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Mayor Williams and Councilmember Schwartz Issue Final Report of Interagency Task Force on Lead in Drinking Water and Make 15 Specific Recommendations(Washington, DC) Mayor Anthony A. Williams and Councilmember Carol Schwartz today released the final report of the Interagency Task Force on Lead in Drinking Water, established on February 11, 2004. The report summarizes the work of the Task Force, which was co-chaired by the Mayor and Schwartz, and contains 15 recommendations by the co-chairs for further action by the District of Columbia Water and Sewer Authority (WASA) and relevant city and federal agencies as the problem of excess lead found in some residents' water continues to be addressed. "Coordination and communication were and continue to be critical in this situation," said Mayor Williams. "The involvement of several local agencies as well as more than one federal entity necessitated a coordinated effort to keep the public informed of the changing circumstances and to address the actual situation. The Task Force brought together those entities in order to develop an effective community outreach plan and an ongoing strategy for resolving the problem." In its final report, the Task Force summarized its activities since its formation on February 11. The task force has met 10 times and informed the public and the media of its work at frequent press briefings. As a result of the meetings, the Task Force established coordinated public communications efforts among participating agencies. The DC Water and Sewer Authority has participated in 23 community meetings throughout the city, organized a command center to address questions from the public, distributed more than 23,000 water test kits, conducted more than 12,000 tests of water, and distributed approximately 28,000 water filters to District residences. "The Task Force was needed," Schwartz said. "It got the various agencies together on a weekly basis, coordinated the response in the urgent fashion the situation called for, ensured an accurate and consistent message, and regularly kept the public and the media informed of its activities." Schwartz added, "I am proud of having initiated and co-chaired such a productive endeavor. Now I look forward to the recommendations that the Mayor and I have made being accomplished, and to the day when the issue of lead in our water is behind us." Both the Mayor and Councilmember Schwartz expressed confidence that the level of coordination and cooperation among the various entities will continue, and both committed to remaining actively involved until the problem is resolved. The full text of the report is attached. FINAL REPORT OF THE INTERAGENCY TASK FORCE ON LEAD IN DRINKING WATER
|
First Draw |
||||||
Lead [ppb] |
Lead |
Copper | Brass | Unknown | Other | |
0-15 |
1501 |
3341 |
901 |
1550 |
203 |
7496 |
>15-50 |
1418 |
289 |
42 |
624 |
17 |
2390 |
>50 - 100 |
219 |
44 |
8 |
76 |
1 |
348 |
>100-150 |
32 |
12 |
1 |
11 |
0 |
56 |
Over 150 |
31 |
8 |
3 |
9 |
0 |
51 |
3201 |
3694 |
955 |
2270 |
221 |
10341 |
Second Draw |
||||||
Lead [ppb] |
Lead |
Copper | Brass | Unknown | Other | |
0-15 |
1609 |
3397 |
916 |
1630 |
193 |
7745 |
>15-50 |
938 |
191 |
27 |
389 |
18 |
1563 |
>50 - 100 |
451 |
71 |
6 |
175 |
7 |
710 |
>100-150 |
147 |
25 |
4 |
53 |
1 |
230 |
Over 150 |
56 |
10 |
2 |
23 |
2 |
93 |
3201 |
3694 |
955 |
2270 |
221 |
10341 |
Source: WASA.
WASA conducted extensive testing of public schools and administrative buildings in February 2004. In order to address concerns about representative and complete sampling, WASA has begun resampling these schools with a protocol approved by EPA.
With respect to residential buildings whose owners or landlords refuse to conduct water lead level tests or release the results of such tests to the tenants, WASA considered sending a test kit to one tenant or owner-occupier in the building if that individual agrees to publicly post the results of the test in the building for other tenants to see. However, on April 20, 2004, Councilmember Schwartz and Councilmember Sharon Ambrose introduced legislation that would require the owner of a multi-family residential building to have a lead level test of the tap water in the building conducted if a rental tenant or an owner-occupier of a unit in the building requests the testing. Councilmembers Schwartz and Ambrose are considering introducing similar emergency legislation at an upcoming Council legislative session.
At the recommendation of Councilmember Schwartz, WASA has tested water lead levels at Department of Corrections facilities in the District, including the jail (Central Detention Facility). The lead level content in the water at these facilities was under the action level of 15 ppb. WASA says that it will provide the results of water lead level tests in public housing and hospitals once it determines the proper protocol for taking these samples.
The Task Force has developed guidance and supported logistics for the distribution of water filter kits. This action has been taken, like others, under the principle of acting with an abundance of caution. Task Force members have coordinated many of the activities associated with the overall lead issue. Following are the specific actions taken to date.
To date, the District has received donations of 10,600 water filter pitchers from the Brita Products Company and 12,000 pitcher and faucet water filtration systems from the Proctor & Gamble Company for distribution to District residences with lead service lines. These filters are certified by the National Sanitation Foundation (NSF) to remove up to 98% of lead in water at amounts up to 150 parts per billion (ppb). In addition, WASA has purchased 13,400 water filters. EMA was originally given the responsibility of distributing these water filters to affected residents. Pregnant women, nursing mothers and children age six and under who live in homes with lead service lines were identified as the most at-risk population and were scheduled to be among the first to receive filtration devices. In the initial distribution on March 4 and 5, 2004, EMA delivered water filters to approximately 300 home-based daycare centers with lead service lines. Beginning Saturday, March 6 and continuing through Monday, March 22, EMA set up distribution sites at various places across the city, primarily at locations at which the DOH was offering free blood lead screening or at community meetings hosted by WASA. A total of 3,164 filtration devices were distributed at these sites.
WASA has since mailed or shipped the remaining water filters to all of the approximately 23,000 residences with known or suspected lead service lines. The filters were accompanied by a multilingual letter and instructions. A six-month supply of replacement cartridges for these water filters was also provided to those residents who received a filter. With a particular focus on households that have been identified as having a lead service line pipe and those households for which WASA has no record of service line pipe, WASA continues to strongly encourage participation in its water lead testing program (contact the Lead Services Hotline at 202-787-2732 or wqp2003@dcwasa.com.) WASA has already distributed filters to addresses believed to be served by a lead service line pipe, and is also providing a water filter and replacement cartridges to households that participate in the testing program whose test results exceed 15 ppb.
Both Councilmember Schwartz and Mayor Williams have called upon WASA to also distribute water filters to the approximately 21,000 residences with service lines whose make-up is uncertain. Testing conducted thus far by WASA indicates that approximately 28 percent of the "second draw" samples collected from properties served by service lines of "unknown" material exceed the action level of 15 ppb. WASA is planning to distribute free water filters and replacement cartridges to additional residences whose water lead level tests are at 15 ppb or higher, but it does not have plans at this time to distribute filters to all of the approximately 21,000 residences with service lines of unknown composition. WASA currently has 8,000 water filters in inventory and will start distributing these filters this week to residences whose water tests above the EPA action level.
WASA has been continuing its replacement of lead service lines in public space in the District. DDOT has been coordinating with WASA's lead service line replacement program to reduce WASA's costs and ensure that, where necessary, lead service lines are replaced before work begins on scheduled repaving projects.
The WASA Board of Directors has expressed support for a management proposal to increase the lead service replacement schedule for FY 2004 by an additional 500 replacements of service lines in public space. These replacements will be implemented at properties that meet specific "priority" criteria as established in conjunction with the DOH. WASA is receiving requests for inclusion in the priority replacement program and is coordinating with DOH to expedite a review by DOH of these requests. Under the plan, the criteria that will be used to select service lines for priority replacement are as follows:
WASA continues to work with DOH and EPA to evaluate the decision to replace the public space service line pipe up to a threaded joint when an owner does not replace their portion of the service line simultaneously. This issue involves resolution of compliance questions raised under the requirement to replace the line that rests in public space. WASA is also awaiting technical analysis over the next several weeks on whether to continue to cut lead service lines. Additionally, WASA is undertaking test "dig-ups" where test results suggest the presence of a lead service line.
WASA's Board of Directors has approved a resolution that proposes that the Board adopt a policy to remove all of the known lead service lines in public space in the District by September 30, 2010 and replace them with EPA-approved service lines. Additionally, the resolution states that if a lead service line is discovered that was not previously identified and replaced prior to September 30, 2010, WASA would replace the public space portion of that service line within 90 days of knowing of its existence. WASA will hold public meetings for two months for public comment, and will decide in June 2004 whether to formally adopt this plan.
An outstanding issue remains regarding whether homeowners should be required to pay to replace the portion of a lead service line on their property. Councilmember Schwartz made a proposal to the Task Force at its third meeting that a revolving fund be established to make no-interest loans to homeowners to replace the portions of lead service lines that lie on their property. She also has called on WASA to reduce by 20 percent the water bills of residents who have been advised to flush their lines. WASA also mentioned that they were examining potential liability concerns.
On February 5, 2004, one day after the Committee on Public Works and the Environment held its first public hearing on the issue of lead in the water, representatives from EPA, WASA, the Washington Aqueduct and DOH conducted a teleconference call to discuss the formation of a group tasked with developing a plan to reduce the corrosivity of treated drinking water in the District to reduce the level of lead in the water to allowable levels. This group, named the Technical Expert Working Group (TEWG), first met on February 9, 2004, and is comprised of staff and contractors for WASA, the Aqueduct, DOH, Arlington County, Virginia and Falls Church, Virginia, as well as EPA staff members from the Mid-Atlantic Regional Office, EPA's Office of Research and Development in Cincinnati, Ohio and EPA's Office of Ground Water and Drinking Water. New members will be added to the TEWG as the need to add additional expertise is determined.
As a part of its Action Plan, a subgroup of the TEWG has completed its Desktop Options Analysis and has presented it to the full group. This analysis will undergo an independent peer review before it is finalized. The recommendation of the TEWG subgroup is to conduct a partial system test using orthophosphates at WASA's Fort Reno Pumping Station and thereafter a full-system test by feeding orthophosphates at the Dalecarlia and McMillan water treatment plants. The Aqueduct had originally been preparing to add orthophosphate to a portion of the District's water on June 1, 2004, and the entire system by September 1, 2004, which is expected to counteract the corrosive effects on lead pipes of the treated water. EPA officials have since informed Councilmember Schwartz at the April 19, 2004 public oversight hearing of the Committee on Public Works and the Environment that a decision has been made to use zinc orthophosphate and that the date for complete implementation of the treatment of drinking water with zinc orthophosphate may be moved up from September 1, 2004 to July 15, 2004. WASA said that there will be consideration of accelerating the timetable for a full-system implementation if the partial system test is successful.
Task Force co-chairs Mayor Williams and Councilmember Schwartz sent letters to the President and to the United States Congress requesting the assistance of relevant federal agencies and federal funding to help address the issue of lead in some of the District's drinking water. Because EPA and the Washington Aqueduct, which is a part of the United States Army Corps of Engineers, are federal entities, Mayor Williams and Councilmember Schwartz believed that it was important and appropriate that the federal government be involved in - and cover costs associated with - addressing the lead problem.
On February 13, 2004, Mayor Williams and Councilmember Schwartz sent a letter to Representative Tom Davis, Chairman of the House Committee on Government Reform, requesting that Representative Davis hold hearings on the actions of EPA and the Washington Aqueduct regarding the issue of lead in some of the District's drinking water. Partly in response to this letter, the House Committee on Government Operations held a hearing on this matter on March 5, 2004 and may hold additional hearings in the future on EPA and Aqueduct's involvement in the lead issue.
On February 27, 2004, Councilmember Schwartz sent a letter to President George W. Bush requesting that the President instruct EPA and the Washington Aqueduct to become actively involved in addressing the issue of lead in some of the District's drinking water.
On March 11, 2004, Ruben Barrales, Deputy Assistant to the President and Director of Intergovernmental Affairs at the White House, sent a letter on behalf of the President in response to the February 27, 2004 letter from Councilmember Schwartz requesting that the President instruct EPA and the Washington Aqueduct to become actively involved in addressing the issue of lead in some of the District's drinking water. Mr. Barrales wrote, "Your concerns and requests will be shared with the appropriate officials in the White House, the Environmental Protection Agency, and the United States Army Corps of Engineers. Rest assured, the Administration is aware of the situation facing our Nation's Capital and will work with you and the city to address important issues."
On February 27, 2004, Mayor Williams and Councilmember Schwartz sent a letter to Senator James Inhofe, Chairman of the Senate Committee on Environment and Public Works requesting that Senator Inhofe hold hearings on the actions of EPA and the Washington Aqueduct regarding the issue of lead in some of the District's drinking water. The Senate Environment and Public Works Subcommittee on Fisheries, Wildlife and Water held a hearing regarding this matter on April 7, 2004.
On March 23, 2004, Mayor Williams and Councilmember Schwartz sent a letter to President Bush requesting full reimbursement to the District and to WASA for the costs involved in addressing the issue of the increased lead levels in some of the District's drinking water. The letter explained that, since the apparent cause of this recent rise in lead levels was a change in the treatment chemistry of the District's water which was initiated by the Aqueduct and approved by EPA, it would be unfair to make the District taxpayers bear the financial burden of addressing this problem. Additionally, Mayor Williams and Councilmember Schwartz stated in this letter that the regulatory decisions of EPA, a federal agency, appear to have generated the costs involved in this matter and that, even had the actions of EPA not been the cause of this problem, the structural imbalance the District faces due to its unique situation relative to the federal government warranted federal assistance in this matter. Mayor Williams and Councilmember Schwartz calculated that the situation of lead in some of the District's drinking water has thus far cost the District a total of $25,824,101 in expenses related to blood testing, water testing, communications, logistics support and lead pipe replacement, and they requested full reimbursement of this amount from the federal government.
On March 31, 2004, Ruben Barrales, Deputy Assistant to the President and Director of Intergovernmental Affairs at the White House, sent a letter on behalf of the President in response to the March 23, 2004 letter sent by Mayor Williams and Councilmember Schwartz seeking full reimbursement to the District and to WASA for the costs involved in addressing the issue of the increased lead levels in some of the District's drinking water. Mr. Barrales wrote, "The US EPA is providing $11.3 million this year in State Revolving Loan Grants to WASA for lead line replacement and has created a new program with the National Nursing Centers Consortium, called Lead Safe D.C., to bring lead education information, home visits, and blood lead level testing to District neighborhoods. In addition, the US EPA Region III is working with the District and WASA to assure that certified water filters are delivered to occupants in the estimated 23,000 homes and businesses with lead service lines, placing a priority on high risk population, and to ensure the completion of additional sampling to fully identify the extent of the problem. The Administration will continue to work with you, WASA, and other agencies to resolve this problem so that the residents of the District of Columbia are provided with safe drinking water."
On April 7, 2004, Mayor Williams and Councilmember Schwartz sent a letter to Ruben Barrales, Deputy Assistant to the President and Director of Intergovernmental Affairs at the White House in response to his letter of March 31, 2004 on behalf of the President clarifying the lead in water issue and making it clear that the $11.3 million being sent to WASA this year in State Revolving Loan Grants for lead line replacement is not earmarked specifically for lead line replacement, but rather for a host of improvements to the water system. They also wrote, "As you know, the State Revolving Loan Grants are provided to the District of Columbia on an annual basis, just as they are to other states, based on a federal formula. The resources provided in the current year are equivalent to those provided in prior years. These are not new funds provided by the federal government through the EPA for the increasing costs associated with addressing the elevated lead concentrations in water. As a consequence of the lead-in-water problem, WASA has re-allocated the State Revolving Loan Grant resources away from other important water projects in the District of Columbia, such as water main and large valve replacements and other work required to improve the reliability of water service in the Southeast quadrant of the city. Regarding the other US EPA activities mentioned in your letter, none of these involve additional resources to the city to cover expenses that WASA and the District have incurred.
"In your letter, your mention of the $11.3 million in grants is simply a repeat of the standard US EPA line that we have heard over and over again in our hearings and our discussions with US EPA officials. If you ask these officials just one follow up question, you will find out it is not one nickel more than we are entitled to under the Safe Drinking Water Act and not one penny more for remediation of this lead problem.
"We continue to seek full reimbursement from the federal government in the amount totaling $25.8 million to the District and to WASA for costs associated with addressing this problem in 2004. Again, as we wrote in our March 23 letter to President Bush, the apparent cause for this recent rise in lead levels is a change in the treatment chemistry initiated by federal entities including the United States Army Corps of Engineers' Washington Aqueduct, the provider of the District's water, and approved by the US EPA, the regulator of the District's water. Because the regulatory decisions of the US EPA appear to have generated these costs, and the resources to address them reside within the US EPA, it seems blatantly unfair that the citizens of our city should have to bear the expenses associated with addressing the problem."
On April 1, 2004, Mayor Williams and Councilmember Schwartz sent letters to the Chairmen and Ranking Members of the Senate and House Subcommittees on Energy and Water Development, Labor, HHS, Education and Related Agencies and Veterans' Affairs, HUD and Independent Agencies in support of Representative Eleanor Holmes Norton's request for reimbursement of the costs involved in addressing the issue of the increased lead levels in some of the District's drinking water. As with the March 23, 2004 letter to President Bush, the letters explained that, since the apparent cause of this recent rise in lead levels is a change in the treatment chemistry of the District's water which was initiated by the Aqueduct and approved by EPA, it would be unfair to make the District taxpayers bear the financial burden of addressing this problem. Additionally, Mayor Williams and Councilmember Schwartz stated in these letters that the regulatory decisions of EPA, a federal agency, appear to have generated the costs involved in this matter and that, even had the actions of EPA not been the cause of this problem, the structural imbalance the District faces due to its unique situation relative to the federal government warranted federal assistance in this matter.
Since the development of the lead in drinking water situation, EPA has considered the possibility of allowing the District to have primacy over its drinking water program. Because the District is included within the definition of "state" under the Safe Water Drinking Act (SDWA), it would be eligible to be considered for primacy over its drinking water program provided, according to EPA, that the District could satisfy the criteria contained within 40 CFR 142.10. Among those criteria, the District must demonstrate that it can compel compliance with the national primary drinking water regulations by all public water systems in the District, and that it can take appropriate enforcement actions to enjoin any threatened or continuing violations of the national primary drinking water regulations. EPA says that, in the event that the District seeks primacy, the District would need to establish that Section 602(b) of the District of Columbia Self-Government and Governmental Reorganization Act of 1973 (the "Home Rule Act") gives the District sufficient authority over the Washington Aqueduct, one of the two public water suppliers in the District (along with WASA), to enforce the SDWA.
The co-chairs of the Task Force make the following recommendations with respect to the lead in drinking water matter in the District:
The Aqueduct was preparing to add orthophosphates to a portion of the District's water on June 1, 2004, and to the entire system by September 1, 2004. EPA officials have since informed Councilmember Schwartz that, due to successful desktop analysis, the date for complete implementation of the treatment of drinking water with zinc orthophosphate may be moved up from September 1, 2004 to July 15, 2004. The Task Force believes that EPA and the Aqueduct should strive to meet this July 15 date for complete implementation of the District's drinking water with zinc orthophosphate, provided the June 1, 2004 preliminary sample test results are successful.
EPA also stated that the water could temporarily turn a red or mud color once the new chemicals are added. Councilmember Schwartz has urged the EPA to conduct a thorough and vigorous public information campaign prior to the change.
WASA should pursue a course of service line replacement that includes the full length of the service line, including public and private portions, at a rate of at least 1,600 lines per year (which is roughly 7 percent of the current 23,000 identified lines). The Task Force recommends that WASA continue to explore the no-interest loans recommended by Councilmember Schwartz, as well as financial assistance options for residents in need of assistance in order to replace the portions of lead service lines that lie within their property.
DOH has been offering free blood lead level testing to those District residents who request it. DOH should continue to offer this service until the lead in drinking water problem has been resolved.
WASA should continue to provide free water lead level test kits to single-family residences, apartment buildings, condominium buildings and cooperative buildings that request them. WASA also needs to provide the results of these tests in a timely manner.
Owners of apartment, condominium and cooperative buildings should promptly request a water test kit from WASA, collect first-draw and second-draw samples of the tap water in their building and send these samples to WASA for testing after receiving a request to do so by a rental tenant or owner-occupier in the building. Legislation introduced on April 20, 2004 by Councilmembers Schwartz and Ambrose would mandate this.
The Task Force recommends that WASA continue to distribute free water filters and replacement cartridges to residences that test high for lead in their water, and that WASA should begin distributing these free filters and replacement cartridges to all residences with water service lines of unknown composition. The distribution of these filters and replacement cartridges should continue to each residence with a water service line of unknown composition until the residence is determined to not have a lead service line and the test of its water shows a non-excessive lead level.
The Task Force recommends improved communication between WASA and the Mayor, the Council, DOH and the public. The public and government officials were not properly notified by WASA of the discovery of excessive lead water samples. WASA must improve its procedures for communication to the public and government officials regarding issues relating to the quality of the District's drinking water, especially with respect to health hazards like lead.
The Task Force also recommends continued consultation between WASA and EPA regarding the lead in drinking water issue. Although EPA failed initially to provide the leadership and oversight in this matter that it should have, it is important at this time to continue discussions with EPA and receive the benefit of its expertise in drinking water issues now that it appears to have become engaged in this matter.
WASA and DDOT should continue to coordinate their efforts with respect to the lead service line replacement program to ensure that District roadwork is conducted efficiently and effectively.
The Task Force strongly recommends that WASA reevaluate its Operating and Capital Budget in order to forestall consideration of its proposed water rate increases.
The Task Force recommends that the District continue to seek funding from the federal government to help pay for the costs of addressing the lead in drinking water issue in the District. Since the federal government was responsible in large part for helping to create this situation, it is only fair that it help pay to remedy this problem.
The Task Force recommends that the federal government continue to investigate the federal entities in this matter, the Washington Aqueduct and EPA, through oversight hearings and other means.
The Task Force is pleased that WASA recently contracted with a health professional expert to provide information on drinking water and health-related issues, and supports further such efforts by WASA in the future.
The Task Force recommends that District government communications on this matter continue to be coordinated by EMA. EMA has does an excellent job of coordinating communications regarding this issue thus far.
The District should continue to consider obtaining primacy over its drinking water program, pursuant to the Safe Water Drinking Act. Although EPA currently regulates the District's drinking water program, EPA has indicated that it might support District efforts to obtain primacy over this program if the District can satisfy certain criteria.
The Task Force was a working group charged with finding answers to questions of concern to the public and government regarding the lead in drinking water issue. It served as a forum in which relevant government entities were able to share information and develop responses. When the Task Force was established a little more than 3 months ago, it was originally scheduled to be active until April 9, 2004, on which date an interim report was issued. This final report of the Task Force's activities is now being issued on April 22, 2004.
The Task Force co-chairs, Mayor Williams and Councilmember Schwartz agree that the Task Force's highest priority - to ensure coordination and cooperation among the agencies involved in addressing the problem of lead in some District residents' drinking water - has been achieved. The nine weekly Task Force meetings and the numerous Task Force public briefings have opened the lines of communication, and the co-chairs, as well as other members, expressed confidence that the appropriate individuals and agencies will continue to cooperate and coordinate as need be. Therefore, Mayor Williams and Councilmember Schwartz decided that, with the issuance of this final report, the Task Force would be dissolved. A few appropriate modifications have been made to the Interim Report, issued on April 9, 2004, which has also been updated with the latest testing data.
Mayor Williams and Councilmember Schwartz expect WASA to report back to them on the agency's activities and actions related to each recommendation included in this report. In their respective roles as head of the Executive Branch of the District government and Chair of the Council's Committee on Public Works and the Environment, Mayor Williams and Councilmember Schwartz will continue to act to address the problem of excessive lead in some residents' water until it is fully resolved.
1. Following a discussion at a Task Force meeting, the City Administrator partially activated emergency operations at EMA to coordinate the work of all city agencies involved in responding to the issue of high levels of lead in some of the District's drinking water. Toward that end, a Drinking Water Quality Workgroup was established to identify key issues associated with this situation and develop a plan of action to address and resolve those issues. A key component of EMA's coordination was ensuring that members of the work group carried out functions related to this situation according to the roles and responsibilities outlined in the District Response Plan (DRP). The agency also provided support services, including GIS mapping services to WASA and DOH. EMA continues to track agencies' completion of tasks identified in the work plan and provide coordination and support for ongoing efforts to abate the problem. Finally, the agency has served as a communications clearinghouse and a logistics manager.
2. There has been a tremendous increase in the amount of activity designed to address the lead issue since the formation of the Task Force. While it is difficult to catalog exactly which actions resulted from Task Force discussions versus which were merely influenced by them, versus which were accelerated by them, etc., it is safe to say that virtually all of the activities have flowed through the Task Force and/or have been led by Task Force members. This report does not intend to give undue credit to the Task Force for all of what has been accomplished, but rather to catalog the prominent activities, which makes clear the value the Task Force has added to the overall process.
3. One woman who was nursing was subsequently retested and had a second blood lead level that was not elevated.
4. One additional child from Maryland but who attends a daycare center in the District had an elevated blood lead level.
5. Again, one woman who was nursing was subsequently retested and had a second blood lead level that was not elevated.
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