year: 2002: 0; 
Year: 2003: 1; 
Year: 2004: 0; 
Year: 2005: 0; 
Totals: 9. 

Type of Action: Administrative orders: 

Type of Action: State (without penalties); 
Year: 1995: 107; 
Year: 1996: 93; 
Year: 1997: 89; 
Year: 1998: 114; 
Year: 1999: 83; 
Year: 2000: 45; 
Year: 2001: 89; 
Year: 2002: 68; 
Year: 2003: 71; 
Year: 2004: 78; 
Year: 2005: 21; 
Totals: 837. 

Type of Action: State (with penalties); 
Year: 1995: 84; 
Year: 1996: 67; 
Year: 1997: 42; 
Year: 1998: 319; 
Year: 1999: 97; 
Year: 2000: 52; 
Year: 2001: 52; 
Year: 2002: 56; 
Year: 2003: 49; 
Year: 2004: 57; 
Year: 2005: 5; 
Totals: 880. 

Type of Action: Federal (proposed); 
Year: 1995: 561; 
Year: 1996: 153; 
Year: 1997: 4; 
Year: 1998: 1; 
Year: 1999: 0; 
Year: 2000: 0; 
Year: 2001: 0; 
Year: 2002: 3; 
Year: 2003: 0; 
Year: 2004: 0; 
Year: 2005: 0; 
Totals: 272. 

Type of Action: Federal (final); 
Year: 1995: 145; 
Year: 1996: 146; 
Year: 1997: 197; 
Year: 1998: 64; 
Year: 1999: 29; 
Year: 2000: 13; 
Year: 2001: 9; 
Year: 2002: 10; 
Year: 2003: 24; 
Year: 2004: 17; 
Year: 2005: 5; 
Totals: 659. 

Type of Action: Administrative penalties assessed: 

Type of Action: State; 
Year: 1995: 11; 
Year: 1996: 28; 
Year: 1997: 19; 
Year: 1998: 21; 
Year: 1999: 26; 
Year: 2000: 10; 
Year: 2001: 41; 
Year: 2002: 31; 
Year: 2003: 33; 
Year: 2004: 30; 
Year: 2005: 3; 
Totals: 253. 

Type of Action: Complaint for penalty issued[B]: 

Type of Action: Federal; 
Year: 1995: 9; 
Year: 1996: 0; 
Year: 1997: 10; 
Year: 1998: 10; 
Year: 1999: 8; 
Year: 2000: 3; 
Year: 2001: 0; 
Year: 2002: 3; 
Year: 2003: 0; 
Year: 2004: 0; 
Year: 2005: 0; 
Totals: 43. 

Type of Action: Civil cases referred: 

Type of Action: State (to attorney general); 
Year: 1995: 10; 
Year: 1996: 15; 
Year: 1997: 21; 
Year: 1998: 13; 
Year: 1999: 10; 
Year: 2000: 3; 
Year: 2001: 3; 
Year: 2002: 1; 
Year: 2003: 9; 
Year: 2004: 9; 
Year: 2005: 3; 
Totals: 97. 

Type of Action: Federal (to Department of Justice); 
Year: 1995: 0; 
Year: 1996: 0; 
Year: 1997: 4; 
Year: 1998: 1; 
Year: 1999: 0; 
Year: 2000: 0; 
Year: 2001: 0; 
Year: 2002: 0; 
Year: 2003: 0; 
Year: 2004: 54; 
Year: 2005: 0; 
Totals: 59. 

Type of Action: Criminal cases filed: 

Type of Action: State; 
Year: 1995: 1; 
Year: 1996: 2; 
Year: 1997: 1; 
Year: 1998: 0; 
Year: 1999: 3; 
Year: 2000: 0; 
Year: 2001: 0; 
Year: 2002: 0; 
Year: 2003: 0; 
Year: 2004: 0; 
Year: 2005: 0; 
Totals: 7. 

Type of Action: Federal; 
Year: 1995: 0; 
Year: 1996: 0; 
Year: 1997: 0; 
Year: 1998: 0; 
Year: 1999: 0; 
Year: 2000: 0; 
Year: 2001: 0; 
Year: 2002: 0; 
Year: 2003: 0; 
Year: 2004: 0; 
Year: 2005: 0; 
Totals: 0. 

Source: GAO analysis of EPA data. 

Notes: 

[A] We included the most commonly used enforcement actions in this 
table and excluded miscellaneous actions and activities unrelated to 
enforcement or the lead rule. 

[B] EPA files a "complaint for penalty" when the terms of an 
administrative order are violated. 

[End of table] 

[End of section] 

Appendix V: Comments from the Environmental Protection Agency: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY: 
OFFICE OF WATER: 
WASHINGTON, D.C. 20460: 

NOV 18 2006: 

John B. Stephenson: 
Director, Natural Resources and the Environment: 
Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Stephenson: 

Thank you for the opportunity to review the proposed Government 
Accountability Office (GAO) Report; Drinking Water: EPA Should 
Strengthen Ongoing Efforts to Ensure that Consumers are Protected from 
Lead Contamination. We appreciate the information in the report and are 
fully committed to strengthening consumer protections from lead 
contamination. 

As your report acknowledges, the Environmental Protection Agency (EPA) 
has been working since early 2004 to better understand implementation 
of the Lead and Copper Rule nationwide. On March 7, 2005, we announced 
the Drinking Water Lead Reduction Plan, a series of efforts we are 
undertaking to revise regulations and guidance in order to improve 
implementation of the rule. We will continue to collect and analyze 
information to help us target areas where implementation needs to be 
further improved. We want to ensure this rule, which has been critical 
in lowering exposure to lead in drinking water, continues to be 
successful. 

Your staff evaluated (1) the completeness of information that EPA has 
to evaluate implementation, (2) areas of the rule where modifications 
could strengthen public health protection, and (3) the availability of 
information to assess the quality of drinking water in schools and 
child care facilities with respect to lead. I would like to respond to 
your findings in each of these areas. 

Lead Compliance Information: 

Your report fairly represents the challenges that we faced in working 
to understand the effectiveness of the rule in reducing exposure to 
lead in drinking water. In initiating our review, our focus was on 
understanding the extent to which utilities were currently exceeding 
the 15 ppb action level. While states were responsive to our immediate 
request, your report correctly indicates that many have not continued 
to focus on adding new data reported by utilities to the database. We 
will continue to emphasize to states the importance of having this data 
to understand national implementation and will work with our Office of 
Enforcement and Compliance Assurance to assess the adequacy of 
enforcement efforts. 

Your report stresses that information on how utilities have met 
milestones associated with taking steps to meet the rule is important 
in determining the effectiveness of implementation. As you noted, our 
Safe Drinking Water Information System (SDWIS) has incomplete data for 
milestones that were effective with revisions to the rule in 2000. 
However, while your report accurately characterizes the incompleteness 
of new milestones, we believe it is important to note that an absence 
of new milestone data does not necessarily mean that utilities did not 
take steps to implement corrosion control. Many states failed to update 
their data to convert the older milestones that were used with the 1991 
rule into the new milestones for individual systems. For example, in 
Wisconsin, although none of the 13 large systems have the new DEEM or 
DONE milestones in SDWIS, 9 did have a milestone under the old data 
structure to indicate that optimal corrosion control treatment had been 
installed. However, notwithstanding that difference, it is accurate to 
state that data for milestones - under both the old and new structures 
- is incomplete. We will work with states over the coming year to 
ensure that relevant information is loaded into SDWIS. 

Reassessment of the Regulation: 

Your report describes several areas where you believe there are 
opportunities to improve the effectiveness of the rule. We agree with 
GAO that these areas warrant additional attention and we are addressing 
some of them (e.g., criteria for reducing monitoring, customer 
notification, management of treatment changes) as part of our package 
of revisions to the Lead and Copper Rule that we will be proposing 
early in the new year. Our decision to revise several provisions in the 
rule was based on a review of our information request to states asking 
how they were implementing provisions of the rule and feedback we heard 
from stakeholders during the expert workshops we conducted during 2004. 

However, we need additional information before we can address several 
of the other issues discussed in the report, including data on the 
effectiveness of lead service line replacement programs and analysis to 
determine appropriate monitoring requirements for combined distribution 
systems. Ongoing research projects being funded by the American Water 
Works Association Research Foundation should help inform efforts on 
lead service line replacement and the sufficiency of existing 
requirements related to lead content and leaching potential of devices 
used in residential plumbing. 

Programs to Control Lead in Drinking Water at School and Child Care 
Facilities: 

We take seriously the issue of lead in schools and child care 
facilities, as children are more vulnerable to the negative effects of 
lead. We agree with you that there is insufficient information to 
determine whether there are widespread problems with lead in school 
drinking water. However, we understand the concerns that water 
utilities have about being considered the responsible party for 
drinking water quality within specific facilities. Although some water 
utilities are working with local communities to facilitate testing, 
ultimately they have no authority over conditions within a specific 
facility. We believe that approaches such as that in Connecticut, which 
requires testing of drinking water to be conducted as part of the 
licensing process for child care facilities, represent a more 
commonsense approach to ensuring that children are protected. We also 
acknowledge the concerns of state administrators about balancing risks 
of exposure to lead in drinking water with other environmental 
exposures within school environments. 

Because there are no federal requirements for testing drinking water in 
schools that are not already a public water system, we are strongly 
advocating a voluntary program to encourage school districts to test 
drinking water. As your report notes, we have entered into a memorandum 
of understanding with the Department of Education, Centers for Disease 
Control and Prevention, Association of State Drinking Water 
Administrators and associations representing drinking water utilities. 
We are committed to work with these organizations and other 
organizations representing schools and child care facilities to 
encourage greater consideration of drinking water quality. We are 
working to release a revised guidance document for testing drinking 
water in schools and additional products over the next several months. 

Our experience with the lead rule reminds us that a regulation is only 
effective if it is effectively implemented. We understand that EPA 
regional staff, state staff, and utility managers face challenges in 
carrying out federal requirements in addition to their other duties. 
But the experience of Washington, DC reminds us of the importance of 
maintaining public confidence in the safety of drinking water. We 
believe that improvements are already happening due to the renewed 
emphasis on rule. Many states have begun efforts to review their 
programs and have already made changes to improve oversight and 
reporting. However, staff at local, state and federal levels must 
continue to carry out implementation and oversight activities to ensure 
that public confidence is maintained. 

I appreciated the opportunity to coordinate with your staff on this 
project. Should you need additional information or have further 
questions, please contact me or Cynthia C. Dougherty, Director of the 
Office of Ground Water and Drinking Water at (202) 564-3750. 

Sincerely, 

Signed by: 

Benjamin H. Grumbles: 
Assistant Administrator: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

John B. Stephenson (202) 512-3841: 

Staff Acknowledgments: 

In addition to the individual named above, Ellen Crocker, Nancy 
Crothers, Sandra Edwards, Maureen Driscoll, Benjamin Howe, Julian 
Klazkin, Jean McSween, Chris Murray, and George Quinn, Jr. made key 
contributions to this report. 

(360478): 

FOOTNOTES 

[1] For purposes of this report, we are referring to day care centers, 
nursery schools or pre-schools, and school-based after school programs 
as child care facilities. 

[2] Because this report examines only those requirements and activities 
applicable to lead, we will henceforth refer to this rule as the "lead 
rule." See 40 C.F.R. § 141.80 et. seq. 

[3] 42 U.S.C. § 300f et. seq. 

[4] Under the lead rule, high risk sites include single-family homes 
that contain copper pipes with lead solder installed after 1982 or lead 
pipes--or that are served by lead service lines. 

[5] Generally, schools and child care facilities that operate their own 
water systems are required to test their drinking water under EPA's 
lead rule. EPA estimates that there are approximately 10,000 such 
systems in the United States. 

[6] GAO, District of Columbia's Drinking Water: Agencies Have Improved 
Coordination, but Key Challenges Remain in Protecting the Public from 
Elevated Lead Levels, GAO-05-344 (Washington, D.C.: Mar. 31, 2005). 

[7] In addition, all systems that have installed corrosion control 
treatment and consistently meet water quality control parameters 
specified by the state may also qualify for reduced monitoring. 

[8] If testing indicates that the source water is contributing to 
elevated lead levels, then water systems may be required to install 
additional treatment. 

[9] Large water systems exceeding the action level must install 
corrosion control treatment unless (1) they already had such treatment 
in place prior to the effective date of the lead rule and have 
conducted related activities equivalent to those specified in the lead 
rule or (2) they can demonstrate that their source water is minimally 
corrosive, thereby reducing the likelihood that lead will be introduced 
into the drinking water from corrosion of lead-bearing plumbing 
materials. 

[10] 42 U.S.C. § 300g-6(d). 

[11] 42 U.S.C. § 300j-21 et seq. 

[12] Coolers are considered "lead-free" if any parts or components that 
may come in contact with drinking water have no more than 8 percent 
lead or include solder, flux, or interior surfaces with no more than 
0.2 percent lead. 42 U.S.C. § 300j-21(2). 

[13] EPA provided us with a data run as of August 9, 2005. According to 
EPA, these data represent, for the most part, compliance information 
reported through June 30, 2005; however, states may have made a limited 
number of additions or corrections to the data through the run date. 

[14] EPA issued minor revisions to the lead rule, including changes to 
the reporting requirements, in January 2000. While the revisions 
generally took effect as of April 2000, one exception was the reporting 
requirements. Although states were encouraged to begin meeting the new 
requirements sooner, they did not officially take effect until January 
2002. See 65 Fed. Reg. 1991 (Jan. 12, 2000). 

[15] Our analysis included active community water systems. Of the water 
systems lacking data, 157 are large and 2,457 are medium-sized systems. 

[16] For the purposes of this report, we are using the term "corrective 
action milestones" although, in some instances, water systems can be 
reported as meeting a milestone without taking or completing a 
corrective action. For example, water systems do not necessarily have 
to install treatment to be deemed to have optimized corrosion control. 
They may be eligible for a DEEM designation because their lead levels 
are consistently low or they can demonstrate that they have minimally 
corrosive water. 

[17] EPA, Drinking Water Data Reliability Analysis and Action Plan 
(2003), EPA 816-R-03-021 (Washington, D.C., March 2004). The report's 
estimates of data quality have an 80 percent confidence level and a 7.5 
percent margin of error. 

[18] EPA includes several types of violations in its treatment 
technique category, including failure to install optimal corrosion 
control treatment, failure to meet water quality control parameters, 
failure to replace lead service lines, and failure to meet public 
education requirements, among other things. 

[19] 65 Fed. Reg. 1991 (Jan. 12, 2000). 

[20] 63 Fed. Reg. 20043 (Apr. 22, 1998). 

[21] EPA, Data Reliability Analysis of the EPA Safe Drinking Water 
Information System/Federal Version (SDWIS/FED), EPA 816-R-00-020 
(Washington, D.C.: Oct. 2000). EPA found that from 1993 to 1998, 1 
state had not reported any lead monitoring violations and 21 states had 
not reported any treatment technique violations related to the lead 
rule. 

[22] If a water system does not have a sufficient number of Tier 1 
sites in its sampling pool, the system may use Tier 2 sites, which are 
buildings (including multi-family residences) that meet the Tier 1 
criteria. If necessary, the system may obtain samples from Tier 3 
sites, which are single-family structures that contain copper pipes 
with lead solder installed before 1983. 

[23] For example, homeowners may drop out of the sampling program, 
homes may be torn down or become vacant, or homeowners may install 
water softeners or other treatment devices that reduce lead levels. 

[24] Under the lead rule, systems that qualify for reducing the 
frequency of monitoring because of consistently good test results may 
also reduce the number of samples they test (and accordingly, the 
number of locations from which they collect samples). Except for the 
smallest systems, which serve populations of 100 or fewer (and are only 
required to take 5 samples), water systems can cut the number of 
samples they collect by half. This means, for example, that the largest 
systems, serving populations of over 100,000, can reduce the number of 
sampling locations from 100 to 50. 

[25] Specifically, if the test results are at or below the action level 
in two consecutive 6-month monitoring periods, the systems may reduce 
the frequency of monitoring to once a year. Further, systems that test 
below the action level in three consecutive annual monitoring periods 
may be allowed to conduct testing only once every 3 years. Small 
systems may be eligible to reduce their monitoring frequency to once 
every 9 years if (1) they can demonstrate that their distribution 
system, service lines, and drinking water supply plumbing (including 
the plumbing conveying drinking water within all residences and other 
buildings connected to the system) is lead-free and (2) all applicable 
test results do not exceed 5 parts per billion at the 90th percentile. 

[26] When systems install corrosion control treatment, states must 
evaluate tap and water quality parameter samples to determine whether 
the system has properly installed and operated the treatment. 

[27] When systems submit new monitoring or treatment data, or when 
other relevant data become available, states are required to review 
and, where appropriate, revise their determinations. 

[28] In analyzing these data, we compared the most recent test results 
reported during the 2002 to June 2005 time frame and data on water 
systems' current monitoring frequency. 

[29] Although the lead rule states that test results must "meet" the 
action level (i.e., be at or below the action level) for a water system 
to be eligible for reduced monitoring, 10 states reported that reduced 
monitoring is allowed only when the test results are "below" the action 
level. We did not follow up with these states to determine whether they 
actually differ from the federal rule or their response was in error. 

[30] In some of these instances, the states' responses implied--but did 
not specify--additional criteria. Otherwise, two states (Louisiana and 
South Dakota) reported that water systems would be approved for 
triennial monitoring if their 90th percentile test results were less 
than half of the action level. Michigan limits reductions in the number 
of sampling locations in the case of "combined distribution systems," 
in which systems that purchase water are interconnected with a water 
wholesaler. 

[31] 40 C.F.R. § 142.10(b)(5). 

[32] 40 C.F.R. § 141.90(a)(3). 

[33] Information provided by the remaining 19 states was unclear, 
generally because their responses were limited or based on a literal 
interpretation of EPA's question (e.g., states responded "in writing," 
when asked how systems notified the state about treatment changes). 

[34] Overall, 65 water systems with lead service lines were included in 
the survey. Although a total of 41 systems responded to the survey, the 
number of responses to individual questions varied. 

[35] In addition, nine states reported that one or more of their water 
systems were replacing lead service lines voluntarily (including one 
state that also reported requiring systems to replace lead lines). Two 
more states reported that systems with lead goosenecks, which connect 
water mains to the service lines, have either replaced the goosenecks 
or are doing so as they are discovered. 

[36] Another two states said that they issued regulations or provided 
guidance instructing systems to comply with the testing requirements; 
three states indicated that they review a system's replacement program 
during periodic inspections; and six states did not provide any 
information regarding their oversight of lead service line testing. 

[37] Under EPA's proposed definitions, a "water wholesaler" is a water 
system that sells or otherwise delivers treated water to another system 
on a regular basis (at least 60 days per year); a "consecutive system" 
is a system that buys or otherwise receives some or all of its treated 
water from another water system at least 60 days per year. EPA defines 
the totality of the distribution systems of all interconnected 
wholesale and consecutive systems as a combined distribution system. 

[38] We were unable to confirm the actual number of community water 
systems in EPA's estimate. According to EPA, they are in the process of 
developing better data on the number and type of water systems involved 
in combined distribution systems. 

[39] 40 C.F.R. § 141.29. EPA must concur with modified monitoring 
arrangements. 

[40] According to a Massachusetts Water Resources Authority official, 
the 30 communities receive corrosion control from the Authority and are 
part of the modified sampling arrangement approved by the Massachusetts 
Department of Environmental Protection. The Authority also provides 
more limited services to 17 other systems, including water that is 
mixed with local supplies in some cases and emergency water supplies in 
other cases. Each of these other systems has its own lead rule 
compliance program. 

[41] In this case, the individual communities did notify their 
customers of the 90th percentile results for the applicable consecutive 
system. However, EPA's database does not contain this information so it 
is not readily available to the public at large. 

[42] 42 U.S.C. § 300g-6(a),(d),(e). 

[43] See NSF, ANSI/NSF Standard 61: Drinking Water System Components - 
Health Effects (Ann Arbor, Mich.: 1997). NSF focuses on food, water, 
indoor air, and the environment. NSF is accredited by the American 
National Standards Institute (ANSI) to provide third-party 
certification to NSF Standard 61. 

[44] Dudi, A., Schock, M., Murray, N., and Edwards, M., Lead Leaching 
from Inline Brass Devices: A Critical Evaluation of the Existing 
Standard, Journal AWWA (August 2005). 

[45] McLellan, C., Purkiss, D., and Greiner, P., Interim Report on 
Extraction Results on Leaded Products Submitted for Evaluation Under 
NSF/ANSI 61, NSF International (Ann Arbor, Mich.: June 2005). 

[46] Model plumbing codes include the International Plumbing Code and 
the United Plumbing Code. 

[47] See Cal. Safety & Health Code § 25249.5 (part of the initiative 
known as Proposition 65 adopted by popular vote in 1986). 

[48] Under the lead rule, water systems are not required to replace an 
individual lead service line if the lead concentration in all service 
line samples from that line is less than or equal to 15 parts per 
billion. This is sometimes referred to as the "test-out" provision. 

[49] See ACORN v. Edwards, 81 F.3d 1387 (5th Air. 1996). 

[50] 55 Fed. Reg. 22387 (June 1, 1990). 

[51] Under the terms of the recall order, the manufacturer was required 
to (1) provide periodic reports to the Commission for 3 years, 
including information on the number of replacements shipped and refunds 
mailed, and (2) maintain records related to the recall for 5 years. 

[52] Natural Resources Defense Council, The Lead Contamination Control 
Act: A Study in Non-Compliance (June 1991). Because this study is used 
for context purposes, we did not assess its reliability. 

[53] EPA published the first guidance document in 1989. See EPA Office 
of Water, Lead in School's Drinking Water, EPA 570-9-89-001 
(Washington, D.C.: Jan. 1989). EPA updated the guidance in 1994. See 
EPA Office of Water, Lead in Drinking Water in Schools and Non- 
Residential Buildings, EPA 812-8-94-002 (Washington, D.C.: Apr. 1994). 
Also in 1994, EPA published a separate guidance document to address 
child care facilities. See EPA Office of Water, Sampling for Lead in 
Drinking Water in Nursery Schools and Day Care Facilities, EPA 812-B- 
94-003 (Washington, D.C.: Apr. 1994). 

[54] GAO, Toxic Substances: The Extent of Lead Hazards in Child Care 
Facilities and Schools Is Unknown, GAO/RCED-93-197 (Washington, D.C.: 
Sept. 14, 1993). 

[55] EPA Office of the Inspector General, Report of Audit on the Lead 
in Drinking Water Program, Report No. E1HWF9-03-0316-0100508 
(Washington, D.C.: Sept. 28, 1990). 

[56] The Lead Contamination Control Act: A Study in Non-Compliance, pp. 
6-7. 

[57] EPA, Controlling Lead in Drinking Water for Schools and Day Care 
Facilities: A Summary of State Programs, EPA-810-R-04-001 (Washington, 
D.C.: July 2004). 

[58] Although not reported in response to EPA's information request, 
Washington state also conducted a survey of school testing shortly 
after the LCCA was enacted and found that 25 percent of 121 schools 
that conducted testing detected unacceptable levels of lead in one or 
more drinking water outlets. 

[59] In New Hampshire, the testing requirement applies only to 
facilities that care for 24 or fewer children and have their own 
independent water supply. 

[60] See ACORN v. Edwards, 81 F.3d 1387 (5th Cir. 1996). 

[61] In EPA's guidance for schools and child care facilities, the 
agency recommends using a sample volume of 250 milliliters and 
establishes lead concentrations greater than 20 parts per billion as 
the trigger for follow-up action. In contrast, the testing protocol for 
public water supplies requires a sample volume of 1 liter and follow-up 
action if lead levels at the 90th percentile exceed 15 parts per 
billion. According to EPA, the testing protocol for water systems is 
designed to assess lead levels for the system as a whole, using a 
representative number of households; if applicable, the testing also 
serves as a means of determining the effectiveness of corrosion control 
treatment. The protocol for schools and child care facilities is 
slightly more stringent than that used in water systems, and is 
designed to determine lead levels at specific outlets. 

[62] Some schools and child care facilities have their own water 
sources and are subject to Safe Drinking Water Act requirements, such 
as the lead rule. Such systems are defined as non-transient, 
noncommunity water systems, which serve at least 25 people for more 
than 6 months in a year. According to EPA estimates, about 10,000 
schools and child care facilities are regulated as non-transient, 
noncommunity systems but, according to one official, these data are 
incomplete. 

[63] Specifically, the parties agreed to encourage schools and child 
care facilities to test drinking water for lead, disseminate the 
results to the public, and take appropriate actions to correct 
problems. 

[64] The National Child Care Association is active in 26 states and 
represents about 8,000 private, licensed child care facilities that are 
based outside the home. The association does not represent the family 
home care industry, which consists of an estimated 3,000 individually- 
owned family homes that offer child care services. 

[65] The National Head Start Association represents more than 1 million 
children, 200,000 staff, including teachers and family service workers, 
and 2,700 Head Start programs in the U.S. 

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