these waters / mind dump on water quality
I’ve been deep in the water hole the past few months on water systems and regulations. It initially started with an interest in how water rights are distributed and how current and future drought might impact water availability in desert cities. While I was down that rabbit-hole, I became increasingly aware of the lack of regulation regarding chemical pollutants in terms of public health. Water quality regulation falls under the jurisdiction of the Environmental Protection Agency, but water quality is inherently a public health issue, not an environmental issue.
history of EPA and water regulation (from troubled water by seth m siegel)
timeline
1902, John Laing Leal started adding chlorine to the Jersey City Water Supply Company water to kill waterborne bacteria. Within a few years, 75% of US cities on a municipal water grid were using chlorination to ensure safety of drinking water
Early 1970’s, scientists realize that chlorine was mixing with organic material (decomposing leaves, etc) to create trihalomethane (THMs), a known human carcinogen. This became a major news story that led to the passage of the Safe Drinking Water Act in 1974
Under this legislation, the Environmental Protection Agency was tasked with solving the chlorine problem, as well as identifying and managing a growing list of industrial and other contaminants and come up with plans for protecting the public. The law also made utility companies responsible for monitoring the contaminants identified by the EPA and figure out ways of controlling or eliminating them
1986, the Safe Drinking Water Act was amended after frustration that only 23 chemicals had been regulated by the EPA after twelve years. Now, Congress demanded that EPA set standards for 83 chemicals in the following three years, and select and regulate another 25 contaminants by 1991. After 1991, 25 contaminants would be added to the list every three years after
Political backlash mounted over the legislation, especially among smaller cities with smaller water budgets (water monitoring and treatment can be expensive). In 1994, the Safe Drinking Water Act was amended once again to eliminate mandatory standard setting by the EPA. It also removed the minimum number of contaminants to be regulated every three years, and it allowed the EPA to set standards based on the balance of public health and economic cost of regulation. The EPA was prohibited from studying more than 30 contaminants in any five year period.
Since the 1996 amendment, more than two hundred chemicals have been presented to the EPA for review (including perchlorate, PFAS, pharmaceuticals, pesticides, and other known carcinogens). Only 26 has been selected for investigation. 2 have been selected for possible regulation. None have been regulated.
what does this mean for drinking water?
Water utilities are incentivized to maintain the highest allowable levels of contaminants because it minimizes their treatment costs
SDWA allows states to set higher standards than EPA, but regulation and disciplinary actions are the responsibility of the state
EPA is politically incentivized to not add any chemicals to their regulatory list. More than 85,000 chemicals have been put on the market since 1996, and none are regulated
Water regulation is a politically unpopular issue because it’s viewed as “environmental”, and therefore partisan, even though it is a life-critical resource and affects absolutely everyone
LA’s last published water report
Los Angeles Department of Water and Power’s 2018 water quality report.
Even if we look at just the tiny list of EPA regulated chemicals, this gets interesting. The table can be intimidating to look at, but I want to highlight two columns. The State Primary Standard is determined by California based on EPA guidelines. Most are the same as the federal EPA guidelines. The State PHG guideline is “public health goal”, which is a better numerical indicator of whether the concentration of chemicals have the potential to harm human health. The EPA is not a public health agency. They are not obligated to prioritize public health in making their regulatory decisions. They actually don’t seem to be making any regulatory decisions at all in terms of public drinking water, so as far as health concerns go, the EPA numbers basically mean nothing. We’ll reference the PHG column to gauge whether chemicals might be of concern. The Environmental Working Group has a contaminant database that outlines issues with contaminants and filtration methods that can reduce levels.
Bromate
As it says in the water report, bromate is a by-product of ozone disinfection (a common method of disinfecting municipal drinking water) when naturally occurring bromide in water reacts with the ozone. Bromate is a suspected human carcinogen, and while it is well under the EPA standard of 10 µg/L, at a level of 1-3 µg/L in Los Angeles’s drinking water, it’s an order of magnitude above the public health goal.
Activated carbon, reverse osmosis, and ion exchange filters can reduce bromate levels.
Uranium
Uranium is a radioactive material that is a known human carcinogenic. Again, the EPA diverges greatly from California’s public health suggestions here. The EPA’s federal guideline of 20 pCi/L would cause more than 4.6 cancer cases per 100,000 people. California Office of Environmental Health Hazard Assessment defines 0.43 pCi/L as the public health target, and Los Angeles’s water is well above that at 2-4 pCi/L.
Reverse osmosis and ion exchange filters can reduce uranium levels.
Lead
EPA establishes a “safe” level for lead, but there is no known safe level for lead. Even low level exposure in healthy adults can lead to kidney issues, and as demonstrated in Flint, officials are not incentivized to be open about lead problems in their communities. Lead testing is basically designed to measure the lowest possible levels (taps are run for a few minutes to first dispose of any water that has been sitting for a while, reducing the concentration of lead. The tests are also allowed to be conducted at much lower flow rate than normal use, which is less likely to cause lead pipes to flake into the water, also reducing the concentration of lead in the samples).
Quick summary of what happened in Flint
Racial tension, economic downturn, and widening inequality led to the abandonment of Flint after the 1960’s
Flint was placed under emergency management in 2011, and in 2014, the city looked to change their water source from the Detroit Water and Sewerage Department water (sourced from Lake Huron and the Detroit River) to the Flint River in order to save money
Citizens began noticing and reporting rashes, hair loss, and clear contamination of their tap water. Officials defended themselves saying that levels tested at the treatment center were normal without accounting for the fact that the Flint River water was more corrosive than the Lake Huron water, and was causing lead pipes to flake after leaving the treatment plant
In October 2014, a GM plant switched it’s water source after the tap water was deemed too corrosive to manufacture engine parts, but the State of Michigan continued to deny any fault in the water, seeking to discredit whistleblowers (including an independent EPA official) rather than acknowledge the problem
A Virginia Tech study found that 40% of homes had elevated lead levels, but officials expressed skepticism
Flint pediatrician Mona Hanna-Attisha found that elevated blood-lead levels in children citywide had nearly doubled since 2014 and nearly tripled in certain neighborhoods
2016 Michigan ACLU and citizens sued city and state officials. In November, a federal judge ordered door-to-door delivery of bottled water to every home without a properly installed and maintained faucet filter. They also eventually won a major settlement requiring the city to replace the city’s thousands of lead pipes with funding from the state
Los Angeles has had reports of elevated lead levels, and as demonstrated by Flint, it can be hard to draw enough attention to the issue to force officials to make changes. Water utilities are not incentivized to provide quality water to residents since upgrading filtration systems and changing lead pipes is costly.
what’s unregulated is probably scarier than what is regulated
Overall, the LADWP report shows generally safe levels of chemicals for consumption, but it is important o remember that only regulated chemicals are on that list, which does not include anything that has been found toxic in the last 20 years.
how do you protect yourself?
The EWG has a water selection filter tool based on your zip code. It shows contaminant levels based on each water district and how that compares to the EWG’s independent recommended health levels. Based on the specific chemicals, the tool suggests the best water filtration method.
This is what it shows for my zipcode in Orange County, but use your zip code to figure out what filter makes sense for your specific water utility.