September 15, 2000
Carol M. Browner
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Re: EPA Newly proposed arsenic standard for drinking water
Dear Ms. Browner:
The Washington Environmental Council (WEC) is a statewide coalition of 90 member groups and thousands of individuals working to protect, restore, and enhance the environment of Washington State. For 33 years we have worked on a wide range of environmental issues, including preventing pollution and protecting public health. For the past several years, WEC has served on the Water Supply Advisory Committee, which provides advice to the State Department of Health regarding implementation of the Safe Drinking Water Act. We thank you for this opportunity to provide the following comments relating to the newly proposed standard for arsenic in drinking water.
Arsenic contamination is of particular concern in Washington state, due to issues such as arsenic-contaminated soils on Vashon and Maury Islands in King County and wood treated with arsenic compounds used to build playground equipment.
EPA is proposing a public health goal of zero for arsenic. The zero health goal is the level below which no known or anticipated health effects would occur. In addition, EPA is proposing to change the arsenic standard in drinking water from its current value of 50 ppb to 5 ppb to more adequately protect public health. EPA is also accepting public comment on other possible arsenic standards of 3 ppb, 10 ppb, and 20 ppb. Both the zero health goal and the new standard are intended to protect consumers against the effects of long-term, chronic exposure to arsenic in drinking water.
WEC supports the zero health goal, and the 5 ppb standard for the following reasons: Although the proposed arsenic standard of 5 ppb exceeds the technically feasible level of 3 ppb, we understand that the 1996 Amendments to SDWA granted EPA discretionary authority to adjust the standard to a level that maximizes health risk reduction benefits at a cost that is justified by the benefits. Although the new standard will apply to all 54,000 community water systems, serving approximately 254 million people, EPA estimates that only 12 percent, or 6,600, of these water systems, serving 22.5 million people, will have to take corrective action to lower the current levels of arsenic in their drinking water.
We believe the 5 ppb standard would provide considerable additional public health protection, without requiring excessive corrective action. We are hopeful that you will move forward with this change.
Again, we thank you for the opportunity to comment on this important issue.