Dear Ms. Bethel,
Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA) proposed updated human health criteria for 94 chemical pollutants, noticed at 79 Fed. Reg. 27303 (May 13, 2014). Clean Water Action is a one million member organization working in 15 states and at the national level on a wide range of health and environmental issues. The NC Conservation Network is a state-level advocacy group working in partnership with 90 affiliate organizations and over 80,000 supporters to protect public health and the environment across North Carolina. We share an interest in effective implementation of protections for drinking water.
We write today to raise three concerns related to a subset of the pollutants in your proposal:
- Some pollutants, in addition to posing direct risks to human health, also act as precursors to toxic disinfection byproducts (DBPs) when the water is withdrawn for potable use. We argue that, as a matter of both sound public policy and law, the impacts of these pollutants as DBP precursors should be assessed in setting human health criteria.
- Several of the pollutants proposed for criteria revision are themselves DBPs. In addition to the DBPs created at downstream water treatment plants, the DBPs already present in source water pose cumulative risks. The proposed human health criteria are calculated without regard to that cumulative risk, and have the effect of both of increasing risk to downstream users and transferring additional costs to downstream public water systems. We recommend tightening the criteria for these pollutants to avoid that result.
- The agency proposes to loosen criteria for several of the DBPs on the list. Several of the drivers for these proposed changes are problematic, failing to take account of dermal exposures, an important pathway for DBPs exposures in adults and children. In addition, changes to the cancer slope factor, average body weight, and average daily consumption of water fail to address the specific characteristics and vulnerabilities of children.
We explain these comments in greater detail below. Click here to download the full letter.