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Re: E-M:/ EPA arsenic panels point toward stronger protections

According to the USGS, the eleven Michigan counties in which arsenic is present in drinking include: Huron, Genesse, Ingham, Lapeer, Livingston, Oakland, Saginaw, Sanilac, Shiawassee, Tuscola, and Washtenaw. You can visit the USGS website (www.usgs.gov) to learn more about their work on arsenic occurrence in U.S. and Michigan drinking water sources. Also, we have a USGS fact sheet which includes a map of MI's arsenic in drinking water (based on the data available to USGS). While these counties emerged in the USGS data, other parts of the state could also find arsenic in their drinking water sources.
Some effected Michigan counties have developed their own arsenic occurrence maps (Oakland for sure and I think Washtenaw and Livingston). The Oakland County maps released in 1998 (I think) delineated above and below 50 ppb (the current 60-year-old standard). When the maps were being developed in 1997, Clean Water Action members worked hard to get the county to do more detailed delineations (such as 3, 5, 10 and 20 ppb). At the time, we believed the final two-tiered maps were a disservice to Oakland County residents without this detail. However, based on the new National Academy of Sciences report (referenced in my original posting below), arsenic apparently poses serious health risks REGARDLESS of the occurrence level.
At least the following three things can be done immediately on the public water system side:
1)    Submit comments during EPA's current public comment period, which is seeking public input on whether you want 3, 5, 10 or 20 ppb of arsenic in your drinking water (see my previous posting included below for details on how to submit comments). Clean Water and its state and national allies have been advocating for 3 ppb because this the level EPA has deemed "feasible" and because it's the lowest level at which arsenic can be detected with widely available laboratory techniques.
2)    Join with other groups who are calling on the DEQ to proactively set the Michigan standard at a level which is protective of our health...regardless of where EPA sets the standard. Last June, Clean Water Action joined with Dr. Michael Harbut (a Michigan physician with extensive experience treating persons affected by arsenic in Michigan drinking water), the Michigan Environmental Council, the Ecology Center, Lone Tree Council, East Michigan Environmental Action Council, and the League of Conservation Voters Education Fund in petitioning DEQ to move ahead with establishing an updated standard.
The following is an excerpt from the denial letter we received from Flint Watt, Chief of the Drinking Water and Radiological Protection Division, in response to that petition:
"The DEQ has not concluded that there are substantial health risks at and above 0.01 mg/l [10 ppb] of arsenic."  He also says, "The DEQ cannot conduct and complete an independent analysis of arsenic in drinking water, including a risk assessment, before the EPA-authorized work will be done. Further, the EPA work is already funded and underway and draws upon far greater personnel and financial resources than the state of Michigan can provide. Thus, it is neither appropriate for the DEQ to initiate an independent analysis nor initiate administrative rulemaking at this time, and your petition is denied."
Clearly, the results of the National Academy of Sciences 2001 review of the arsenic in drinking water studies (referenced in my original posting) show that even the final Clinton Administration withdrawn 10 ppb standard was exposing the public to risks far beyond what EPA has historically used as its MAXIMUM risk level.

3)    Communities served by public water systems with arsenic in their drinking water should move ahead with removal. Those communities unable to afford such treatment on their own, should be given top priority in receiving funds from Michigan's allocation of the Drinking Water State Revolving Fund as well as other sources of assistance as necessary. We need to get this cancer-causing poison out of our drinking water and provide support those communities needing assistance.
As for those served by private wells, the most important thing to do is to get your well tested for arsenic by a certified lab using techniques that can detect to at least 3 ppb. If you detect arsenic in your water, there are both point-of-use and point-of-entry devices available that can effectively remove arsenic. I believe that State Representative Ruth Johnson (who was key to getting the Oakland County maps produced) has introduced a bill that would provide tax credits to those purchasing such devices. Efforts to educate residents about the need to EFFECTIVELY test for arsenic coupled with a measure such as this would go a long way toward protecting residents served by private wells.
Cyndi Roper
Michigan Director
Clean Water Fund and Clean Water Action
1345 Monroe Ave., NW, Suite 216
Grand Rapids, MI  49505
----- Original Message -----
Sent: Sunday, September 16, 2001 9:52 AM
Subject: Re: E-M:/ EPA arsenic panels point toward stronger protections

Do you have any URL's which address the eleven counties in Michigan and to what degree?
What options are available to home owners, on both public and private water systems?
----- Original Message -----
Sent: Saturday, September 15, 2001 11:08 PM
Subject: E-M:/ EPA arsenic panels point toward stronger protections

Because at least eleven counties in Michigan have significant levels of arsenic in their drinking water, I thought it was worth elaborating on a news event that was overshadowed by this week's tragedies.

Just minutes before the terror began on Tuesday, the EPA provided some bad news about the health effects of arsenic exposure in drinking water. At the same time, the agency offered hope that millions of U.S. residents will finally get AT LEAST the level of protection offered by the World Health
Organization and the European Union (10 ppb).

The news came in the wake of the National Academy of Sciences (NAS) "Arsenic in Drinking Water: 2001 Update" (available at: www.nas.edu) which was made available on Monday evening. The study finds that the cancer risk from arsenic in drinking water is higher than that estimated by the EPA in its January 2001 rule (the "Clinton Rule" which set the standard at 10 ppb).  Specifically, even at 3 ppb, the NAS estimated that the cancer risk is between 4 and 10 per 10,000 people. The EPA's MAXIMUM acceptable level of risk for the past two decades for all drinking water contaminants has been one in 10,000.

Importantly, the NAS report points to health effects other than cancer that should be considered, including heart disease, high blood pressure and diabetes. It also rejects arguments by industry and some local water utilities that there is a clear, safe threshold below which arsenic does not cause cancer.

In the agency's words, as reported by the Associated Press:  "This makes it more difficult," Whitman spokeswoman Tina Kreisher said Monday. "Their study reinforces the cancer risks. ... If anything, they believe that there is more risk than the EPA thought previously." [A couple of other versions of
the story are available in Tuesday's editions of the Washington Post (www.washingtonpost.com/) and the New York Times (www.nytimes.com/).]

EVEN WITH ALL THE OFFICIAL EVIDENCE POINTING TOWARD GETTING ARSENIC OUT OF OUR DRINKING WATER***, we must continue submitting comments to the EPA during its current pre-proposal public comment period asking for the strictest possible standard given current laboratory techniques:  3 ppb.
Since the public comment period remains open through October 31st, take a few moments to send your comments to EPA in support of a 3 ppb standard. Consider sending a copy of your comments to your U.S. Representative and to both of Senators Levin and Stabenow because, as you might recall from events in July, Congress has begun weighing in on this issue.

E-mail your EPA comments to: ow-arsenic-docket@epa.gov

or mail them to:

W-99-16-VI Arsenic Comments Clerk
Water Docket (MC-4101)
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

***This report comes on the heels of the following two EPA-mandated reports released by panels formed to review arsenic in drinking water rule.

1)    The national Arsenic Cost Review Working Group -- on which I served -- released its report last month. Interestingly, there was very little coverage of our panel's findings because we concluded that the EPA did a credible job of estimating the costs of implementing the standard at 3, 5, 10 and 20 ppb. If our panel had found that EPA overestimated the costs -- as many parties hoped -- there
would have been an all out media effort to spread the word. Instead, the only newspaper coverage I saw on the report was a recent LA Times article. The full report of the cost review working group can be viewed at: www.epa.gov/safewater/ndwacsum.html#ndwac.

2)    The EPA Science Advisory Board, which identified among other things several short comings in the agency's cost-benefit approach. The final report ("Arsenic Rule Benefits Analysis: An SAB Review") is now available on the EPA Science Advisory Board Website at http://www.epa.gov/sab/ec01008.pdf.
Posted by:
Cyndi Roper, Michigan Director
Clean Water Action and Clean Water Fund
1345 Monroe Ave., NW, Suite 216
Grand Rapids, MI  49505
616.742.4084 phone
616.742.4072 fax