U.s. Federal Regulation of Arsenic in drinking water Bruce macler, Ph.D. Original Public Health Service standard was grandfathered as EPA Maximum Contaminant Level in 1974. 1986 Safe Drinking Water Act amendments directed EPA to review, revise EPA's Regulations. MCLG generally set between 1 / 10,000 and 1 / million increased lifetime risk for cancer.
U.s. Federal Regulation of Arsenic in drinking water Bruce macler, Ph.D. Original Public Health Service standard was grandfathered as EPA Maximum Contaminant Level in 1974. 1986 Safe Drinking Water Act amendments directed EPA to review, revise EPA's Regulations. MCLG generally set between 1 / 10,000 and 1 / million increased lifetime risk for cancer.
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U.s. Federal Regulation of Arsenic in drinking water Bruce macler, Ph.D. Original Public Health Service standard was grandfathered as EPA Maximum Contaminant Level in 1974. 1986 Safe Drinking Water Act amendments directed EPA to review, revise EPA's Regulations. MCLG generally set between 1 / 10,000 and 1 / million increased lifetime risk for cancer.
Copyright:
Attribution Non-Commercial (BY-NC)
Available Formats
Download as PPT, PDF, TXT or read online from Scribd
USEPA Region 9 (415) 972-3569 macler.bruce@epa.gov
+ Ë Rule promulgated January 22, 2001 ± FR 66, #14, pp 6975-7066 ± Effective date February 22, 2002 Ë MCL proposed at 5 ug/L, set at 10 ug/L ± Based on cost-benefit balance ± Used bladder and lung cancer risks Ë 5-year implementation period ± MCL compliance January 23, 2006 ± CCR reporting beginning February 22, 2002
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+ - Ë Ariginal Public Health Service standard was 50 ug/L ± Based on non-cancer endpoints Ë PHS standard grandfathered as EPA Maximum Contaminant Level in 1974 Ë 1986 Safe Drinking Water Act amendments directed EPA to review, revise arsenic MCL ± Concern for skin cancer )
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/+ Ë Maximum Contaminant Level Goals ± Not enforceable, but direct MCL ± "Each MCLG...shall be set at the level at which no known or anticipated adverse effects on the health of persons occur and which allow an adequate margin of safety" Ë National Primary Drinking Water Regulations ± Enforceable ± Set as close as feasible to MCLGs ± Feasible analytical methods and treatment technologies ± Administrator can adjust MCL for cost reasons Ë Ather regulatory applications generally not considered .|
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Ë For contaminants with no threshold for adverse effects (i.e., initiator carcinogens) ± MCLG = zero as default or positive data for initiation ± MCL generally set between 1/10,000 and 1/million increased lifetime risk for cancer, based on risk assessments Ë For contaminants showing a threshold for adverse effects (promoter carcinogens, non-carcinogens) ± MCLG based on Reference Dose (RfD), set to be below any known adverse health effects ± MCL set as close as feasible to MCLG
| Ë Arsenic health effects have been extensively studied Ë A variety of human cancers are associated with arsenic ingestion ± Lung, bladder, prostate, skin, liver« ± Arsenic inhibits chromosomal repair, enhances cancer progression Ë Circulatory and neurological damage, diabetes also can occur ± Arsenic inhibits mitochondrial respiration Ë High disease levels seen in populations drinking water with arsenic 5-20 times higher than current 50 ug/L MCL
- Ë We don¶t lack health data« ± 100¶s of arsenic publications in last two years Ë Arsenic appears to act as endocrine disrupter to block glucocorticoid action ± May affect diabetes, hypertension, cancer ± Acts as low as 10 ug/L Ë Dimethylarsinic acid is toxic ± Causes DNA strand breaks in lung tissue (complete carcinogen) ± Promotes bladder, kidney, liver and thyroid cancers ± Methylation NA a detoxification mechanism
+ Ë Money Ë Affected drinking water purveyors Ë Ather affected parties Ë Health effects/ regulatory benefits Ë reatment
) Ë U59,000 community water systems in US ± U10,000 use surface water, U49,000 use ground water ± About 2500 utilities serve >10,000 people ± >90% of smallest systems use groundwater Ë Highestarsenic levels are in small groundwater systems ± 3300 GW systems, 90 SW systems >10 ug/L ± 3300 small (<10,000), 90 large
) Ë Most affected systems are very small, rural Ë Smaller systems not really utilities ± Few have a full-time operator ± Little or no treatment infrastructure ± Limited financial resources Ë Most affected systems have had few regulations to follow up to now Ë Basically, implementation starts from scratch A
| Ë Drinking water MCLs used for Superfund and other hazardous waste cleanups ± While not directly applicable, these are considered ³relevant and appropriate regulations´ ± Groundwater cleanups may be set at MCL Ë Mine wastes, oil extraction brines, coal flyash often high in arsenic ± Arsenic may be dominant risk in site assessments Ë Cleanup costs are less important ± Costs could be greater than for all drinking water - . ) Ë is arsenic a public health problem in the US? ± SDWA goals versus risk perceptions ± Safety is in the eye of the beholder Ë SDWA has public health risk goal ± MCLs have been set with estimated risks between 1/10,000 - 1/million excess lifetime ± Not law, but precedent Ë here are no ³bodies in the streets´ in U.S. from arsenic - . +
Ë Epidemiology, medicine can at best resolve risks >1/100 level ± For arsenic, exposures not high enough for epidemiology to find disease in U.S. Ë Risk assessments can extrapolate data to lower exposures and risk levels ± Regulatory risk assessments are conservative, generally go to upper risk boundaries Ë Arsenic has always been here, so some biochemical detoxification mechanism must exist ± Real risks could be lower Ë For smaller GW systems, going from nothing to something Ë For larger GW systems, wellhead treatment at multiple wells Ë Waste disposal hassles and costs Ë Peripherals: land, permits, human resources, NiMBYs, etc V
+ - Ë in early 1990¶s, new cancer concerns were growing Ë But strong opposition by oil, extractive and drinking water industries Ë 1996 SDWA amendments featured arsenic, cost- benefit decision-making Ë EPA proposed 5 ug/L as arsenic MCL in June 2000 Ë EPA promulgated MCL at 10 ug/L in January 2001 Ë New Administration postponed effective date, set up review + 1 Ë EPA Administrator Whitman said, ³it's only a review. he MCL may stay the same or even go down.´ Ë National Academy of Sciences reviewed health data and risk assessments from 3-20 ug/L Ë National Drinking Water Advisory Committee reviewed cost and technologies materials Ë EPA Science Advisory Board reviewed benefits analysis
)- ++ Ë he Academy¶s National Research Council reviewed EPA¶s arsenic risk assessment ± Reviewed use of aiwanese studies and aiwanese populations ± Evaluated data for 1% (ED01) cancer risk level ± Considered EPA¶s analysis of mode of action and dose-response uncertainties ± Judged whether EPA risk estimates for 3, 5, 10 and 20 ug/L were consistent with current science
) Ë Data from aiwan, Chile indicate high risks for cancer ± Appropriate for risk assessment use ± Utah study too problematic for use Ë Use linear approach to extrapolate from 1% (ED01) cancer risk to 1/10,000 regulatory risk level ± Sublinear extrapolation not justified ± Substantial variation in human response needs to be incorporated ± Consider using U.S. background cancer levels Ë Epidemiological studies unlikely to show effects in U.S.
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Ë NAS estimated arsenic-associated lung and bladder cancers ± Bladder cancer risk about 12-23/10,000 @ 10 ug/L ± Lung cancer risk about 14-18/10,000 @ 10 ug/L ± (EPA had estimated bladder + lung cancer at 0.6- 3/10,000 @ 10 ug/L) Ë Athercancers not quantified, but add risk Ë Averall 1% cancer risk level < 50 ug/L .|
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,,+ Ë Science Advisory Board examined how EPA valued benefits from Arsenic Rule ± Reviewed quantification of cancer costs, and benefits from not getting cancer ± Also reviewed quantification of costs of other diseases Ë Recommended EPA quantify ischemic heart disease, diabetes mellitus and skin cancer Ë Suggested EPA consider quantifying prostate cancer, nephritis, nephrosis, hypertension, hypertensive heart disease and non-malignant respiratory disease Ë Said EPA should consider latency adjustment Ë Net result could increase or decrease benefits of Rule
+ Ë Examined costing methodologies, assumptions, information and national estimate of system costs for the Arsenic Rule Ë Concluded that EPA¶s estimate was credible Ë Affered a variety of improvements ± New technologies will lower costs ± Necessary related activities add to costs ± Net result unlikely to significantly change national costs
, 2 3 !!!%%&*+4 u Proposed Proposed ³What if´
Cost Benefits Benefits
$645-756 $44-104 $42-448
$379-445 $32-90 $35-384 $165-195 $18-52 $20-224 $63-77 $8-30 $9-128 Costs and benefits in $M/yr Also, unquantified health benefits for cancers of the skin, kidney, nasal passages, liver, and prostate and noncancer effects on the cardiovascular, immune, nervous, and glandular systems likely to be substantial '51 Ë EPA let MCL stand at 10 ug/L without comment on reviews Ë implementation by small systems will be a challenge ± Need simple, user-friendly treatment ± Must be easy to design, ³off-the-shelf´ to cut costs ± Need to find and train operators ± Need money ± Need to change some minds