From: Craig Cummings <Craig.Cummings@arlingtontx.gov>
To: kim feil <email@example.com>
Sent: Monday, October 22, 2018 1:49 PM
Subject: RE: Lead testing going from 6 months to every 3 years
The Texas Commission on Environmental Quality (“TCEQ”) was requested by the City of Arlington, per United States Environmental Protection Agency (“USEPA”) lead and copper regulations, to move to reduced sampling because of our excellent record regarding lead and copper results as well as associated water quality results as they relate to corrosion control. This was granted and thus we are on the reduced sampling schedule of every three years.
We selected sampling sites prior to the initial lead and copper sampling, that met he USEPA criteria for assumed age of the plumbing materials based upon construction age of the home. We have used the same sites since the beginning of that testing to provide consistency in the testing process and to follow the sampling rules.
I would not be able to add your home to the list of testing sites unless the existing sites in your area are no longer able to be tested. I have included a list of certified laboratories that you might use to have your water tested for lead and copper although I am confident that Arlington’s water is providing protection from possible leaching from lead bearing internal plumbing fixtures and piping in your older home. I downloaded the list from a state site of accredited labs and it, unfortunately, does not have telephone numbers in the file.
You are correct that the USEPA sets the federal standards and states with primacy can set more rigid standards. But in either case, the USEPA standard or more stringent State standard is the standard that must be adhered to; in the former by all states or in the latter case, by only the State that has set the more stringent standard.. Regarding your comment that Arlington has the 4th worst drinking water as determined by the Environmental Working Group’s standards, but of which many are nothing more than goals, I would vigorously disagree with this assertion. Arlington meets and in many cases is much better than Texas and USEPA drinking water standards that are set after robust scientific research and standard setting procedures. To my point, we must adhere to Texas and USEPA standards, not a standard set by another jurisdiction, even if that standard is purported to be a “better” standard or a goal.
Instead of cherry-picking standards that Arlington, Texas is not bound by , if the Environmental Working Group would care to compare Arlington Texas’ adherence to USEPA standards, which are the safe drinking water standards set for the United States, I am sure we would be talking about a completely different ranking. Arlington, Texas would probably in the top ten of the largest cities in the United States. The Environment Working Group has also chosen to look at some California public health goals and not even enforceable standards or laws in California in all cases.
Looking at safe drinking water enforceable standards, and comparing them to something analogous to, say Texas traffic laws, you cannot compare Arlington, Texas’ adherence to the Texas speed limit based upon using a different speed limit from California. Regardless if California purports it’s speed limit law to be “safer”, it is not a law that Arlington, Texas must follow because it does not exist in Texas. Getting a ticket in Arlington, Texas with an explanation that you were speeding compared to, not a Texas law, but a California law, is preposterous. And to make matters worse, the explanation could be that getting a ticket in Arlington, Texas with an explanation that you were speeding compared to, not a Texas law, but a speed limit goal in California does nothing but reinforce the typical drama and unscientific output from the Environmental Working Group.
Drinking water standards are no different; they are generally very uniform across the country with some State exceptions unique to that state. The USEPA standards are set to provide a national standard that spans the enormity of the United States with vigorously scientifically researched standards to provide consistency and enforcement. If a primacy State wishes to enact standards that are more restrictive than the federal standards, they may do so, but it is understood that those standards are for that State only. Public Drinking Water Supplies are bound by enforceable standards, not goals.
From: kim feil <firstname.lastname@example.org>
Sent: Monday, October 22, 2018 10:45 AM
To: Craig Cummings <Craig.Cummings@arlingtontx.gov>
Subject: Lead testing going from 6 months to every 3 years
Reference the City blog post, http://www.arlington-tx.gov/news/2018/10/17/arlington-water-utilities-completes-lead-copper-testing/
How is it that TCEQ directed you to stop testing every six months and so now it is every three years?
You use the same 50 sites of 100 sites…one of the sites is/was? the UTA Student Lutheran Center…that is an old building, but MY home is almost 100 years old…I am officially requesting that you put my home put on the list.. But I don’t want to wait 3 years. If I get it tested myself who/how would I go about doing that?
The EPA is a starting point…the states and local gov can be more protective of public health and set more stringent standards….like California does.
On the City blog I asked them in the (pending comment)….
Please explain why Arlington has the 4th worst drinking water by Calif. safe from cancer standards in the top 200 largest cities in the US! https://barnettshalehell.wordpress.com/2018/03/18/arlington-tx-top-4-worst-tap-drinking-water-score-in-us/
From: kim feil <email@example.com>
To: “firstname.lastname@example.org” <email@example.com>; Buzz Pishkur <firstname.lastname@example.org>; “email@example.com” <firstname.lastname@example.org>
Cc: Robert Rivera <email@example.com>; Lana Wolff <firstname.lastname@example.org>; Charlie Parker <email@example.com>; Robert Shepard <firstname.lastname@example.org>; Jimmy Bennett <email@example.com>; Michael Glaspie <firstname.lastname@example.org>; Sheri Capehart <email@example.com>; Jeff Williams <firstname.lastname@example.org>; Kathryn Wilemon <email@example.com>; Trey Yelverton <firstname.lastname@example.org>; Cynthia Simmons <email@example.com>; Don Crowson <firstname.lastname@example.org>; “email@example.com” <firstname.lastname@example.org>; Collin Gregory <email@example.com>; Maria Carbajal <firstname.lastname@example.org>; Jim Parajon <email@example.com>; Brett Shipp <firstname.lastname@example.org>; Cindy Powell <email@example.com>
Sent: Tuesday, January 26, 2016 11:22 AM
Subject: Cynthia & Mr Gildersleeve, please respond on GM’s emissions #ArlingtonTXtheNextFLINT?