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EPA has claimed that their studies indicate that benefits that <br />could result from reducing exposure to lead in public water systems <br />go beyond the actual health factors attributable to reducing the <br />risk of lead contaminination to the reduction in corrosion in service <br />pipes and materials. A key point of the analysis, however, is the <br />emphasis that the benefit EPA attributes to reduction of lead levels <br />also assumes that EPA will reduce lead levels in tap water as well <br />as monitor lead levels in the operation of water utilities. <br />EPA has acknowledged that water distributed from water treatment <br />facilities is usually not contaminated by high lead levels, but <br />lead levels at the user tap can be much greater due to pipe and <br />solder corrosion. Use of lead service pipes and mains is not <br />generally a practice for most water systems, but the use of solder <br />and related materials is more common generally, according to EPA. <br />In fact, EPA has stated that "...lead concentrations in fully <br />flushed water...even under corrosive conditions and with new <br />solder, are generally below 50 ppb and usually below 20 ppb." <br />In the same report, the agency declared that "...levels in fully <br />flushed water (in community water supplies) and in distribution <br />water are typically low." Further, EPA acknowledged that while <br />corrosive waters have the highest levels of lead contamination, <br />non - corrosive conditions can also have significant amounts of <br />leaching of lead into the water supplies. The key factor in that <br />phenomenon appears to the presence of new solder. After 5 years, <br />the levels decline and "...are generally not elevated beyond 5 <br />years... ", according to studies cited by EPA. <br />Another problem with the data that concerns numbers of people <br />trying to understand the nature of the threat from lead in drinking <br />water is the relationship between water lead levels and blood lead <br />levels. Studies used by EPA assume that there is a direct <br />relationship; other studies have even suggested a higher probability <br />of damage from exposure than a simple linear relationship. <br />Since lead is not believed to have any beneficial effect on human <br />health, elevated blood lead levels are viewed with particular <br />concern. Even so, EPA acknowledged that there is still much <br />uncertainty and lack of knowledge about lead health effects and <br />agreed that other analyses of benefits of reducing lead levels in <br />drinking water would be helpful in judging the reasonableness of <br />the estimates developed by EPA. <br />In the meantime, however, the costs of implementing standards mandated <br />by regulations such as those proposed by EPA for lead, copper and pH <br />levels in drinking water must be of concern to every responsible <br />city official. <br />Attachments <br />Attached please find a sample letter and council resolution regarding <br />the proposed EPA rules on lead and copper. Alter the sample wording <br />to illustrate your city's particular circumstances. <br />PAGE -15- <br />