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Tha hazards of ing sting chamical cllutants in
drir cirig watsr car 4 b. ass ssad in two g nera1 WayS, ?1d3 1
ogical studias and laboratory studies of toxicity. The
ot both rovide in:or a’.on on tht risk to man. os of the
currant knowl adg of toxicity is based on observatic s of the
affect on man and animals of dose -— and dose ratas that ar
much larger than those that corrss ond to the usual concentra-
tion of harmful material in drinking water.
There is consequently great uncertainty in estimat-
ing the magr.itude of thea ris< to health that ingestion of con-
tarninants in drinking water ma’i oroduce. An additional ‘ rob-
1a is pres’antad by the cc thined affects of wc or more cor.-
taminants.
The theoretical and experimental basis for extrapo-
lating estimations of risk to low lapel of doses ar raviaw d
in our study, and scrne crinci 1es ware orocosed to cuide the
conduct of this and similar studies, They were reviewed cr
you this morning by )rs. : oel and 3 a-tas.
The organic compounds that ha za be n identifiad in
drinking water rna a up a small fraction of the total orcan c
matter cr sent. About 90 cercent of the voLatile organic
compounds have bean ider.tified and quantified, but these rep-;
resent not more than 10 percent by weight of the total org i
material.
Only 3 to 10 percent of the nonvolatile organic
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11
12
13
14
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19
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ccr ounds tccrncrised the : mainirig 90 percent of the total
c:gan.Lc rnatarial has bean identified.
3 The cc pounds salactad for raview in this study
4 1 included 74 non oesticides and a rc_ i l v 300 voiatil
organic cor-iccunds of t. ’a 300 icentifiad at tna time tna
6 was made in drin cing water and 55 pesticid.as. Some of the
7 pesticides ware not detact d in drin1
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l l3:
tal ±nc about th us -- wnola isu of c .lcrofc rn of
2 1 chlcrnat!o of water, of ch1orin in th disi f ction of
3 watar. or your information, w i ar at this ti going into
4 3cm detail to xa tizi th cons qu ncas of th us of chlcro—
form at diffar r 4 t stacas during th disinf ctLcn procass.
ars comparing those, that r sult with a nurribar c
other disinf ctants, both as to d±sinfactar.t €ff±cacy to th
by rcducts form d and to tha rcc ss of : mcva1 of th s com
9 oounds. This study, ow v r, is bar ly und iay, and w wi .
10 not b having rasults for s vsral months, possibly a yaar.
thin:< that concludas y stata nt. f you have
any qu st.icns, I would b glad to answer thamn.
1:3 MR XIMM Dr. useright, rha s on coii z nt that
14 wa must nave heard frcm dozans and dczans of with s s througr
15 th h.aarings h8ld up until this tin a -- assantially, thay
16 in-tart tad th NAS raport as saving, one, that additional
17 ras a:ch was necassary and consequantly standards should n t
18 b set for caro nccans.
19 Can you resoond to that in on syllable words and
20 ;erhaps put that concarn -*
21 DR. HOUSERIGHT: I will do tha b ist can. Tha
22 Acada y did mnaka a rather long list of :acomnrn ndaticns for
23 research that we felt was requir d. I thin3 , so far as this
24 particular pr bla n is concarn d, there appears t b no qu s-
25 tion but what, first of all, chlcrofc is found in drinking
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wat er 1 and it is a carcinocen.
We do not feel that it is .n cv rsi olification to
:3 say that this creates an added hazard to an as far as carcinc
genesis is concerned. I don’t thirJ that 9A has rushed into
this decision to decide to regulate the 1eva . i’ie tried to
b roi,ide th information on which that level could b based,
but I don’t think that there is going to be anything in the
next 12 months that is going to drastical .y change the results
MR. MN Stholy st tad, your : or endaticns for
additional research were not in lieu of es ilish3 ng a stand
a .
13 DR. -iOUS R G T: That .s corrects
14 R . KL 24: I think that misunderst iding has occurre
DR. HO JSERIGHT: One other ques ..on raised iii that
1 connection, someone, I believe, has said that - e:e was s a
blem because the ?.cade.rrty did not spe ik i terms of : c:s.
thi .k I would li) a to address that for ju . t a moment.
The congressional r tandate in Sec: .- 1412E call. d
for the Acadaxny to make this study cm i var c con inants,
21 and they used the t.ern ‘ma:
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1—133
do - befor this study st rt d, w said that the Acad my
2 consi er d that thc intent of Congress in using the as
‘maximum contaminant levelwhich should be reccm end d in
or to ot c the hea 1 th of oersons from a’ y 1 riown or an ic
1pat d adverse effect” is to ‘ rovide for raco ndatioris that
h ar consistent with the bast scientific.
It was the ?cadarn ’s udc ient, frorr a ciantific
oint of view, that. the absc1ut guarantee of safety implied
9 by th3.s langua a could not be made for most or all of the con-
taminants that were found in drinking water. The Acada. v did
agree o rovida info ation along t a f.ällowina lines:
12 t ev said that wt enWe have .sufficiant,.data
from whi. ch a hui an dose response ia cn5 p ou1d e pro ec
ed with sc e degree of Drecision, that Drojec on would be
made. The rojacticrL would be explained and its cua1ificatic
I made explicit.
iT secondly, or ccnt& tünants for which the data are
13 sufficient, quantity and quality, th ? cadamy would ex rcisa
19 scientific judgment and idantify and propose conta iinant
20 levels for which it anticipates the risk of advarsa health
21 effects to be s cifiable and very small. Th risk of orc os-
22 ed levels would be described in the e lanat on as to why io
23 safe level had been identified,
24 Then the third group would be those for which there
25 was insufficient information.
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I think this i a act1y what was do a in th study.
2 Th or anics wars di’;idad into two rou s, those for which w
:3 thought th r was o vidanc that they w r ca cincgans, ai d
4 for those did do - - e dia - a< a ca1cu1a i.cns o
not r 1d to cancer. Thcs that w r consid : d to b car-
cinogeriS were d!vi d into various 1 v 1s tha cn found to
7 be a car:incgan in h ans, some susp ct d carcinogens in
ans, others found to b carcincgenic in exparin nta1 animals.
9 iS. C ANG: Ar th ra anY other cTu Sti.Cns?
Thank you v r1 r uch, Dr. -tcusaright.
11 At this time I have had a r quast from Susan :
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1—135
i±11 dsta±i th position of Los Angal s; but, first, I would
H lika to briafly discuss th fscts of ?rc ositicn 13 on
L. s Anc 1 s, which ff cts us as w look at this. It a±f acts-
cur rn 1oymant, 1 v 1 of s iic of programs.
It is clear that tha passage of Proposition 13
indicatss that owols dsmand Less gcvarr r ntal spending at a11
l v ls. Although th prcpcsition app1i s currantly only to
Cal!fcr a, I think is cl:a th t the over ant is sor adinc ;
and it is not 1imit d just to taxas, but it is dirscted towardi
all cov rnmental soendina aXc ot essential 34r’ .’ CCS.
? ool tall us they want essential servicss to ramai
and they w t the fat to ba cut. It is up to us, I think, to
13 deterrnir.e which is which. I hava been told by many ccnstitu-
ants that they want us to stop Federal and stats prcgr s
which are costing the city and that is one of the
w a e ha’iincr to look at caraf’.illt.
There is no cusation that Prooositicn 13 has dras-
ica1 ’i ‘ u—tai1ad the abi i v of our local ce c as o
r’enuas, and we ar having to make tough choices. As a
rasult, the issue of cost-effectiveness has taken on a new
meaning since June 6th.
A new yardstick Is being used today to data ir
which projects and programs ar rdab1e within our new
budget restraints. one case in point is that as . nge1as
already faces a.n expenditure f $30 million for a fi,ltraticn
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lant to meet P d8ral turbidity standards uncLe: a ‘3ravicus
J E? Safa Drinking Wat r \ct lagislat .or1.
:3 New EPA proposals for dan agd coni could have
a lar r financial i. pact on our city wi’. n sv r r stric ioris
been placed upon our govrnnental spending.
3 r w u!d like Mr. ‘1innard to now detail our so cif±c
concerns about the cos d rsgulations .
3 MR. 1INNABD: Thank you, Mrs. Russ ll.
Uj ‘7innard, arid I arrt Garieral Managa:
1) of the L.os ?.ngelas Daoartt en . of 7at.er arid Power. We a:
11 veri leased to be able to have an oDoo:tunitv to
today abcut some of our oroblart s.
Througn its Depar ent o at ar arid ?cuer, ne Ci .i
14 of L s Angeles suoolias water and energy to aporoxiriatelv a
15 oo ulation of 3 rt il1icn o le. We Ea r , ;e fa l, an excaller t
16 record of furriish±nq a reliable and safs water supply to
people for over 75 years.
1$ We are very active in r e ting tha objectiv s of th
19 Safe Drinking Water Act, as currently admInistered by your
20 agency. As Mrs. Russell has pointad cut, we are currently
21 planning a very expensive filtration project to r eet the new
22 turbidity require nts which were enacted in the last fe
years.
24 WhIle we ara :es or .sibl in supplying sate water
and meeting you.r cbj ctives, j- a caine tii e we have to
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ansur xo ditu a of os ur s a cos b r i-
c al to the cornrr un .ty. ‘ Ia f e1 there is consid ab1 infcr .a-
:3 tion laCking on the Drcg:arn ou are c t1 DroDosinc wit h
- the new standa -d3 being discussad here today.
e would like to offer to ‘ iou four reccendations.
H I have a statement, which I will not read in its
nti: -ty; but I would lika to extract f:c it, and th re will
b ufficiant coflies available for everybody.
first of ail,.we are cc ending that you dalay the
i p1 mentaticn of th s and any ther organic regulations
nti1 etrong-3r ;idence of all of these has b en established.
H Second, we would like to cor nd that you expand
and a’ce1 at deally financed 1arce—sca1 health e±f cts
14 research, as recom endad by AS.
15 Thirdly, w would like to ask you to encourage water .
systems to lower triha1o ethan levels by setting the 103 ppb
1.7 -as a goal rather than a standard, and require utilities that
19 serve Cc munities of 75,300 or more to monitor these.
Fourth, w would raccc’ .z end that the d.aral Govern—
2 (3 ment monitor major water sourcas nationwide to d t .irmine tha
synthetic organic chemical levels. As I oint d out, w obj ct
22 to s tting 100 pob as a standard and also yc r ac ncwledged
2 :3 intent to r duc this to 10 somet me in the uturs
24 ie nave n a.d tas .mcny bY the tAS, and, in CSS flCC,
25 a agree; although after listening to Dr. Houseri;ht, there
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1—138
may be confusion in cur minds as to int rnratation of the
- original r3ccrt. We fe 1 that the testimony by the American I
3 Water Works Association this morning -- and i was not here,
but we h a been furnished with a copy of it -- I think ?rett?i
w 1l states he industry’s Dositicn.
b H Also, we understand that during A fl’iA’s presentat±on
that they would have ?rasent d a two-year study, financed by
your acericv, by i7ircinia, as the effect of the contaminants
9 cu are ns dering esta.cl .s ’_’a s a caros for
H We feel that the lack of kncwledce on synthetic
crganics i : indicated somewhat. by the vagueness of your procos-
[ 2 ed reculations, usinc lancuace like, ‘A variance can’t be
1:3 issued i significant contamination exists “ We think it
ought to be : cre carefully defined.
Also, we are somewhat concerned about the cost esti
H rr.ata th t had been ut forth b i cur agency earlier, and we
are l :ed to sea that it has been re crted that you have
H dcuoled -H s costs, which accear to be more in line with ‘ iha
industry be-an sayinc all along.
H don’t feel that ut3.lities oucht to be forced to
21 H s end hunb eds of millions of dollars nationwide when there is:
22 H, scme raas .able justific t!cn in cuestioning what you are do—
2:3 H ing now. :n Los Angeles, for instance, we would have to spend
H an additit miljion— lus over what rs * Russell was
stating .itr, and cve.r 4-l,’2 million in annual O& 1 ex Denses.
A me eport ng ornpony
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1—139
will have to justify these costs; articularly in the wake
of ?rcccsition 13, this becomes more critical.
3 For your infornation, the Department of Water d
?c cannot enact a rate increase or finance a major orojact
5 withcut the a oroval of the City Council, arid I can tell you
r -c m fl04 - it ce ::1c 1t
As I coi tec1 out earlier, we are recc r ding that
H Cu :ecu±re utilities 3arvLng over 75,000 ceopla to monitor
trihalomathanes, and that the Federal Covernmant monitor the
d tJA synthetic organic levels
s t33 Finally, we would like to rat the racomnendation
that zou postpone these regulations until the cuestions cur-
rantly being raised have been answered in a reasonable manner.
14 Wa realize that in each and ever-’ case conclusive evidence
cannc-t be forthcoming.
W sincerely feel that there is encuch serious gues-
than in other areas that this could be done without any serious
long—tern health effects
H While we are awaiting this, I am sure you recognize
H that the water coinmuniti: in the United States has a responsible
1 one, and they will continue to maintain water su p1±es in a
safe and adecuate manner.
Thank :0u ‘ ‘er-i much.
(The full staterr. ant follows:)
H
H Acme RepcrHng Company
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STATENENT BY THE
CITY OF LOS ANGELES
ON THE
PROPOSED ANENDMENT TO THE NATIONAL INTERI’1
FR [ I LARY DRINKING WATER REGULATIONS
FOR THE
CONTROL OF ORGAN IC CHEM I CAL CONTAII I NANTS
IN DRINK1NG ‘;IATER
PRESENTED AT
EPA’S PUBLIC HEARING N
WASHINGION D 1 C.
ON
JULY 11 1978
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STATEMENT BY THE
CITY CF LOS ANGELES
ON THE PROPOSED ORGANIC CONTROL NIENDtIENTS TO THE
NAT I OHAL INTERIM PRIMARY DRINKING /ATER RE U L T I ONS
THE CITY OF Los ANGELES ELCOMES THIS OPPORTUNITY TO PRESENT
ITS ‘/IE’4S ON THE PROPOSED REGULATIONS FOR THE CONTROL OF ORGANIC
CHEMICAL CQNT jINANTS ZN DRINKING ATER 1
THROUGH ITS DEPARTMENT OF WATER AND POWER. THE CITY PROVIDES
ATER AND PC ER TO 3 MiLLiON RESIDENTS AND HAS AN EXCELLENT RECORD
OF OVER 75 YEARS OF PROVIDING A SAFE i 1A1ER SUPPLY 1 Los A 4GELEs
IS ACTIVE IN MEETING THE OBJECTIVES OF THE SAFE DRINKING WATER
ACT AS ADMINISTERED 3Y THE ENvrRow aNTAL PROTECTION hGENC’( (EPA),
WE ARE CUR; ENTLY IN THE PLANNING STAGE OF A COSTLY FILTRATION
PROJECT FOR THE Los ANGELES AQUEDUCT TO MEET THE NEW EPA TURBIDITY
STANDARD 1
WHILE Los ,ANGELES SUPPORTS MEASURES NECESSARY TO PROTECT
PUBLiC HEALTH 1 E ARE RESPONSIBLE TO OUR RATEPAYERs TO ENSURE
THAT EXPENDITURES OF PUBLIC FUNDS ARE tADE ONLY AFTER THE NEED
AND BENEFITS HAVE BEEN ESTABLISHED VITAL INFORMATION ON THE
NEED BENEFITS 1 AND COSTS OF THIS PROGRAM IS LACKING 1 AND ThEREFORE
E ARE STRONGLY oPPOSED TO THE PROPOSED STANDARDS AND RECOMMEND
tNSTE D THAT EPA SHOULD
L DELAY IMPLEMENTATION OF THESE AND ANY FURTHER
ORGANICS REGULATIONS UNTIL STRONGER EVIDENCE OF
NEED HAS BEEN ESTABLISHED..
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2 Ex . o AND ACCELERATE FEDERALLY FINANCED, LARGE—
SCALE ALtH rr LiS R EARCH AS RECOMMENDED 3Y
THE NATIONAL ACADEMY OF ScIENcE
31 ENcOuRAGE WATER SYSTEMS TO LOWER TRIHALOMETHANE
LEVELS 3Y SETTING THE 100 PARTS PER BILLION (p )
STANDARD AS NATiONAL OAL AND REQU R MCNI tURING
BY UTILITIES SERVING OVER 75,000 PEOPLE, AND
L PROVIDE FEDERAL MONITORING OF MAJOR WATER SOURCES
NATIONWIDE TO DETERMINE SYNTHETIC ORGANIC CHEMICAL
ir:i -
LL. F I
fE OBJECT TO THE EPA PROPOSAL TO SET A MAXIMUM CONTAMINANT
LEVEL FOR TRIHALOMETHANES CF 100 PPB AND THEIR EXPRESSED INTENT
TO LOWcR THIS LEV L IN THE FUTURE iO 10 PPB 1 TH NAtIONAL AcADEMY
OF SCIENCES WAS CHARGED BY CONGRESS AND THE EPA TO RECOt’IMEND
MAXIMUM CONTAMINANT LEVELS FOR ORG.ANICS IN WATER TO PROTECT PUBLIC
HEALTH 1 THE ACADEMY FOUND THEY LACKED SUFFICIENT DATA FOR DOING
SO AND RECOMMENDED THAT FURTHER RESEARCH BE CONDUC D 1 AMONG
MEMBERS OF THE SCIENTIFIC COMMUNITY, THERE IS WIDESPREAD DISAGREEMENT
OF THE HEALTH SIGNIFICANCE OF LOW LEVELS CF ORGANIC CONTAMINANTS 1
THE At1ERIcAN WATER WORKS AsSocIATIoN (AWWA) RECENTLY PUBLISHED THE
FINDINGS CF AN EPA—SPONSORED STUDY OF THE EFFECTS ON HUMAN HEALTH
OF TRACE ORGANIC CHEMICALS IN DRINKING WATER 1 THE TWO—YEAR STUDY
REPORTS AWWA FOUND NO EVIDENCE TO BACK EPA’S REGULATIONS FOR THE
CONTROL OF ORGANIC CHEMICAL CONTAMINANTS IN DRINKING WATER 1
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EPA HAS PROPOSED A TREATMENT METHOD USING GRANULAR ACTIVATED
CARSON (GAO TO REMOVE MANMADE SYNTHETIC ORGANICS FROM 4ATER
UPPL - HE iAiIQNAL ACADEMY O SCIENC S ?AS DiREC D 0 MAKE
STUDIES AND RECOMMENDATIONS ON SYNTHETIC ORGANIC CHEMICAL LEVELS
IN ‘1ATER, HOwEvER, THE ACADEMY RECOGNIZED THAT UNCERTAINTIES
EXIST REGARDING HEALTH RISKS OF THESE COMPOUNDS AND RECOMMENDED
FURTHc SE R H TO DETFRMI\IE WHETHER LO LEVELS OF THESE COMPOUNDS
ACTUALLY INCRE ASE THE PROBABILITY OF HUMAN CANCER, WE AGR E THAT
THt ADDITIc IAL RSEARCH IS NECESSARY AND THAT IT WOU SE PREMATURE
FOR EPA TO POSE THE GAC TREATMENT REQUIREMENT O t IATER SYSTEMS
THE LACK OF KNOWLEDGE ON SYNTHETIC ORGAN 1CS 13 DEMONSTRATED
3Y THE VAGUENESS OF THE PROPOSED REGUL ATIONS 1 T HE REGULATIONS
REQUIRE UTILITIES TO MONITOR FOR 6ü SYNTHETIC ORGANICS 1 HoWEvER ,
THE ONLY GUIDANCE PROVIDED FOR DETERMINING THE NEED TO INSTALL GAC
TREATMENT 13 THE STATEMENT THAT A VARIANCE CANNOT SE ISSUED IF
“SiG FICANy CONTAt’t!NAT!CN” EXISTS 1 THE TERM SIGNIFICANT
CONTAMINATION rs 4OT DEFINED BUT LEFT OPEN TO FUTURE INTERPRETATION
EPA AND STATE HEALTH MGENCIES IT IS IMPOSSIBLE FOR UTILITIES
To DETERMINE THE IMPACT OF THIS REGULATION ON THEIR COSTS UNTIL IT
IS SEEN HO’t IT WILL BE APPLIED 3? REGULATORY AGENCIES 1
THE COSTS OF CONTROLLING THE FORMATION OF TRIHALOMETHANES AND
PROVIDING GAC TREATMENT ARE UNKNOWN 3ECAUSE THERE HAS NOT 3EEN
ADEQUATE EXPERIENCE WITH DESIGN CONSTRUCTION, AND OPERATION OF
IHESE FACILITIES 1 FOR EX AMPLE IT IS INTERESTING TO NOTE THAT
DETAILED COST ESTIMATES OF THE CAPITAL INVESTMENT FOR TUR3IDLTY
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REDUCTION i Los ANGELES ALONE ILL BE APPROXIMATELY ONE HALF OF
EPA’ s ESTIMATE OF THE NATIONWIDE COSTS FOR TURBIDITY CONTROL IN ALL
CITIES OVER 100,000 IN POPULATION A SAMPLE SURVEY CONDUCTED BY
Los ANGELES CF ONLY 31 SUCH CITIES FOUND THAT A $257 MILLION
INVE3TMENT WOULD BE REQUIRED TO MEET THE TURBIDITY STANDARDS RATHER
THAN THE 135 MILLION EPA ESTIMATED 1
UTILurIEs MUST NOT 3E FORCED TO CONSTRUCT TREATMENT FACILITIES
AT A COST OF HUNDREDS OF MILLIONS OF DOLLARS NATIONWIDE WHEN THESE
PROJECTS HAVE ONLY QUESTIONABLE JUSTIFICATION 1 UsING ERA COST DATA,
Los ANGELES WOULD HAVE TO SPEND $93 MILLION IN CAPITAL COSTS AND
$ 6 MILLION EN ANNUAL OPERATING COSTS TO PROVIDE GAC TREATMENT
THIS ESTIMATE AAS MADE BEFORE EPA ANNOUNCED THAT THEIR ORIGINAL
ESTiMATE FOR ORGANICS CONTROL HAD DOUBL 1 MUCH MORE TIME IS NEEDED
TO GAIN INFORMATION FROM RESEARCH AND EXPERIENCE BEFORE TREATMENT
METHODS ARE ADOPTED 1
THE EPA SHOULD REQUIRE LARGE UTILITIES TO MONITOR FOR
TRIHALOMETHANES TO IMPROVE OUR DATA 3ASE 1 TEST METHODS ARE
ESTABLISHED AND COSTS ARE JUSTIFIABLE FOR THOSE CITIES SERVING
OV R i) ,000 P:OPLz 1 ON TH O HER HAND, TH COST AND CCMPL X IY
CF MONITORING FOR SYNTHETIC ORGANIC CHEMICALS IS TOO EXPENSIVE
FOR THESE UTILITIES AND SHOULD BE MANAGED, OPERATED, AND FINANCED
3? THE EPA 1 SUCH A PRCGRA9 SHOULD BE 3ASED ON COST EFFECTIVENESS,
FOCUSING ON THE SYSTEMS IDENTIFIED AS HA’/ING THE HIGHEST SYNTHETIC
ORGANIC CHEMICAL LEVELS 1
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IN CONCLUSION) THE CiTY OF Los ANGELES RECONtIENDS THAT THE
PROMULGATION OF THE PROPOSED ERA STANDARDS SHOULD BE DELA’(ED
1NDEFINiTELY EPA SHOULD CONTINUE THE TOXICOLOGICAL AND
EPIDEM1OLOG1CAL RESEARCH ON ORGANICS IN WATER SUPPLIES 1 THESE
STUDIES SHOULD 3E FEDERALLY FINANCED AND THE FINDINGS MADE AVAILABLE
TO THE ‘tIATR SUPPL’( INDUSTRY 1 tF EVIDENCE OF THE HEALTH RISK OF
ORGANIC CONTAMINANTS IN WATER IS DEVELOPED 1 AND THE MONITORING OF
WATER SUPPLIES SHOWS WHERE IMPROVED WATER QUALITY IS NECESSARY
TREATMENT METHODS CAN THEN BE IMPLEMENTED 1
1HiLE AWAITING THE RESULTS OF THIS RESEARCH) AND ENCOURAGED
3Y EPA’s LEADERSHIP, WATER UTLITIES THROUGHOUT THE NATION WILL
CONTINUE THE SOUND WATER QUALITY MAINTENANCE PROGRAMS THEY HAVE
BEEN NOTED FOR WORLDWIDE,
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1—190
MS. C:- NG: Thank you.
Ar th r an” c st.icns?
MR. IMM: o you curr ntlv monitor for iha1cm th-
an in your systam?
MR. qiNNARD: Yes, w do.
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1—191
I oint ‘ cu1d hays to ins a1l scrr faci1iti , ws a z
to bcrro r funds on a 40-vsa: basis, at soma cint Ln tL ,
dsS’3it5 ths du oroc ss quiz z, you should Lower it again
this may mean adding to, or us rsmo ’;in and rso1aci ’. what
S wa alrsad’. hays.
what ws ars saying basically is ws don’t obj to
your. satting a la’ .’sl, but ws want to b cartain tha laval vou
S sstabi!sh is tha orcow cns and that w can go ahsad and plan
9 ‘ on a long-t.srm basis to financa it accordingly. Ws u ;t dcn’
‘cu a a t-at 
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1—1 )2
H of th custcm rs in th ar a. 3ut s a tachnica1i ’ , ycur
2 costs would ba covarsd th cuch iat r ratss, whi wcul not
b a cov arad by ?rooosition 13, is that correct?
4 MR. ZINNARD: I would li z to correct what I rcaiv
to be a isccncaption. Th Proposition 13 vote was not a tax
6 ra o1t. •I k ow it asb an b raldad as this, but i isn’t.
It is rsally a ravolt, a s rs. Russall pointad out, against
what tha public percaivsd to b scassive pu iic sxpditurss
9 Th public dc s not objact to paying for fira sar-
to vica, po1ic rotaction, nor alth, in tarc s of an ad uata
‘a water. , but it has to ba shown to ba cost-b neficia1 and that
is ti-ta t -.rust of tha whola arg ant.
13 As far as the raaranue is concerned, you ar ccrr ct,
but we must get the rav nua increased. first, b fcra we can
float necessary bonds to build the facilities.
COCNCLWCMi :R SSELL: That is a gccd s ta ent on
- ‘tr. Winnard s oart. I wanted nlv to add that, as he indicata ,
s a -sr ratas -‘ave to e aonrcve o tV-a vote of C. .:, Co ’ nc..1
The concern of osoole is that, rather than cut sDandinc, what
we are coma to do is nickel and di. a OSCOIS to death by addin
n fees here, there and everywhere; and rate increases are scan
as part of that package.
22 Again, w have to do what is necessary, and I az
convinced that peopla will sea that. 3ut they really want thai
c oic.es to be carefully made and be sure they are absolutely
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csssary.
2 . :< g: cx om your d cr1p ion cf th SOU CziS
3 of your ‘.• at r and your d sc:i ticn cf th T • 1 V i, lt 5 5
4 1 un1i 1y that L. Ang 1 s woud fac any i act frcrt’ th s’
r gu1at .ons other than doing tbz oni oring; ±s that correct?
N . WINNARD: At th level of 100, Doctor, that is
probably true; but, as pcint d out by r. I i n, in th p: e—
arr ble it is Indicated you would tracc this down.
9 MS. CEANG: e appreciate your corning. Thank you
H very n uc .
i i (Aop lause)
MS. C ANG: Is Susan : ing here, please?
13 STATE 1ENT o sUSAN 3. c i; ;N,
U.S. CCNSUMER PRODUCT SAPETY COM 1iSSIO ;
15 CCOMP NIED 31 DAVID AEL C<, GENE ?L COU ;S L S
c rcz, AND RICHARD HELL R, c:-L;IP AN’s STA ,
17 U.S. CONSUMER PRODUCT SAFETY COM11ISS1ON
I MS. 
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1—194
Offic , who workad : iv lv on th d ; lcci nt of C?SC s
carcincc n coiicv On mv right is ichard i 14r, of mv
3 It is a pl asur for us to app aar h r today bafcrs
- th Envirorur.ental ?rctaction Agency to state C2SC ‘Ti W5 Cfl
5 iSSu. 3 raised by EPA s prcposal ccnc rning control of organic
ch zd.cal contaminants in drinking watar.
7 Th CPSC ‘s visws ar3 bas d on our p ctiv a
P ad ra1 ragulatcry ag rtcy charc sd with th responsibility cf
9 protacting tha public h a1th and safatv frcm unr ascnabLa
risks of injury aszociat d with ccnsuxn r orcduct . In carry—
ing out this raponsi i1ity with r card to ch mica1 and ‘;ircn —
t2 rt anta1 hazards, CPSC has had an oo crt’m!t9 to oonsid r many
U3 of tha sarn a basic sciantific and r-agulatorv oolicv issu s
14 addressed by EPA in tha orcoosad rula now undar ccnsida:ation.
15 This stat m nt will discuss CPSC’s aoo:cach to
16 sciantific and o1icy S5U S as thay : alt to ccnsum r ro—
1 ducts and will indicats tha araas wh ra CPSC and EPA sha: a
common approach to r gulaticn of chemical and nvir_ i na1
19 hazards.
20 Lika EPA, C?SC may ba callad upon to ragulata a lar
21 nunth r f oroducts containing known or suspact. d human carcinc-
22 ans. Sirtca the agexicy’s craation in 1973, CPSC has takan or
23 1 proposed action against four carcinogans in consumar products
21 1 vinyl chlorIde, Trig, asbestos, and b nz na.
25 EPA has statad in the prear ie to .ts proposed
A rne Ré brting Company
2 )
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1—195
1 d:i:2i c : gi 1atic ri that toxicc.ogic i studies with
2 b t a r Llab n a s of : dicti:.g hazar 5 to
hu ans frcr axoosur t :oxic substar css.
2 ou: basic s nti ic orir ci 13s ar s t forth i
th prsar b1 to th ro cs d z1ation r a:di g i a1
i g and its 1atian hi to as s nt of : uman h a1th risk
Ths princip1 s, bri f1y s r ar!:sd, are:
Or.a; Effects ani a1s, prop :ay qua1ifi d, ar
a D1icabL% to man.
T.•;o; athcds :. not now xi t to stab1ish a thr s-
ho1 for r g—t :ti of toxic agsn:s.
L2 tr ; Exooaur f sxp rim nta1 animals to zoxic
ants in high doses is c ssa:y and ialid m t od of dis-
ccv ring pcssib1 c .rcincc .nic hazards in man.
Pour: should b asad n tsrms of human
risky rath r than as f ’ or ‘ t U f3 .
Th s pri i 1 s, which w r u liz d by ? ; in
astabLishing th rac l. for th ?ropc d r.iguLatior.s, also
19 ar uti1iz d by CPSC in 1yzing th vidsnca of potential
20 carcincg nioity of su st .c s in consurt r pr:ducts and classi -
fyin tha substanca o 3 basis of that vid nca.
This clas ±±i i .i n process is art of CPSC’s an.ar—
al approach for r gulat.:... g carcincgan , as s forth in tha
ag ncy’s ntari ?oi.icy ncf ?c d r for Classifyinq, valua-
25 ing, and Ragulating Ca .nogsns in Con Products, pu 1ish
Acme pom ariy
-------
.
? gi t r of J n 13, 1373 —— 43 . 256 3.
T full text of C?SC’s policy is 3:t c d id is
ubm d for inclusion in th r- cord of this roc din .
-1 C?SC concurs in SPA’s conclusion that ffaccs in
a i. a1s, prop3rly qualifi3d, ar app1icabl o man. ‘]i tualy .
all chsni.cal sbs ancas or tur. s that ava s:- .cw o
c carcinoc r ic in h r ans as a r. suit cf s i niological
S stu iss : a also o s’nown to b carcincgsnic in p r _ nt l
9 ni.-na1 .
ii ) Ho a r, b caus of th difficulty in obtaining
11 api r io1cgic l data, t r is oft ri no vidsr.c as to w h r
12 a cal that :- ba n shown to b carcincg nic in ar.i.- als
13 is also ca:c!nog nic in hur ans. Nav rthal ss, prudanca
ra uir s art assuniption that such ch mica1s pcs a a ris< of can
15 c r to huznarts
This rincip1a is sat forth in tha ? a ra1 Critaria
for Assessing th E tidanc a for Ca:c no anicity of C . ioa1
1 S :1 Substanc s’, r 4 : d to tha Nath onal C nc c s tu by th
19 Subcoitt on Environni ntal Carol n sis of its National
20 Canc- r Ad iisory 3oard -- ‘ NC Raport — 53 J. Nat. Cancsr
21 net. 4 1 —— ? brua: y, 1977.
22 CPSC is 1so i agrs m nt with E?A i±th : gard to
23 th.3 est ol!shi rit of thr shcld 1i Its for icrig-tar a facts of
to 
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1—137
establIshed for car:inog nic substances.
2 While CPS recognizes that re1ationsh ps bateean
3j dose and response have been identified for a number of carc n
4 ogens and generally these seem to follow traditional curves,
with response increasing with incrsastng dose, no threshold
6 has yet been identified below which a carcinogen has no
I effect.
The nature of the dose-response relationship and th4
9 existence of thrssholda have been discussed by many experts
to; in the field of cancer research, and they are substantially i:
11 agrsennt that dose—response data cannot be used to set
12 1 no-effect levels for exposure to chemical carcinogens.
13 Moreover, CPSC must consider varying individual
14 susceptibilIties within the heterogeneous human population.
Is I This contrasts with the homogeneous strains of animals used
14 i in tests • Thus, once a presumption of carcinogenicity has
17 been established for a substance, any exposure to the sub—
stance must be considered to be attended by some risk.
19 CPSC has addressed the issue of the validity of
20. testing at high doses and has concluded that the exposure of
21! experimental animals to toxic agents in high doses is a
22! necessary and valid method of discovering posstble carcinogen
ic hazards to man.
24 Tasting of chemicals at high exposure levels I at or;
approaching the maximum tolerated doss level, is mplcyed to
I Acme Repái’tlng Company
an maul
-------
H
1 cort’ nsat for th 1± itad numb : of sni als a il b1 for
lcnç—t rr ioassavs - d to a ;oid t1 ibi i axnz
:1 in ,ol ; d in using th nu. bar of anir ais r qu±r d to fuplicats
th hur a oou1ation.
C?SC will cor sid r :asuits in such t. st3 : liabl
indicator s of arcincc nicitv.
Lika EPA, CPSE r cocnis s that tha lir itaticr s of
th curr, nt x ri ntaJ. t. chrJ.cu s do not allow th stablishH
nt of safa dosas. A1on thasa linas, CPSC has concludad
10 that in astiaating tha rIsk of injury or il1n ss pr s nt d by
11 a rcduct containinc a carcir .cg nic substanca, it is i ocrtant
to .ass ss th int racticn of sav ral factors, incl. dinc tha
1) oot ncv of tha carc.incg nic substanca, tha axtant and tura
14 of human zosura to that substanca, and the availability of
15 th substanca for human u taka.
CPSC racognizes that th aryirig pctancy of c !cai
carcinogens -— in ccrtparabla animal tast systarns —- can alici
l which vary by as much as a factor of 10 illicn.
19 LikawIsa, ax csura pat rns of products vary wid iy and
0 diffa anc s oft n axist bst’ an routas of axpcsuza in animal
bioassays and actual product use.
Diffar ncas in human uptaka pattarns and ifl
ity batwsan animal arid human systar s ar also factors which,
4 to a ..ass r d gr a, affect the carcincg riicity of substances
5 to humans.
Acme Reporting Company
2 2
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1—199
1 Tha r at magnituda of tha diffar nc3s citad abova
2 H uggast that n a1tion of ri r ust c saa i1v d o nd
:3 Cfl informad, but ulti at 1y alitative judgmants. C?SC’s
4 r C n lY issuad int ri i policy for raculating carcir.ogans
scribas the r th d by which the Cor mission will aak thas
qualita iva judgments.
:1 First, use of a carcinogen will be prohibitad if
rsascn&zi subsUtutas exist. Second, if not r ascn. b1e sub-
9 stitut s x!st, then use of the substancs will nonetheless b
j prohibited unless such prohibiticn wculd result in unaccept-
able concmic and social costs.
I Finall-’, if such costs would be un ccs tab1 , then
use of ti’e su stance 1l ot oa a.osol e1, i—e
14 tn level of that stwstance in consumer oroduc s woul
be recuired to be reduced to the lowest le7el consistent with
not ra u th
lC costs.
C?SC’s aocroach is therefore ccr carable to E?? ’3 in
that. levels of risk will be assessed in the event that : ason-
20 able suost .tutes are not avai lable and the costs o: an absol-
21 H ute ban would be unacc otabla.
I In a recent case, the Court of Appeal for the is-
H trict of Co1ux bia Circuit said:
“ 1 Thil a ccnc rnsd Congress has passed legislation
25 rcviding for protaction of public health against gross
Acme Reporting Company
ia
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,
l ai rcr’ m - taL tha r. cu1atc:3 ntrust d . ibh
c ant of suc ’. i- av r ct th .r bv b ri idcw d ;‘iith a
3 asci nc t .at r cias all do f crn ir cisn a i g.
4 P ath r, s eculation, conflicts in vidar ca, nd thwr3ticai
5 a olaticn zv ify thai: avary ac .ion. ou 1sa ca
‘3 ac’ ., gi n . tar dat to prot ct th public a1th only a
sli ht or ncn :dstant data ba a pcn which :
Ethyl Corp. t a1 i. E?A, 541 F.2d 1, 24 —— DC Cir.,
1976; c t d j d ______ J.S, / 96 SCt. 2663 1976.
II ) Thosa cbs iations : a r maaning for all agancias
11 involved in th r gula cn of carcincganS .
12 Our ta&c is tha p tacticn of tha public : alth and
13 saf ty, wh th r from drinking watsr c r..inatad by carcino—
14 r s f crn consu.nar prodi cts that r ay ex’ osa h ans to car-
15 cinog ns.
gu1atory ag ncias must accs t th ir public raspcn_!
IT sibility and co tinu to r sOiva dcubts in favor of rotaction
i3 of ths public.
This ccnc1ud s CPSC’s pr par d sta: rn nt. I hcp
20 th sa cc iit nts av b ri halpf 1 to PA in its consid.ir tion
21 of the ro o ed rsgi. 1aticn on control of organic chez icaL con
22 tainants in dr n ing watsr.
23 (The attac r ant to C?SC’s repa:ad stata ant fo1lcw :)
23
Acme Reporting Company
1 4i 3
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—
-

TUESDAY 1 JW’IE 13, 1E78
PART V
CONSUMER
P ODUCT SAFETY
COMMISSION
CLASSIFYING 1
VALUATING, AND
REGULATING
CARCINOGENS IN
CONSUMER PRODUCTS
ln erim Statement cf Poii y nd
Procedure
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25658
ZUI.E3 AND RE 3ULAflOMS
T ll-e 1 —Cornrnercid ?rad1c. s
C:? rS !J—CON2UM ?WDUC7
SAiST? COMML3 iON
C 4APT R AN LM.
?O’.:CY ANr
CLA33 Pr1N ,
COHSUM el
iatement of ?oik’y and ?rocedure
AC •iCY: Consumer Product Safety
Cot. :n .toston.
ACTON: lriterin atemect of policy
and procedure on which comment s
solIcited.
S iIM.AR .?: The purpose of this boo.
umerit Ls to establish on an Interim
basis, and to solicit comments on, the
CPSC’s general policy and procedure
concerning the cisasificacioti, evalua-
tion. and regulation of substances
that, If present in consumer products,
pose a risk of cancer to conzuxaers.
The system is Intended to assist the
general public and regudated Industry
by provIding guideiines cortceraing (1)
The standards CPSC vJl apply in cIa-s.
ytng suostances suspected of caus-
Ing cancer, and evaluating products
containing such substances, and (2)
the regulatory action Likely to be
taken by the Consumer Product
Safety Cornm.isaior. foUo ’wtng cla.ssifi-
cation and evaluation. This document
aLso sets forth the procedures CPSC
will follow in arriving at the etassifica-
tion of sabsta.neee and the regulation
of carcinogens in consumer products.
‘ cTTVE DATE: The policy and
procedure will be effective on an inter-
fin basis June 13, 1973.
COMMENT DATE: Written comments
on the interim statement of policy and
procedure, preferably in five copIes.
should be submitted ‘og October 11.
1913.
ADDRESSES: Written coc’.merit.s
should be submitted to the Secretary,
Consumer Product safety Commis-
sion, Washington, D.C. 20201. All ma.
terial relevant to this policy and proce-
dures statement, Inc ludIng any corn-
meric.s that may be received, may be
seen in, or copies obtained from, the
Office of the Secretary, 3rd Floor,
liii 13th Street NW., Wshington,
DC.
FOR Pt RTRER INFORMATION
CONTACT:
Prancine Shacter, OffIce of Program
Management, Consumer Product
Safety Commission. Washington,
DC. 20207, 301—192—6357.
• 3D C!D1TARY INFORMATION:
The purpose of this document is to es-
: blish and solicit public comments on
a statement of policy and procedure
concerning the classification, evalua-
tion, and regulation sf substances
that, if present in consumer products,
pose a risk of cancer cc consumers.
acstoaoucn N rca a
Srarr .snn r 0 ? POLICy urn ?aocznras
Like the Occupational Safety and
:- ea th Ac nistratton (ObHA). the
Food and Drug Administration (FDA),
and the Environmental Protection
Agency (EPA), the CPSC may need to
reguisto a large number of products
containing knov.m or suspected human
carcinogens. CPSC recognizes that a
number of chemical substances or aim-
tures are known to cause cancer in
humans. Many inure have been identi-
fled a.s carcinogens lit animais Still
others are currently being tested by
the National Cancer institute and
other groups.
CPSC has, .si.nce its creation l it 1913,
ideatiiied and taken regulatory action
to prohibit the use of four carcinogens
Li consumer products. The first wa-s
the C7SC’s ban of aerosol products
containing vinyl chloride and intended
for use in or wound the household.
(39 FR 36578 (October 11. 19’74), re-
vised and reissued. 43 FR. 12303
(March 24, 1913).)
The second instance wa-s the agen-
cy’s interpretatIon of the Federal Haz-
ardous Substances Act as banriircg the
use of the chemical Tris (2.3-dibromo-
propyi) 2hosphate (TP.IS) iii chil-
dren’s sieepwear. (42 FR 18350 (April
3. 1911). revised and reIssued. 42 FR
51521 (December 5. 1917).)
The third instance was CPSC’s use
of the provisions of the Consumer
Product Safety Act to ban consumer
patching compounds and artificial em-
berizing materials containing respira-
ble free-form asbestos. (42 YR 52354
(December 15, 1911).)
The fourth and most recent action
wa-s CPSCts decision of April 27, 1973,
to propose a ban on benzezse as an In-
lentlortally added ingredient and as a
contaminant at levels of 0.1 percent or
greater In all ocnsumer products.
except gasoline and beozene for Labo-
ratory use. (43 PP. 21339 (May 19,
1918).)
CPSC belIeves that in regulating In
this area it will be helpful to set forth
Its approach and policy regarding cer-
tain issues which tend to recur In each
case. The present document is Intend.
ed to provide general guidance to the
staff and the pubUc.
While full implementation of a regu-
latory policy ultimately depends on
the financIal and personnel resources
a.vallabls to the agency, CPSC believes
that. failure to develop and publish its
general approach and poUcy at this
time would be a failure to fulfill Its
public responsibility.
CPSC’o policy Is similar in some re-
spects, and di1f rent in others, from
the proposed rule on regulation of car•
cinogens published by CSEA on Octo-
ber 4. 1977 (42 FR 34143). (The Corn.
mission has aLso considered guidelines
published by EPA oct May 25, 1 9 1 ’ S (41
FR 21402).)
A fundamental difference between
the CPSC and OSHA documents is
that this document is not being pro.
posed as a rule and has no sinning
.egai effect. The determination to take
regulatory action against particular
products or classes of products will
continue to be riade in individua.l pro-
ceedings, in accordance with the appii-
cable statutory provisions and the
terms at this polIcy statement.
The chief similarities between the
CPSC and OSHA policies are the un’
denying scientifIc concepts, and the
existence of a classification system for
substances based on evidence as to
their carcinogenic potential.
Since this document is a general
statement of policy, it Is exempt from
the notice, public procedure and be.
layed effective date provisions of the
Administrative Procedure Act. (3
U.S.C. 333). However. in view of the
importance of the policy nd the Coin-
mission’s belief that comments on the
policy from the general public. indus-
try, and experts in :eicvanc scientific
disciplines are a valuable source of in-
formation and views which must be
considered in establishing the policy,
the Commission has decided to solicIt
publlccomrrtertt. In addition, CPSC is
Interested in gaining some practical
experience (rota the operation of the
policy and procedure set forth in the
document before Issuing a final state-
ment. Accordingly, the policy arid nm-
cedu.re will be effective ott an intcrim
basis a-s of the date of publication of
this document in the Fma’ -in P2013-
t ’ (June 13, 1978). The docu.menc will
be included in the Code of Federal
Regulations so the public and all af-
fected parties will have notice of and
access to the policy and procedures
which CPSC wtJJ follow in this area. In
publishing this statement of policy
arid procedure for comment, the Corn-
mission does not intend to set a prece-
dent for future policy statements.
Therefore, pursuant to the Consum-
or Product Safety Aot, Pub. Li 92-. 73
38 Stat. 1201 et seq. as amended. 15
U.S.C. 2031 et seq.. and the Federal
Hazardous Substances Act, Pub. 3.., 86-.
t313. 34 Stat. 372 et seq., as amended,
15 U.S.C. 1261, et seq., CPSC adds to
Title 13, Chapter fl, Subchapter A. of
the Code of Federal Regulations, a
new Pert 1040 as follows:
PA tT l04O—iNT !M
Pl CC DU 2
S’/ ..\LUATING, AND
.A C:NCGSNS iN
P 01 ) U C i ’ S
FWE*A1 . UG 5 ’TE*, VOl., 43, HC. 114—7lJ 5 A’f, JUN! 13, 197$
-------
UL 5 AND ULAfl0NS
25659
?A2T 1O— NT JUM
P OC2Dt)2.
/,\LUAfl ’JG AN
cA C:NcG NS U 4
? 00 UCT3
Suópart A—G.ner,I Si i m ni o
r’ Jflc1, ?ro o is, n 1 S4JmmQr (
Sec.
1040.1 Stater srtt of eneriJ poEcy.
1040.2 ccpe of policy.
1040.3 DL itior .
1040.4. Legal b kground and statutory au
thority.
:emg r cy orion.
1040.0 Summary of prcnc pe3 aod proce-
dare for i (cat on, evatu on. uid
:st c of .cu oge s.
S b art 3— r,;imi ry
1040.11 Scope ol prel1n nary screezt.tc .
:340.12 ?rccedure.
t’ bp rt — i iRc tkn
1040.21 Scope an prnctples of ci& stilca.
lion.
1040.22 DesCrtpcfon of mt r 4 es.
1040.23 review f taLf :.ssLfl .
: a tton.
5 ,bo rt —3 H F vutl n ,d C .mm esl n
Ar lsoi e Pr ,civ t3 Ce it . inin1
1040.31 ? ct-tties cr stall evaluation and
cor m s oon sp ai.
1040.32 Gui iLn tnd ;roc . dur s cr
stall iauon and cotr.nue.sto ;prai3-
al.
1040.33 F ctors ton dered staff evsdua.
lfld cOzt .rrussiOn l2pra .sa1.
S bp r$ — .gu1 t ,y ir* trnan4 Q r’,thiets
Cnraincnsj C4 eq A
1040.11 P eruistorj e.pproach.
1040.42 3llecti;e date. recall, and nsmi.
r ent basards.
1040.43 Public prtpaclort.
5ub r i — Iaterf . ,,th ,nt f ?,o4ucf$
C n oit ic q C t. oq ! ai,
1040.31 ory oioos.
S ør$ O—?r thje i C .ntt th,ueg C . t..goq 0
1040.31 CPSC acr.loo.
.Aor oRrrY: Coctsun er ?roduc 5aje y
Act. Pub. L.. 92-373, asnended 36 Stat.
t2O’ . et sect. (15 U S.C. 2051 et 3e .) ‘ederat
rtloiss Substances Act. Pub. L . 38-. fl3.
an ertded. 34 Stat. 373 seq. (5 U. S. c.
1251, et seq.)
Su p . rt A—Ger efol S emen$ f
& cy, k reund, OenoM ? ovi
sionl, end imm4r)’
4 1040.1 Stace ient t( general oflcy.
(a) The Consumer ?roduct 5ajety
C ixiLs.sion to .s both statutory juZtS .
dlctio t and a public respon.sibtjLcy to
regulate coritathlzz g oarcLno-
where 11cc car nogst avas able
for human upta e.
(b) The C?SCs poUcy Is that it
snould not permit ccown carcinogens
to be inter .tionaUy s.dded to consumer
products if they can be absorb , in-
haled or irr estad into the human
system.
(c If c arcinogeas are capable of en
ter.ng the human system. CP C wtil
require that the use of such carc!rro-
gens be phased out in faror of reason•
able substitutes they exist.
(d) I! no reasonable substitute is
available, and there is evidence that
elimination ox’ the carcinogenic sub.
stance vould result in unacceptable
economic and social :oscs. the Cl’SC
will require redUCtIon of the substance
to the lowest attainable level until
substitutes are dentlfled.
41040.2 Scope of pol.
This policy is intended to address
risks of cancer associated ;-ith the
presence of toxic substances in con-
surner products. The CPSC recognizes
that these substances may also create
risks of mutations, birth defects, steril-
ity and other conditions, the causes of
athich also .may not easily be traced.
The C?SC does not intend, by adopt.
Lig this poilcy, to preclude regulatIon
of a product or substance that ci.n be
shown to cause chronic illrtes.ses or
conditions other than cancer. :-Iowev
er, the princ pies voiding such re uia
lion ‘will be estabUshed on a case by
case basis unril the CPSC is able to es-
tablish general poUcles for chase con.
dittons as weil.
41040.3 Definitions.
A.s used in this Part 1040, the foilow-
Lrtg terms shall have the meanings set
forth:
(a) Cnrcinc en. Any substance
which may produce cancer in humans
or animaLs.
(is) l7urnuiis U .ota.’ a The process by
a substance enters the human
system, eIther through ingestion. in-
halation or absorption through the
skin.
(e) fntisfü sa!1ii tadd.ed.. Any sub-
stance or rnL cture (1) added deUbe rate-
ly as an ingredient intended to impart
specific characteristics or (2) con-
tamed in the final product a.s a result
of intenttonally using a ra9t material
containing the substance, whether the
raw material contains the substance as
a result of delibersce addition or
through contamination.
(d) Lotcest AtW.inab (a LeveL The
lowest tevel to ‘which a substance can
be reduced that is consistent ‘with the
pubic health and safety and that does
not result in unacceptable economic
and social costs.
4 1040.4 L.egal Smekgr iind and statutory
3uthority.
(a) L.eticl bcck;ro1in i. (1) The causes
and mechanisms of cancer induction
are still at the frontIers of
knowledge. everthelests, the courts
have recognized :he need for agencies
to make decisions concerning the regu.
lation of cancer and other chronic has.
ards, even n Inc aosence or data 3Uiii’
dent to resolve aU questions factually.
In such cases, the courts recognized
char agency decisions are essentially
poUcy judgments rather than resolu-
tions of ccntroverted facts, e.g. Ertvi.
romm nfaf Defense Fund v. E?A (VeLoi
cofl, 343 ?.2d 998 (D.C. Cir, l9’ 5);
Zf by2 Corp. v. .E .P .4, 541 P.2d I (D.C.
dr. L9 ’ 3), c rf. denied, 9 S.Ct. 2662
(1916); Soclefy of the Plastics lndu.s(r’j
v. OSH.-i, 309 POd 1301 (2d dir. 1915),
cer denied sub noin. 7irestone P!a.s.
tics Corp. v. Dept. of L.j.bor, 42]. t .S.
992 (1315): Zndostria .Z Union .Jeot.,
4FL—C!O V. : oct on, -199 FOb 462
(D.C. Ctr. 1914).
(2) it is clear that In regulating ..
cino,gens, as well as other hazards, the
statutes administered by C?SC, dis-
cussed more fully below, permit 11 to
act on a precautionary basis and do
not require It to establish proof of
actual harm. The test mandated by
the CPSA as a predIcate to regulatory
action to ban or limit the use of a sub-
stance is the existence of an unreason-
able risk of iniury, Risk, as noted by
the cous- s. is not a fixed probability of
harm but rather a complex i-elation-
ship involving probabLilty arid severity,
“That is to say, the :subiic health may
properly be found endangered both by
a lesser risk of a greater harm and by
a greater risk of a lesser harm.” t)tY1
corp. t i EPA, supra at 13.
(is) Sfnfufcri author (fcI. (1) ‘I’wo stat-
utes are administered by CPSC under
which It Is empowered to regulate sub.
stances in consumer products wbuch
present potential carcinogenic haz-
ards. Under the Consumer ?roduct
Safety Act (15 U.S.C. 2051 et seq.),
CPSC has the responsibility to protect
the public from the mreasor able risk
of injury, Illness or death associated
with consumer products. in addition,
the Commission has the responsibility
under the Federal Ranardous Sub-
stances Act (15 U.&C. 1251, et seq.) o
protect the pubic health and safety
from hazards involved in the presence
or use of toxic and other hazardous
substances in households.
(2) Cons-uiner Product Srzjrrp Act. (1)
The basis for issuing consumer prod-
uct safety standards arid bans under
the Consumer ?roduct Safety Act
(C’?SA is the existence oi an unrea-
sonable risk of injury assocIated with
a consumer product, The deterrnina-
tIon of unreasonable rts c Involves a
balancing of the probability that risk
-wiU result in harm and the gravity of
such harm against the effect of reduc-
liii or eliminating the harm ott the
produccis utility, cost and availability
to the consumer. A.s the legislative his-
tory of the CPSAjndicates
An ‘saressoriabie ha rd L i clearly one
w tjc can be prevented sr i-educed without
POlICY AND
‘3U LA 1. iN 0
P!OU. l. iQl ’TU 4 ‘101.. 40, MO. fl4.—flJ SOAY, JW41 l , 1971
-------
25660
UUS AND GUL . flCNZ
iectin the ; roduct ’s utility, cst, or avaIl.
ab (hty ot c,ne vhich the f ect on the prod.
ucts utility, LOSt. or svaflab(I!ty Is
outwet bed sy toe need to protect the
putiic !rorn toe hozard s.ssociated elth the
product. There ;ooaid be no trnpllcotlon,
doarever, tba In orrtvtrtg at Is deterrnina-
tier the Con mission vould be required to
conduct and co n Lete a cost-benefit analysis
prior to pr utsactog standards under this
t. Of course, no standard it’c ,uid be expect.
ed to Impose added costs or Inoonveroence
on the constur.er uaisas thsre Is .sorable
assurance that ‘the h’squsrtcy or seventy of
tn uries or ilIneases a11 be rsduced.”
Rep. No. 92-1133. 3crd Cong., Ind Sose. 33
19 P2).
(:1) Cl’ C j’.ss the authcrizy to take
regulato y actIon to ‘crot cs the pubic
nst such eazotiable risk
through the Issuance of conswner
product safoty standards, or, where no
feasible standard would adequately
protect the public from such risk,
through the issuance ‘of a rule declar
(zag the product a banned hazardous
product. tn ssuing consumer product
safety ru ss Istandards or bans) CFSC
roust find that the rule is reasonably
necessary to eliminate or reduce an
ur oasoruabie risk of injury.
( ii i) CPSC also may, by rule, require
recordl The ap-
parent potency of the substance: (UI)
The extent of cor .sumer exposure to
products containing the substance in-
cluding, (A) The number and kinds of
products (B) The amount of the sub-
stance contained in the products; and
IC) To the extent feasible, the amount
of the substance available for hunmn
uptake,
(2) In addition to the factors set
forth above, in ’ rr ent hazard, determi-
nations under the FHSA (See 15
U S.C. 1261(q)(2)) are subject to regu-
lacions issued by YOA at 21. C7R. 25,
4 l 4o.5 Interagency cooperation.
Cooperation among the Pederal
agencies charged with pr tectlug the
pubUc health and safety from risfgs a s-.
sociatctt with toxic substa cee is clear-
ly essential in order to afford the
greatest possible protection at the
least cost to society. C?SC, PA, FDA,
and CSHA. have formed the ir1ter
agency 2 .egulacory Liaison Group to
achieve this roal of common coopera-
tion. CPSC isso partic:pates as an
agency member of the Toxic Sub-
stances Strategy Committee, chaired
by the Couricil on nvironmenta1
Quality.
10411.d Summary of orird pies and proce.
dur for dess fication, evaluadon, and
regulation of carcinogens.
(a) In order to ensure that rapid, ef-
fective and responsible regulation
ensues in appropriate cases, arid that
consistent cnte a will’oe applied, the
following internal procedural guide-
lines are established. These guidelines
describe a four-step process to be used
by CPSC for: The preliminary screenS
ing of substances about which a ues
tion of carctnogen,icity has been raised;
the cla.sstflcation oi those substances
used in consumer products: the e’ aiua-
tion of consumer products containing
classified substances: ,arid a determina-
tion as to arty regulatory action to be
taken regarding chose products. This
document does not address the proce
du,rc CPSC staff may use in seeking
out arid identinytog potentially car-
cistogenic substances. To data, the
agency has had to assume a predomi-
nasally reactIve posture with respect to
carcinogenic and other chronic ions.
aids. Petitions, consumer complaints,
interagency referrals. etc., have con-
sumed all available staff resources.
The Coramissiora L a now attempting to
develop an internal system for idenci•
fying chronic hazards needing Investi-
gation.
(b) ?relirn-tnary screening. The first
step in addressing substances about
which a question of carcinogezaicity
has been raised is a preliminary
screening conducted by the stall. The
purpose of this screening is to deter.
mine whether CPSC has jurisdiction
or authority to act. During this stage,
a determinaclcn La made whether
there is reason to believe the sub-
stance It present In any consumer
products subject to CPSC urisdlctioa
or whether the agency need not act
because another agency Is adequately
dealing with the potential hazard.
Cc) CZassi/icc,fioi . (1) When it is de-
tea-mined that the substance may be
present in one or more con.sumer prod.
ucts subject to cPSC Jurssdictloa. the
nect step Is the claasillcaclon of thiS
substance based on the type and qual-
Ity of the available test data and stud-
ies. CPSC recognizes that the question
of what presents a carcinogenic rl.ek to
humans is highly concro ersi*l. Sciex*-
tiats do not agree on the meehar i n
of carclnogenesls. daflY gaps remaLi
In our noW1edge of the Calisels, pZ $-
vention and citre of C Xi4 5 t . fsawex r.
the Ctimmisslon believes it is u s con-
flDELa.L 2* ’G$Tfl, ‘/Qt. 43, MO, 1 14—flJSSQAY, JUNI 13, ) 7*
-------
UL S AND GULAT1ONS
2 6t31
. stent vith its is sri to rocect the
puoi:c ealt t :0 wait :or yearz to re .
solve these i ues scntiial’ywitli.
out a OktCy and system or tzie regula .
ti m-. of those substances in cor.aucner
products icr wriictt there .s evidence of
a caretnogenic risk.
(2) The Csir.mission therefore - i1l
use a system for the classification of
such substonces into four categories,
based on the ava iable data that the
substances present cinc enic risks
to humans. The rirst category (Catego-
:y A) will contain suostanc’ s for
which there is strong evidence of car-
ciriogenlcir,v. The second category
(Category 3) wtLl contain those sub-
stances for which the evidence is sug-
gestive but not as strong. Th third
category Cacegory C) will contain two
types of substances. First, it will con-
tarn substances scout which a ques-
tion has been raised regardL-tg the po
tentlal carotnogenic hazard to humans,
but for which thore is very limited evi-
dence of carcinogenicity, Second, it
will contain substances belonging to
classes or familles of chemicals where
many members of the c!as .s or family
have been shown to be carcinogenIc.
CPSC believes that substances belong-
ing to such a class or family reouire
further testi if the substance is at
may become widely used in cor amer
products. The fourth category (Cate-
gory D) will contath substances which
had been previously classified as
etcher A, B or C but for which the ex-
isting evidence does riot indicate car-
cinogenic potential at the time of re-
classification.
(3) CP C recognizes that new In .for-
macion about classified substances will
likely be developed as a result of fur-
ther costing and Investigation. There-
fore, the classification detertninatlons
under this poilcy, particularly in Cate-
gory B and C, ‘.dll be subject to
change. fla order to insure that sub.
stances are olassifted en the basis of
the most current information, the
classificatIon of all substances under
tbi.s policy will be subject to periodic
review and reaffirmation or adjust-
merit by the Commission. Individual
substances may be reclassifIed by the
Commission on art ad hoc basis should
the need arise.
Cd) 2t a.ZuoJ.fon of radtw .fs con€ain-
ing cf ed bfance ,s. The nect
step in the Comm.iselon’s procedural
guidelines provides for evaluation of
products containing classified sub-
stances. This includes an evaluation of
the factors to be considered by C?SC
in determining the nature and extent
of any regulatory actIon that should
be taken. including such factors ss the
extent to which products containing
the substance are used and by whom;
the patency of the substance, poten-
tial for human uptal e, the probable
effect of regulation on the hazard; and
the social and economic impact of the
regulatIon.
(e) uZccCcr i fret meiit of prodcr d,
con ainin Caieçorj A nthstances.
This step includes the selection of the
appropriate regulatory strategy, in
cluding both idencu scion of the ap-
propriate statutory authority arid the
specif Ic remedial action required.
if) CPSC action re o.rding producis
corctairtirtg Czre orj 3, C, and .D rud-
seances. Generally, CPSC’s policy will
be to make every reasonable effort to
see that Category B substances receive
further testing. Pending the comple-
tion of additional tests, CPSC may
take appropriate steps to warn the
public of the possibility of consumer
risks by methods such as requiring
mariulacturers to make health arid
safety tnformation available to con-
sumers. The CPSC may cake similar
sce s for Category C substances which
are or may become widely a ed in con-
sumer products. The CPSC will riot
take action on Category D substances
other than to maintain records and
update Information on available test
data arid studies.
(g) .4d mel -its to fhs ,polic-j. CPSC
recognizes that from time to time, ad-
ju ,stment.3 to this policy may be neces-
sary to reflect significant new scIentif-
ic ln ,fcrmatton, legal and policy devel-
oprrierttzs arid interagency regulatory
initiatives,
Subpcrt 3—?relhninary Screening
1040.11 scope at ?reIiminal7 screening.
When Information comes to the at-
tention of the Commission or Its staff
concerning a substance about which a
question of carcixtogeriictty Is raised . t
(he’ staff on its own initfative shall
conduct a preliminary screening of
readily available data. The chief pur-
pose of this screening is to establish
whether there is reason to believe the
substance is present in any consumer
products subject to CPSC Jurisdiction
before initiating additional analyses
and evaluation In’7olvlng substantial
expenditure of resources, In additIon,
this process may reveal cases in which
the z -thl to the public health a.rid
safety posed by a ubscance is being
adequately reduced by another
agency. The only criteria for riot pro-
ceeding beyond this stage are the ab-
sence of cor .sunier products containing
the substance or action by another
agency. Questions of potential caz -elno-
genicity, human upcake, exposure, etc.
will be addressed at a lacer point In
the process,
‘The Commission or fts st.tt! curt-early re-
ceives tntormscian concerning possible car-
cizogens prthartly from interagency refer-
rals tram testing agencies such ss the Na-
tlota.L Cancer tnstltute, arid from regulatory
tjencies such a.s 4.. and from petittoni.
The staff will also monitor the raed1ca and
scIentific Literature for tad actoas of new
.j 10401? ?rocedure,
a The staff ‘a-ill periodically notify
the Commission, in writing, of the re-
ceipt ci the information referred to itt
1040,11 and set forth a time schedule
for the preliminary screening arid if
warranted, the subsequent classifica-
tion of the substance and evaluation
of products containing the substance.
The Commission may revise the time
schedule, as it deems appropriate.
(b) In the relL’ainary screening, the
staff will coiect arid assemble readily
available data on the uses of the sub-
stance in consumer products under
C?SC jurisdictIon and determine if an-
other agency is addresstng pcss:bie
risks of injury presented by such pt-ac-
ucta. The staff will notify the Cam,mis-
sion, by memorandum, only if one of
the criteria for riot proceeding further
applies. Otherwise, the staff will pro-
ceed to the classification stage of the
process. The order in which the staff
will classify substances will be based
on priority criteria that will be devel-
oped and approved by the Commis-
sion.
Su p rt CCosai ka ion
104021 Seope and princip’es of classih.
e3XiO
(a> . copa After the initial screening
arid the determination that a sub-
stance may be present i t - i consumer
products subject to CPSC jurisdiction.
the staff will classify the substance
into one of four categories based on
the existing evidence that the sub-
stance is a possible human card.no-
(b) P tc p1ee. In analyzing the evi-
dence regarding potential carcinogen-
tcity. the staff wiLl be guIded by the
following general principles:
(1) Human .studfe3—U) C;’se and Limi-
tzWona. pidemioiogical studIes of
human populatiocts can provide strong
evidence of a relationship between ex-
posure to substances and disease.
uman studies can provide direct data
about such factors as sensitivity and
metabolism, route arid length of e:tpo-
sure, latency periods and spontaneous
tumor rates, On the ocher hand.
human epidenilological studies almost
‘In sddltlon to its own scientifIc staff, the
agency may 3ee out expert advice b re—
ta.ln .jng consultants or estabLish a panel of
experts from relevant disciplines such as
toxicology, medicine, pathology, chemistry,
biometry, an epidemiology. stabU . ,lnieni
of juan a panel vi i i be governed by the Fed-
eras dv1 . ,ory Co mittee Act ( 5 TLaC. App,
I, I e seq,). These experts may be available
to the Commlasion sta.ti as necessary to
evaluate the available data and test results,
In term., of the t u.aljty, adequaey and Inter-
pre at1oa of ex erlment.al zpd epidemiolog-
Ical data.
‘th the a es i L atIon phase the staff il1
be limited to readily available data. Full
L iterature aee.rebes and consultations with
expert in the field may be conduc ted.
DUAL R!G4STl , VOt. 43, NO. T14—TUUOAY, JUN1 13 197$
-------
JU5 AN GU1.ATONS
neier . :abU$h ‘. tir ct cause r c1
ff ct r cic-i between :o ure
a sub: atc ‘ ,rtd eaz . rn unt s
3X;G Ur2 1.3 r . ro.liy estl .t . d azid
he s: dy oup Li i suail ’ expcsed o
. ‘aiiety o s ibstances a.s weil s being
ai: c d by zrter tactors. F .trther,
s nce the study grop s vlrtuaUy
always selectei :etro. pective y, exert-
nencal te id ttloc .s ca.iifloC be con-
troLied. ev Ieee, while ues:inrts
nay be ed cc scerning human scud.
ies, C?SC iU re’ ard positIve :esuit .s
in sou.nd idemloglcc.1 st ’i1es 3.s re.
Liable ndicc.cors of carc no en .Icity in
humans.
(ii) s ’t. ive n ;ac ve esi Lts.
or tite t .scns sec forth 5- 1ci; ’, the
a eacy fl act te .y tn t acite re-
epjdeItiio cai , 3tUO.leS O Cs-
abiLsh the salety cl sub -tces. The
tateacy pestod between xposue to
cb en substancee and the onset
of disease can vary !ro live to orty
years. Qiven tiiLs tency period. C SC
believes chat the ba.sic type ol cohort
or case ccucroi study. which U3t be
coduct.ed retrospectively, La more
ilicely to provide lakte ziegattve than
faLse ;osittve results. . oUow-up time
may sicnply have been OO anort to
cover ni due4 scepttbLilties in in.
teacy perod or the cohort study. or
the C e-coacrot study, the lcttency
per-lcd may be too iCng to .dequate!y
evaluate er;o ure1 Thu3, a chemical
that appears safe or human exposure
on the basl.s of negative results a-
subsequeucly be demonstrated to
cause cancer. The latency period also
creac s special problems when young
children are exposed to a carcinogenic
substance because sore time will be
available during their Lives for disease
to manliest ltzeiL
t2) .4ns nni . su fie.?. (I) With the poe-
sibte exception of arsenic and benzene
(still under study) all thematcal sub-
sta.rices or rnLacures that have been
shown to be carcinogenic in humans as
a result of epidemlological studies
have also been shown to be carcino-
;enio In etperi encaj animads. owev-
er because ! the diffIculty in obtain-
ing ept m .ioiogteeJ data, there is often
no evidence as to whether a chen .lcal
that has been shown to be carcinogen-
ic in animals La also carcinogenic in
hurnav .s. Nevertheless, pridence re-
quires an s .ssurnptiori that sudh chetn.t-
eels pose a rLai of cancer to humans.
This principle ha.s been o nlzed and
applied by a number of ederaI agen-
cies. including CPSC In It., lrnei-preta .
tloo. of the ?ESA as baanlng TBL in
cialidrens sespwee.r, and has b eem af.
firmed sy the courts. it La set forth in
the Qenera1 Criteria for Assessing
the -iIdence or Carcinogenicity I or
Chetn .tcai Substances ’ recently pro-
posed for the National Cancer Instl-
cute by the Subcommittee en vlron-
encal Careinogenesis of its National
Cancer Ad sory Board (“NCAB
P.eporc”) 53 J. Nat. Cancer tnsc. 451
‘eb. l9 ’7). The ataif will he eneraUy
uid.e’l by the NCA 3 P. -eporc in assess-
my e:cperinsental cortitions attd the
cthda of statistically si niiicant
cnwges in tumor incidende that may
be ‘coed to characterize carcinc;exuc
?0 ten tiai.
(ii) Ilore specifIcally, SC -a-ill, rely
on the following concepts in evaluat-
Ing c.nttnal studIes Icr purposes oi cbs-
slilcation:
(A) Mc ’nma2iart speoses. CPSC gen•
emily sill rely only upon results
found in testing ntancmaiian species as
ooposed to reptIles, fish, ccc. As a
practIcal ocacter, small mancruats such
as : e .s:ers, rats acid mice will be the
test animals of choice, because of their
csnventer.ce. relatively low cast, and
susceptibility to agents ‘nowci to be
carcinogenic to humans.
( ) ?osit(ve v sus n -e jct ive esmdts.
in ?enemal. positive results in tests
with experImental animals, LI obtained
under sound experimental conditions
and with proper statistical confirma-
tion, should supersede negative re-
sults. P crther, because of incerspeciss
var atIons in susceptibility. negative
results in one species should not de-
tract from the slymlicance of clearly
positive results obtained in another
Species. Moreover, because of the in-
:tere difficulties In epideacbological
studies. sou.r d positive animal da:a
should generally supersede r.egatl’ie
human data.
(C) Trsli.ng cal , ‘s(jh lose. Testing of
chemIcals at high exposure levels, at
or apprcachir.g the maaimum tolsra:-
ed dose level, La employed, to compen-
sate for the Llm ,itcd number of anImaLs
available for long term bioaasays and
CPSC will consider results in such
tests reLiable indicators of carcino eri-
Icity.
(D) Qr caa e,eciffc iy. in some in.
states the site Of aim-.me: seen In labo-
catory animals La often the same as
that recorded in human eptdsmiolog-
IcaJ studies. in others. the site is dif-
ferent, Therefore, the Commission ‘vi i i
not presume that the organ affected
in animal studIes will necessarily be
the same as chat in humans.
( ) 3siU n tumors. CP C proposes
placing the same weight on the results
of animal experiments in which only
benign tumors are observed, as unen
experiments in whIch both malignant
and benign tumors are observed. Al-
though historically a distinctIon ha-s
been drawn bet’ween cb.e two kinds of
tumors, consideratloxt.s such as the
fact that benign tumors are har.ardous
without progressing to malignant
stages, and the lack of any basis for
deter ilr ing which benign tumors may
or may not prog-ress to the maLignant
stage, have led agencies and expert
conimittees to be more cautious. Thus.
in the Instances where benign, but not
malignant, tumors are observed. CPSC
will give these results the same weight
as tests resultIng in malignant tumors.
(t ’) ? rsoemd inc dsmtcs o/ cpc tco7te-
Ol .3 cu:7W75. C?SC reecgnL - ss chat tsr -
cain animal strains have high and van-
able spontaneous Incidence of tumors
it s one or more cr ers. An e:tampie Is
the incidence of live: tumors in certain
strains of mice. Even in cases where
the spontaneous tumor incidence is
high, however, positive inferences can
be drawn from a decrease in the laten-
cy period or an Lacreace in the number
of tumors per animal. According.y,
CPSC propose . 3 to interpret the results
of experiments sho ’a ’Icg a sta:isticaily
signillcant’increa.sed Incidence of
tumors, or a sza:Lsticaily si ni!lcant
decreased tIme cc onset sf tumors irs
treated astixanis versus controls as
positive evidence of carcinogenlcicy,
regardless of the spontaneous cantor
incidence.
(G) oisfes of exooszir in cases
where the test ccn;ound, adminco-
mered to the experimental animals La
circulated systenticeLly, giving rice to
tumors at sttcs other than the point of
it seems reasonable to
regard, the route of admIntsti-aeitrs as
in weighing the potential
to hu.mans. 7 he:e tumors as-s in-
d’cc d cniy at the site 51
clan, It bersmnes bn;oran: cc evaluate
the appro riaceness of the route ‘tI
wIth chat hicely to occur during
use of the consume: products, Iter cx-
ampe, this evaluation Is pamicinariy
important in chose costs in ‘which the
only tumors o serv d are si .cin tumors
at the site of appLication, but coruum-
er exposure Li ithely to be through
s’ in contact.
(ill) In relying on aciL—cal sc’cdin for
purposes of classL ’icazlcn, CP C will
ensure that tests, to the extent feasi-
ble. conform to the guidelines for
of ohonnis toxicity and carrino-
yer,loity tesc,s set forth in
i.nd ?-m-o:edures for E;’aIuacin the
Toxicity of House l- ,cld Substances, -,
National Academy of Sciences (June
19fl) (“NA3 Publication 1138’),
(3) Shorf-tec-m or i a ifro is-sos ,“or
cso ec’4. (1) C C La aware that a
number of short-z -erm or ía vclmo tests
are currently being developed and .A
appear promisIng as of a screen-
ing system for poenttai carcinogens In
humam- .s acid experimental animals.
The de’zelopm-er.t of such tests La
en the assumpcton that cancer tan be
reinted to genetic altemactons and that,
therefore. detectIon of such changes is
indicative that a. substance may itav ’e
carcinogenic potentIal. The various
shora - erm testa are discussed more
fully In NAS Publication 1138, cIted
above.
(U) ls the NC.AB report states.
none of the exinttng 3hort.term tesc ,5
can be used to establish whether a
58.7. Nat. Cancer Inst. 4c53.
F L&L ZIGt5Tfl 4 V P4 . . 43, NO. 14—TUESDAY, JtlNl P3, 1971
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UU3 AN JLi ON
23& 3
conipounci iiU or Jill not be arcLco-
,n:C in .Um2.r 3 or ;t terment&i axn•
mas. Therefore. CPSC ciudes t
t:-Lt3 mt t t pcsitiv e IC. U t3 .fl UCr
t sto chout crt mat cn n animal
pecte or t h’im.an s ul not xu;port
a decnion to ban or Linnit the u. e of
the sub;r.ance in consuxner roduct .s on
the ba i of tt xu .x ecr2d carcu o’ en
icity. owever . tn Iew of the fact that
positive r .su1ta in these tests ug est
the need or cing of the sut otance
La iori term b1oa. says, CP C rtU mon.
‘.s ;oa ib1e o ;icns: per’formm’.ing,
requtnn• or enco ‘ir .. further t est .
(zig of such ost.axtces. and me uir!n
r cor eng aimc su iion of tooh-
n.ic i tata o the a f tmC7.
(-s) or f i s •oJ ;iternteaL .
O SC b&J .r:es that b3t mces beicn-
(zig to c. mio .ss or family of cinilcais.
many me mber2 of vhich have been
shown to be ocinogenic, 3hoUld be
subject to further testing ! they are
presently or -z-iLl bec tue widely used
in consumer pr ducrs.
(3) trexho (d limits. CT?SC concludes
that threshoLd tmits or e ;osure (0
Lrmoger.s below which It can be said
there is io effect have yet to be esab-
Uokiect. Ttij e CT—SC :eco ilttes that re-
hstior..sh ps be en dose and response
ye been tdentjjted for a number of
ec!nc emnj nd neraUy these
to oifow :ditional u—;ea, with re-
sponse inc ee .sing with increejtri dose.
no threihoid baa yet been idertWled
below -tich a ca nogets ha.s rio
effect. The nature of (he dose-re-
spoose relationship and the eds etice
of threshoids have been discussed by
rnany expero in the fIeld of cancer re-
search and they are subscartcially in
agreement that dose-reapcn.se nat-a
ca.nnot he used to set no--effect levels
for em posure to emical ccthogerss.
Lore aver, CPSC musz consider vary-
ing Individual 2uceptibilitles within
the heter eneous human population.
This cot crast.s ‘with the homogeneous
auis of itmals used In tests and
the relative bonmogenejty of defined
: -iuman study -roups. Thus, once a re
suntçstioti of carctno enicity has been
estaotished for a substa.nce. any expo
sure to the sub t4.nce must be consid-
ered to be attended by some r when
considering act ivea opulatton.
1040.22 Ducription of c te;orle .
CP$C recognizes that any assess-
of carcinogenic risk must u.ltI-
macely rest. upon the best judgment of
LadivtduaL e ert in evaluating and
interpreting the data derived frc er-
perirnencal studies arid human obser.
vatlons. owever, uiclaxice Is neces-
sa.ry (0 5tzi ctU.re such findings and
ssure consistency of re ixiatory treat-
ment. Such aldazice Is provided In the
foUawing criteria for classifying sub-
stance a.sed on the cojusions
reached from the existing data.
(a) Cnfecorj A. This category con.
slst .s of those substances for ‘h1ch
there is stro tg evidence of carcinogen.
(city. This evidence y come either
from human epidemiological studies,
ong tei animal studIes, a combiria-
mba of long term animal studies and
:n cnitro testing, or other lor mcion
provided by the staff which time Com-
mission regards es compeUltig evidence
of earcinogenicLty. l3teciflcaily, a sub-
stance wifl be classifIed as Cat,ogory A
If:
(1) The tlcrial Cancer Lastitute
issued a finding that the sub-
stance is an animal or hu.man carcino-
etu or
(2) The substance either signWcazmt-
ly increases the incidence or reduces
the mime to onset. of benign or rn2Jig-
nant oplasms in humans in the ex-
posed versus rionexposed group; or
(3) (1) The edmtn.istration of the sub-
stance :o groups of animals in well de-
signed azid soundly conducted experi-
meats si Lficantly increases the inci-
dence or reduces mne tIme to onset of
one or more types of benign or inalig-
rtanc neoplasms in the treated groups
as compared to control groups main-
tained under identIcal coxid.It(ons but
not given the test compound.
(U) Ordinarily, the results referred
to in paragraph (3X1) of this section
must follow from systemic dLsti -thution
of the substance and must be obtained
in either L ) ‘Z’ o specIes of zest ant-
ntaLs; (3) One species of test anlraa.l
a-hen repLicated in a second experi-
ment using independent control
groups: (C) One species of test animal
when supported by a battery of well
designed and soundly conducted rele-
vacit short-term tests, such as assays
tort Neoplastic transformation of
mammalian cells in culture; mut.agene-
sis In mammalIan somatic celis muca-
genesis in bacteria, yeast, doscphfla
inelanogoster or other appropriate cell
systems; or the inductton of DNA
damage and re’paLrm or
(4) The CommissIon finds that there
l other evidence .tu1llcie tly compel-
lIng t,o warrant classifying the sub-
stance as Category A. Fmr example, on
(he basis of a. staff analysis that the
result3 constItute suffIciently strong
evidence of carcinogerticity, the Com-
missbon may, in its discretion, classify
a substance as Category A based on a
single, unrepllcated long term s n rn l
study.
(b) C fe or’j B. This car. ,egor; wi]2
consist, of those substances for which
the evidence of caroinogeriscity is sug-
gestive that a r1s to humans exists. A
substance will be classifIed as Catego-
ry 312:
(3.) uman or data are g .
esz1ve but not conclusive of carcano-
exsic1ty because they are stacistcally
inconclusive or methodologically defl .
dent but nonetheless tend to support
a finding of earelnogen.lclty or
(2) PositIve results exist in one or
more short-term tests but have not
been confirmed by positive data from
either swoman studies or kng-ierm
animal experiments; or
(3) ?csmttve :esuit.s exmst um only one
unrepitcated inrg term animal zest nne
results of wh ch are not suIlic ently
compelling to tvarrarmt classificatiofl as
Category A, and are not upporz d by
a battery of positive result-s in sh rm-
term test:
(C) Cr.feqcrj C. This category will
consist of substances which are mem-
bers of a class ot- family of chemicals.
many eaibera of which are nown no
be carcinogens, it also consists of
other substances about which a pues-
(Ion he been raised regardi the pa-
tentlal carcizicgemc hazard to humans,
but for which the evidence is ,ery lim-
ited.
(d) Categor’; D. This oategcry will
consist of substances which had been
previously classifIed as either A. B or
C, but for which the existing evidence
does riot indicate carcinogenic poteri-
mial at the time of re-classifIcation.
1G4023 Comm!ssfot renew of reff dss.
il cat i on
after the cIassiIIc-atton has been Ini-
tially detenmnsd my t I-i c staff, the
staff :vifJ propare a brteftng paci age
and, where risces-s.a.ry, a l ’ nnw. Rxo-
:srmt notice, sumzimarizixig the tat or-
mambo and ((-me opinions of mime staff
and others who assisted In decermain-
tag the classLflca:ion. At the same
mime, the staff will bring to the Com-
mission’s attentIon any evidence which
It believes the Comrcission might find
suffIciently compelling to exercise its
discretion under l040. (al(4). The
Commission will expeditIously coasts-
er (he !rjornmacion furnished by the
staff and any ocher informatton and
data it. deems relevant and a proprbate
and will approve the staff recomnien-
dalton or make such changes as the
Coraminsion determines are appropri-
ate and necessary. The provtsicnal
classification of a substance nto C,tte-
gory A or 3 will oe puoLaned tor
public comment in the l ’mazi .u. itzo:s-
rne Commerit will also be requested
on the dittt-lbutio and use of trie suo-
stance in consumer products and the
availability of the substance for
human uptake. Any comments re-
ceived m ciii be analyzed by the sta ll to
determine Li significant questions are
raised concerning the correctness of
mla ,sstflcacbcn. . in the opinion of (lie
Executive Director or his or her deslg-
race, signifIcant questions are raised..
the issues a-ifl be brought before the
Ccrnirr - ’ ion for resolutIon. 1! the sub-j
stance is classified as Category A, the
Commission. In aceordane wIth 34-
signed priorities (see 1040,31). mciii
direct the staff to proceed with the
evaluation p iaza whl e awaiting reso-
lution by the Comm ,ssa1o et of any sit-
uiflcant uest4ons rs4aed by the public
colnmeflt3 .
21G1$TZ*, VOt. 4, $ . I 14 Tt/ SOAY, 3W41 13, 1971
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256 4
UtE ANO GUtAflO S
,vort 0— ioH yciT. t on cr d
C. mia ct rersoi o
Cooitt i Clas ifi d Sutcnce
1040.01 Priorities ior staff e a1uation
and Comzithsion appraisaL
l.a daterrain.ing the order in which
products ontainj g cissatfied sub.
stances will be evaluated by the staff.
the Co salon recogrines that it ay
need to set priorities arr.ong sub.
stances. Generally, priorit.y wifl be
based on ti-jo relstI ’ie certainty cf the
evince oc!’Jrg the su tance (I.e.
the category to which it i s
the apparent o ency o.i t sub-
StO .flCO,’ the t:ttsn: of c nc : ecpo-
3Ur5 to oduct contai.aing the sub-
stance, Uc1ubl ng the approximate
number c i products and the amount of
the substance contained in each. and
the potential for hu.maa uptake. This
nisy lead in sotne cases to the alloca-
tion of resources to the investigation
and pcsatb ie regulation of high prior-
ity Category 3 or C substances nther
than low priority Category A rub-.
stances.
10-10.02 Guideilnea snd procedures for
staff evaluation and Conuaisaion ap-
praLial.
(a) Guicfe inea. In accorda.ace with
Co mLsaion assigned priorities, as dLs-
cussed in 1040.31, the staff trill pre-
pare, for each Category substance,
and in cot-cain appropriate cases. for
Category 3 or C substances, an evalua-
tion of products contain the substance
for the use of the Comm i’-ciou in con-
sidering the nature and extent of an
reguiacor.p action. In appraising the
staff evaluation, the Commission will.
be guided by the Statement of (letter-
aJ Policy set forth in 1040.1
(b) 2’-ocsdurr. There zn.a7 be two
stages of staff evaluation 01 products
containing classifIed substances.
(1) iirst .zfnge evo.2uarion. Tn the
first stage, the staff will supply Only
the data and aaiaiysia wbjcia ran be de-
veloped adequately within a n ’ um
amount of tizo . The staff will, u
peditlously as possible, prepare a
report and brief the Corrmlsalou on
the result.s of the preliminary analysis.
. 2ter reviewing the report, the Com-
missiOn will decide eIther to consIder
regulacot-y action, or to proceed with a
second level of staff evaluation and
CorainaLsafon appraisaL
(2) Secoit4 a rage e lualloi. The
Comnaissiori will cilrecz the staff to
prepare a. second level of analysts only
when the first tndica.tes that unre-
solved uesrtons are serious enough to
warrant further erploratlon. The
CornmLi .vioa a-ill provide the staff with
‘Potency houid be *tlmated using
human teas ar. 2 sre that Is not avtilabte,
t ng dose espor .se data (or the most serisi.
tive inimel s ectes In icti the substance
has been tested.
nidanee as necessary on speci!tc nob-
lerns tO covered tnt he second stage
analysis. ‘Thus, the second stage anaiy-
si need not expand on every factor
considered in the first stage, but only
those where substantial uncertainties
remain. The staff will prepare a report
and ‘chef the Commission on the re
sult.s of the second stage analysis. ?..eg’
u.larory action will then be considered.
104023 Factors considered in staff oval.
uation and Commission spprassaL
The factors set forch below will be
cor.sidered by the staff and t he Corn-
mission in evaluatIon and appraisal of
products containing Category l sub’
stances trid, in certain appropriate
cases, products containing Category 3
or C substances;
(a) Exposure. The staff evaluation
shall consider, to the cictent warranted
by the particular circumstances at
each case, the following information
ott ecposu.ret l) Products and/or
classes of products in which the sub-
stance appears: (2) ranges or leveLs of
concentration and forms in which the
substance appears: (3) maJor use char-
acteriscics of the products as they nay
affect routes of entry into the body:
(4) intensity or duration of exposure
of the public to a substance; (5)
volume of products in
hands and the dlstrthutlon chain: and
( ) population exposed, including high
esposure or high vulnerabUlty groups.
(b) Human wp(cfce. The staff esrnlua
tiara shall consider. to the eictent war-
ranted by the particular ctrcuzastazsces
of each case. the factor of human
uptake, including the quantIty of the
substance that could come in contact
with tissue or organs under reasonably
foreseeable conditions of product use
or misuse. This analysis may take into
account the physical and chemical
characteristics of the substance and
the product in which it appears, in-
cLuding sotuhiUty. partIcle size for act-
osol,s, sk.i.n penetration, and absorption
rates.
(a) Srth ,tWutsa The stat! evaluat0on
ithaU consider, to the extent warranted
by the particular circumstances of
each case, the avaltabillt7, adequacy
and conapa.raclve costs of probable sub-
stitutes. The evaluation should e isa
discuss possible hazards of probable
substitutes, including toxhetty.
(d) F esWal ecasu,mio an accoaf ef-
fec.t& The staff evaluation shall con-
alder, to the extent warranted by the
particular circumstances of each case
the following information.
(1) The need of the public for the
consumer producra containing the sub-.
stancel
(2) The prohable effect of regulation
on the utility, cost, or avaijabiUty of
products to inset the rmeed and
(3) Any means of ath.tevtzag the regu-
latory obfecsive while ‘ ttg ad-
verse affects on competttlofl or disrup .
tion sr dislocatIon of rnanafacttu-fng
and other commercial practices.
o) Eaviror.mnental arsessrter.f , To
the miaxinsuna extent possible, the
staff evaluation shculd serve as the
basis for CPSC’a assessment of the
effect of possible regulatory action on
the environment.
(f) Interaction c / risk Jcctors. (1) Ira
estimating the risk of injury or illness
presented by a product contair.ing a
carcinogenic substance, it 0 importe.nt
to assess the interactIon of several ac-
tors, including the potency of the car-
cinogenic substance, the exposure to
that substance. acid the availability of
the ubstxnce for human uptake. Tints
of the risk of Infury or tU .
ness will generally take the font-i of art
estimate based on reasonable sasurap-
tions or sell-evident circumstances.
(2) CPSC recognizes that the vary-
ing potency ci chemical carcinogens
(Ira comparable animal test systems)
can elIcit responses which vary by us
much as a factor of 10 million. Like-
wise, exposure patterns of oroduct.s
vary widely and differences often exist
between routes of expc .su:e in animal
bloassays and actual product use. Dli-
terences in himtan uptake patterns
and itt sensitivity between animal arid
human systems are also factors which,
to a lesser degree, affect tine caccino-
genicity of substances to humans.
(3 Tine great magnitude of the till-
ferences cited above suggests that
there are situations Ira which it is de-
sirable to estimate uant1tatIve1y the
level of risk presented by a product
usltg matheniatleed relatlonshJps In.
terrelating estimates of exposure con.
ditlons, sensitivity, and ‘cunaan uptake
factors. It Is recognized, however, that
these quantitative estimates of risk
utilizing mathematical relationships
have varying degrees of relIabilIty. do-
pending both upon the data and the
assumptions involved. This is especial-
ly so when extrapolating from doses
sutitciently high to produce tumors in
animals to the lower doses of expected
consumer exposure.
<4) AccordinglY, quantitative esti-
mates of risk may be used by CPSC in
making judgments as to the relative
degree of riak of injury or Illness pre-
sented by a product In setting prior-
ities for regulatory actIon.
S4. àp4rt —*e1u ct,ry ‘Ti-ectmen* e l
O Ur . 1 Conteining Ce eg ry A
ubstancas
1o4&41 Reg ilatory approach,
(a) As stated In the Statement of
t3eneral Policy, 1040.1, CPSC will not
permit known carcinogens to be iratera-
tiortaily added to consumer products if
they can be absorbed, irthaled or in-
gested into the human system. unless
elimination of the carcinogenic sub-
stance would result in unacceptable
cW1 M 2 C15T ‘/Ot, 43, iO. JU A’ , JU 2 , t7I
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UUS AND 2EGULAT1ONS
25665
econoa,ic and social costs, In which
case CPSC will require reduction ot
ihe substance to ;he lowest attainable
level until easooable substitutes are
iderittfled.
(b) Couse uently, It Is reasonable to
assume that CPSC will act to ban. or
reduce to the lowest level attainable,
the intentional addition to a consumer
product of’ a Category A substance.
Eowevtr, the tiinjng of this action will
depend, as discussed in 1040.31. on
the priority accorded the substance In
comparison with other substances.
Products coricaitung Category A sub-
stances assigued a low priority for reg
ulatory action to ban or limit the use
of the substance, may be subject to in-
terim regulatory action as provided in
1040.51(b).
l )40.42 Effective date. recall and lmml.
nen hazards.
in determining the effective date of
a ban, as weLl as the need to exercise
its recall or im minent hazard authori-
ty, CPSC ‘will. 3é ways to
the disruptive effect of its actions on
commerce to the extent consistent
with protection of public health and
safety.
1040.43 Public perticfpatloa.
The Corn issica will ensure thai the
public is invo1 ed to the greatest prac-
Ucabie extent In the decision-making
process leading to the regulation of
carcinogenic risks. The public has the
right, under the C ’SA, to furnish to
the Comnik. 1on data. v1ew and arzu-
ments in writing and orally on pro-
posed consumer product safety rnles
and has similar procedural rights
under I-he FEZA. In addition, where
nppropriate, the Commission wi1T ro.
vIde for other hear1n and public
meetings on questions of regulation of
carcinogens,
Subpart P—a.guiatory Treatment of
Products Centeining Category B
and C Substances
1040.31 Regulatory optiouia.
(a) Taetino Category B substances
á re those for which the scientific evl-
dance of care1noger icity is suggestive
but not as strong as that for Category
. _ Category C substances are’ those
about which a question of carcinogen.
Icity is raised, either on the basis of
limited evidence or membership in a
family or class of chetnicalt, many of
which have been shown to be carouse-
genlc. Oenerally, CPSC will ma. e
every reasonable effort to see that
substances classified as Category B
and C receIve further testing. 1
(b) Zn erim re Lstory action. Pend-
ing the completion of additional test.s.
CPSC may consider whether interim
regulatory actico should be taken.
(1) Warning sfaternents. Interim
action could take the form of regula-
tion under secticu 1T(e) of the CPSA
recuiring manufacturers to make in-
formation available to consumers at
point of sale, including requiring an
explicit cauttorl&X7 statement regard-
ing posttl’re results of any tests con-
ducted on the substance;
(2) LabeWtg C?SC may consider
mandatory labeling of products con-
teinrng Category B and C substances.
CPSC may require manufacturers, undec
the prev1slo s of section T(e) of the CPSC
to conduct specific tests and to provide It
with the results of those teats. C? C may
request E A to require maniscaurers
to up testing data under the Toxic Sub..
cances Cot’ ot Act,
(See e.g., section 2 ’ (e), 15
U.S.C. 2O ’76(e> and sCotlon Sib) FESA
(15 U.S.C. 1262(b)).
(5) F scorcikeeping. CPSC may con-
sider mandatory recordkeepuig of the
production and ithtribut1on of prod.
ucts containhig Category B and C Sub-
stances under sectIon 16(b) of the
CPSA (15U.S.C. 2065(b)).
Subport G—Products Conlaining
Category D Substances
1040.61 CPSC .iction.
CPSC will. monitor sourbee of izilor-
macion concerumg Category D sub-
stances and maintain’ any data. re-
celved In order to determine whether
re-classiflcaclon into Category A, 9. or
C is warranted. No regulatory action
‘will be taken with regard to products
containing Category D substances.
Interested persons are Invited to
submit written comments Ofl this
statement of poUcy and procedures
before the close of busIness October
11. 1918. Coes. ents received after that
date will be considered to the extent
practicable. Comments should be ac-
companied by any relevant supporting
data, and should be submitted prefer-
ably In five copies, addressed to the
Secretary, Consumer Product Safety
Commission, Washington. DC. 2O20 T.
Received comments may be seen in
the Office of the Secretary, Consumer
Product Safety Com s .s1on , 1111. 18th
Street. NW., third floor, Washington,
D.C. during working hours 3 ionday
through Priday.
Datecl June 8, 19?3.
S.tnrr Z. D st ,.
4ctlnq Secretary, Con.n m.er
Prodxct So /sty Conissson.
(7R nec. ‘78.48441 Ptled 8-0-It 023 paLl
5 0 3O.lZ5
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1—201
1 MS. CHANG Thank you very much.
2 Are there any questions?
:3 1 Thank you.
4 The next speaker on cur list will be fron the N w
Or1a ns Sewerage and Watsr 3 oard, Mr. Stuart Brahn and Noel
6 Brodt ann.
7 STATEMENTS OF STUART H 9REHM, JR.,EXECtJTIVE
DIRECTOR, SEWERAGE AND WATER BOARD ‘OR NEW ORLEANS;
AND NOEL BRODTMANN, CHIEF CHEMIST, JEFFERSON PARISH
Ii ) WATER Q JALITY LAB
11 1 MR. BRODT 1ANN: Good aet.erncon. My n& ne is Nc 1
12 ?rod ann, and I n Chief Chemist at the Jaff rson Parish
13 t’iatar Qual y Lan.
14 I a t ne e c present additional comants on the
1.5 proposed rulemaking. In our initial ccttunents at the New
18 Orleans Public Hearing, and we feel enough has been said from
17 that standcoint. So we would like to talk about the aspect
is o the proposed dnent , wherein chlcraxt ..a would ce
19 hibited as a prii ary disinfsctant.
We would like to talk about this for t o reasons
21 One, Jefferson Parish has been using chlcrai ne as a primary
22 disinfectant for over 30 years, and we are of the opinion that
23 we have been doing good jcb in disinfacting drinking. wat er.
24 Seccndly, we have bae able to demonstrate that
25 ccr nin trea ent allows us to ?rcduce a fin.ishad water at
Acme e 3! rty Company
iU 4fl ]
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1—202
I this time with a total trihalomathana level on the order of
2 10 to 20 micrograms per liter; and the City of New Orleans,
3 downstream from us, using the same raw water source at this
4 time of the year, is producing water with a concentration on th
5 order of i0 to 80 micrograms per liter.
6 And as the water continues to warm up, I am sure
7 they will go over the 100 parts par billion level being dis-
8 cussed, whereas we will continue in the 10 to 20 range during
9 the summer. During the winter, our levels get down to the 5
10 to 10 range. Therefore, we feel it is important that EPA
11 review its tentative position on chioramine.
12 An extensive literature review by Siinons, and the
13 werk of several other researchers, would lead one to conclude
14 that a comparison with residual chioramine is a poor biocide.
15 However, it is important one considers some aspects of ch1orin a
16 water chemistry not necessarily emphasized in reports of
17 bench studies on biocidal effects.
18 Querling reports that in the normal range of pH for
19 drir king water, between a pH of 6 and 9, the pre-chlorine
20 residual consists of varying proportions of hydrochloric acid
21 and associated hydrochorida ion; at a pH of 6, the hydrochlor±
22 acid is the dominant species comprising 100 percent of the
23 residual — - well, at a pH of 9, hydrochorida ion is found to
24 make up 100 percent of the residual.
25 It is particularly important to point out that the
Acme Reporting Company
(202) 6284888
-------
1—203
1 hydrochiorida ion is reported to ba 150 to 300 times less
2 affective than hydrochloric acid in the production of virus
and bacteria. Since most water utilities using surface water
4 supplies do not currently produce a finished water with a p1-1
of 6, tis also appropriate to point out that even in.those
6 systems using pre—chiorine, considerable improvement in disin- 1
7 faction is indicated should those systems seek to adjust seek
8 to adjust effluent pH to 6.0. Such an adjustment would not
be recommended, as water with a pH of 6 would be expected to
10 show considerable corrosion activity.
Also, Butterfield, in comparing the relative bactar-
12 iacida] efficiency of chiorarnina versus chlorine, reported
13 that “to obtain 100 percent kill with same contact period
14 requires only about 25 times as much chloraznjne as pre-chlorii
1 -5 Hence, under actual water plant operating condition
16 particularly in terms of pH ranges, it would appear from the
17 literature that biocidal effectiveness of chioramina, as pra-
18 pared, to pra—chiorina treatment is not so much lower as to
19 preclude tha former treatment from considaration.
20 As mentioned earlier, the use of ch1ora ina as a
21 primary disinfectant is especially effective in reducing the
22 public exposure to trihalomathanes in the drinking water.
23 What I would like to discuss at this point is a
24 five-month study that we entered into,shortly after the propo
25 ad amendments came out, to demonstrate the biocida]. eff active as
Acme Reporting Company
1202) 8 B.46 8
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1—204
1 of chioramina. The study was undertaken at the East Jefferson
2 Watarworks .Jafferson Parish is divided by the Mississippi
R3.var and we have East Jefferson and West Jeff arson Watarworks
4 a total of six water plants with a combined capacity of over
5 100 inillt.on gallons a day.
6 We use cation polyelectrolytas for primary coagulant
7 Up until a year ago, in May, we practiced coaline softening
8 without any carbonation, and our pH went out in the order of
9 9.8 to 10.2. We would be forming high levels of tr halomathan
10 if we were using a pra’-chlorina residual in stool softening,
11 We decided to stop softening effects in an attampts
12 to lower the trihalornathana levels, and to save money on
13 increased limecosts. We also decided to change our chlorine
14 application point to further reduce the trihalomethane level.
15 As I said, we have been using chioramines for many years, long
16 before I tarted with the waterworks.
17 By using our chioramination application point to
18 pre-chioramination, intermediate - — that is, to move frcm pre-
19 clãrifiôatión:.. to after-clarification, we reduce our ’ch1orina
20 time by about an hour on the average. However, we took sampi”
21 of the raw water coming into the plant, the early samples of
22 the raw water coming into the plant, water just after clarifi-
23 cation, and water after about 10 minutes contact with the
24 chioramine residual; and we found the ch3 oramine treatment was
25 effective in the destruction of ãbout: ’60 percent of total
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1 bacteria population remaining after clarification.; and that
2 is with only tan-minute contact time.
I might add the chlor ini.ne treatment was affective
4 in destroying about 88 percent of the coliform bacteria ramai
ing aftar clarification, again with only 10 minutas contact.
6 Unfortunately, we do not have visual aids here, and I cannot
7 show this plot that I am referring to, but I have a graph of
8 bacterial counts in raw water, effluent, clarified, before an
9 after the agent, and the affluent in sand filter prior to the
10 water’s entry into the distribution system.
11 We had to plot his on a five-cycle logarithmic scalE
12 because of the vast differences in bacterial count between
finished water and raw water. We also found there was a
14 statistically significant difference between the clarified
15 water only and the clarified water treated with hiorainifle a
16 very highly significant difference, using the P test.
17 Our average chi.oramine residual during this test
18 period was 1.6 milligrams per liter of combined chlorine. Th
19 average sand filter influent had a total bacterial count of
20 about 240 per milliliter. This study was undertaken during
21 the months of January, abruary, March, April and May, during
22 which time t ie river temperature was about 3 degreeS Centigrad
23 at the start of the study, and has risen to about 19 degrees
24 Centigrade at the ar 4 d of the study.
25 Butterfield reported pronounced affects of tamp4rat1.
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on the kill efficiency of chioramina. However, cur data show-
2 ad a rather weak correlation with temperature.
I have a table here that we are not able to show,
but I would like to quota some numbers from it. For example,
total baqteria in the river during this period of time, avara
6 total bacterial counts par milliliter using standards methods
was 8,564. Clarified affluent was 610, and clarified with
8 tan minutes contact time with c or znina was 241. Coliforra
9 bacteria counts, river, 2,218; clarified affluent, 226;
10 clarified with chioramina;, 27.
U We already discuss the present reduction, 88 per—
12 cent killed bacteria, and 97 percent coliform bacteria. This
13 is prior to clarification, and I will emphasize that, stricti
14 for the affect of clarification and separate effect of chior-
15 amination. Of major importance is the fact that our data are
16 in good agreement with k 11-efficiancy and contact time
17 reported by the same author, Butterfield, in an earlier pub1i-
18 cation. Th that study he used various strains of coli to
19 determine biocida]. effectiveness, In his work, 100 percent
20 ki11s for a].]. species studied, were achieved with chioraittina
21 after 10 minutes of contact time.
22 Examj tjon of the curve we have plotted here shows
23 total bacteria count was not more than 100 par millitliter
24 during entire study. Effluent with the sand filter —— even
25 the raw water levels were two to three orders of magnitude
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1 higher.
2 Mmittedly, it is not the usual practice of the
Water Quality Lab to run bacteriological analyses on samples
of clarified affluent, and a portion of the data discussed wa
collacte4 and supportive of this response to the EPA’s propos d
6 ban on the use of chioramina as a primary disinfectant.
However, as part of a rountina microbiological inoni-
8 toring procedure, the Water Quality Lab daily takes samples
of each of the six filter plants’ filter effluents, clear
10 walls, and points of entry to the distribution systems for
11 Districts 1 and 2.
12 Moreover, over 2,000 field samples, collected at
13 random throughout the distribution system, are examined each
14 month; and I am speaking of microbiological samples; a suxnma
15 of the results of these routine analyses is shown in Table 2,
16 which we are unable to share with with the audience.
17 But I can say that we had a mean chloroform distri-
18 bution in all field samples taken through the bi-month period
19 of 0.0 —- .02 entry into this distribution system, two sample
20 not to be considered as positive, overall a high quality in
21 terms of bacteriological qouñt ..
22 It is believed these data provide substantive evi-
23 dance as to the use of c lcram.the as a primary disin actant.
24 Good disinfection is achieved, and regrowth in distribution i
25 insignificant. Moreover, the presence of a long-lived
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1 disinfectant residual throughout the distribution system pro-
2 vidas sortie measure of protection, generally in terms of the
3 rapid disappearance of that residual that would occur in the
event of a cross connection.
5 We can conclude that, properly applied dosages, 1.5
6 to 1.8 milligrams par liter in this case, can produce 100 par-
7 cent kills of pathogenic bacteria species and affectively
8 reduce total bacteria populations to within an acceptable
9 range.
10 Moreover, the result of large number of THM analyses
11 parform d by the labs - - it is apparent that the usa of
12 chloramine,as the only disinfectant, is particularly affactiv
13 in preventing the formation of trihalornathanas during the
14 treatment process and during continued disinfacting contact
15 throughout the distribution system following traatrnant.
In light of this information, it is inconceivable
17 that chlora ntir.a, erroneously labeled as a poor biocida, shoul
18 be prohibited for use by those water purification operations
19 seeking a cost-effective alternative to GAC in the reduction
20 of exposure of consumers to T}IM; as demonstrated, it is possi—
21 ble to produce and deliver to the consumer’s tap a drinking
22 water that contains one-tenth to one-twentieth of the proposa
23 MCL for trihalomethanes, even in this case where a raw water
24 supply is the Mississippi River.
25 Wa heard this morning how polluted the Mississippi
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1 River is. Further more, this traata nt alternative does not
2 require great expenditures of capital, nor does it require th
3 consumption of tr nendous quantities of energy, which would
be the case with the reactivation of GAC.
5 Of major importance is the demonstrated affective-
6 ness of chiorainine, as used as a primary disinfectant.
7 Mr. Rirnzn, when we spoke in New Orleans, I promised
8 you reams and reams of microbiological data, and I have photo
9 raproductions,that I would like to hand you,:for five years.
10 on the order of 70,000 to 80,000 analyses.
11 MR. KIMM: Are you adding the chlorine and airunonia
12 together?
13 MR. BRODTMANN Thay are added within 30 seconds of
14 each other.
15 MR. KIMM: Hava you looked at -— at least one permu
16 tation of that, which is using pre-chiorina for some period o
17 time?
18 MR. BRODTMANN: Oh, yes, we have-had anunoniated fail
19 urss. Unfortunately, they seem to occur most frequently in
20 the plant involved in the orqanics r moval study. nbarrass-
21 ingly enough, we have had periods of time where chioramina
22 residuals seemed to be producing high levels of pra-chiorina,
23 and we pass it off as ammoniatad failure. We know th e source
24 of the problem.
25 MR. ROBECK: If you have any data involving the
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1 interval of time between when you added ch1ori .a and when you
2 added the ammonia, we would appreciate it. We appreciate the
3 excellent af fort you have made in this analysis. We know that
4 this is true for many other large water systems in th United
5 States as far as ammoniation is concerned, and we also know
6 there are some systems that have had troubla with that, and
7 that is why we were anxious to be cautious with its use.
8 If we can have evidence between when it is added as
9 chlorine, and then ammonia, we think, for a matter of 30 second
10 to a minute, might be very helpful to kill viruses particularl
11 and also any nematodes that might get into the filtration sys—
12 tern.
13 As you know, we are doing additional work on that i .
14 Texas, and we would like to have any information you have on
15 it.
16 MR. BRODTMANN: The 30-second estimate would be on
17 the long side. Actually, the conductor -- type from the
18 chlorine conductor comes into the main and -the ammonia pipe is
19 right next to it.
20 DR. COTRtJVO: You said you ware achieving 100 par-
21 cant kill of pathogenic bacteria. Did you look for any other
22 bacteria besides coliform in general plate counts?
23 MR. BRODTMANN: By total coliform and facal bacteria,
24 we have done some typing of growth on the total bacteria plate
25 counts, and we are finding some flaval bacteria and actinomyca
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1 and that sort of thing. We are not finding pathogenIc species
2 Wa are not set up to do that sort of work. We are set up to
3 large numbers of membrane and filtration samples, whatever
4 number of confirmations we have to do on the positives and
5 false—positives.
When it gets into speciation, we are not set up for
7 large numbers.
8 DR. COTRUVO: You did not look for virus, for proto-
9 zoa either, I assume.
10 MR. BRODTMANN: We occasionally do gross examination
ii for protozoa. This has never been a problem. Virology is
12 a whole -— another ballgama. I would be happy to send some
13 samples to any EPA labs that would like to do the virology, if
14 you can tell me where there is one.
15 DR. COTRUVO: Did you have any comparative studies,
16 side—by-side, chioramines versus pre-chiorine?
17 MR. BRODTMANN: Oh, yes. Actually, we have this in
18 terms of trihalomethane formation potentia ., stored samples
19 bacteriologIcal quality, no. This is in terms of trihalonieth-
20 ana formation.
21 DR. COTRUVO: Was there any major difference in the
22 bacterial counts before and after you used the lime softanar
23 As I understand it, now, you are not using lime softener.
24 MR. r3RODTMANN: This study was commenced in January.
25 We stopped lime softening the May before. We never did take
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1 samples out of our clarif jar for bacteriological analyses.
2 Our microbiology effort was primarily after it ca ine out of the
3 filter, either from the reservoir or the clear well pumps into
4 the distributIon system, and then a fairly intense monitoring.
5 DR. COTRUVO: Do you think it would be possible to
6 look at some of the data in that folder from the earlier times
7 where you ware using lime softening, looking at plate counts
8 and so forth -— and comparing that to your currant practice?
9 MR. BRODT 1ANN: That may be possible.
10 DR. COTRUVO: One question -— slightly different
11 In the organics carbon study, which we referred to, you are
12 doing comprehensive analyses of chemicals in water before and
13 after carbon treatment?
14 MR. BRODTMANN: That is true.
15 DR. COTRUVO: Organic analyses; prospectively,
16 inorganic -— prospectively, have you observed any differences
17 in the water with or without the use of granular carbon?
18 MR. BRODTMANN: The only Inorganic we have been
19 doing is the traditional production analysis that you would
20 usa in a lime softening plant, for example. The only change.
21 we have noticed is that there is a change on the crdar cf
22 about 2 percent calcium deposition on the average on the car-
23 bon. That jo .:’, in the form of calcium carbonate, and was in
24 the period of lime softening when our water was vary unstable.
25 DR. COTRtJVO: You have not looked for trace inorgai i
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1 MRe BRODTMANN: No, this was no considered appropri-
ate to the study.
3 MS. CHANG: Thank you.
4 Mr. Brshm.
5 MR. BREHM: Thank you.
6 My name is Stuart Brabxn, and I am Executive Directox
of the Sewerage and Water Board of New Orleans.
8 On March 29, 1978, in New Orleans, I presented a
9 statement to the Environmental Protection Agency dealing with
10 the cost that the proposed regulations for the control of tn-
11 halomethanas and synthetic organics would cost the Sewerage
12 and Water 3oard of New Orleans, if the Board ware to install
13 the proposed granular activated carbon -- GAC -- filters.
14 At that time, I pointed out th& three alternatives
15 that were under consider tiozi, pointing out that the capitali-
zation cost, together with operation and maintenance cost,
17 would result in rate and revenue increases ranging from 74.4
18 percent revenue increases to a low of 66.7 percent revenue
19 increases.
20 Based on the typical bill in New Orleans of 7,000
21 gallons of water consumption par month, this would have meant
22 an increase in customer cost ranging from a high of $71.16 pax
23 year to a low of $47.76 per year.
24 EPA had not onig na11y made any cost estimates sap-
25 arataly for the City of New Orleans, therefore tha $8 .8 m l-
lion of capital cost -- the highest estimate - - could not be
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I related to the cost as visionsd by the Environmental Protac-
2 tion Agency.
3 An itinerant engineer, challenging the N w Orleans
4 cost was quoted in the local press as estimating the N w Orlea
capital cpst at approximately $5 million.
6 At the March 29th, New Orleans hearIng, more detail
7 cost figures were requested by EPA, which were subsequently
8 furnished at the EPA public hearing that was held in Boston,
9 Massachusetts, on April 6, 1978.
10 At the time, the more detailed breakdown of cost
11 figures was furnished to the Deputy Assistant Administrator,
12 Mr.. Victor Kirnn , a request was made to EPA for a meeting with
13 engineers from Temple, Barker and Sloane for purposes of
14 clarifying the differences between the figures that had bean
15 developed by TBS for EPA and those which had bean prepared by
16 the Board’s engineers.
17 A total of three meetings wars held with represanta-
18 tives of Temple, Barker and Sloane, Inc., and also with Gannet
19 larning, Corddry and Carpenter, Inc ., in an effort to resolve
20 these cost figures.
21 At the first meeting that was held with Temple, Bark
22 er and Sloane, the estimated cost for New Orleans utilizing
23 the Temple, Barker and Sloane criteria was estimated at $21.7
24 Thi11 on. The first meeting was devoted almost entirely to
25 discussions of the Board’s inItial estimate of 89.9 million
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I and educating the TBS personnel to the site specifics at New
2 Orleans,
3 Ior the second meeting, the Board’s engineers did
4 a restudy which resulted in a capitalization cost -- exclusive
5 of intarast on bonds to be issued -- of $85 million. The
6 $4.8 million of reduction was due to redesign wherein the
7 filters were increased from a depth of five feet to 10 fact o
8 granular activated carbon.
9 At this second meeting with representatives of
10 Temple, Barker and Sloana and Gannett, Flaming, Corddry and
11 Carpenter, Inc., it was agreed that criteria would be develop-
12 ad that would be used for purposes of cost estimation; and
13 based upon this criteria, both the Sewerage and Water Board
14 engineers arid Gannett, Flaming, Corddry, and Carpenter, Inc..
15 would prepare cost estimates and subsequently compare these
16 cost figures.
17 This comparison of cost was accomplished at the
18 th!rd and final meeting, which was held on June 19, 1978.
19 Using the criteria that had been developed at the
20 second meeting and with the understanding that the criteria
21 being used was for purposes of cost comparison only and would
22 not necessarily constitute a design for tha New Orleans facili
23 ties, it was determined by the Sewerage and Water Board angiri-
24 ears that the capital cost would be $67. .-mi].1ion, while the
25 cost estimates prepared by Gannett, Fleming, Corddry and
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1 Carpenter, Inc. were estimated at $55.3 million, both of
2 which were substantially different from the $5 million astizna e
3 by the itinerant engineer and the first estimates of Temple,
4 Barker and Sloane, Inc. of $21.7 million.
5 DR. COTRUVO: Would you identify the “itinerant
6 engineer”?
7 MR. BREHN: Mr. Robert Havis, He comas and goes,
8 like the seasons, but they very seldom change.
9 Two main differences in cost between the Gannett,
10 Fleming, Corddry and Carpenter, Inc. estimate and that of the
ii Sewerage and Water Board engineers revolve about the need for
12 tha acquisition of two squares of land necessary for the
‘3 installation of the C,AC facilities at the Carroliton Purifica-
14 tion Plant -— a $1.7 million differential.
15 The second and major difference in cost estimates,
16 however, relate. to the furnaces that would be used in raganer-
17 ation. With these items, there is a cost diffarential of
18 $7 million between the Board’s engineers and those of Gannett,
19 Flaming, Corddry and Carpenter, Inc.
20 This $7 million difference is now being further
21 investigated by the staff of the Sewerage and Water Board,
22 since the estimates prepared by Gannett, Flaming, Corddry and
23 Carpenter, Inc. and the Sewerage and Water Board Engineers war
24 based on criteria and information coming from two dIfferent
25 sources.
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1 When this matter has been resolved, hopefully before
2 the and of the tIme allocated for receiving ir1forTt ation, any
additional information will bo furnished to the Environmental
‘ Protection Agency.
It is noted in the “Revised Economic Impact Analysis
6 of Proposed Regulations en Organic Contaminants in Drinking
Water” dated July 5, 1978, by Temple, Barker and Sloane, Inc.
8 that the figures now being used for capital cost in Naw Orlears
are now estimated by TBS to be within the range of $32 to $40
10 million, which, of course, does not compare with either the
11 $67.6 million estimate by the Board’s engineers or the $55.3
12 million estimate by Gannett, Fleming, Corddry and Carpenter,
13 Inc.
14 As properly point out in the above-cited report of
1• TBS in Appendix A, on page A—4, the Sewerage and Water Board
16 does not accept the technical assumptions as the best estimat
17 of desIgn and operating parameters which would be used if GAC
18 were actually installed in ew Orleans.
19 If, in fact, the Board is required to install
20 granular activated carbon filters, the design that will be
21 utilized will be the best design that will comply with the
22 regulations as wet forth in the February 9th standards astab-
23 lishad by EPA and which are presently being considered.
24 While the “supplemental notice of proposed ruleznaki g
25 and extension of public comment period”, recently distributed
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I by EPA, takes note of tha ncraased construction cost after
2 reevaluation of the original cost estimates, it is felt by the
3 Sewerage and Water Board of Now Orleans that these cost esti-
4 mates are still significantly lower on a national level than
5 those that have been more recently developed by TBS.
6 It is again called to EPA’s attention that the state
mants made on page 15, with reference to the systems that
s would be impacted by the c,AC requirement most probable is too
g low and thus the national cost will be substantially higher
i than the $616 million to $831 million now projected for the
11 national cost 4
12 This, of course, will change the effect on residen-
13 tial bills for average familias,and it must be remembered that
this cost impact will be made and have its greatest effect in
15 larger urban areas which can least afford to install and oper-
16 ate such facilities, andmore particularly, when the degree of
17 health improvement has not baa indicated or shown and the
18 adverse health affects and the possible adverse health affects
19 are lightly brushed off as “information available to EPA rang-
20 ing from the past literature to currant studies has not indica,
21 ad any substantial problems of these types from the use of GAC
22 in treatment of drinking water”.
23 Inasmuch as competent scientists have testified to
24 EPA on numerous occasions of the potential health hazards in
25 the use of ragneratad granular activated carbon, it would seen’
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1 to me unconscionable for EPA to proceed with the promulgation
2 of these regulations which would require the use of granular
3 activated carbon filters without at least having prepared and
4 submitted for public review an environmental impact statement
5 on the use of granular activated carbon filters.
The statemenst on page 29147 of this latest document
of July 6, 1978 -— Pedaral Register —- relative to “energy
8 impacts” leaves much to be desired. It is noted in this state
g ment that the BTU per pound of GAC regeneration is increased
10 by a factor of which is still different from that which was
used ifl the studies of Temple, Barker and Sloane, Inc., as
1 well as Gannett, Fleming, Corddry and Carpenter, Inc.
13 Relating this to 2900 barrels of oil daily appears
14 to be low when checked against the New Orleans estimates.
This also is another area in which the very least the EPA
16 should do is to provide an environmental impact statement on
17 the energy requirements needed for regr aration of granular
18 activated carbon, and in this context, consider not only the
19 minimum number of water plants which were considered in the
20 Temple, Barker and Sloane report, but at the same time consid 1 r
21 the potential plants that would be impacted by the regulations
22 and 1 more importantly, the impact should the level of THMS of
23 100 parts per billion be reduced to even a lower level. To d
24 less is not dealing honestly with the American public.
25 Rather than impose upon your tIme here today ccnc8r
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1 the effects on the City of New Orleans energy-wise, I am
2 attaching a statement that was submitted to the National DrirJ
ing Water Advisory Council in Dallas, Texas, on May 24, 1978.
I would certainly urge you to review this statement, because
it points out some of the difference in energy impact between
6 the most recent EPA statement on page 29147, and that which
7 is being developed in the real world where operators will be
8 responsible to carry out the EPA rules.
Let ma also take this opportunity to thank you for
10 allowing the sewerage and Water Board to make this preserlta-
11 tion to you here in Washington, D.C.
12 (The attached statement, submitted to the NatIonal
13 Drinking Water Advisory Council in Dallas, Texas, on May 24,
14 1978, fo1loc ,s:)
15
16
17
18
19
20
21
9 ’,
23
24
25
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STATEMENT BY
STUART H. BREHM, JR., EXECUTIVE DIRECTOR
SEWERAGE AND WATER BOARD OF NEW ORLEANS
TO
THE NATIONAL DRINKING WATER ADVISORY COUNCIL
AT
DALLAS, TEXAS, WEDNESDAY, MAY 24TH, 1978
HAVING READ THE ADVISORY COUNCIL’ S 1977 REPORT AND HAVING READ
SEVERAL OF THE “RANSCRIPTS OF THE COUNCIL’ S MEETINGS, I AN IMPRESSED
WITH THE GENERAL OBJECTIVITY THAT HAS BEEN INPLIED, AS WELL AS THE
COUNCIL’S APPRECIATION OF THE SERIOUS STEPS THAT MUST BE TAKEN IF THE
PROPOSED EPA STANDARDS OF FEBRUARY 9, 1978 ARE PROMULGATED.
I AN NOT TECHNICALLY QUALIFIED TO SPEAK TO THE HEALTH ASPECTS OR
HEALTH BENEFITS AND I’M EQUALLY UNQUALIFIED TO SPEAK TO THE SUCCESSFUL
OR TJNSUCCESSFtJL OPERATION OF GRANULAR ACTIVATED CARBON (CAC) AS A
MEDIA FOR THE ELIMINATION OR REDUCTION OF ORGANICS ON A CONTINUING BASIS
IF I HAVE ANY EXPERTISE TO SPEAK TO IT THAT OF CAPITAL EXPENDITURES>
WATER RATES, OPERATION AND MAINTENANCE COSTS, BONDS, AND LAST BUT NOT
LEAST THE IMPACT THAT THE PROPOSED REGULATIONS WILL HAVE ON TRE WATER
CONSUMER AND MORE PARTICULARLY ON THE POOR, THE NEEDY AND THOSE ON
FIXED INCOMES MOST OF WHOM GENERALLY LIVE IN OUR LARGE URBAN AREAS AND
WHO ARE THE LEAST ABLE TO AFFORD THIS ADDITIONAL COST THAT WOULD BE
IMPOSED ON THEM.
RATHER THAN IMPOSE ON YOUR TIME BY READING TO YOU THE STATEMENT
I PRESENTED TO EPA AT THE HEARING IN NEW ORLEANS ON MARCH 29TH, I AM
FURNISHING COPIES THAT YOU CAN REVIEW AS TIME PERMITS. I HAVE A
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CONCERN THAT HAS NOT BEEN EXPRESSED TOO STRONGLY AT ANY OP THE EPA
PUBLIC HEARINGS, BUT IT IS A VERY REAL CONCERN OF THOSE OF US WHO
MUST LIVE IN THE WORLD OF REALITY. -
IT IS ONE THING TO STAND BEFORE THE LOCAL GOVERNING AUTHORITY,
THE PUBLIC AND THE -PRESS AND ASK FOR RATE INCREASES WHEN EVERY
‘l
EXPENDITURE CAN BE FULLY EXPLAINED AND JUSTIFIED -
ITS A DIFFERENT STORY, HOWEVER TO CONVINCE THOSE WHO MUST APPROVE
THE RATES AND THOSE WHO MUST PAY THE BILL THAT THESE PROPOSED TREATMENT
STANDARDS NAY SAVE A LIFE,, THAT THE STANDARDS WILL REDUCE POTENTIALLY
HAZARDOUS CHEMICALS AND EPA CONSIDERS THIS GOOD LIFE INSURANCE BECAUSE
THE ADMINISTRATOR HAS SAID SO.
BASED ON THE NEW ORLEANS CAPITAL COST SET FORTH BY THE BOARD’S
GENERAL SUPERINTENDENT OF 89.9 MILLION DOLLARS WHICH IS AN ANNUAL COST
- OF 7.2 MILLION DOLLARS AND OPERATION AND MAINTENANCE COST OF APPROXI-
MATELY 9.1 MILLION DOLLARS, WHICH WILL BE INCURRED ANNUALLY, WATER RATES
MUST BE INCREASED TO PRODUCE AN ADDITIONAL 16.3 MILLION DOLLARS ANNUALLY
OR JUST ABOUT DOUBLE OUR CURRENT LEVEL OF COLLECTED WATER REVENUES.
THUS FOR ALL CATEGORIES OF CUSTOMERS OUR RATES MUST DOUBLE. STATED
DIFFERENTLY OUR AVERAGE RESIDENTIAL CUSTOMER (7,000 GALLONS PER MONTH)
WHO NOW PAYS $71.16 ANNUALLY WILL PAY $142.32 WHICH IS A FAR CRY FROM
THE $3 TO $6 ANNUAL COST SET FORTH BY EPA ON PAGE 5775 OF THE FEDERAL
REGISTER OF FEBRUARY 9TH, 1978.
TO INDICATE 1-lOW CONSERVATIVE THE FOREGOING FIGURES REALLY ARE LET
ME POINT OU THAT OUR CAPITALIZATION COSTS ARE BASED ON 25 Y R BONDS
AT 67, INTEREST.
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AT THIS POINT LET ME POSE 4 QUESTIONS. SINCE THERE HAS BEEN
NO LARGE SCALE GAC OPERATION FOR CONTROL OF ORGANICS ANYWHERE
DESPITE STATEMENTS TO THE CONTRARY WHAT WILL HAPPEN iF THIS
NATIONWIDE EXPERIMENT FAILS? WILL WE SCRAP THE IDEA? SWITCH TO
PERHAP S BAC? WHAT WILL WE DO?
LETS JUST TALK FOR A COUPLE OF MINUTES ON THE PRACTICAL ASPECTS
OF CARRYING OUT THE PROGRAM AS PROPOSED IN THE REGULATIONS. THE EPA,
AND SOME OF THE SUPPORTERS OF THE PROPOSED REGULATIONS, ASSUME THAT
WITH THE PROMULGATION OF THE REGULATIONS THAT THE MAIN PROBLEM HAS
BEEN SOLVED. NOTHING COULD BE FARTHER FROM THE WORLD OF REALITY.
ASSUME THAT WATER SUPPLIERS WOULD PROCEED TO ADJUST RATES TO PRODUCE
THE PROPER REVENUES. THEN, IF YOU ARE FAMILIAR WITH TillS PROCESS, THE
FUN REALLY BEGINS.
THE GENERAL PUBLIC MUST BE CONVINCED THAT WHAT IS TO BE BUILT IS
IN FACT GOOD, PROPER AND NEEDED WITH THE WATER INDUSTRY STILL UNCONVINCEE
THIS WILL BE MOST DIFFICULT. EVEN MORE DIFFICULT WILL BE CONVINCING THE
ELECTED OFFICIALS WHO WILL BE THINKING OF REELECTION.. BUT SO FAR, ALL
WE HAVE SPOKEN ABOUT ARE RATES FOR THE REVENUES. LETS TALK ABOUT THE
BOND ISSUES. UNLESS THE GENERAL PUBLIC HAS BEEN CONVINCED THE NEGATIVE
VOTE WILL OUTWEIGH THE POSITIVE VOTE. WILL EPA BY COURT ORDER, OVER-
RIDING ALL LAW, ORDER THE SALE OF BONDS? WILL ANYONE BUY THE BONDS?
WILL EPA COME UP WITH A LOAN AND GRANT PROGRAM TO OVERCOME THIS HURDLE?
CAN THE AMERICAN PUBLIC AFFORD TO PAY FOR ANOTHER P.L. 92-500?
AS A PRACTICAL MATTER AND AS A MANAGER OF AN ENERGY PRODUCING
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UTILITY, AS WELL AS A WATER UTILITY, A SEWAGE TREATMENT UTILITY AND A
STORM WATER DRAINAGE UTILITY, I AN VERY ENERGY CONSCIOUS.. OUR
CURRENT ENERGY COSTS WILL REACH $5,205,537 DOLLARS FOR 1978. BECAUSE
OF MY CONCERN FOR ENERGY CONSUMPTION, I HAVE TAKEN THE TROUBLE TO
COMPUTE SOME COMPARISONS OF ENERGY, AS RELATED TO REGENERATION AND
THAT SAME ENERGY AS RELATED TO SOME OF OUR EVERY DAY LIFE STYLE
ACTIVITIES.
BASED ON THE 87000 RTU PER POUND FOR REGENERATION AS CITED BY
EPA (AND INCIDENTLY WE WILL ONLY BE 7O7 EFFICIENT BURNING OIL DIRECTLY)
THE ENERGY REQUIREMENT FOR REGENERATION ALONE WILL AMOUNT TO 2 OF THE
TOTAL ELECTRICAL CUSTOMER LOAD FOR THE CITY OF NEW ORLEANS ON A DAILY
BASIS. STATED DIFFERENTLY OUR ANNUAL REGENERATION ENERGY REQUIREMENTS
WOULD PROVIDE SUFFICIENT ENERGY TO SATISFY THE ENTIRE ELECTRICAL LOAD
FOR THE CITY OF NEW ORLEANS FOR EIGHT DAYS.
IF THE ELECTRICAL COMPARISONS SEEM STARTLING, AND REMEMBER I AM
SPEAKING ONLY FOR NEW ORLEANS, LETS USE FUEL OIL. TO PRODUCE THE
ENERGY TO REGENERATE FROM FUEL OIL WILL REQUIRE 8,053,780 GALLONS OF
FUEL Olt ANNUALLY. THE CURRENT VEHICLE REGISTRATION FOR NEW ORLEANS
IS 224,000 AUTOMOBILE VEHICLES. ASSUMING AN AVERAGE OF 10 MILES PER
GALLON THIS MEANS THAT OUR ANNUAL FUEL CONSUMPTION WOULD DRIVE EACH
VEHICLE IN TEE CITY APPROXIMATELY 360 MILES.
WHEN THIS RATE OF ENERGY CONSUMPTION IS APPLIED NATIONALLY, I
WILL BET ARABS WILL BE QUITE HAPPY.
IN CLOSING LET ME SRABE WITH YOU SOMETHING I READ IN TIME
MAGAZINE SO iE 32 YEARS AGO WHEN I WAS JUST STARTING IN PUBLIC WORKS.
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IT SEEMS THAT A TIME MAGAZINE REPORTER ASKED PHILLIP OPPENHEIMER THE
NOTED NUCLEAR PHYSICIST WHAT DID THE PRINCETON INSTITUTE OF LEARNING
ACTUALLY DO? OPPENHEIMER, WHO WAS THE HEAD OF THE.INSTITUTE, REPLIED
BY SAYING THAT THE SCIENTISTS OF THE INSTITUTE EXPLAINED TO EACH OTHER
THOSE THINGS THAT THEY DIDN’T UNDERSTAND AFTER ATTENDING ALL OF THE
EPA PUBLIC REARINGS, EXCEPT DALLAS, TEXAS, AND AFTER READING EVERYTHING
I COULD FROM THE FIRST 1972 EPA REPORT ON INDUSTRIAL POLLUTION IN THE
LOWER NISSISSIFFI RIVER TO THE MOST RECENT NCI POSITION PAPAR, I NOW
FEEL FULLY QUALIFIED TO JOIN THE INSTITUTE AT PRINCETON.
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STATEMENT OF THE
UPPER TRINITY BASIN COMPACT
TO THE
ENV RONMENTAL PROTECTI ON AGENCY PUBLIC HEARING
CONCERNING
PROPOSED REGULATIONS CONCERNING CONTROL OF
ORGNIIC CHEMICAL CONTAMINANTS IN DRINKING WATER
JULY 11-12 1978
WASHINGTO D 1 C,
fC
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9/10/78
THANK YOU FOR THIS OPPORTUNITY TO PRESENT TESTIMONY AT THIS PUBLIC
HEARING CONCERNING THE PROPOSED SYNTHETIC ORGANICS REGULATION.
MY NAME IS I. N. RICE AND I AM SPEAKING ON BEHALF OF THE UPPER
TRINITY BASIN COMPACT. THIS IS AN ASSOCIATION OF THE FOUR MAJOR
WATER SUPPLIERS IN ‘NORTH CENTRAL TEXAS 1 THESE ARE THE CITIES OF
DALLAS AND FORT WORTH,, THE TRINITY RIVER AUTHORITY AND THE NORTH
TEXAS MUNICIPAL WATER DISTRICT. REPRESENTATIVES FROM EACH MEMBER
AGENCY ARE HERE WITH ME TODAY. COLLECTIVELY WE SERVE MORE THAN
2-1/2 MILLION CUSTOMERS, COMPRISING THE FIFTH LARGEST STANDARD
METROPOLITAN STATISTICAL AREA IN THE COUNTRY.. IT IS A WATER
SHORT AREA AND OUR CITIZENS ARE VERY MUCH WATER CONSCIOUS BOTH
AS TO QUANTITY AND QUALITY. OUR CITIZENS HAVE REPEATEDLY DEMONSTRATED
THEIR WILLINGNESS TO INVEST THE LARGE SUMS OF MONEY NECESSARY TO
PROVIDE ADEQUATE SUPPLIES OF CLEAN AND PALATABLE WATER. THEY DO,
HOWEVER, DEMAND AN ACCOUNTING OF THE STEWARDSHIP OF THOSE ENTRUSTED
TO OPERATE THE WATER SYSTEMS. THEY MUST BE CONVINCED THAT EXPENDITURES
ARE NECESSARY, THAT THEY ARE COST EFFECTIVE AND THAT THEY REPRESENT
THE BEST ALTERNATIVE.
OUR WATER SUPPLIES COME FROf1 NINE LARGE NAN—MADE LAKES IN THE UPPER
TRINITY BASIN AND ONE IN THE SABIME BASIN. ALTHOUGH WE THINK OUR
WATER SUPPLIES ARE INHERENTLY OF HIGH QUALITY, WE ARE FULLY
EXPOSED TO THE EFFECTS OF THE PROPOSED REGULATIONS, AND ARE BY NO
MEANS ASSURED OF BEING GRANTED A VARIANCE FROM THE TREATMENT
TECHNIQUES,
WE HAVE UNDERTAKEN TO REVIEW THE PROPOSED REGULATION IN AN EFFORT TO
ASSESS ITS IMPACT ON OUR WATER SYSTEMS. A PRELIMIMARY REPORT OF OUR
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FINDINGS IS SUBMITTED HEREWITH FOR THE RECORD. WE WILL PROVIDE A
FINAL COPY PRIOR TO THE CLOSING OF THE RECORD. MY STATBIENT TODAY
SUMMARIZES THE REPORT UNDER SEVEN GENERAL TOPIC HEADINGS.
UNPROVEN HEALTH RISK
THE DALLAS/FORT WORTH METROPLEX IS PROUD OF THE PUBLIC HEALTH RECORD
ASSOCIATED WITH OUR TREATED DRINKING WATER. COMPETENT AND ACTIVE
LOCAL, STATE, AND FEDERAL PUBLIC HEALTH PROFESSIONALS HAVE CONSTAI’ITLY
WORKED FOR THE BEST ATTAINABLE PUBLIC WATER SLIPPLIES, RECORDS HAVE
BEEN KEPT FOR DECADES WHICH REVEAL NO PUBLIC HEALTH DANGER ir OUR
DRINKING WATER.
WE MONITOR METALS, PESTICIDES, AND ORGANIC SUBSTANCES INCLUDING
TRIHALOMETHANES (THN’S), ANALYTICAL INSTRUME !I S CAN NOW FIND A
DETECTABLE AMOUNT OF ALMOST ANYTHING ANYWHER SOME OF THEM MAY BE
DANGEROUS AT SOME HIGH BUT AS YET UNDERTESMINED LEVEL. WE MONITOR
THEM THE BEST WE CAN AND ARE BUILDING UP A DATA BASE FROM WHICH
CONCLUSIONS CAll EVENTUALLY BE DRAWN, THE EPA, IN ITS, NATIONAL
ORGAI1ICS MONITORING SURVEY, MONITORED THM’S IN DALLAS AND FORT
WORTH SYSTEMS. THEY FOUND THM’S IN BOTH SYSTEM O BE UNDER
THE PROPOSED MAXIMUM CONTAMINANT LEVEL (1’ICL) OF 100 PPB THROUGH
VARIATIONS IN OUR OPERATIONS, AND THROUGH MONITORING AT DIFFERENT
POINTS IN OUR TREATMENT PROCESSES, WE FUID CONFIRMATION THAT THM
LEVELS IN OUR WATER ARE QUITE CONTROLLABLE BY OPERATION OF EXISTING
FACILITIES. WE ARE INTERESTED IN, AND WILL CO lTINUE SUCH MONITORING
AND OPERATIONAL STUDIES AND WILL BASE OUR OPERATIONS ON FACTS AND
EXPERIENCE. HOWEVER WE STRONGLY ADVOCATE TI’AT ADDITIONAL PESEARCH
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3.
BE CONDUCTED TO DETERMINE THE ACCEPTABLE LEVEL OF HEALTH RISKS
POSED BY TRIHALOMETHANES AT THE CONCENTRATIONS NORMALLY FOUND IN
DRINKING WATER, ALL OF LIFE IS SUBJECT TO RISK - AN ABSOLUTELY
NO—RISK SITUATION IS AN UTOPIAN CONCEPTS NOT A REAL-WORLD CONCEPT 1
WHAT WE ARE SEEKING IS TO CONTAIN RISKS WITHIN ACCEPTABLE LIMITS 1
WE DO NOT DEFER TO ANYONE IN OUR OBJECTIVE TO PROVIDE SAFE DRINKING
WATER TO OUR CUSTOMERS, NONE OF US WOULD DELIBERATELY RISK THE
LIVES OF OUR CUSTOMERS. WHAT WE ARE CONCERNED WITH HERE IS THE
AUTHENTICITY OF AN ALLEGED RISK, OUR PERCEPTION DIFFERS FROM THAT
OF THE FRAMERS OF THIS PROPOSED REGULATIO 1.
BURDEN OF PROOF
SINCE THE DALLAS/FORT WORTH ARE S WITHIN THE PROPOSED MCL FOR
THM’S, ORGANIC CHEMICALS BESIDES THM’S ARE WHAT THE PROPOSED REGU-
LATIONS WOULD HAVE US REMOVE WITH GAC. SINCE EPA HAS NOT SPECIFIED
WHAT CHEMICALS SHOULD E REMOVED WE DO NOT KNOW WHETHER OR NOT THEY
ARE PRESENT. YET THE BURDEN OF PROOF IS ON US TO CONVINCE THE EPA
THAT WE DO NOT NEED TO INSTALL GAC, WE ARE NOT CONVINCED THAT GAC IS
THE ONLY OR THE BEST METHODS IE ADDITIONAL TREAThENT IS PROVEN TO
BE NECESSARY. BUT HERE AGAIN THE BURDEN OF PROOF IS ON THE OPERATOR
TO SHOW THAT ANOTHER SYSTEM IS ADEQUATE. UNDER THESE CONDITIONS,
WE HAVE NO CHOICE BUT TO DISAGREE WITH THIS PART OF THE PROPOSED
REGULATIONS, (
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4
COSTS AND RELIABILITY OF GAC
COSTS
ONE SECTION OF OUR REPORT DEALS WITH COSTS AIID I COMMEND IT TO YOU
FOR STUDY, THE ENGINEER WHO PREPARED IT DID A FINE JOB. HOWEVER,
IN SUBMITTING IT HE POINTED OUT THAT HE DID SO WITH RESERVATIONS BECAUSE
THE INFORfi1ATION ON COSTS AND PERFORMANCE WHICH HE WOULD NORMALLY USE
TO MAKE A COST ESTIMATE DOES NOT EXIST 1 WHAT HE DID WAS USE AS MUCH
REAL INFORMATION DIRECTLY FROM INFORMED SOURCES AS POSSIBLE.
OUR FINDINGS ARE THAT GAC WOULD COST OUR AREA:
$275 ULLION ORIGINAL CAPITAL COST
$33 MILLION ANNUALLY AT CURRENT ENERGY C. RBO L A D
OTHER OPERATIONAL COSTS
$23.6 MILLION FOR THE INITIAL FILL ONLY OF GAG ALONE
22-28 /1OOO GAL. COMPARABLE TO THE TOTAL COST OF RAW
WATER TREATMENT AND DISTRIBUTION PRESENTLY, THUS
ALMOST DOUBLING WATER RATES, RESULTING IN ADDITIONAL
COSTS
OF
1O-18$ PER CAPITA PER YEARS OR
33-55s FOR AN AVERAGE HOUSEHOLD OF 3+ PERSONS EACH YEAR OR
$3 TO $5 ON A MONTHLY WATER BILL FOR OUR LOW USAGE
CUSTOr iERs
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NO FUTURE INFLATION HAS BEEN TAKEN INTO ACCOUNT. NOT ALL COSTS
WERE INCLUDED. FOR EXAMPLES LAND COST WAS EXCLUDED (AND SOME OF OUR
PLANTS DON’T HAVE UNDEVELOPED LAND ON OR ADJACENT TO THE PLANT SITE
WHICH COULD BE USED). AIR POLLUTION CONTROL COSTS FOR THE REGENERA-
TION FURNACES WOULD ALSO BE AN ADDITIONAL ITEM.
OUR COSTS WILL BE ABOUT 3 TIMES EPA’S LATEST ESTIMATE WHICH IS TWICE
THEIR ORIGINAL ESTIMATE. DECISION IIAKERS NEED TO HAVE THE BEST DATA
AVAILABLE. OBVIOUSLY COST IS A FACTOR IN DECISION MAKING, ELSE
THE PROPOSED REGULATIONS WOULD NOT DWELL. SO EXTENSIVELY ON COSTS.
WE HAVE ALREADY HEARD FROM MR. JORLING AT ATL4NTIC CITY THAT EPA HAS
DOUBLED ITS COST ESTIMATES FOR GAC. SUCH AN IMPORTANT DECISION AS
REQUIRING INSTALLATION OF AN EXPENSIVE TREAThENT SYSTEM REQUIRES
ACCURATE COST DATA,
RELIABILITY
AS I IIENTIONED , OUR ENGINEER FOUND THAT HISTORICAL COSTS AND PERFORMANCE
INFORMATION ON GAC DIDN’T EXIST, AND THE REASON IT DIDN’T EXIST WAS
BECAUSE SUFFICIENT INSTALLATIONS DON’T EXIST. WE KNOW OF ONLY A FEW
S 1ALL PLANTS AROUND THE COUNTRY THAT HAVE SOME GAC BUT THEY CANNOT
PROVIDE ADEQUATE OPERATING DATA. 1O ‘NEW PROCESS SHOULD BE REQUIRED
WITHOUT ADEQUATE KNOWLEDGE OF COST AND RELIABILITY.
OUR WATER SUPPLIES MAY SATURATE OR CLOG GAC MUCH FASTER THAN WE NOW
GUESS, THUS MAKING IT INEFFECTIVE WHEN STARTED UP AND MUCH MORE
EXPENSIVE WHEN CORRECTED. SOFTENING TREATMENT (WHICH SOME OF OUR
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6
SYSTEMS USE) MAY RENDER GAC INEFFECTIVE; BIOLOGICAL GROWTH, WHICH
IS A PROBLEII IN OUR PRESENT PLANTS, MAY REDUCE GAC EFFECT! VENESS
POLYMER TREATMENT MAY RENDER GAC INEFFECTIVE. THERE ARE MANY
OTHER PRESENTLY UNEVALUATED POTENTIAL PROBLEMS.
WHAT WE NEED IS SOLID PERFORMANCE INFORMATION. 1 FROM ACTUAL OPERATIONS
ON A SIGNIFICANT SCALE.
ALTERNATIVES
THERE ARE ALTERf IATIVES IN THE FORM OF DIFFERENT OPERATIONAL ADJUSTMENT
OF PRESENT FACILITIES, RELOCATION OF CHLORINE APPLICATION, USE OF
DIFFERENT DISINFECTANTS, USE OF HOME PURIFIERS OF SUFFICIENT SIZE AND
EFFECTIVENESS, AND BOTTLED WATER TO NAME A FEW.
BUT WE KNOW ONLY AS MUCH ABOUT SOME OF THESE ALTERNATIVES AS WE DO
ABOUT GAC, A ID THAT ISN’T ENOUGH. ALL SHOULD BE THE SUBJECT OF RESEARCH,
DEVELOPMENT, AND, AT THE CHOICE AND IN THE JUDGMENT O.F THE RESPONSIBLE
STATE AND LOCAL AUTHORITY, APPLICATION,
HOWEVER, ONE ALTERNATIVE DISINFECTANT WHICH GREATLY REDUCES THM FOR-
MATION HAS A LONG AND WELL-DOCUMENTED HISTORY AS AN EFFECTIVE PRIMARY
DISINFECTANT--THAT IS, CHLORAMINES. WE STRONGLY URGE THAT THE EPA NOT
EXCLUDE CHLORAMIUES FROM CONSIDERATION, FOR GIVEN ADEQUATE CONTACT
TIME, AND WE HAVE THIS IN OUR LARGE PLANTS, CHLORAMINES ARE VERY
EFFECTIVE. OF COURSE, ENSURING THAT PROPER CONTACT TIME IS AFFORDED
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REQUIRES PROPER OPERATIONAL CONTROL OF THE TREATMENT PLANT--BUT SO
DO ALL THE OTHER PROCESSES INVOLVED IN TREATMENT.
CHANGING OBJECTIVES
THIS PHRASE SYMBOLIZE 1HAT WATER TREATMENT PLANT OPERATORS FACE WITH
THE PROSPECT OF CHANGING STANDARDS. THE PROPOSED REGULATIONS WILL
SET AU INITIAL MCL ON ThM’S OF 100 PPB, BUT GOES ON TO SAY, AND I
QUOTE:
“AS ADDITIONAL OPERATING AND TECHNICAL EXPERIENCE IS
GAINED WITH RESPECT TO THE USE OF ALTERNATIVE DISIMFECTANTS
NID THE USE OF GAC 111 THE TREATMENT OF DRINKING WATER, THE
SCOPE OF THESE REGULATIONS WILL BE EXPANDED TO INCLUDE SMALLER
CO NUNITY WATER SYSTEMS. IN ACCORDANCE WITH THE REQUIRE—
MENTS OF THE SDWA, REVISED PRIMARY DRINKING WATER REGU-
LATIONS WILL BE FORTHCOMING WHICH WILL IMPOSE ADDITIONAL
MCL ’S ON ORGANIC CHE11ICAL WELL AS. REQUI RE FURTHER
REDUCTIONS IN THE LEVELS OF THM AS ADDITIONALTOXICOLOGI-
CAL, TECHNOLOGICAL AND ANALYTICAL INFORMATION BECOMES
AVAILABLE.”
HOW CAN A MUNICIPALITY SPEND MILLIONS OF DOLLARS TO DESIGN AND
CONSTRUCT TREATMENT FACILITIES WHICH MAY WELL BE OBSOLETE BEFORE THEY
ARE COMPLETED? IF NO ONE KNOWS WHAT CONSTITUTES AN ACCEPTABLE LEVEL
OF TILM’ S, THEN NO TREATMENT STANDARD SHOULD BE ESTABLISHED AT THIS
TIME. UNTIL RESEARCH IS COMPLETED TO DETERMINE IF A THRESHOLD LEVEL
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EXISTS FOR THM’S, ALL FEDERAL GUIDANCE SHOULD BE EXPRESSED AS
GUIDELINES, OR GOALS) RATHER THAN MANDATED MCL’S .
STATUTORY PREREQUISITES
THE SAFE DRINKING WATER ACT, IN SECTION 1412 (E) (2) (E) SPECIFICALLY
REQUIRES THE ADMI 4ISTRATOR OF EPA TO ARRANGE FOR THE NATIONAL ACADEMY
OF SCIENCES TO PREPARE A REPORT WHICH WOULD CONTAIN A NUMBER OF SPECIFIC
THINGS AMONG THEM, “A LIST OF CONTAMINANTS THE LEVEL OF WHICH IN
DRINKING WATER CA OT BE DETERMINED BUT WHICH MAY HAVE AN ADVERSE EFFECT
ON THE HEALTH OF PERSONS.” SECTION 1412 (s) (1) (A) (II) IN TURN
REQUIRES THE AflfiI ilSTRATOR TO REPRINT THAT LIST IN THE FEDERAL REGISTER.
SECTIO!1 1412 (B) (1) (B) REQUIRES THE REPRINTING OF THE LIST IN RULE
FORM,
THESE REQUIREMENTS IN THE LAW ARE NOT DISCRETIONARY. THEY ARE EACH
IN THE LANGUAGE OF “THE ADMINISTRATOR SHALL,..” THEY ARE MANDATORY.
WE HAVE EXAMINED THE NATIONAL ACADEMY OF SCIENCES REPORT DRINKING WATER
AND HEALTHS WHICH WAS PREPARED PURSUANT TO SECTION 141.2 (E), AND COULD
NOT FIND THE LIST REQUIRED THEREIN BY THE LAW. WE ALSO SEARCHED THE
FEDERAL REGISTER MID OTHER EPA BACKUP DOCUMENTS REGARDING THESE
REGULATIONS AND COULD NOT FIND THE REQUIRED LISTS 1 WE INQUIRED OF
MR. COTRUVO, DIRECTOR OF THE EPA CRITERIA AND STANDARDS DIVISION,
OFFICE OF DRINKING WATER, BY LETTER ON JUNE 12 WHERE THE RE( UIRED
LISTS OF CONTAMINANTS COULD BE LOCATED. BY RETURN LETTER OF JUNE 2L
HE ACKNOWLEDGED, “THE NATIONAL ACADEMY CF SCIENCES DID NOT PREPARE
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EITHER LISTS OF CONTAMINANTS OR RECOMMENDED MAXINtJfI CONTAMINANT LEVELS,
AS DIRECTED BY SECTION 1412 (E) (2) OF THE SAFE DRINKING WATER ACT.”
THESE LISTS ARE NOT. IRRELEVANT.TECHNICALITIES, TO THE CONTRARY, THEY
ARE LOGICALLY AND SCIENTIFICALLY, AS WELL AS LEGALLY, VITAL AND
NECESSARY TO THE PROPOSED REGULATION OF SYNTHETIC ORGANIC CHEMICALS
I QUESTION AT THIS HEARING. THESE LISTS WOULD CONTAIN. THE CONTAMINANTS
WHICH YOUR REGULATIONS WOULD HAVE US REMOVE. WITHOUT THE LIST, WE
HAVE NO PRACTICAL, NOT TO MENTION LEGAL, GOAL
RECOMMENDATIONS
1, HOLD THE PROPOSED REGULATIONS IN ABEYANCE UNTIL THE IECESSARY
RESEARCH IS CONPLETED AND REVISE AS NECESSARY.
2, VIGOROUSLY SUPPORT, AND STUDY THE RESULTS OF, MONITORING AND
TREATMENT TECHNOLOGY DEVELOPMENT, INCLUDING GAC.
3, EPA WORK WITH THE WATER SUPPLY INDUSTRY IN THE DEVELOPMENT OF ANY
FUTURE REGULATIONS,
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MS. CHANG: Thank you vary much.
2 Are there any questions from the panel?
3 MR. XIMM: I am trying to put this in context. Rav 4 s--
4 ing our estimates, we finally got through trying to take New
5 Orlean as a case point, comparable assumptions. You had scm
6 thing like 67 million. Dr. Fleming caine in around 55 --
7 MR. BREHM: Using the same criteria?
8 MR. KIMM: Yes, andthe application of.u ing.the
9 Temple, Barker and Sloan numbers, would indicate something
10 in the neighborhood of 42, 45, something in that area. A
ii large proportion of that difference has to do with the assurnp
12 tion on construction used for-.the. filter, concrete units -—
13 MR. BREHM: I would say that is an accurage statame t,
14 Yes.
15 MR. 1 <1MM: I believe that the Gannett, Fleming --
16 that is where much of that diffaranca comes in. More import—
ant is the notion of trying to say to the public that these
18 difference in cost seam very large. In actuality, in view of
19 the fact that we are talking about technology that has not
20 been put in place yet, it is not like pricing some hardware
21 device that exists, and there is room for differences.
22 I believe that those who do work their way through
93 our revised economic backqround document, I think there is
24 a fairly clear statement of how large the cost increases are,
25 the differences in flow assumptions, in generation capacity
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i with furnaces and a number of other items picked up in these
2 estimates.
3 Would you care to comment on how significant the
4 remaining differences are?
5 MR. BREUM: Let me sea if I can state your question
6 in the language that I understand. What you are asking me to
7 comment is, first of all, do I think that the estimates, as
8 they currently stand, with Temple, Barker and Sloane, nation-
ally, are good estimates?
10 MR. KIM 4: EPA estimates, right.
11 MR. BREHM: The other part of its is that, what
12 differential would there be, if they are not; and, thirdly,
13 how significant would that be? I think those are the three
14 questions you are asking, all in one.
‘5 Let me answer that by stating this: I think your
16 source of information is not in accordance with what a cornpa—
tant and respected engineer would use in the design of a
plant like that if ha was employed to do it. Ha is going to
19 design a plant that will Meet your requirements, of EPA, unda
20 these regulations at all time, not 50 percent of the time,
21 not 20 percent of the time, because your regulations don’t
22 allow it to be different.
23 You write that into regulations, and then we can
24 start talking about how adequate we can make these construc-
25 tion costs, on a temporary basis, on whether it be 60 million
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1 gallons a day, 100 billion gallons a day. -—. choose any number
you wish, but you have to deliver 100 percent of the time,
3 and that is the way the plant would b designed.
4 Wa made it perfectly clear when we spoke with
5 Mr. Glauthier on this in New Orleans. That is the way the
6 plant in New Orleans willbadesigned. We will not design
7 something that we have to come back later on and add sornethinç
S toit.
9 It will be designed one time, built one time, and
10 last for the lifetime of the bonds that will be issued. I
11 think that answers your question. Therefore, when you start
12 talking about the number of plants -- I notice the number of
13 plants has bean reduced in the latest -estimate from the
14 original number of plants considered under the original 319
15 to 519 million, or whatever the numbers are.
16 But you have reduced the number of impacted plants,
17 and that is one thing. Also, no consideration has bean given
18 in these regulations for the reduction of trihalomethanas.
19 You indicated this conceivably could go down to 10 parts per
20 billion. Again, are we going to come back to the general pub-
21 lic and say, “We made a mistake, so we will add on to the sys
22 tern, and now will put in more filters or different filters,
23 and hit you up for another $50 million.”
24 Whan we design it, it will be a design to take care
25 of the New Orlaar.s problem and take care of the EPA raquireme
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1 as they are written.
2 DR. KIJZMACK: I appreciate the comment that the ragu
3 lations should be clear, whether these are average or all-the-
4 t .rna recruiraxnents, and so forth. I would like to clarify a
5 couple o pointsLin the statement. You mentioned that ongoing
6 work is being done with your estimates, and, again, at Flaming’s
7 and so forth, for these differences.
8 Are you also going to look at some of the suggestion
9 made by Gannett, Flaming in terms of other alternatives that
10 should also be considered that might reduce the actual cost to
11 the consumer?
12 MR. BREHM: I don’t Gannett, Flaming made any altar-
13 nate suggestions along those lines.
14 DR. KTJZMACK: Pages 4 and 5.of their report.
15 MR. BREflM: I don’t have it in front of me, and I
16 only got it yesterday or the day before, so I am not in a
17 pOsitiOfl to make a comment.. at this time. Let’ s put it this
18 way. If there are any constructive statements or racommenda-
19 tions made, they would certainly be taken into consideration.
20 DR. KUZ ACX: You mentioned on page 5 of the state-
21 ment that the cost increases are significantly lower than
22 those recently developed by TBS. Then, on the next page, you
23 make a similar statement concerning the energy consumption as
24 being different from the new figures used by TBS.
25 What are you referring to in this instance?
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MR. BREHM: I am referring to -- I think Mr. Glauth r
2 can help ma on this, but I think he used a figure of around
3 7,000 B Us par pound for your estimation of regeneration; is
4 that correct?
5 , MR. GLAUTHIER: No, it is 5,000 now. The aar1i r
6 estimates were 3,750.
7 MR BREHM: It is 5 now, and it must have bean
8 Gannett, Fleming that used 7,000. Yes, it was them; I though
9 it was you. I am mistaken; it was not TBS, it was Gannett,
10 Flaming who used 7,000.
11 What I am trying to say here, to the EPA, is that
12 if we keep playing a numbers game, someone is going to get
13 hurt. We all ought to start using the same numbers. For
14 example, we checked out with our own local utility people to
15 find out what effectiveness we would get out of the use of
16 fuel, and we find out that there will be only 70 percent
17 raduction of the BTU requirement - - will be used through fuel
18 oil.
19 Therefore, you automatically have to multiply your
20 ETU load by 130 percent to -- in order to bring up the number
21 of BTU you will be using daily.
22 MR. GLAUTHIER: On the point of BTUs, the Gannett,
23 Flaming estimates did not look at operating costs, and I don’t
24 believe made any assumption, really.
25 MR. !3REHN: I th ik it was taken into consideration
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1 in the sizing of the furnaces.
2 MR. GLAUTHIER: Would you agree the discussions we
3 had in New Orleans identified the fact that there are altgrna-
4 tiva designs that could be implemented, and that there are
5 decisions to be made during the whole engineering design of a
6 GAC installation?
7 MR. BR HM: I would daf nitaly agree with you there
8 would be decisions made after the pilot plant was run and the
9 design was finally solidified, yes.
10 MR. GLAUTHIER: The two major differences in cost,
ii among the various astimatas we have discussed, have to do with
12 tha design of the contact rs, whether they would be filter-
13 type contactors or contactor vessels, on one hand, and sizing
14 the volume of water treated at that level.
15 MR. BREUM: I think you will find that will be the
16 predom&nant essential, the size of the filters to accommodate
17 the capacity of the plant.
18 MR. GLAUTHIER: On the capital costs, to clarify the
19 assumption used for purposes of cost comparison, assumed that
20 the total hydraulic capacity of tha plant could be processed
21 through the contactors and there would be no bottleneck set
22 up in the plant, but that the amount of carbon placed in those
23 contactors would be sized to yield the desirable contact time
24 target time, at the flow, during the peak month -- the daily
25 fl ,w, during the peak month the year, rather than at the
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I design capacity flow; is that correct?
2 MR. REflM If you mean that that was cn of the
3 criteria used for the purposes of making the cost comparison,
4 the critaria was the average day of the peak month, if that
5 is what ou mean, yes.
6 MR. GLAUTHIER: So the numbers most comparable,
7 compared for that reason —-
8 MR. BREHM: If my memory serves ma right on filter
9 size and filter costs, we almost hit it on the nose.
10 MR. GLAUTHIER: .Ies, we did, for that purpose; it
11 came out very much the same • That was assuming an 18-minute
12 contact time in the peak month, which, over the year, was just
13 over 20 minutes on average. Had it been sized to design capa
14 ity, it would be something like 35 minutes, on average.
15 One other question, would you supply to EPA the
16 details on the operating and maintenance costs? You mentioned
17 the cost estimates to customers, and yet, we had not received
18 any breakdown -
19 MR. BREHM: We plugged the figure in. It is a roun
20 figure, and I would like to finish the details of it, getting
21 down to labor, regeneration costs, energy’ costs, and so fort
22 We used a figure of $25,000 par day for the O&M additional,
23 $25,000 day,, I will furnish that. when I finish the infor-
24 mation relative to the furnaces.
25 MR. GLAtJTHIER: Was that $25,000 a day on tha actua
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1 amount of water put through the plant avery day of the year?
2 MR. BREHM: Yes, that is based on an annual water
3 pumpage.
4 MR. GLAIJTHIER: Thank you.
5 MR. BREHM: Do you have any other questions?
6 I want to say one thing, in closing. I was not hera
7 this morning, and I was not here to listen to where the state-
g mant was made where I was called the “guru” of the water indus
9 try. I will respond to that, and I will sat the record
10 straight with EPA.
11 I just happened to read through the article -- I
12 did not study it closely, but there were quite a few -- I
13 think it was made by Mr. Nader.
14 MR. KIMM: He did not read the statement.
15 MR. BREHM: It is in the record, and that is why
16 I responded to it. It is in the record in its entirety, and
17 was submitted as such; and I assume it will go into the
18 record.
19 MR. XI iM: Yes.
20 MR. BREHM: I would like to correct some of the
21 statements made in there. They are completely erroneous, and
22 just show that Mr. Nader is not safe at any speed.
23 (Laughter)
and t3B 24 MS • CHANG: Thank you.
s t4A 25 Is Robert McGarry hare? We are planning on followir
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the schedule, even though we are behind.
2 STATEMENT OF ROBERT S. McGARRY, GENERAL MANAGER,
WASHINGTON SUBURBAN SANITARY COMMISSION,
PRINCE GEORGE’S AND MONTGOMERY COUNTIES, MARYLAND
5 . MR. McGARR?: I am Robert McGarry, General Manager
6 of the Washington Suburban Sanitary Commission, and I thank
7 you for the opportunity to present our views.
8 The Washington Suburban Sanitary Commission, or WSSC,
9 is a water and sawer agency serving Prince George’s and Mont—
10 gornery Counties, the Maryland suburbs of Washington. We pro-
11 vida water for the 1.2 million residents of these two counties.
12 We draw our water from the Potomac and Patuxant Rivers in
13 Maryland and have traatmtant plants in both rivers.
14 The Washington Suburban Sanitray Commission -- WSSC
15 -— strongly endorses the proposed regulations that we are die-
16 cussing today. we feel that EPA has taken a bold step forwar
17 in protecting health and welfare of the citizens of the Unite
18 States.
19 We agree with EPA that synthetic organic chemicals
20 and trihalomethanes are a health risk, and, furthermore, we
21 agree that the regulations as proposed are a practical solu-
22 tion for this problem.
23 WSsC has been concerned about both matters for a
24 number of years • In regard to trihalomethanes, we have bean
25 studying and collecting data on trihalcmathanas and altarnati a
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I methods of operating our two water plants for about two years.
2 We have found that by changing the point of chlorination, and
3 other operating changes, we can insure that the trihalornathana
4 content is less than EPA’S proposed 100 parts par billion.
5 In fact, we were about tc establish thIs criteria -—
6 100 ppb -— for ourselves and initiate it as a local policy at
7 the time the regulations were published in draft form. Since
8 the regulations have been published, WSSC has established the
9 EPA criteria for trthalomathanas as a standard that we will
10 meat.
11 Wa will manage our supply andtraatinent process to
12 insure that we do meet the standard and if we fail to meet it
13 we will take the same action -- to include advising the public
14 -— that we would take if we violated any of the other standard
15 established under the Clean Water Act.
16 With regard to synthetic organics and the use of
17 granulated activated charcoal to control them, we are not as
18 far along as I would like to be. However, we intend to catch
19 .zp quickly. Our Commissioners and the County governments who
20 review our budget have strongly supported research funds in
21 our current fiscal year budget to develop the necessary angin-
22 earing and background data for the design of GAC facilit as
23 and/or a request for variance.
24 At the prasent time, we do not have sufficient data
25 on the synthetic organic problems in our raw water supplies to
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1 make a decision on the variance or the installation of GAC.
2 However, we ars on an accelerated schadule to gather that date
3 and will move promptly to f na1 decision depending en what we
4 learn from our research this sun mer.
5 .• I recognize that our position is different than that
6 of many other large water supply utilities and the AS’ WA.
7 However, there are several indications that our “public” is in
8 agreement with our position. A few indications of our “public
9 attitude follow.
10 Last summer was a series of water crises for the
11 Washington Metropolitan Region. WSSC had an outage that
12 almost crippled the bi-county area. Fairfax County’s Occoquan
13 Reservoir was dangerously low. While we ware having water
14 supply problems, droughts in California and the west ware
is highlIghted by the local media.
16 Last summer the public was very aware of the water
17 quantity problems facing our regions and vary aware of the im-
18 pact of a drought. Yet, when the Corps of ,.Enginears made a
19 survey of the public concerns as part of their cn-going
20 Washington Metropolitan Water Supply Study, 60 percent of
21 those responding in the Washington MetropolItan area felt that
22 water quality was their highest concern and whareas only 40
23 percent felt that water supply quantity was a primary concern
24 -— this attitude despite the crisis situation and the wide
25 publicity given to droughts, pending , and the
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i periodic shortages that many metro residents experienced last
2 sui mer.
3 Furthermore, 77 percent of the public responded that
they would be willing to pay increased water bills to insure
water upply of high quality and to reduce health risks, where
6 as only 14 percent said they would not be willing to pay more
for high quality and 9 percent had no comment.
s Another indication of our region’s concern for water
9 quality is the fact that both County Councils we serve asked
10 WSSC to provide them information and plans to address the
ii problems of trihalouiethanes and synthetic organics prior to
12 th EPA regulations.
13 Our governing bodies are concerned about these prob-
14 l9ms and despite their many other concerns had already started
15 us addressing these problems. A final last indication is my
16 mail. The General Manager of a utility does not receive much
17 fan mail these days. However, every latter I have received
18 since announcing WSSC’s strong support of these regulations
has been favorable, not just slightly favorable, but vary
20 favorable.
21 In conclusion, wssc agrees that there is a risk.
22 WSSC feels that the EPA proposed regulations adequately addresis
23 this risk. We feel that our public is very concerned by the
24 risk; we feel our public wants us to do somath ng -- whether
25 there are EPA regulations or not -- and we are very confidant
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1 our public is willing to pay what is necessary to provide the
2 safest possible driflking water.
We intend to move forward as rapidly as possible
4 and fins the proposed EPA regulations a strong support for Cu
5 objectives and strongly urge their adoption.
6 (Applause)
7 MS. CHANG: Thank you vary much.
8 MR. KIMN: The first thing I would like to do is
9 arrange to trade in-boxes with you. My mail has not been so
10 unanimous. I wonder if you would -— obviously, we have a
11 large problem ahead of us and a large undertaking, in terms
12 of modifications, techniques, analytical capability at the
13 utility level or state level, or a region basis.
14 Do you have any sense on the time f rains we have
15 originally proposed? Do you thing that looks reasonable, or
16 do you think some of that needs to be changed?
17 MR. McGARRY The, I believe the time frame laid
18 out would be very difficult to achieve, if you don’t get a
19 running start, such as we have. We have felt a need to move
20 in this direction and are almost assuming that the rsgulation
21 ara final this summer and not losing this time.
22 I did not comment on that, because I know you have
23 received other comments on it; the work that Malccim Parney
24 submitted is an indication of the difficulties in meeting the
25 time schedule. But I do believe that the time schedule should
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1 be one that stresses a sense of urgency, rather than a long
2 drawn—out affair.
3 DR. KtJZMACI : In the discussion on the data on pub-
lic opinion, in talking about willingness to pay, was there
5 actual mention of dollar figures in questions people were
6 asked?
7 MR. McGARRY: No. This, of course, was prior to
8 your regulations, and was trying to sense the metropolitan
water area’s concern. The question was, Would you be willing
10 to pay a higher water bill for higher quality water?. And 77
11 percent said, “Yes.”
12 DR. COTRUVO: Did that survey extend beyond the
WSSC jurisdiction?
14 MR. McGARRY: It was the Washington Metropolitan
15 Region, quite extensive. The Corps of Engineers can provide
16 you the data. The sent out some 23,000 and 12 percent
17 response, which .wasquite high.
18 MS. CIiANG: Are there any other additional questions
Thank you very much, Mr. McGarry.
20 MR. McGARRY: Thank you.
21 MS. CHANG: Is Nancy Maloley, hare, representing
22 Senator Lugar from Indiana?
23
24
25
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I STATE’IENT OP NANCY MM OLEY, REPRESENTING
2 THE HONOPABLE RICHARD A. LUGAR, A UNITED STATES
3 SENATOR FROM THE STATE OF INDIANA
4 MS. MALOLEY: I am here presenting this statement on
5 behalf of Sanator Richard Lugar of Indiana.
6 “Tha k your for this opportunity to participate in
7 EPA’s rulemaking involving organic chem±cals in drinking
8 water. At the outset, I commend the Agency for responding
9 to the concern expressed by Congress in the Safe Drinking
10 Water Act for maintaining the quality of our nation’s drinking
11 water.
12 “I commend, also, our nation’s water utility indus-
13 try for providing our people with what is generally knwcn
14 throughout the world as extremely high quality public drinking
15 water, It is withint this context of mutually concerned and
16 highly professional individuals, organizations, and agencies
17 that I address you.
.18 “Cancer is a subject very much onour minds. We
19 should not relax our daterTninatior to discover its causes and
20 to deal with them. We must not fail to take appropriate actio
2i when available evidence indicates that a real cancer risk
22 exists.
23 “With respect to EPA’s proposed organics regulation,
24 however, I have substantial doubt that there is sufficient
25 basis for concluding that such a risk exists in drinking
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1 water. I have an even greater doubt that what EPA is propos-
2 ing as a remedy here is realistic in a cost-benefit s nsa.
“The proposed regulation has two principal features
‘ which I want to address. The first sets a maximum contaminant
level -— •.MCL -— for chloroform and other trihalomethanas in
6 drinking water of 100 parts per billion.
7 “The second prescribes a treatment technique using
8 granular activated carbon -- GAC - - for the removal from water
9 of trace amounts of synthetic organic chemicals.
10 “I am informed that while more is known about
11 chloroform than most other synthetic organic chemicals found
12 in .drinking water, there is signifIcant conflict within the
13 scientific community as to whether chloroform at the levels
14 found:actually constitutes any risk to humans.
15 “I am told, for example, that the National Cancer
16 Institute has performed two studies on rats and mice using
17 extremely high doses of chloroform, and by an extremely con-
18 servativa extrapolation down to levels found in some drinking
19 water has concluded there is a possibility of a risk to
20 humans.
21 ‘ I am also aware, however, that NCI personnel havá
22 written that certain epidemiological studies purporting to
23 link drinking water in New Orleans with cancer are more akin
24 to ‘astrology than sound statistical reasoning’.
25 “I am aware, further, that chloroform studies by
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I D • Francis 3. C. Roe of England involving lower doses of
2 chloroform administered to dogs, mice and rats, producad no
3 tumor response in the animal. Thus, Dr. Roe concludes that
4 safe levels of chloroform are apparently at variance with the
5 two studies at the NCI.
6 “I am also told that a recant study done at the
7 Medical Collage of Virginia has cast substantial doubt on the
8 validity of the conclusions based on the Nd studies.
9 “However, I am not hare to mediate such conflicts
10 within the scientific community. I am more concerned with
11 addressing what could be a health problem, but in a sensible
12 and realistic manner. I am not qualified to judge whether a
13 100-parts-per-billion MCL is set at a correct lava], for tn-
14 ha1orn thanes in dnink ng water.
15 “It does appear, however, than any MCL should at
16 least await the development of a consensus within the scian-
i tific ccrnmunity, based on sound data and sufficient research,
18 as to what any such level should be. Moreover, we must be
19 very careful than any MCL which mat be adopted does not impose
20 a financial burden on our water consumers disproportionate to
21 the perceived risk.
22 “Moving to the second part of the proposed regula—
23 tion involving GAC, I have serious corLcarn It appears tc ma
24 that a very costly remedy is being prescribed for an axtrama1
25 small benefit, if any.
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“As I understand the explanation in the Federal
2 R gistar, the development of sophisticated measuring devices
3 only within the last few years has enable us to detect trace
4 amount of organic chemicals in water supply systems which have
5 given ±ise to this regulation.
6 “EPA states that the mere presence in any amount of
7 synthetics in drinking water, ‘both those we can currently
S measure and those which may be identified in the future’, pose
a potential risk to human health. Based on this preposition,
10 the Agency prescribes a treatment technique for all organics,
ii using granular activatsd carbon, because ‘it would not be
12 technologically or economically feasible to monitor for the
13 presence of all the synthetic organic chemicals in drinking
14 water which may have an adverse effect on human health.’
15 “All things being equal, I would not object to irnpl
16 xnenting a protective philosophy to deal with all problems -—
17 both known and unkown -— even if the problems ware as tenuous
18 as this one seems to be. However, all things are not equal
19 hers,
20 “This treatment technique is going to cost consumer
21 millions of dollars locally, and billions of dollars, nationa
22 ly. That being the case, I believe that a responsible, fisca
23 perspective on this regulation is needed. As a former mayor
24 of a large city -— and now as a member of the Senate Banking
25 Corranittaa’s Subcommittee on Housing and Urban Affairs, I will
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1 try to introduce that perspective.
2 “While a zealous pursuit, regardlass of cost, of the
3 goals of the Safe Drinking Water Act might be feasible in a
4 vacuum, one must recognize that the quality of drinking water
5 is but on of a myriad of concerns for the people of this
6 country,
7 “Crime in the streets, urban decay, adequate health
g sarv ces, refuse removal, mass transportation, and schools.
9 are but a few of the major items on the agenda of cities, All
10 of these problems cry for solutions and for the money to
11 finance these solutions.
12 “As we have bean reminded recently, there are limit
13 to how much taxation citizens will tolerate. I believe that
14 it is incumbent upon us all to try to establish priorities
15 among the problems demanding our attention arid resources, and
16 to approach each problem with a view to accomplishing the
17 feasible, instead of mandating one’s concept of the ideal.
.18 “I suppose that in the ‘best of all worldst there
19 are a number of changes which we might seek. But in the
20 present world, we must legislate and regulate with common
21 sense and limited resources, It is for that reason, I ba1iev
22 that the Safe Drinking Water Act requires that EPA take costs
23 into account when it promulgates regulations under the Act.
24 “In considering costs, EPA is called upon to recon-
25 cii idaal solutions with achievable goals.
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I “in terms of priorities, id does sa m to me that the
2 alleged potential danger from all synthetic organics that may
3 appear in drinking water, even at trace levels, is highly
4 speculative. The proposed remedy is prohibitive. The Nation-
5 al Cancer Instituta.staff study conveyed to EPA by Dr. Upton
6 concludes that ‘measures taken to control large classes of
7 contaminants are likely to be useful in reducing lev ls of
8 material whose carcinogenic or mutagenic potential is still
9 unknown.’
10 “However, Dr. Upton makes it clear that NCI did not
11 study -- and takes no position on -- the EPA’s proposed method
12 for effecting the reduction. This omission is highly signifi—
13 cant in view of the enormous cost of implementing GAC filtra-
14 tion facilities to combat the potentials of such materials in
15 drinking water, potentials which Dr. Upton conceded to be
16 unknown.
17 “I do not presume to speak authoritatively on the
18 disparity between EPA’s cost estimates and the much higher
19 estimates of the water industry. I understand, however, that
20 EPA recently doubled its estimates. I have seen the cost
21 analysis prepared for Indianapolis in my home state of Indiana
22 and have no reason to challenge the $45 million price tag whic
23 the engineering consultants have calculated will accc pany the
24 regulation for that city.
25 “I am also aware of even higher cost estimates for
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1 neighboring cities —- e.g., $81 million for Louisville, Ken-
2 tucky. I am informed that when the GAC treatment is in place,
3 it will generate addit ona1 pollution in air and water which
will have to be controlled, at a high cost, assuming that the
5 elm n tad chemicals in the waste water can be disposed of at
6 any cost.
7 “The cost of city services which use water will
8 escalate as rates rise. These are financial burdens which
public officials should not impose on any city -- certainly
10 in today’s troubled urban fiscal climate -- except in the
most compelling circumstances.
12 “In my judgment, those circumstances have not been
13 demonstrated by EPA.
14 “Let ins suggest an alternative. It is apparent that
15 the GAC treatment is being suggested to deal not only with
16 risks now perceived by EPA, but also with risks which EPA
‘7 believes may exist, but are not yet identified. Under the
18 circumstances, I believe that EPA should start now to address
19 the known problems before it mandates a costly treatment tech-
20 nique to deal with problems which it has not verified.
21 “It is my understanding that EPA has compiled a list
22 of organic chemicals which have been found in drinking water
23 and which EPA believes present a risk. Drinking water from
24 different systems will have varying combinations and varying
25 amounts of these chemicals in them. For each such substanca
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1 an appropriate MCL should be established after thorough invas
2 igation and input from the water supply industry.
3 “Thereafter, on an anrni l, or some other appropriate
4 basis, each water system should monitor to determine which of
5 the susp c chemicals appear in ts source of supply. For the
6 following year, the company would be required to meat the MCL
7 for those chemicals and to perform the necessary monitoring t
B assure compliance.
9 “However, they would not, on a continuous basis, be
10 required to monitor for the full spectrum of organics, an
11 undertaking which EPA says is not feasible and in any realis-
12 tic view surely is not necessary. With limited monitoring,
13 however, the regulation should not be unduly burdensome and
14 the nasd for the costly GAC systems could be avoidad.
15 “At the seine time, EPA could pursue with damonstra—
16 tion plants the necessary tasting for GAC treatment facilitias
17 on an experimental basis. I note that the Federal Register
18 notice states that a reason for not requiring GAC treatment
19 by water systems serving populations under 75,000 is that
20 implementation would be too expensive.
21 “Rather, it was proposed that the technique be
22 tasted in the large systems to work out problems and perhaps
23 make improvements before imposing it on small systems. Having
24 conceded the need for tasting and experimentation, EPA should
25 do just that.
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1 “Making an unknown, but significant number of cities
2 the guinea pigs for tasting the C AC process is a more costly
3 approach than this country can afford. I urge you to proceed
4 with caution, deliberateness, and an eye on the taxpayer’s
dollar.
6 “Thank you for your attention. I believe that the
7 concern expressed by EPA in this proposal is genuine. I
8 believe also that the concern expressed by the water systszns
9 which will have to conform to this regulation is genuine.
10 “If I can be of any further assistance in achieving
11 an acceptable and workable regulation, I stand ready to lend
12 my efforts to that and.”
13 MS. CHANG: Thank you.
14 Are there any questions?
15 MR. 1(1MM: Two comments, f I might. One is to
16 note that the reference to the Univars ty of Virginia -- I
17 would like to clarify the record with regard to the findings
18 of the study done at the University of Virginia tiedical Col-
19 laga. We have received countlass pieces of mail on this sinc
20 the existence of that study and an interpretation, which we
21 think is inappropriate, appeared in a newsletter.
22 Basically, the study conducted by the Medical School
23 with EPA research funds, was looking at short-term affects on
24 laboratory animals tasted in terms of changes in behavioral,
25 neurological attarns and Immunization factors in the animals.
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1 As such, they found no adverse effects at anything like the
2 levels in drinking watar, for which we should all be very
3 thankful.
4 But this did not, in fact, look at long-term feeding
5 studies for the impact on cancar rates in the ar 1 .tinals and has
6 no significance in terms of the underlyIng rationale and con—
7 cern that led the agency to propose these regulations.
8 Information from the principal researcher has bean
9 distributed; that is, he has written some letters backing a
10 newspaper article that kicked off this controversy. And we
ii asked other people involved in the process to review the
12 raqord and help us clarify that matter.
13 MR. GLAtJTHIER: I would lIke to pass two other corn—
14 ments b ck to the Senator. One is that while he has’ no ‘basis
15 for takIng issue with Indianapolis costs, we have raised
16 questions and have presented some issues in the revised report
17 available now through EPA.
18 The second has to do with the poUutiori control
19 effects, or the pollution effects, mentioned. The costs for
20 for pollution control are included in the cost astimat4s which
21 EPA is using.
22 MS. CHANG: Thank you vary much.
23 Wa would like to proceed now to Mr. I. M. Rice,
24 from the Upper Trinity Basin Compact, and he will be accompani
25 by Mr. Browning.
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1 STATEMENT OF I. M. RICE, REPRESENTING THE UPPER
2 TRINITY BASIN COMPACT, NORTH CENTRAL TEXAS;
3 ACCOMPANIED BY CARL RHEEN, MANAGER, NORTH TEXAS
4 MUNICIPAL WATER DISTRICT, MR. NELSON ?ROM THE CITY
5 ., OF FORT WORTH, AND DR. RICHARD N. BROWNING FROM
6 T1 TRINITY RIVER AUTHORITY.
7 MR. RICE: Ms. Chang, first of all, I would ike to
S thank you for the opportunity to coma hera and testify at this
9 hearing. I am I. M. Rice and I am associated in this andaavo
10 in a group called the Upper Trinity Basin Compact. On my left
11 is Mr. Carl Phean, who is Manager of North Texas Municipal Wat
12 ar District; and on my right is Mr. Nelson from the City of
13 Fort Worth, and Dr. Browning from the Trinity River Author ty.
14 Wa collectively serve about 2.5 million customers,
15 and we are the fifth largest SMSA area in the count y. We are
16 a water—short area. Our citi ens have repeatedly demonstrated
17 their willingness to invest large sums of money necessary to
18 supply adequate supplies of clean and pallatable water. But
19 they do demand from us an accounting of the stewardship of th
20 money given to us to operate these systems. Our customers mu t
21 be convinved that expenditures ara necessary, that they are
22 cost—effective and raprasnat the best alternative. Apropos 0
23 an earlier statement concerning California, we had the unfor-
24 tunate experience, just recently, in a bond election. Dallas
25 has always passed bond elections without axcapt on. This tim
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1 five propositions out of 17 wars defeated, and these were the
2 peripheral areas, the ones not understood by the voters. They
3 were not the bread-and—butter things that th y are always awar
of, fIre stations, streets, and that sort of thing.
5 Our water supplies ccme from nine large man-made
6 lakes; in the Upper Trinity Basin and one in the Sabina Basin.
7 Although we think our water supplies am inherently of high
8 qualIty, we are fully exposed to the effects of the proposed
9 regulations, and are by no means assured of being granted a
10 variance from the treatment techniques.
11 We have undertaken to review the proposed ragulatic
12 man effort to assess Its irnoact on our water systesm. A pr
13 liminay report of our findings is submitted h rawith for the
14 record. It is very preliminary, and we will have to review i
15 as the result of information supplied by you today. We will
16 leave you a preliminary copy -- it is missing some tables, an
17 will be replaced during the reportIng time.
18 I would like to talk very briefly on seven topic
19 headings, and the first one I have entitled, “An Unproven
20 Health Risk”. We monitor metals, pesticides, substances in ’
21 cluding trihalomethanas, THMs. Analytical ins truments can no
22 find a detectable amount of almost anything anywhere. It is
23 present in almost anything we look at; it is in our s atar.
24 Some of these substances may be dangerous at some level, but
25 we don’t know how high that is.
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1 We ar developing a data base and eventually there
2 will be some conclusions that can be drawn from that. EPA
3 has monitored T} 4s in Dallas and Fort ‘Jorth. They found THMs
4 in both systems to be under the proposed maximwn contaminant
5 level —- 4CL —— of 100 ppb.
6 However, we strongly advocate that additional raseax
7 be conducted to determine to acceptable level of health risks
8 posed by trihalomathanes at concentrations normally found in
9 drinking water. What we are concerned with is th3 authanticit
10 of the alleged risk.
11 Our perception differs from that the framers of tha e
12 proposed regulations. *
13 The second topic has to do with”Burdan of Proof”.
14 Since the Dallas—Fort Worth area is within the proposed MCL
15 for THMs, organic chemicals besides THMs are what the proposec
regulations would.have us remove with GAC. Since EPA has not
17 specified what chemicals should be removed, we do not know
18 whether or not they are present.
19 Yet, the burden of proof is on us to convince EPA
20 that we do not need to install GAC. We are not convinced that
21 GAC is the only or the best method, if additional treatment iE
22 proven to be necessary.. But here again, the burden of proof
23 is on the operator to show that another system is adequate.
24 Under these conditions, we have no choice but to
25 disagree with this part of the proposed regulations.
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1 “Costs and Reliability” —- you have heard from peopi
2 batter versed than I am today, and I will not go into detail
on th±s, other than to say that for our custorrtars we are look—
4 ing at a $3 to $5 increase on a monthly water bill. That migh
5 not seem . lot of money to some people here in the audience,
6 but when you are on a very fixed income, on welfare, that make
7 a difference, and whether that $3 or $5 goes to food or drugs
8 or to make a supposed inprovarnent in the quality of water make
9 a big difference.
10 “Reliability ” —- we just don’t know enough about the
11 GAC. We looked at the list appended to the white paper of
12 plants in the United Stat.es where c equipment exists. We
13 note that the biggest plant is on the order of 30, 35 MGD.
14 Our smallest plant is 150 MGD and our largest is 250; and this
15 is important. Little plants don’t operate like big plants.
16 I believe there are only 10 or 1]. of the plants
17 cited here that are even to digits. Most of them are below
18 10 MDG. We don’t know enough about GAC. Our water supplies
19 may saturate or clog GAC much faster, making it much more
20 expensive when started up and: to-operate.
21 Some of our softening systems may render GAC inaffac
22 tive. We have heard about biological growth, which is a prob-
23 lam in our present plants and may reduce the effectiveness of
24 GAC. We don’t know what the effect of polymer trea nant may
25 be on GAC, and there are too many unevaluated potential
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1 problems.
2 What we need is solid parfo nance evaluation on a
3 significant scale before we install this or any other procass.
4 “Alternatives” -- there are alternatives in the form
5 of differant operational adjustment of present facilities,
6 relocation of chlorine application, use of different disinfac-
7 tants, use of home purifiers of sufficient size and affective-
8 ness, and bottled water, to name a few.
9 But we know only as much about some of these alterna
10 tives as we do about GAC, and that isn’t enough. All should
11 be the subject of research, development, and, at the choice
12 ana in the judgment of the responsible state and local author-
13 ity, application.
14 In our water shad we fInd slightly more THM, but I
15 would consider the less-polluted source into the water shad
16 that has the fewer population, fewer sewage plants discharging
17 into the river. Of course, when we are talking about chioro—
18 mane disinfection, we must assure that the .propar contact time
19 is afforded, and this can be handlad through operational con-
20 trol of the treatment plant.
21 ‘Changing Objectives” -— this phrase symbolizes what
22 water treatment plant operators face with the prospect of char
23 ing standards. The proposed regulations will set an initial
24 MCL on THMs of 100 ppb, but goes on to say, and I quota:
25 “In accordance wIth the requirements of the Safe
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1 Drinking 1ater Act, revised . . .drinking water regulations
2 will be fo hcoxrting which will impose additional MCLs on
3 organic chemicals as wall as require further reductions in th
4 levels of THM as additional toxicological, t.achnological and
5 ar.alytical information becomes available.”
6 W are vary concerned about a moving target. If we
7 know what we have to achieve, we can do it; but it is vary
8 difficult to pain, when you don’t know what your objective is.
9 Flow can a municipality spend millions of dollars to design an
10 construct treatment facilities, which possibly will be obsol 1 a
11 before they are put into operation?
12 “Statutory Prerequisites” -— this is covered in my
13 statement, which you all have hera; and it has to do with
14 SectIon 1412(b). fla.havec’correspondad with Mr. Cotruvo in a
15 letter dated June 21st. It contains the statement, “The
16 National Academy of Sciences did not prepare either lists of
i’ contaminants or recommended maximum contaminant levels, as
18 directed by Section 1412 (a) (2) of the Saf ..Drinking Water Act.
19 These lists are not just technicalities; they are
20 needed by us. They are vital to our planning. We need to
21 know exactly what we have to contend with. These lists would
22 contain, presuinably, the contaminants which the regulations
23 would have us remove. Without the list, we have no practical
24 goals.
25 Now, our “Recommendations” are vary simple, three
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I r cornmandations;
2 Nwnber one; hold the proposed regulations in aboyanc
3 until the necessary research is completed and revise as necas-
4 sary.
5 . Second; vigorous].ysuppcrt,and study the results of,
6 monitoring and treatment technology development, including GAC.
7 Thirdly; work with us in the water supply industry
s and with the state regulatory bodies in the development of
9 these regulations.
10 Thank you.
11 (The full statement follows:)
12
13
14
15
16
17
18
19
20
21
23
24
25
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I MS • CH NG: Thank you very much.
2 Does anyone have any questions?
3 MR. GLAUTHIER: I have a question on cost. I know
4 you will give us a detailed report and more information later,
5 but in your written testimony you mentioned that the cost
6 estimates are about three times what developed for EPA.
7 Have you identified the major areas of difference
8 and what it is that seems to account for that?
9 MR. I BEEN: My agency staff did most of the work on
10 costs, in particular programs we are putting together, and we
ii do want to make some revisions there. However, I think when
12 we .get down to it, we have not r eally looked, item-for-item.
13 Wa used your basis in many areas.
14 Wa do feel there is probably a great deal of differ-
i5 ance when we start talking about capacities to be utilized
16 when looking at whether you are using 70 percent of design
17 capacity.
18 In our area of the country wa have several problems
19 that are not prevalent in other parts of the country having
20 plant capacity available, when we use two to two and a half
21 times daily average, peaking in the summertime, primarily for
22 water and irrigation; but we would still have to treat that
23 water with these regulations. Therefore, we have mora of a
24 problem there.
25 Wa are a very fast-growing area • My agency incraas
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1 water sales last year by 22.7 percent in one year’s time. So
2 we have to have considerable plant capacity available to meet
3 those needs.
4 This means, what do we have in the way of GAC facil
5 ties, sitting idle, ready to go to meat those needs? We thirj<
6 that is probably one of the major differences.
7 MR. GLAUTHIER: Those would sound like they would
8 also be the subject of a great deal of careful design work in
9 actually going through with any sort of installation, some wa j
10 to try to optimize, to not be driven out of sight on costs.
11 MR. RHEEN This is one of the things we fear. We
12 worked with EPA and we have some experience on what happens.
13 We are not sure we would have a logical progression once we
14 get a regulation. This is once concern that we do have. We
is also found other things. Our carbon price, delivered to us,
16 is higher than yours; and we developed a differential there
17 in the cost of carbon itself.
18 There are quite a few areas.
19 MR. KINM: In a continuing effort to sharpen costs
20 up, we appreciate the going back and forth; and perhaps a
21 better understanding will come out of these factors.
22 One of the comments you had with the Academy, the
23 Academy of Sciences, I think, as was represented a little
24 earlier this afternoon, gave us specific help, a no-effects
25 health level for certain contaminants, where they felt there
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1 was a great deal of data, and in other areas gave us various
2 levels of summaries, which could be said from the toxicologica
3 data on record, and that was as far:- as a judgment allowed them
4 to go with the evidence, and that is where we are at.
5 MR. RICE: As you know, Mr. Kirnrn, this is an imper-
6 fact way to reach a consensus. We prepare what we are going
7 say before we coins hare. Other people say things which, if we
8 had known about them, we might have expressed ourselves a lit-
9 tie bit different way.
10 I think we need to continue this dialogue. What yo
11 just said about we need to continue cost estimates -- 1 t’s
12 continua on the rest of it, too, in a dialogue, and let’s do
13 it in technical sessions where we can —- I am not an expert ir
14 chemistry and water treatment. I run the operation thara. I
15 would like to bring some of my other people in and talk with
16 you folks.
17 MR. KIMM: We would be most pleased to do that, and
18 I, for one, note a very different tone to this hearing than
19 some of the previous; and I view that as a constructive step
20 on both sides. As we talk, we probably can arrive at more
21 areas of agreement than have surfaced thus far.
22 MR. RICE: I think that is the whole point, Mr. Ki
23 wa have observed a lack of consensus today amongst tha expert
24 We need to arrive at as near a meeting of minds as Wa can. I
25 think we all have the same objective, we have diff arent
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I percsptions as to priorities, costs and that sort of thing.
2 MR. 1 <1MM: I think that .s very true. It seams to
3 ma that at the heart of the matter is the agency’s concern
4 that we start and try to determine some feasible way of begin-
5 ning to ghasa into a program of limited exposure in these
6 areas, w±th new applications of technology, at cetera.
7 I think it is your industry which is in the ideal
B position to give us some assistance on what is feasible to do;
9 and if we all sea it as feasible and reasonable, perhaps it
10 will make it easier to actually imp1arnan . but if it comes
ii out of this regulatory process.
12 MR. RICE: I would not quarrel with that.
13 DR. COTRUVO: Excuse ma, on the matter of the lists
14 -— those lists are being worked on prepared on the basis of
15 the information presented by the Academy. It will be awhile,
16 but definitely working in that direction.
17 Ona quick question. You talked about chiorornenas.
18 Does your district use plate counts, standard plate counts, dc
19 you know, in water quality turbidation?
20 MR. RICE: I think we all do.
21 DR. COTRUVO: Do you think that is a good sensitive
22 method for looking at differences in treathent processes that
23 are introduced?
24 DR. BROWNING: This is another area where we would
25 like to get our primary people together with your primary
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1 people.
2 MR. RICE: I regret putting ycu on the spot here.
3 did not know you were going to be on the panel this morning,
4 but we are recording them as we saw them. I thought you were
5 very can4id in your answer to our latter, and we appreciate
6 that candor.
7 MS. CHANG: Thank you vary much.
8 We will have to move along. We have only gotten
9 through about half of our speakers and have already passed
io 4:00 o’clock.
11 Mr. Blake Early, please.
12 STATEMENT OF A. BLAKEMAN EARLY, REPRESENTING
13 ENVIRONMENTAL ACTION, WASHINGTON, D.C.
14 MR. EARLY: Good afternoon.
15 My name is A. Blakeman Early. I am hare today to
16 present the comments of Environmental Action on the Environ-
17 mental Protection Agency’s proposed Interim Primary Drinking
18 Water Regulations for Control of Organic Chemical Contaminants
19 in Drinking Water.
20 Environmental-Action full ’ supports the bas.icth us’t
21 of these proposed regulations as an important part of the
22 effort to reduce the dissemination of toxics, particularly
23 cancer—causing substances, throughout the environment. In
24 our view, these proposed regulations represent only the begin-
25 ning of what must be a much greater effort.
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1 The proposed regu1at ons must be viewed in the
2 context of this greater effort. The rationale behind this
effort is eminently logical. I recognize that some of the
‘ testimony I provide is repetitive with other tastimony that
has been’presentad, but I feel it .s wcrth re-emphasizing in
6 order to place the proposed regulations in what Environmental
P ction view is the proper perspective.
8 The National Cancer Institute and the World Health
9 Organization have estimated that between 60 and 90 percent of
10 human cancer is càused’.by environmental factors. The cancer
11 death rate has been increasing on the average of 1 percent
12 per year for the last two decades and cancer is now one of th
13 major k llars in the United States, claiming nearly 400,000
14 lives each year.
15 Bear in mInd that cancer has a latency period
16 between initial exposure and manifestation of the disease of
17 between 20 and 40 years. Thus, we are only now beginning to
18 experience the result of rather limited population exposures
19 to chemicals when the “chemical revolution” was just gaining
20 momentum.
21 Environmental Action submits that we should not wai
22 for these figures to become more gruesome before aggressive
23 action is taken to reduce and eliminate the axwironm ntal
24 exposure of humans to carcinogens. The difficulty is to
25 identify which exposures must be controlled.
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1 While toxicological data demonstrate that some car-
2 cinogens carry a greater r±sk of canar causation than others,
a highly respected body of data suggests that there is no con-
cantration below which exposure is safe. Therefore, each
5 exposure to a carcinogen increases the risk.
6 Thus, it is not only important to consider the rLsk
7 involved with the exposure of the public to chloroform and tn
8 halornathanes, THMs, i n drinking water, but also the fact that
the public risk is being multiplied through exposure to car-
10 cinogens in the occupational environment, food and the ambient
11 air.
12 Furthermore, we do not understand vary well the in-
13 taraction between two or more carcinogens and between carcino-
14 gans and non—carcinogens. For instance, it &s well known thai
15 workers who smoke and are exposed to asbestos have a far great
16 er chance of contracting lung cancer, masothalioma or asbasto-
17 sis than workers who incur similar exposures, but who do not
18 smoke.
19 Little is known about this phenomenon concerning
20 other combinations under d ffarent conditions of exposure.
21 What is the nature of the various interactions that take
22 place in the “chemical soup” that we drink?
23 While the foregoing testimony provides only a thumb
24 nail sketch of the problems we face with human exposure to
25 cancer—causing chemicals, it does illustrate the need to /
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I r duca human exposure to carcinogens wh ravar it iS tachnicall
2 oclitically, administ3rably and economically feasible so to
3 do.
4 Clearly, finding opportunities that meet these cri-
5 teria is difficult. The proposed regulations meat these cri-
6 taria and we should grasp this opportunity.
7 Whether the proposed regulations are, in fact, pout
8 ically feasible still, apparently, hangs in the balance, as a
9 significant amount of opposition to them has bean generated by
10 drinking water treatnant and supply officials. The opposition
11 to the proposed regulations is a classic illustration of the
12 emergence of political opposition to the case-by-case impla-
13 mantation of measures to achieve goals having overwhelming
14 public support
15 The ar uentsJ raised by the drinking water treat-
16 mant and supply officials who are supposed to ba public sor-
17 vants ciscaly parallel those offered by industrial interests
18 during the consideration of the Toxic Substances Control Act
19 as wall as industrial dischargars of toxic pollutants during
20 the consideration of the Clean Water Act of 1977.
21 They raise cries of inadequacy of proof of a problem
22 and costs outweighing the benefits and the unproven state of
23 the treatment technology. The situation reminds me of an
24 expression of Senator Russell Long, except ha uses the word
25 “tzx” where I use the word “regulate” -— “Don’t regulate you,
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1 don’t ragulata me, regulate that fallow behind the tree.”
2 Whi1 such an attitude may be axp ctsd of corpora-
3 tions motivated by the need to make a profit, it is not befit-
4 ting those who enjoy a spac al public trust as guardians of th
5 public d ±nking water supply. Indeed, we question whether the
6 expend turas to finance a campaign against these proposed rag-
7 ulations, which is being paid for by the public these ragula—
8 tions w±ll protect, are being made in the public interest.
9 Wa note that while the statement of the American Wat
10 er Works Association suggests that the Clean Water Act might
ii be more effectively used to attack the problem of THMs, other
12 municipal officials have vigorously protested EPA pretreatment
13 regulations to reduce or eliminate industrial discharges to
14 publicly owned wastawatar trea nant facilities in spite of
15 strong av denc that these pollutants pass through to the
16 receiv±nq surface waters.
17 Some of these waters are used as public drii king
is water supplies. It is obvious that municipal water supply
19 officials and municipal wastawatar treatment officials do not
20 see eye to eye on the best approach.
21 Moreover, industry is vigorously protesting a draft
22 proposed revision of Section 402 of the Clean Water Act which
23 would restrict industrial discharges to those chemicals actua
24 ly identified in the discharge permit application.
25 Many companies claim that they do not have the
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1 resources to even identify the hundreds of different synthati
2 organic chemicals they discharge into surface waters. Furthe
3 more, there should be sufficient time to investigate the feasi
4 bility of app1y ng the provisions of the Claan Water Act and
5 then obta.ining a variance from the treathent requirements unde
6 Section 141.54 of the proposed regu1at ons.
7 What is of great concern to Environmental Action, is
8 that the opposition to these proposed regulations does not
9 reflect the rather obvious publiô concern for the environment
10 and public health threats from environmental pollution. Publi
11 support for more stringent measures to protect and enhance the
12 environment has been high.
13 Indeed, a February 1977 Opinion Research Corporation
14 poll indicates that a large majority -- 68 percent -- of the
15 public is still ri1ling to pay higher prices and taxes for
16 environmental protection. Moreover, there is ample evidence
17 that this willingness to pay extends to the protection of
18 drinking water.
19 Recant sales of bottled water have risen impressive-
20 ly over the last few years. Sales have been growing at an
21 annual rate of over 15 percent and will reach wall over
22 $200 million in 1978. Another impressive indicator of public
23 concern for the safety of their drinking water is reflected in
24 the emergence of the home carbon filtration systems that are
25 installed directly on the tap or the tap line.
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1 Home fi-ter sales are predicted to reach in excess o
2 4 mil1 on units annually in 1978. This is a truly remarkable
3 figure when one considers that there ware approximately 75 nil
4 lion households in 1977. Assuming approximately 3 million hous
5 holds par year are acquiring these daviôes, about 4 percent of
6 all households par year care enough abcut their drinking wate
7 quality to purchase these systems for roughly $20 to $30 per
8 unit, with annual filter replacement costs at half that figure.
9 , the concern of drinking water treatment
10 officials that the cost of these regulations are excessive
11 are not reflected by the figures I just cited. These costs
12 ar wall within the rnage of the costs which the Agency has
13 recalculated and published in the Paderal Regcster last weak.
14 Water treatment systems should have little trouble
15 recovering the cost of implementing the treatment requirements
16 under these regulations, particularly after the public has
17 bean informed that the treatment technology applied will pro-
18 vida more effective protection of their dr .nking water than
19 the tap systems can provide.
20 We think this attitude will be sustained notwith-
21 standing the view reflected in the vote on Proposition 13 in
22 California. Voters in California were protesting the increas
23 of property taxes vastly greater than any Increase of public
24 services provided them.
25 In paying for the treatment systems necessary to
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1 ccmply with the proposed regulations, the public knows that
2 hay are paying, in mcst communities, in accordance with thei
3 usa of dr±nking water and that they are getting greater assur-
4 ance of drinking water quality in return.
5 The proposed regulations must be strengthened.
6 Opponents of the proposed regulation try to portray the
7 requirements as representing an over-protective extreme.
8 Environmental Action submits that the requirements do not go
9 far enough.
10 The .10 mg/i maximum contaminant level, MCL, fcr
ii trihalomethanas represents a compromise lava].. The epidemic-
12 logical studies done found that some communities having static
13 tically signif±cant levels of cancer were axposad to far lower
14 levels of THMs and other synthetic organic chemicals.
15 There is little evidence to suggest that the .10
16 mgi]. MCL is a “safe” one, as the discussion in the preamble to
17 the proposed regulations confirms. Until a safe level can be
i established, which we recognize will be very difficult, every
19 effort should be made to institute additional procedures that
20 would reduce the MCL for THMs to a greater extant.
21 - Finally, we do not endorse limiting the application
22 of the T!Tht and GAC treathant requIrements to cities of popula-i
23 tions greater than 75,000. The proposed regulations only pro-
24 tact approximately 52 percent of the total U. S. population.
25 Since a variance system is being created to exempt systems
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1 from installing GAC systems, thera is no reason why smaller
2 communities should not be required to examine the potential
3 public health problems that may exist in their drinking water
4 and apply the necessary treatment where required unless it can
5 be shown . 1 that a GAC system is simply not affordable.
6 Perhaps, it would be necessary to allow smaller coin—
7 munities a longer period to examine the alternatives.
8 Conclusion —— in conclusion, we support the proposed
9 regulation as a creditable effort which should make a valuable
10 contribution to protecting the public frcm the dissemination
11 of toxic substances in the environment. This effort must be
12 broadened by EPA, PDA, OSHA, and the CPSC.
13 Wa urge the Agency to promulgate the proposed ragu-
14 lations with the modifications werecornmend above as soon as
15 possible.
16 Thank you.
17 (Applause)
18 MS • CHANG: Thank you.
19 DR. KUZMACK: You made some comments about the
20 75,000 population cutoff. Would it be your position simply
21 that that number should be lower or there should not be a
22 cutoff? Behind the question is the fact that there are in the
23 neighborhood of 25,000 systems serving fewer than 500 people.
24 It would be a tremendous job to look at all of those, and it
25 is hard to see that systems of that size would be able to
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I deal with the eng neeri g probLams involved. -- involved in
2 sophisticat treatment.
3 MR. EARLY: I agree that probably the more rational
4 approach would be to narrow the population and not eliminate
5 the cutof.f completely. A system of that size w±ll not be able
6 to comply with these kinds of requirements.
7 MS. CHANG: Any other questions?
8 If not, thank you vary much.
9 Wa would like to proceed to Dr. Farral Robinson
10 from the City of Indianapolis.
ii STATEMENT OP FARREL R. ROBINSON, D.V.M., Ph.D.,
12 PROFESSOR OP TOXICOLOGY AND PATHOLOGY, SCHOOL OP
13 VETERINARY MEDICINE, PURDUE UNIVERSITY, WEST
14 LAFAYETTE, INDIANA, SPEAKING ON BEHALF OP THE
15 INDIANAPOLIS WATER COMPANY
16 DR. ROBINSON: I am Farra]. Roblnscn, D.V.M., Ph.D.,
17 Professor of Tox colcgy and Pathology, at Purdue Univars ty,
18 West Lafayette, Indiana. I am speaking on behalf of the
19 IndianapoliS Water Company - - a marnb r of the Coalition for
20 Safe Dr r king Water.
21 I have been asked to comment upon the proposed
22 amand nt to the National Interim Primary Drinking Water Ragu-
23 latLons, I would first like to discuss the “principles” sat
24 out in the National Academy of Sciences’ “Drinking Water and
25 Health” r p t upon which EPA is relying to assess the effact
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1 of long-expcsu a to carcinogenic substnaces at low-doses.
2 These ‘principles” are batter defined as opinions.
3 As opinions they reflect the views of some but not the rnajori-
4 ty of people qualified to express them. Consequently, they
5 should nqt be looked upon as absolutes, but merely as expres—
6 si ns of an approach to a complex set of problems. I might
7 add that they should be constantly reexamined as additional
8 data becomes availabe.
9 Principle 1: Effects on an±mals, properly qualifie
10 are applicable to man. The statement that cancer in man and
11 animals is strikingly similar must, as is observed, be 9 prop-
12 ar .y qualifIed”. Meoplasms in man and animal can be similar
13 morphologically, but many neoplasms are quite different and
14 the spectrum of neoplasms in each species is different.
15 Principle 2: Methods do not now exist to establish
16 a threshold for long-term effects of toxic agents. The argu-
17 ment against the principle of thresholds is given and adroit1
18 set aside because they state that thresholds cannot be estab—
19 lishad experimentally, rather than because the argument is
20 not valid. Thresholds do exist or incidence of macplasms fal
21 so low as to be indistinguishable from the background flCi
22 dance.
23 Pr ncipla 3: The exposure of axperienitnal animals
24 to toxic agents in high doses is a necessary, and valid method
25 of discovering possible carcinogenic hazards in mafl. The
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1 argument is pr sentad that high dosages to which animals are
2 xpos d have ralavanc in assessment of human risks.
3 This approach completely ignores that a threshold
4 may exist for a given substance or that the probability that
5 the 1nci ance of neoplasms in the human population for a giver
6 substance may fall below background levels. It also ignores
7 the argument for high dosages of chemicals overwhe1ming an
8 animal’s biochemical mechanisms so that neoplasia results.
9 The discussion conceded that not all substances that
10 cause a given incidence of cancer in an animal model, such as
11 the rate, are equally carcinogenic for man, and further that
12 chronic toxicity studies are mperf act assay systems for
13 carcinogamicity testing.
14 Principle 4: Material should be assessed in terms
is of human risk, rather than as “safe” or “unsafe”. I agree
16 in concept with the principle that material should be assasse
17 in terms of human risk, rather than as “safe” or “unsafe”. I
is do believe that theoretical statisticians should have a brcad
19 ar background in biological processes-to fully understand wha
20 their projections and estimates really mean in terms of real-
21 life situations.
22 I do not agree that accurate reliable data on mci—
23 dance of neoplasia cam be produced using the highest dose tha
24 can be tolerated -- maximum tolerated dcsa -— in a labcratory
25 animal.
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1 Next, I would like to address the dangers of basing
2 conclusions as to th health effects of chloroform upon the
3 Nd study. The Nd carcinoganesis bioassay studies are rala-
4 tively inexpansiv screening tests where very high doses of
5 chemicals are administered to rats and mica for about two
6 years.
7 If the chemical is carcinogenic to rats and mica,
8 the most prudent ccnclusion is that it is carcincgenic to
9 that particular strain of rat or mouse under thosa specific
10 conditions —— and that is all • These conditions are vastly
11 different in numerous ways to “real-life” situations with
12 humans.
13 The problem of extrapolating animal data to man is
14 difficult, statistical methods used are complex and involved.
15 They are a ciencs in themselves. Prudent statisticians are
16 hesitant, even reluctant, to make judgments relating to human
17 health based on equivocal and/or inadequate animal data, as
18 was acknowledged in the National Academy of Sciences ‘Drink-
19 ing Water end Health”, where it is obsarvad
20 “Current knowledga of the proper principles for
21 extrapolating toxicological data from high dose to low dose,
22 and from one spaci s to another is inadequate.”
23 I agree with that statement, as I believe most
24 scientists would.
25 The problem with using the NCI bioassay data is tha
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I there are only two points —— two doses —- to draw a dose-
2 response curve. If a straight—line relationship is assumed,
3 erroneous hypothetical extensIons of data occur. In many toxi
4 cological studies a straight-line function is not the case or
5 even expected.
6 I believe, as does the mainstream of scientifIc
7 thought, that the dose—response curve to chemicals that cause
8 risoplasms at high doses is curvilinear. This means that for
9 a given range of dose-response relatIonships there is a rala—
10 tively straight-line function, but at lower doses there is no
11 detectable response to the chemical.
12 This is a well-known and accepted princIple that a
13 dose has to be present in adequate quantities to cause a
14 detectable response. I would be very reluctant to base hard
15 and, in this case costly, conclusions on the NCI study. Much
16 more data is needed.
17 The fact is that a threshold to chloroform has bean
18 strongly suggested and supported by Dr. Francis Roe. Even if
19 the TIINs were entirely removed from drin)dng water, however,
20 there is no evidence t indicate that the background Incidence
21 of spontaneous neoplasia in man would be altered.
22 At this point information is inadequate on animals
23 exposed to low doses of T1 s over a long term to sarv as a
24 basis to make realistIc risk-banef t estimates for man.
25 But r sk-benaf it considerations govern the need to
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i limit Cr control chemicals such as th THr 1s, and these consid
2 ratiors must be basad on realistic facts. Th ra is no doubt
3 that chlorination of watar supplies has had a marked effect o
4 controlling infectious diseases since the turn of the century
TI Is have been identified recently in chlcr natad
6 drinking water only because analytical technicological advanc s
have allowed these chemicals to be detected in extremely low
8 amounts. There are no firm data to link the negligible amouni
9 of T}iMs in drinking water to human health problems.
10 Scientific bases are even more tenuous when the
11 discussion is broadened to include all synthetic organic cham-
12 icals. In affect, it seems EPA’s working hypothesis is that
13 the problem is so ov helning and scientific data is so lirnil
14 ed that it becomes unmanageable.
15 On this premise, the proposed regulatory answer is
16 to impose the expansive granular activated carbon, GAC, systa
17 on water utilities. This, I think, is taking the wrong
18 direction. It amount to regulating upon a fear of the unknow
19 rather than upon sound scientific basis.
20 The fact is our knowledge is not so limited. There
21 is a wealth of toxicological data on synthetic organic chaini-
22 cals which EPA is ignoring. The National Academy of Sciancas
23 in its Drinking Water and Health report, prepared statistical
24 estimates for 16 organic compounds or groups of compounds
4
25 known or suspected to be human and animal carcinogens.
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1 Of course, the same dichotomy of knowledge and un-
2 certainty can also be applied to these statistical extrapola-
3 tions on carcinoganicity. There are limitations in making
4 extrapolations to low dose human exposures because of dif far-
5 encas inrnetabolic rates and pathways for handling carcinogen5
6 There are different target-organ responses, and the
7 effect of repair or other macha isms to neutralize the potan—
8 t ally toxic material must be taken Into account. The point
9 is that even though there may be significant problems in
10 interpreting the results of animal tests and extrapolating
11 these results to humans, EPA has not begun to use th toxico-
12 logical. information available with rasp ct to synthetic organ-
13 Ic chemicals.
14 I think it is premature to impose the GAC treathent
15 technique based on the limited data available. The data for
16 SOCs now available does not preclude a selective regulation
17 of a synthetic organic chemical demonstrated by sciantificall
18 reliable data to pose a significant haalth . risk at the con—
19 centrations normally found in drinking water.
20 There is, however, no evidence now that current
21 levels of any synthetic organic chemicals in drinking water
22 are causing public health problems.
23 I would conclude by saying that extrapolations to
24 man of Inadequate toxicolologic data on animals and projected
25 estimate risks are very tenuous and must be done with extreme
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1 care and examination. Moreover, with respect to trlhalometh-
2 anas and synthetic organic chemicals generally, much further
3 study, as recommended by the NAS Subcommittee cn Organic Ccn-
4 taminants -- pages 795- to 799, “Drinking Water and Health” -—
5 IS neade4 in order to arrive at a sound conclusion.
6 I thank you for allowing ma to make this statement.
7 MS. CHANG: Thank you vary much.
8 DR. COTRIJVO: Dr. Robinson, in a couple of places
9 in your statement, you referred to testing -— the incidence
10 rates, cancers, from the background levels, I think both in
11 animals and .n humans. What is the cause of the background
12 level of those cancers?
13 DR. ROBINSON: As I am sure you ar aware, there are
14 multIple causes of cancer in animals, including viruses and
15 other unknown, or undefined, areas, including -- where there
16 are radiation causes and many others.
17 DR. COTRUVO: It would be the aggregate of total
18 insults that organism has received.
19 DR. ROBINSON: That iS true.
20 DR. COTRUVO: It -would stand to reason that raducinç
21 those insults by some amount would have an affect of reducing
22 background rate.
23 DR • ROBINSON: If the .suspectad. ma.tar a1. that is
24 reduced is responsible for these thIngs, and.that is the real
25 serious doubt that I have, that these compounds at the levels
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1 found in drinking water are really r sponsib1e for some of
2 thasa background incidancas.
3 DR. KUZMACX: To pick up on a related point, the
4 statement you made is that either thresholds exist or the
5 incidsnc Is so low as to be indistinguishable from backgrcun
6 I agree with that statement as it stands, but the implication
7 seams to be that an Incidence, i distinguIsh b1.a from backgrour
is too small to spend money to deal with.
9 A lavei. as high as 1,000 or 10,000 cases per year
11) in the total population would probably not be distInguishable
ii from background. But it might well be worth the social invesk
12 mant to control.
13 DR. ROBINSON: There are two points hare. I spend
14 a good deal of my time looking at neoplasms from domestic
15 animals. There is no way that I can determine what the cause
16 of these neoplasms was.. The coma equally from rural areas as
17 wall as highly industrialized areas like Gary, Indiana -—
18 Indianapolis, Evansville, Terra Haute.
19 I sea no diffarancasin the Incidence of tumors, for
o example, in dogs from the rural versus the urban areas. I
21 have suspected and looked for these things, but I have not b
22 able to detect these sorts of things. The other point is, an
23 I can’t stress this enough, that the so-called chemically-
24 related neoplasms are dosa-rasoonsiva. I firmly believe that.
25 There has to be an adequate dose there to induce
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1 nacplasm. I think, in the levels we are daaling with in
2 drinking water, those are unqu’isticnably too low to iI duce
3 neoplasms above the background incid nca. I dcn’t think you
4 could find them. I don’t think you could detect them.
5 DR. COTRt)VO: If they ware some pcrtion of the total
6 exposure and if you had a perfectly clean environinant that
7 had absolutely no insulting chemical, and than that organism
8 was exposed to just that small amount, one could aspect a car-
9 tam level. But if that is some small portion of a total of-
10 portions, than perhaps that is not the question to be asked,
11 that that incremental amount would have a significant affect.
12 DR. ROBINSON: But we are looking at levels that ha
13 no scientific basis for avert considering the possibility cf
14 inducing n op1asia. We are looking at chemicals, particularly
15 chloroforrn and carbon tat, these kinds of chemicals that are
16 metabolized and handled beautifully by the body ifthay.. are
17 not presantad in overwhelming quantities, as in the Nd study.
18 MR. 1 (1MM: Do you have any evidence to support that?
19 That really is quite contradictory to what we have bean hear —
20 ing from lots, of other people. Similarly, on page 5, you make
21 the reference that At 4 point information. is’ inadequate On
22 animals’ exposed to low doses of T t over a long-term to- ’ srv
23 as”’à ‘basis to make realistio ±isk-banaflt estimates for man.:
24 Are you aware of any chemical j which there are
25 adaquata data to talk about the effect of low doses?
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I DR. ROBINSON: My point hare is that the NCI studies
2 intended to do one thing, and that was to identify potential
3 problems. Then, to further elaborate on these data, more dcs
4 should be used --
‘-.
5 MR. KIMM: There are some practical problems, and I
6 am sure some of the witnesses will go into that. The number
7 of animals you get involved with as start reducing the doses
8 virtually becomes unmanageable vary quickly, and that is the
9 reason why no one has been able to do them for the materials
10 I am familiar with.
U To say that we should have that data, the real quas-
12 tion is, do you know any way that that data could be obtainad’
13 DR. ROBINSON: Right now you are bas±ng conclusions
14 on animals receiving very high doses. It seems to ma that
15 negative data is just as important as positive data, and with
16 lower doses, with the same number of animals -- three additio
17 al doses, for example, belcw the area that Dr. Rca used, I
18 don’t think you would detect toxicological ..rssponsa in animals
19 over a two—year period, let alone a neoplastic response.
20 MR. KIMM: Statistics on our largely increased ani—
21 male have to be to make your findings meaningful indicates
22 that those studies have to be very large, and I suspect no Ofl
23 has done it.
24 DR. ROBINSON: I think ons of the reasons NCI has
25 not done this-is because of the entire NCI bioassay study, in
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1 which they wars to look at large numbers of these compounds,
2 and they have not been given the opportunity to go back and
3 study any of them in adaquata detail to dafin mechanisms,
other types of responses that one ordinarily looks for in a
5 toxicological study.
6 MR. 1 <1MM: Dr. Upton and several of his staff will
7 be at thesa hearings tomorrow, and perhaps we can ask him some
8 thing about that. I think that the basic point we ware trying
to make is that this type of animal has, in fact, been the
10 basis for Federal regulatory activities in pesticides, in
11 food and drugs, for at least a decade. This is not a departur
12 it.ig the conventional wisdom among health scientists involved
13 in these regulatory programs.
14 DR. ROBINSON: Wall, I understand that, and I ques—
15 tion the validity of it, or the rationale, to continua to do
16 this. It is just not rtght.
17 DR. COTRUVO: .Dr. Bates. mada th stat3ment that’cne
18 would expect that there would be diffarancas in susceptibili-
19 ties of individuals in a population and one would not expect
20 the same result in every individual. Therefore, one might
21 consider threshold for each individual; but when one deals wi
22 an entire population, because of the mix of suscapt bilit±as,
23 the idea might break down at that point.
24 Would you comment on that?
25 DR. ROBINSON: There is biological variabilLty, and
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1 that is how LD 50 s are run. A group of animals, whatever the
2 size, are givan a series of doses of a compound; and at se ine
point half of them time, regardless of how genetically simila2
4 they are,
DR • COTRtJVO: A human population, which includes a
6 substantial number of people who have damaged livers for one
7 reason or another, either through hepatitis or cirrhosis, or
8 whatever -- wouldn’t you say that those individuals would be
9 at significantly greater risk to chemical insults to that
10 organ than the other healthy segment of the population?
11 DR. ROBINSON: There are so many variables in what
12 you propose. Of what chemical are you speaking?
13 DR. COTRUVO: For example, a haloganated hydrocarbo
14 DR. ROBINSON: It depends on the extant of liver
15 damage, but in a parson, vary healthy, exposed to low levels,
16 I would think it would have no influence on him a bit.
17 DR. COTRUVO: What about that portion of the popula
18 tion that does have substantial liver damage?
19 DR. ROBINSON: If a person, an animal, whatever, is
20 about to die of liver disease, I doubt very seriously those
21 levels of trihalomathanas that you are talking about will haw
22 an influence one way or the other.
23 MS. CHANG: Are there any additional questions?
24 DR. KUZMACK: Yes, i would like to bring up one
25 thing. In your statement, you refer to Dr. Roe’s testimony
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1 concerniig a threshold for chloroform. As you were speaking,
2 I briefly looked through his statezn nt, also, and at no point
3 dces he really bring the argument together. lIe states that
4 ha is convinced it is the case, but never lays out the argu-
5 merit. I would be helpful if you or ha would do that.
6 DR. ROBINSON: I think, either in speaking to him,
7 or reading some of his work, that ha felt 10 mg/kg was the
g no-adverse-affect lava]., and from that you could calculate --
9 DR. KUZMACK: That was based on his conclusion that
10 the linear extrapolation at zero dose was invalid. I would
ii be interested in the reasons why he or you think that that is
12 th case.
13 DR. ROBINSON: I am sure that that would be sub-
14 stance for at least three days of seminars.
15 MR. KIMM: Perhaps a Nobel Prize.
16 DR. ROBINSON: Undoubtedly so.
17 MS. CHANG; Thank you very much.
18 Is Rip Rice hare?
19 STATEMENT O RIP RICE, CORPORATE MANAGER POR
20 GOVERNMENT RELATIONS, JACOBS ENcINEERINc
21 GROUP INC., PASADENA, CALI ORNIA
22 DR RICE: Good afternoon.
23 My name is Rip Rica, and I am Corporate Managàr for
24 Government Relations for Jacobs Engineering Group, which is
25 a Consulting, design and construction ang neering firm based
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I in Pasadena, California. I run the Washington of fics, and
2 for the past three years or so, I have been involved with rub-
3 lic achnoloqy. Incorporated, a Washington-based nonprofit
4 organization that has bean under grant to EPA, first, to look
5 at what çhe currant state of the art is in the usa of ozone
6 and of CO 2 in drinking water treaatrnent, and more recently to
7 assess biological-activated carbon, a water treathant technol-
8 ogy. Both of these programs have involved a world-wide survey
9 of drinking water technology and a detailed final report of
10 some 500-plus pages dealing with ozone and CO 2 as been printed
11 now by EPA, the first draft of the final, dealing with CLT, wil
12 be turned fl this fall; :.
13 The comments I am submitting today coma for the mcs
14 part from the final, which is being printed now, but there
15 will be some data from the most recent survey on PAC. This
will, be said, in terms of what we have learned during the past
17 three years or so, of looking at advanced drinking water treat
18 ment practices in Europe.
19 I say “advanced”, and by that I mean those processes,
20 those :wat r traa nant techniques using technologies we are
21 not using in the U.S. today, microstraining, C0 2 , for a rasid-
22 ual disinfectant, and GAC.
23 By way of introducing this subj act, it is very
24 important to recognize that Europeans that have been treating
45 surface waters for some 20 to 30 years now by these advanced
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1 techniques have two factors going for them: Number one,
2 Europeans want drinking water which tastes as good as dces
3 natural, unpolluted ground waters, which do not have to be
treated. As a result of this, Europeans will not tolerate
5 any unna ural taste in the water.
6 It also happens that natural ground water that does
7 not have to be treated has a total oxidant demand nothigher
8 than .5 ppm, and therefore, whenever a European surface water
9 must be used as raw water supply, it now must be treated to
10 the seine quality as natural,.. unpolluted ground water, which
11 does not have to be treated.
12 It also must have a total oxidant demand of .5 ppm
13 or less.
14 The second major point is that the high pollution
15 levels in European surface waters were reached at a much aar1i
16 ar point in time than those of the surface waters in the USA.
17 C nseauant1y, thasa advanced drinking water traa nent tech-
18 niques have been used in Europe for a much.., longer period of
19 time than we have here.
20 The City of Dusseldorf, Germany, for ex mpla, has
21 bean using ozonation and GAC for treating river sand bank
22 filtered Rhine River water since the late 1950s. Th Europe,
23 except where high level of breakpoint CO 2 is used in the fron
24 Stages of the process, there simply no TIIM problem; and th
25 reason for this is the total CO 2 doses used in the process
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ware always lass than .5 milligrams per lIter.
2 This is because soluabla organics usually are remov-
3 ad earlier in the process using biological oxidative physical
4 chemical processes or combinations of these prior to CO 2 .
When prachiorination is practiced in Europa, then GAC is used
6 after that for dechlorination.of the water so that the residu-
7 al CO 2 is never higher than .5.
8 }Iow do the Europeans treat their surface water sup-
plies to make such high quality water without the pres nca of
10 excessive TIIMs? Firstly, they always considar that each rura
11 surface water requIres its own individual trsa ment. There
12 is no such te as a “standard” in the water treatment prcces
13 Secondly, they use many more biological treatment
14 processes early in the process than we do here. In fact,
15 Europeans actually cause aerobic bacterial growth early on in
16 the processes and sometimes on into the granular activated
17 carbon.
18 However, whenever a European plant that we have
19 looked at makes a majcr trade in their water treatment procas 1 ,
20 they always take a rather lengthy time tasting the new prcces-
21 ing. For example, the French plant at Rouen that used to tak
22 ground water and add Cl 2 to it, ncw uses a vary mcdern prOCaS5
23 involving praozonat on, sand filtering through biolog cal1y
24 active sand, granular activated carbon, followed by ozcnation 4
25 and .5 ppm of Cl 2 .
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1 This took three years of full scale pilot testing
2 bafore it was actually put in cm a full scala. Similarly, the
DC:’ plant in Nuiheim, Germany, has replaced breakpcir.t Cl 2
4 with prozonation and biologically activated carbon. This plar
was pilot tasted for two years prior to going in full scale.
6 My concern is that 18 months of tasting for GAC may
‘ be an insuffic ant time to properly study an advanced treatmer
8 process at a particular location. Oma..of the important pcin
we learned in Europa for measuring water quality after the
10 water is made in the distribution system, Europeans have to
11 rigidly enforce plate count standards for all water supplies;
12 local public health officials monitor weakly by USC, which
13 means the plants are monitored daily by USC.
14 I was appalled that we don’t have a plate count
15 standard in the USA.
16 From the point of view of granular activated carbon,
17 Europeans feel, almost to a man, that GAC must be used in mak
18 ing drinking water from surface waters. H wevar, they do use,
19 as I said earlier, biolcgical treatment processes early on in
20 the process even when they are using GAC.
21 For example, the maw plant at Rottardaia causes bio-
22 logical growth in its reservoir. A French plant in the Paris
23 suburbs i putting in a reservoir, which will be ozoriized at
24 a very low level with a two-day retention time. This has bean
25 shown in pilct work, lowered CLD by almost twothi-rds.
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German plants, taking rthjna R var watar, do t by
2 -— sand n3c filtaring, which is a biolcg ca1 procass, cut of
3 which about 75 r,srcant of DOC is biologically ramcv d. Also,
4 ths sand filtars in th front nd of tha traatm r.t procassas
5 ra many tirnas aaratad, many timas oxyganatsd, and somatirnas
6 ozonatad, to expand the aerobic biological growths in tha sand
7 f ltars.
8 They can use th objectives of th so prcc durss as
9 to eliminate this much DOC as cheaply as can be done, leaving
10 a much lower DOC concentration for the GAC to cope with.
11 I have many more comments, but they are in the writ’-
12 t text and since my time is up - -
13 (ma full statement fc1lo rs:)
14
15
16
17
18
19
20
21
99
23
24
25
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jP
JACOBS ENGINEERING GROUP INC. UKSTRE ETNW
SUITE 835
251 SOUTH LAKE AVENUE PASADENA, CAUFORNIA 91101 wASHINGTON, D.C. 20005
TELEPHONE (213) 449-2171 (213> 681-3781 TELEX 67-5458 (202) 393-0092
STATEMENT MADE JULY U, 1978 AT PUBLIC HEARING ON
PROPOSED REGULATIONS FOR CONTROL OF ORGANIC CONTAMINANTS IN
DRINKING WATER
Good afternoon ladies and gentlemen. I am Rip G. Rice, Corporate
Manager, Government Relations for Jacobs Engineering Group, a consulting,
design and construction engineering firm based in Pasadena, California.
I am also a consultant to Public Technology Inc. (PTI), of Washington,
D.C., a Director of the Technology Transfer Society anda co—founder of
the International Ozone Institute. My formal academic training includes
a Ph.D. dearee in organic chemistry. I am also a member of the AWWA,
although I disagree strongly with that portion of AWWA’s position paper
which encourages EPA to take no regulatory actions concerning orcianics
in drinking water and doing no more than RD&D until adverse health
effects are proven beyond a shadow of a doubt.
For the past three years I have been an active participant in the
PTI program, sponsored by the U.S. EPA/Office of R&D and Office of
Drinking Water, which first involved a world—wide Assessment of the
State-of-the-Art of Ozone and Chlorine Dioxide in Municipal Water Treatment
(1976-78) and more recently has involved An Assessment of Biological
Activated Carbon in Municipal Water Treatment and Industrial Wastewater
Treatment. A detailed Final Report of some 580+ pages dealing with the
technologies of ozone and chlorine dioxide for treating drinking water
currently is being printed by EPA. A first draft of the final report
dealing with Biological Activated Carbon will be submitted to EPA this
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otr, cf these assessment programs have involved detailed literature
surveys and detailed questionnaire surveys of dnnking water treatment
plants in Europe, Canada and the United States. In addition, the PTI
team made visits to some 24 European drinking water treatment plants
using ozone and/or chlorine dioxide during May of 1977, 9 Canadian
plants using ozone during August of 1977 and 12 US. drinking water
treatment plants usThg chlorine dioxide during the Fall of 1977.
During June of 1978, the P11 survey team visited 7 European water
treatment plants using the biological activated carbon process (preoxy-
genation or preoxidation of the water, followed by filtration through an
inert medium -- sand or anthracite -— followed by filtration through
granular activated carbon), 5 European industrial wastewater treatment
plants using activated carbon with or without promotion of biological
activity, and 5 European research institutes and/or universities conducting
research on the use of activated carbon and/or biological activated
carbon for the treatment of drinking water supplies.
-. The comments which I am submitting today for the EPA record come,
for the most part, from the P11 Final Report which currently is being
printed by EPA. Some information will be made based on our June, 1978
survey of European drinking water and industrial wastewater treatment
plants and will appear in the final report to be submitted to EPA this
September.
First, I will address certain of the requests for comments on the
proposed Interim Primary Drinking Water Regulations for the Control of
Organic Chemical Contaminants in Drinking Water made in the February 9,
1978 issue of Federal Register. These will be made in terms of what we
have learned during the past 2.5 years of studying European drinking
water treatment practices. It is my fervent hope that we in the U.S.A.
can learn the philosophies and modern techniques used by Europeans in
drinking water treatment, and will utilize them for the production of
wholesome, palatable and above all, chemically and bacteriologically
safe, drinking waters in the United States.
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Those who currently state that “the U.S.A. has the safest drinking
water i , the world” •are rrouthing a generality which in many cases is
also an untruth, unless they include the word “bacteriologically”
either before or after this statement. Our reliance upon large quantities
of chlorine (to guarantee bacterial safety) produces waters which cannot
be considered to be chemically safe. Were it otherwise, we would not be
meeting here today to discuss the current issues.
By way of introduction to my comments, it is important to recognize
that many Europeans (those that have been treating polluted surface
waters for 25 to 30 years) are ahead of us in treating their drinking
waters, not because of any native superiority in intelligence, but
rather because of three unique and specific factors:
1) Europeans want drinking water which tastes as good as does natural,
unpolluted groundwaters which do not have to be treated. This
means that no chlorinous or other unnatural tastes are to be in the
drinking water. Unpolluted groundwater has an oxidant demand no
higher than 0.5 mg/i.
Therefore, whenever a European surface water must be used as raw
water, it must be treated to the same quality as that of natural,
unpolluted groundwater which does not have to be treated. Thus,
treated surface waters must have a total oxidant demand of 0.5 mg/i
or below. As a result, physical/chemical and biological treatment
processes have been incorporated into the treatment of polluted
surface waters.
If a European tastes chlorine in his water, he immediately assumes
that there is some unnatural contamination present which required
the use of this excessive amount of chlorination.
2) High pollution levels of European surface waters were reached at a
much earlier point in time than did surface waters in the U.S.A.
Consequently, advanced drinking water treatment techniques have
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been in use in Europe for a i nger period of time than in North
America. The city of Düsseldorf, Germany, for example, has been
using 6zonation and. granular activated carbon for treating river
sand bank filtered Rhine River water since the late 1950s.
3) Nearly all European countries have at least one major water research
center whose function it is to study and understand the applicability
of all methods o1 treating drinking water. These institutes also
conduct research on materials of construction for water treatment
plants, specify standards for equipment performance, develop analy-
tical procedures and do pilot testing on raw waters for the various
water treatment plants or municipalities who are their sponsors.
The Netherlands has two institutes, one a Federal government institute
charged with controlling the quality of raw water going into the
treatment plant and the other sponsored by waterworks, charged with
controlling the treatment processing inside the water treatment
plants. -
Solicited Comments
I. MCL For TTHMs
1) Phasing of the Regulations: — My personal feeling is that if TTHMS
in drinking water are cause for concern (and I believe that they
are) for half the U.S. population, they also should be cause for
concern for the other half as well. Regulations should be applied
as broadly as possible.
I do not believe that the TTHM regulations should differentiate
between the water sources so much as between the water treatment
processes . TTHMs are produced during the treatment process by the
action of chlorine upon an excessive amount o-f THM precursor. If
treatment process modifications focus upon reducing the concentra-
tion of THM precursors before chlorination, then less chlorine will
be necessary and excessive amounts of TTHMs will not be formed.
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2) : r.1t de of the MCL at 0.1 mg/i : In Europe, except where breakpoint
chlorination is employed for ammonia removal, th r simply is no
TTHM problem. The major reason for this is that total chlorine
doses for terminal disinfection are never more than 0.5 mg/i. This
is because soluble organics usually are removed using biological,
oxidative, physical/chemical or combinations of these processes
before chlorination. This approach lessens the amount of chlorine
required to be uséU and prevents the appearance of chiorinous
tastes in European drinking water.
There is also a much wider use of chlorine dioxide rather than
chlorine, for carrying a residual disinfectant in European distri-
bution systems than in the United States, again at total dosage
levels of 0.5 mg/i and below. Chlorine dioxide does not react with
ammonia and in the pure state, does not produce THMs from THM
precursors. It is, however, a powerful oxidant, and it does form
organic oxidation products, some of which contain chlorine, depending
upon the particular organics present, reaction conditions, method
of preparing the chlorine dioxide, etc.
When prechiorination is practiced in Europe, then granular activated
carbon usually is incorporated into the treatment process, specifi-
cally for dechlorination of the chlorinated water.
Applying the concepts of Public Law 92-500 to our current drinking
water situation, since “Best Practicable Control Technology Currently
Available” in Europe produces non—detectable quantities of-THMs, my
personal opinion is that the proposed level of 0.10 mg/i of TTHMs
in our drinking waters is much too high, and we should reduce these
concentrations to undetectable levels, since technologies are
available to do so.
How do Europeans treat their surface water supplies to produce high
quality drinking water without the presence of excessive amounts of
THMs? Basically, the Europeans do not use breakpoint chlorination
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:o prevent bacterial growth cr& their sand filters. Their reasoning
is th biological degradation of those organic components of raw
waters that are biodegradable is beneficial. Firstly, these
biodegradable organics exert a higher than necessary chlorine
demand if allowed to remain in the finished water. This will
require more than a 0.5 mg/i chlorine dosage for protection of
water in the distribution systems, and chiorinous tastes will be
noticeable by the consu iiers. Second, biological treatment of raw
waters occurs in the ground and in surface waters and is viewed as
a natural water treatment process. Addition of chemicals is viewed
an an unnatural process. Finally, biological processing is inherently
cheaper than physical/chemical processes, as a general rule.
3) Timing of Treatment Modifications: - Eighteen months may be sufficient
time for most impacted systems to take steps to come into compliance,
as the regulations currently are proposed. However, it is cormion
practice for European plants making significant changes in their
water treatment processes to conduct lengthy pilot testing programs.
-. For example, the French plant at Rouen used to draw well water and
add 0.5 mg/i of chlorine dioxide to it as it went to distribution.
However, increasing pollution of the wells (including current
levels of 2 to 5 mg/i of ammonia) required that a totally new
process be installed.
The new process at Rouen involves preozonation, sand filtration,
GAC filtration, post-ozonation, then addition of up to 0.5 mg/i of
chlorine. This process (which is the first Biological Activated
Carbon process in France), converts arrinonia bio1ogica11 to nitrate,
thereby avoiding the need to employ breakpoint chlorination. Some
of the dissolved organics also are made biodegradable by ozonation.
The process has been operating successfully at Rouen since January,
1976, and the 75 cm deep GAC beds have not had to be regenerated as
of June, 1978 (29 months).
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The BAC process was piloted at Rouen for three years :efcre it was
installed on fy11 scale.
Similarly, the standard treatment process at the Oohne plant in
MUiheim, Germany, included breakpoint chlorination (for ammonia
removal) followed by coagulation, filtration, then GAG for dechlori-
nation. The né , BAC process replaced breakpoint chlorination and
was installed in April, 1977 after pilot testing had been conducted
for two years. BAG filters at MUiheirn have operated 8 months
without regeneration. Under the older, breakpoint chlorination
procedure, the GAC columns had to be regenerated every 6 to 8
weeks.
As of June, 1978, MUiheini was in the process of pilot testing the
preozonation/GAC process for installation into two of their other
plants.
6) Use of Standard Plate Count As An Indicator Of Microbiological Quality -—
I learned during my participation with the PTI programs that Europeans
have a rigidly enforced SPC standard for all water supplies. Local
public health officials monitor public distribution systems at
least weekly for SPC, which means that water treatment plants in
Europe measure Standard Plate Counts and E. coli at least daily.
I was appalled to learn that in the United States we don’t even
have a plate count standard. If we are to reduce levels of chlori-
nation in order to reduce chemical pollution of our drinkTng waters,
then we must apply standard methods for controlling biological
quality.
II. Treatment Technique
1) Applicability to Systems Serving More Than 75,000 People: - Every
U.S. citizen should be afforded the protection available to him or
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ner of :he ica lj b cteriologically safe drinking w :ar
supply. Again, protecting only half the public is doing only half
the job. Since each water supply plant is unique (in terms of raw
water and its contamination), each treatment process should be
different, in terms of producing a high quality drinking water.
The concept of safe drinking water should be applied to all systems,
not to just a portion.
2) Use of Variances: — The proposed variance technique is a good one,
for it provides the necessary flexibility for each impacted water
supply system to study alternative treatment techniques which may
be more technicically effective and more cost-effective for each
particular raw water supply situation than installing GAC, especially
if GAC is not needed. One of my major concerns with EPA’s proposed
regulations is that a water supply system impacted by the proposed
SOC regulations is mandated to pilot test GAG. There may be suffi-
cient time to test GAG, but there is not sufficient time to test
alternative processes after GAG is piloted. In other words, an
impacted system has only one roll of the dice —- either pilot
GAC and gamble that it is the technique most appropriate for its
particular needs, j pilot test a promising alternative and gamble
that this method will be as effective as GAC, or j pilot test both
at the same time. The situation will be compounded further if an
impacted system finds two promising alternative processes available
to it, in addition to GAC.
EPA’s final regulations concerning variances should allowfor
adequate pilot testing of promising alternative processes which may
provide the best long range answer for impacted water supply systems.
Perhaps interim measures for improving local drinking water quality
could be allowed on an “interim permit” basis while more lengthy
pilot studies are being made. These exceptions should be made on a
case—by-case basis where the local circumstances of raw water
analyses, size of system affected, financial, technical personnel
constraints, etc., warrant.
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Such an ‘interim permit t-cçrarn, would prevent impacted systems
from embarking on permanent pilot L.sting programs for the purpose
of avoiding the regulations.
3) Replacement of Existing Filter Media With GAC: — This should depend
entirely upon the individual circumstances, and should be left up
to the impacted system, with concurrence of the EPA. In cases
where raw water supplies contain THM precursors and other organic
compounds which are, or which can be converted into, readily biode-
gradable materials, conversion of currently prechiorinated rapid
sand filters into biologically operating sand filters will remove
much of the chlorine-demanding material (as well as convert ammonia
to nitrate biologically). In such cases, requiring a system to
replace its sand filters with GAC will remove one of its promising
alternatives.
Current rapid sand filters can be converted into biologically
operating slow sand filters by ceasing the prechlorination, substi-
tuting aeration, oxygenation or ozonation, slowing the rate of
filtration and providing means for air backwashing, prior to water
backwashing. In some cases these requirements will necessitate
redesigning and constructing new sand filters, thus each case
should be evaluated on the basis of its own local constraints.
5) The 3 Criteria Specified For GAG Treatment: - In general, it has
always been my feeling that the criteria which should be applied to
th,e operation of GAC and to the determination of when it should be
reactivated are logically related to the specific purpose for which
it is installed. It is well-known that many U.S. and European
water treatment plants are using GAC for taste & odor control. The
tests for indicating reactivation or replacement are taste and odor
tests entirely. When there is breakthrough 0 f taste or odor, the
carbon is reactivated or replac&d. Useful lives of up to 4 or 5
years are usual with GAC media used for this purpose, here and in
Europe.
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Witn respe:t tc the currently proposed regulations, there are
basically four purposes for which water treatment systems will
consider using GAC:
a) To remove TTHMs
b) To remove THM precursors
c) To remove SOCs
d) To remo e combinations of a), b) and/or c).
The second situation is a special case of the first, in that removing
THM precursors before chlorination will reduce the potential to
produce TTHMs during later chlorination.
Studies conducted by EPA ’s MERL in Cincinnati, by several U.S.
drinking water supply systems, and by many European research insti-
tutes and academic institutions have shown that when GAC is used
specifically for TTHM adsorption, its useful operational life is
short -— on the order of 6 to 8 weeks (for purposes of these arguments
I am assuming here the GAC bed sizes, empty bed contact times and
other operational parameters as cited by EPA). On the other hand,
when used to adsorb SOCs in the absence of THMs, the useful life of
GAC media is longer, on the order of 4 to 6 months, depending upon
the specific SOCs present in the local water.
The cities of DUsseldorf, Wuppertal and Duisburg, all in the vicinity
of Düsseldorf, Germany, must reactivate their GAC columns every 5
months or so. The purpose for GAC in these plants is removal of
organics, but those which break through the GAC columns first are
the chlorinated organics (which are not THMs and which are present
in the raw waters (sand bank filtered Rhine River). Because chlori-
nated organics break through the GAC columns first, the Germans
have developed a series of Total Organic Chlorine tests to ascertain
when their GAC is ready for reactivation or replacement.
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However, the TOC1 tests used by the r ns are not based simply on
analyzing the effluents from the GAC columns. Rather the Germans
also analyze the GAC itself for TOC1 at various places in the
columns. When the level of TOC1 increases in the lower part of the
GAC columns, most of the GAC is removed and sent to reactivation.
Some of the GAC is left in the columns during reactivation because
itEontains aerobic bacteria which are beneficial to the water
treatment process, especially with respect to ammonia conversion.
These bacteria take considerable time to establish with virgin or
freshly reactivated carbon. Leaving about 20 to 25% of the GAG in
the columns allows the biological activity of regenerated GAC to be
reestablished within a few days, rather than a few weeks.
If GAG is to be used to remove TTHMs (or TTHMs in combination with
SOCs and/or with precursors), then the life of the GAG media will
be the shortest (6 to 8 weeks). Since THMs are not readily biode-
gradable, nor readily converted to biodegradable . derivatives, they
will break through the GAC columns or beds faster thanwill other
chlorinated organic materials. Therefore, when GAC is to be used
specifically for removing TTHMs (or TTHMs in combination with other
types of organics), the criteria for regeneration should be TTHM
breakthrough into the effluent.
If GAC is installed specifically to remove THM precqrsors and there
are no SOCs of concern in the raw waters, then in theory, the
indicator of GAG reactivation should be the breakthrough of THM
formation potential. However, if biological activity is,promoted
on the GAC media and conditions are established so that much of the
THM precursor is removed biologically in these media, then the
amount of chlorine used to provide adequate residual for the distri-
bution system should be sufficiently low so that very low levels of
TTHMs will be produced. This is the situation in many European
water treatment plants using biologically active sand or biological
activated carbon. If such performance conditions can be established,
then one indication of breakthrough will be a marked increase in
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c iorine c : of the biologically active sand SAC) effluent -.
with attendent production of THMs.
If GAC is installed for the purpose of removing THM precursors and
there are other SOCs of concern present in the raw waters (such as
chlorinated organics, not TTHMs), then breakthrough of either the
SOCs of concern or of THM formation potential (as evidenced by
increase in chlorine demand) should be the controlling parameter
for GAC reactivation.
6) Variances for Certain Raw Water Sources: - Assumptions that raw
water sources such as the Great Lakes, deep ground water and protected
surface waters would more readily justify variances from the SOC/GAC
requirement should be considered just that ... assumptions. There
are water intakes in the Great Lakes which are located near the
confluence of industrially and agriculturally pollutedrivers. The
raw water quality of the lake waters at these intakes is strongly
influenced by the quality of rivers discharging into those Great
Lakes. It seems more pertinent to first insure that the SOCs of
concern in raw water supplies are absent...and this can only be
ascertained by analysis. Only if there are no toxic substances
present should a variance be granted. The’likelihood is that those
raw water sources mentioned will be granted-variances, but there is
no guarantee of the absence of toxic materials.
In this regard, many European drinking water treatment plants
monitor either their raw water sburces or their product drinking
waters biologically for toxic materials. Most of these biological
monitors involve the use of freshwater trout, which are very sensitive
to the presence of small amounts of toxicants. For example, 0.5
mg/i of residual chlorine is sufficient to adversely affect these
sensitive trout. Aquaria of trout are placed most often at the end
of the water treatment process, but before chlorine or chlorine
dioxide is added. If prechiorination is employed, GAC is used to
dechlorinate, and the health of trout is a measure of the dechlori-
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nation efficiency of the GAC. If the trout show any behavioral
abnormalities,, then the plant is alerted to the presence of possible
toxicants in the water, and detailed analyses can be made at that
time.
Many times trout are placed in the plant raw waters for the same
purpose. The situation is similar to the use of canaries to
detect the presence of methane or carbon monoxide in underground
coal mines.
8) Alternative Treatment Techniques: - GAC probably is the best single
treatment technique currently known for reducing levels of a broad
spectrum of organic chemicals in drinking water. In fact, most
European water works chemists, engineers and plant managers have
advised the PTI survey team that they do not believe that surface
waters can e utilized for preparing drinking waters without incor-
porating GAG into the process.
On the other hand, pretreatment of plant waters before the GAC step
is very important to allow the activated carbon to perform its
function(s) most efficiently and at lowest cost. The P11 survey
team is unaware of any European water treatment plant currently
using GAG in place of sand filtration. Some research performed in
The Netherlands on this subject showed that when GAC was substituted
for sand, it was necessary to backwash the carbon more frequently.
We are only aware of GAG columns or beds which follow sand or
anthracite filters.
In those European drinking water treatment plants utilizing GAC, it
is also common practice to precede GAC filtration with a biological
treatment step and even to include a biological step in the GAC
process itself. Thus the new plant at Rotterdam promotes biological
treatment in its raw water reservoir, to maximize the removal of
THM precursors. Processing in the new plant (which is only one
year old this month) involves ozonation, followed by anthracite
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fi ration, then GAC filtration then chlorination. During the PT1
survey team’s visit to Rotterdarn and Amsterdam this past June, we
were advised by the two Dutch Water Research Institutes that 18
Dutch plants currently are pilot testing GAC processes. Holland is
a country about the size of the state of New Jersey.
It is also commôh European practice to promote biological reactions
in the sand filter. This is done by avoiding high level prechiori—
nation and substituting aeration, oxygenation or ozonation. The
function of air or oxygen is simply to add dissolved oxygen to the
water to promote aerobic bacterial activity. Ozone serves to
aerate the water, but also to convert some of the non—biodegradable
organic materials into oxidized organic materials which now are
biodegradable. Recent experiments at Stuttgart show that multiple
applications of chlorine in pretreatment and in conjunction with
aeration also serve to promote biological activity in the sand
filters.
Benefits obtained using biological sand filters include not only
removal of some dissolved organic materials, but also conversion of
ammonia to nitrate ion. Recent data obtained in German and French
plants using biological activated carbon processes show that about
80% of the total nitrification obtained in the plants occurs in the
sand or anthracite filters preceding the GAC.
In Germany all plants taking water from the Rhine River do so by
drilling wells into the sandy soil in the river banks. As’ Rhine
River water passes through these river sand banks (average detention
time is 21 days) considerable biological degradation occurs, and
about 70 to 75% of the original dissolved organic carbon is removed.
The most difficult to remove DOC remains for the treatment processes
to cope with, and most of these involve ozonation followed by
anthracite, then GAG filtration.,
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Tn :: :: ve of all of these pretreatment procedures is tc eliminate
as much of the easier-to-remove organic contaminants as cheaply as
possible, leaving a much smaller dissolved organic carbon concentra-
tion for the GAC to have to contend with.
Additional Comments
1) List of Synthetic Organic Chemicals: — I believe that EPA’s entire
list of Toxic Substances should be cited as the Synthetic Organic
Chemicals of concern in these regulations. As the Office of Toxic
Substances adds to or deletes specific compounds from this list,
the Office of Drinking Water also should add to or delete those
same materials from the list of SOCs in drinking water to be treated.
2) Costs of Water Treatment in Europe: — EPA’s major charge to PTI
regarding this subject was to determine costs for the ozonation and
chlorine dioxide substeps currently employed in drinking water
processing. Nevertheless, we ascertained that the total costs for
producing water at the plants in Europe using such advanced treatment
sequences as microstraining,.ozonation, granular activated carbon
and chlorine dioxide for residual are on the order of 35 to 5O
per 1,000 gallons. For example, at the 13 mgd Rouen plant in
France, which uses preozonation, sand filtration, biological activated
carbon, post—ozonation and residual chlorination, for example,
costs to produce water are about 43 /l,OOO gallons.
Prices of water to European consumers are considerably higher,
however, sometimes by factors of 4 to 5 times, because profits from
water sales often are used to subsidize other municipal activities,
including mass transit systems.
3) Oxidation Products of Organic Materials: — One part of the PTI
survey of ozone and chlorine dioxide technologies in drinking water
treatment was to conduct a detailed literature review on the subject
of oxidation products of organic materials obtained using ozone or
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chlorine dioxide under ec s ccnditions. We found a surprising
similarity of oxidation products obtained from ozone and from
chlorine dioxide. In addition, we also found many similarities of
the non-halogenated oxidation products known to be obtained from
chlorine.
It is well known, that when chlorine reacts with organic materials
as an oxidant (mea4-ing that it does not react by addition or by
substitution, thereby incorporating halogen atoms into the organic
materials), more than 90% of the oxidation products are not halo-
genated. The mechanism of the haloform reaction itself, for example,
involves formation of one molecule of trihalomethane along with one
molecule of a non-halogenated organic acid.
We also found articles showing that the oxidation of oleic acid (a
long chain aliphatic fatty acid containing an isolated double bond)
with ozone, chlorine dioxide or chlorine can produce the epoxide,
albeit in very small quantities, along with other oxidation and/or
chlorination products, depending upon the oxidant employed.
The point we are making here is that water treatment personnel
should regard these findings as further confirmation that organ1
materials should be removed from the water supplies to the extent
feasible and economically practicable before addition of whatever
oxidant is used. There should be little fear of using “new” oxidants
in water supply systems (potassium permanganate, chlorine and
chlorine dioxide have been used for years in the U.S. and these
same oxidants plus ozone have been used for years in European and
Canadian water supply systems for years). What should be feared is
the presence of unidentified organic compounds in the water being
treated with these oxidants. Any of these organic compounds
can form an undesirable derivative, say an epoxide, then that
epoxide probably can be formed to some extent by using oxidant.
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i irig also support the con pt of incorporating biological
treatment process steps after oxidation of or; nic compounds. Our
literature survey found that ozone is the most powerful of all
oxidants currently being used in treating water (only elemental
fluorine has a stronger oxidation potential). Yetonly rarely does
ozone, under conditions normally employed in drinking water treatment
plants, i.e., 1 to 5 mg/l dosages for total contact times of up to
30 minutes, oxfdize organic materials completely to carbon dioxide
and water. it car; be concluded, therefore, that if ozone, the most
powerful oxidant used in drinking water treatment processing, will
not convert organic materials to carbon dioxide and water, neither
will any of the other oxidants used.
This implies that if the water treatment plant chemist could know
the identity of all the organic chemicals present in his raw waters,
he could predict the oxidation products he would be likely to
obtain upon the use of a particular chemical oxidant. Unfortunately,
the day when the plant chemist will know all of these factors still
is a long way off.
What can be utilized at this point in our learning is the fact that
oxidation of organic compounds produces oxidized organic compourfds
which are more biodegradable than before oxidation. This is why
the Swiss observed slime growths in their distribution systems when
they first installed ozonation in place of terminal chlorination in
the late 1950s. Oxidized organic materials in the ozonized waters
plus the higher dissolved oxygen levels provided a garden of Eden
for bacterial regrowth.
As soon as this point was recognized, the Swiss began introducing
small amounts (0.5 mg/i) of chlorine or chlorine dioxide after
ozonation, and the slime growth problems in their distribution
systems all disappeared.
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For t es r sons, when drinking water suppThes contain high levels
of dissolved organic materials, the concept of preoxidation followed
by a biological treatment step is effective. Our U.S. water supply
systems using prechiorination at high levels are performing the
preoxidation function (and are also forming THMs, sometimes in high
concentrations) but are eliminating the potential benefits of
biological treatment after the preoxidation by simultaneously
killing the rnicro rganisms. When low levels of chlorination are
employed, however, the preoxidation function is performed, THMs are
not produced in high concentrations and biological activity still
can occur, provided that the bacteria are given a place to congregate,
sufficient dissolved oxygen and sufficient time to degrade the
dissolved organics and/or to convert ammonia to nitrate.
It is my conclusion from these studies to date that judicious
selection of the proper chemical oxidant applied at the proper
point(s) in water treatment processes can promote beneficial aerobic
biological activity in U.S. drinking water supply systems, which
can result in the lowering of chlorine demands, lowering of THM
formation and removal of some (but certainly not all) of the
synthetic organic chemicals of d’oncern to us today. Once those
materials which can be degraded biologically have been removed,
then the remaining biologically refractory organic compounds are
left for the more costly physical/chemical treatment technique to
cope with. In this manner, the more costly treatment techniques
will not be wasted on treating contaminants which can (and should
be) removed more cost-effectively by other pretreatment processing
steps.
4) Misunderstandings About Bio1ogic l Activated Carbon: - I was only
able to attend the recent meeting of AWWA in Atlantic City for one
day and one night, but I heard many statement about the potentials
for the Biological Activated Carbon process which reveal misconceptions.
I would like to try to set the record straight on this point.
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Biological Acti ’a:e Carbon, BAC, can involve ozonation of the
water to convert those dissolved organics which are non-biodegradable
into dissolved organics which are biodegradable. If all the dissolved
organics present already are biodegradable, then ozonation is not
necessary. Simple aeratiàn or oxygenation will provide sufficient
dissolved oxygen for the bacteria to degrade these organic materials.
But not all disso ved organics can be converted into biodegradable
organics by simple ozonation. Examples of such refractory organics
are the THMs. There is very little, if any, reaction between ozone
and chloroform, other than physical stripping of the volatile
chloroform out of the water and into the contactor off-gases.
Aeration alone will accomplish the same degree of TTHM “removal”.
Non-oxidized chloroform will be adsorbed onto GAC and will not be
degraded biologically at any reasonable rate. As a result, the
only benefit that will accrue to the plant that ozonizes water
prior to GAC adsorption specifically for the removal of TTHMs, will
be that amount of TTHM removal achieved during the aeration step.
In other words, to prolong the useful life of GAC installed solely
for the removal of TTHMs, simple aeration will be as efficient as
ozonation.
Other organic materials which contain lower halogen-to-carbon
ratios in their elemental composition will be more biodegradable
and/or will be more readily converted to oxidized materials which
are more biodegradable by pretreatment with ozone or other oxidants.
In such cases, the amount of oxidative pretreatment employed as
well as the GAC medium designed and operating conditions will be
critical in establishing the optimal biological activity necessary
to give the maximum performance of the GAC media and the longest
extension of useful life, consistent with economics.
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At five of the water wor s in the C se orf, iermany, area hich
treat river sand bank filtered River Rhine water, chlorinated
organics break through the biologically active, preozonized GAC
columns about every 5 months, and the carbon beds have to be regene-
rated at that time.
On the other hand, THM precursors are humic and fulvic materials
which do not cont in significant quantities of halogens, and which
can be easily converted into rapidly biodegradable materials by
preoxidation. It is in this situation that BAC should provide its
full potential of extending the operating life of GAC media.
Thus it is incumbent upon a water supply system first to ascertain
thich organics it intends to remove by using GAC. If THMs are the
major contaminant, then modification of the treatment process
probably will be more successful than simply installing GAC. In
this case it is certainly better to prevent the formation of THMs
than to produce them and subsequently have to remove them.
The BAC process probably will find its greatest potential in removing
THM precursors, along with dissolved organics which are or can be
readily converted by oxidation into biologically degraded compot.inds.
Thank you for the opportunity to make these comments concerning this
most important subject.
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1—294
1 DR. COTRUVO: Could you summarize any observations
2 you hays had in your -— upon any adverse affects from these
3 GACs? Have they had problems with excessive bacterial growth,
4 excess metals in the finished water, anything at all along
5 those li as?
6 DR. RICE: We could not sac any adverse affects in
7 the distribution systems. As I say, these are monitored ragu-
8 larly and analyzed. Distribution systems there are short and
9 water temperatures are reasonably cooler than they normally
10 era hare.
11 Any biolcgical ragrcwth does not appear as rapidly
12 as it might here.
13 Tha major disadvantage -— or tha major problem we
14 found w±th GAC installations over there simply was the wrong
15 kinds of coatings [ in ide tha GAC context. In the early days
16 there were instances, of high ccrrosion inside the columns and
17 beds. But with modern coatings, that does not seem to be a
18 problem.
19 There are problems in. which GAC should be used f r
20 what processing, what process —- nobody over there u es GAC,
21 GAC for TIIM, because they don’t have that sort of problem.
22 They do use it for SOCs, and I would imagine they would b
23 precursors, when we get down to the final analysis; butthey
24 did not know they were doing this.
25 DR. COTRUVO: What kind of physical or chemical
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I parameters are they using to deta nine when their carbon b ds
2 exhausted?
3 DR. RICE: Since they are using it for THM -— were
4 they to use it for TEN, they would take TEN breakthrough,
5 which is. a rather short time. Along the Rhine in Dusseldorf
6 what breaks through the granular activated carbon first are
7 the synthetic organics which are halogenated.
8 They have deva].cpad a series of TOCL, Total Organic
9 Cl techniques, not just analyzing TOCL in the carbon column,
10 but analyzing on the carbon itself. They will sample, at the
11 top of the column, in the middle and towards the bottom, and
12 when TOCL builds up towards the bottom of the carbon, that is
13 the signal to reactivate the carbon.
14 DR COTRtJVO: Is there some numeric level that they
15 have determined?
16 DR. RICE: Not necessarily. At Dusseldorf they have
17 biOlogical activity in the carbon column which has bear. b n-
8 ficial. What they ought to do is fully exhaust the carbon col
19 umn and take all of the carbon out, because then they have to
20 put virgin carbon back in, and the biology takes a reasonably
21 long time to work up to equilibrium.
22 What they do is —- one, the TCL gets down to around
23 75 percent of thaway, then the two two-thirds or three-
24 quarters goes out for regeneration, new carbon gces back in;
25 it is all mixed u and the bottom of the carbon column, which
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1 is biologically active, acts as seed, and biological act±vity
2 is reattained in a day or two. That is what their signal is.
3 DR. COTRUVO: Do you have some kind of indication oi
4 reactivation frequencies that they typically achieve for remo
5 ing synthetic chemicals?
6 DR. RICE: Dusseldorf,and the five plants we know
7 of in that area drawIng water from the Rhine, have to reacti-
8 vate their GAC about every five months. This is because TOCL
9 is in the raw water, and there is not much you can do with
10 that.
ii Right next to Dusseldorf is Neuhaim, which takes it
12 water from the Ruhr. They are operating biologically activate
13 carbon on water which does not have the high TOCLs as the
14 Rhine does. That process bacams full scale, operational ther,,
15 In April of ‘77, but they made a change in the carbon last
16 October. They have been operating ever sInce than, which is
17 about eight months now, on that same carbon without having to
18 reactivate.
19 Rouan, in francs, put in the biological processing
20 system in January, 1976. They have beers operating since then
21 and as of June of this year, which is two and a half years,
22 they have not had to regenerate that carbon, and that is a
23 fairly long time.
24 It- depends on what is ix the rural water, which is
25 why I say we have to know what we are going to use the carbon
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1 for. If you have TOCLs in the carbon, which are not readily
2 degradable and not made biodegradable by oxidation, than they
3 are not going to biodagrade off of the carbon and reactivate
4 the carbon. By that procedure, they will break through and
5 go on.
6 But my conclusion is that in the case of the Th 4
7 precursors only, th ra are no TOCLe and there are no ThN alma
8 formed -- these precursors, which are cumics and fubics, can be
made biologically, breakdownabla readily by oxidation. And I
io would think that the biological processes, biologIcal sand,
ii or biological carbon afterwards, if there are some TOCLS, SOCs
12 in thara, would be effective.
13 What the reactivation times —- you would have to do
14 it at the site, one at a time and not on a national basis.
15 MS. CHANG: Thank you, Mr. Rice.
16 Patricia Nasbltt.
17 STATEMENT O PATRICIA M. NESBITT, ENVIRONMENTAL
18 CONSULTANT AND PROFESSOR, SHENANDOAH VALLEY, VIRGINI
19 MS NESBITT: Good afternoon.
20 My name is Patti N sbitt, and I live in the Shenan-
21 doah Valley of Virginia, where I won as an environmental con-
22 sultant and a professor in our state-sponsored community ccl-
23 lega. I come here today as a ccncerned citizen, deeply concar
24 ad about thaquality of our drinking water.
25 I have worked for nearly 10 years with water and
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1 and sewer issues and have constilted with varIous Gverr inetta1
2 agancias including the Environmental Protection Agency, the
National Commission on Water Quality, the U.S. Genaral Account
ing off ice, and very recently, the National Scianca Eoundation
on their community water management program.
6 The last year I have spend almost exclusively re-
7 searching and writir g a book commissioned by Rodale Press on
8 quality of our drinking water and how it affects our
9 health. I have also worked with our town council over the
10 last year in the town of Strasburg Virginia -- 2,500 pcpulatio
11 -— in securing adequate water and sewer services to meet our
12 ccinmunity 1 s needs.
13 I should add, even in a community of 2,500 people,
14 our people are very concerned about the quality of cur water,
15 regardless of what it costs.
16 In addition to these qualifications, I am also a
17 member in good standing of th American Water Works Associatic
18 although I do not represent the AssociatiOn. In fact, I want
19 to disassociate myself from the opinions of most of my col—
20 leagues in AWWA, because of their staunch opposition to the
21 proposed standards.
22 Their blatant and unrelantless attacks on the pro-
23 posed standards ].aad me to wonder if the watarwcrks i idustry
24 is trying to protect the public’s right to drink risky water.
25 It is my contention, in direct opposition to what the AWWA
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1 says, that the general public is concerned about safe water
2 nd we are willing to pay for it.
3 Wa already have paid $4.1 billion to clean up our
4 municipal wastes in order that our waterways can be portected.
5 The proposed standards for organics in drinking water, astimat
6 ad to cost only about one-fifth of that, are a bargain in corn-
7 parison, especially when you consider that we the people, not
8 the fish, are the direct beneficiaries of that expenditure.
9 I believe the american people agree that there is a
10 need to remove organic contaminants from our drinking water --
11 the souring sales of unproven point-of-usa devices and bottled
12 water is proof enough that many people do care about protect-
13 ing their health and that they ara skeptical of their water
14 suppliers’ claims of safety.
15 The cost of granular activated carbon treatment is
16 an obvious social cost of our modern industrial economy.
17 Because we allow all sort of exotic chemicals, heavy metals,
18 and various other wastes to be dumped into the same waters
19 that we drink from, it is hardly surprising that we have to
20 remove them before we drink it.
21 Our waste treatment practices do not remove these
22 toxins, and pretreatment standards have been very lax in corn-
23 ing about, while every effort shotild’ be made to prevent them
24 from entering our waters, our health is endangered now and it
25 must be protected.
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1 Similarly, research and development on new ways of
2 providing disinfection without the cancerous by-products of
3 THM’s should be expanded. In the meantime, the proposed stand
4 ards are a good first step in ccming to terms with the environ
5 mental ha lth costs of our chcsen way of life.
6 I am concerned that the cost of GAC treatment will.
7 present another unbearable financial burden on some members of
8 our society, particularly those with low or fixed incomes,
9 unless a lifeline rate structure is instituted. Rate struc-
10 tures should also encourage water conservation, which a life-
11 line would do.
12 Federal loan policies for conmiunity water systems,
13 such as those used by the Farmer’s Home Administration,
14 should recuira use of water rates that discourage h!gh water
15 consumption.
16 In closing I want to say that the preventive action
17 that these standards represent is in the best interests of the
18 American people. I hope that the means to apply these stand-
19 ards to all water systems can be found. The ris of daganera-
20 tiva diseases in this country is alarming, and I fear we have
21 only begun to see the beginning of it. Every measure we have
22 that will prevent and/or lessen the h a1th costs of our way
23 of life should be taken.
24 The Environmental Protection Agar 4 cy deserves support
25 and congratulations for taking these. steps.
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I MS. CHANG: Thank you.
2 Any questions?
3 MR. JORLING: Patti, is your research on your book
close to a point where you have any summary conclusions on
5 your g ieral survey of the quality of drinking water?
6 MS. NESBITT: Maybe you could be more specific. It
7 is fairly close to completion. My general sense of it is that
8 since we don’t know enough about the health affects, long- arin
9 low-exposure effects of various toxins in the envircnmant and
10 they synergistic affects of them, that every precaution shoul
ii be taken.
12 Since we can control the drinking water, wharaas w
13 can’t control, to a large extant, the food and air we breathe,
14 and all the sorts of other environmental routes of exposure,
15 it seems to me that that is a definite step we ought to take.
16 MR. JORLING: Doss part of the work ycu have been
17 doing accumulate any data on use of bottled water or home tree
18 mant devices, either regionally or natio l1y?
19 MS. NESBITT: I have not been able to get that data
20 from the manufacturers or from the consumers. As soon as I
21 get it, I will let you know.
22 MS. CHANG: Thanks a lot.
23 Before we break for dinner, we have Dr. Schlcsser
24 and Hymen, from the N w Orleans Sewerage and Water Board. I
25 understand that while Dr. Schlcsser is speaking, there will b
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1 sattir.g up of slides.
2 STATEMENTS OF JOSEPif E. SCELOSSER, CLINICAL PROFESSOR
AND THERAPEUTIC RADIOLOGIST AT TULANE UNIVERSIT?,
REPRESENTING THE NEW ORLEANS SEWERAGE AND WATER
5 : BOARD; AND EDt 7ARD HYMAN, H • D., NEW ORLEANS, AS AN
6 INDIVIDUAL
7 DR. SCHLOSSER: I am a clinical profassor and there-
8 peutic radiologist at Tulane University. My er.tira prof ssior.
9 al career has been devoted to the study and treatment of canca
10 as well as research in cancer. I like to say I was involved
in the problem before it became fashionable.
12 First of all, I would like to say that in picking up
13 one of the reprints by Dr. Epststain, I noticed that he quotas
14 m c by saying -- I suppose this was from the New Orleans meetin
15 -— “The alleged dietary ef fact of seasonsad, South Louisiana
16 Cejun cookIng, in the words of Dr. Joseph Schlôssar, at the
17 Tulane Medical School, would likely be of greater significance
18 to whitas than toBlacks.’ t I did not allude to the fact that
19 it had any correlations between dietary Cajun cocking and can-
20 cer. We thrawthis in as onepossibility in explaining a larg
21 number of pcss bilitias as to the cause of cancer in Lcuisian
22 Whether it was the chemical Industry, or the water
23 air pollutIon, or diet, or anything else, we have no correlat d
24 infcrmation on any of this, and that has been my point.
25 The question is, Do we have a problem? New Orleans
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1 d Louisiana affords an excellent opportunity to study th
2 relationship of cancer to drinking water, and indeed, was one
of the first places to be singled out as a region of high 1ev 1
THNs in the raw organics in the Mississippi River water.
5 Further, cancer mortality rates in Louisiana exceed
6 the national averages. So we base - - and we do have a problen
with cancer, but is it associatad with drinking water? Astü y
8 of the geographical distribution shows that the largest mci-
dence of cancer is in the southern protion of Louisiana, bor-
10 deririg on the Gulf Coast, in parishes or counties that have
marshy coastal waters over large areas at sea level, with
12 high humidity.
13 Of the increased incidanca of cancer, 85 percent is
14 due to a high incidence of cancer of larynx, trachea and lung.
15 ma remainder of the increases are due, in a small part, to
an increase in cancer of the pancreas and gastro CA, both in
17 Black males and females.
18 This is a peculiar statistic and distribution that
19 we have, that we should have gastric CA increase in Blacks,
20 and there might be a logical reason for this if we knew what
21 it was. There is no incidence of increase in bladder cancer,
22 which would be expected if water contaminants ware to blame.
23 There.is no correlation between sex and race or source of
24 water supply that Ihava been able to determine. So the prcb-
25 lam cannot ha corra1at d with drinking water.
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I The second question is, Is the concentration suffi—
2 ient, concentration of organics in the drinking water suffi-
3 ciently high to be considered a hazard? We have heard endless
4 discussions about threshold affect, and I do kflow that there
5 is threshold affect for activity in radiation, particularly in
6 terms of carcinoganesis. That is, there is no threshold for
7 radiation. The question of threshold affects in carcinogens
8 we will have to take on faith, unless w&wara able to test
9 hundreds of thousands of animals.
10 At any rate, even assuming that there was no thres-
ii hold effect for carcinogens as there is for radiation, there
12 still is a level of dosage at which any instance of carcinoma
13 must be so low that it is hardly detectable; so I question thi
14 concentration.
15 However, I would be rather concerned were we to have
16 any data showing concentration of these carcinogens in human
17 organs, in shellfish, oysters or fish. No studies are availab
18 to us to show that the body is concentratir g these in any
19 increased amounts.
20 I talked to Dr. Lassitar about this at the Governor’
21 Conference on cancer in Louisiana, and Lassiter assured ma th -
22 he was beginning to do some work in this particular area.
23 My possition is probably best in agraament With
24 Dr. Lederbarg, who talked before the Safe Drinking Water dvis
25 ory Council in 1976. I would like to read from his testimony,
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as to those oaragraphs that fit my thinking.
2 He. says, “I think there is a limited amount that th
ccmmmunity is wi11 ng to invest, and when you are talking
about the deployment of control procedures, you are not talki g
about tans of thousands of dollars, which is what a research
6 program is consisting of. You are talking about tens of
7 hundreds of millions of dollars, which is what any of the
8 applications of these procedures would, in fact, entail.”
I am not prepared to say that my work or any other
10 work in this field justifies that degree of inves nent. We
are going into any area of concarn,and we think it deserves
12 to be looked at competitively, with a large number of other
13 potential areas of concern.
14 And later on, ha says, “On the basis of fragmentary
15 scientific base, w go all out in trying to clean up particu-
16 lar pollutants.” Again, ha says, “I think this psycholcgy
17 about standards and an aura of respactà.blity that they then
18 hava in the inference of the violation of the standard is some
19 how bad for public health, while my understanding of standards
20 as a vary crude regulatory tool leads me to be more cautious
21 about racorTunending concrete action at this time.. I think
22 once standards are laid, they are very unlikely to be questior
23 ad. They are likely to be regarded as solutions to the prob-
24 lam, and there may be overkill in the sense cf being needless
25 and serious in the sense of instilling false confidence that
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1 the prcblam has ba n d a1t with.”
2 Then, ha says, in speaking ’abóut charcoal filters,
3 and I suppose Dr. Hymar. will take mor of this, I have to teU
4 you, “You can make a horror story of the chamistry of what is
in charc 9 al, carcinogen polycyclic carbons linked together by
6 bonds.” If you take charcoal and hydrogenate it, you and up
7 with a lot of with a lot of horror substances that wa would
8 seriously like to avoid, and I am being quite serious abcut
9 this. It would take a vary small chemical modification of
10 charcoal, parse, to liberate such materials. In fact, I
11 think now doubt that charcoal, as customarily prepared, has
12 large quantities of substances absrobed into it, and not readi
13 ly resleasad under other circumstances. But under those cond
14 tions, certainly one of the questions I would want to ask,
15 having had that chemical intuitior., is what happened when you
16 exposed charcoal to chlorinated compounds that are chemically
17 active?
18 I suppose the last two statements ararnorain
19 Dr. Hyman’s area than the area I have bean interested in.
20 I would like to make an additional point that the
21 mortalitiy statistics we are dealing with are for the years
22 1950 to ‘69, and they probably reflect atiolog±cal agents
23 that existed 10 to 20 years prior, and we don’t really know
24 whether the composition or concentration of organics in the
25 river water has changed since ‘40 or ‘50 or ‘60.
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1 It would be interesting to know what the years 1969
2 tO data show for mortality figurss in cancer. Ar they increa
3 ing or decreasinc? I might point ou that we have an RPP,
4 which is su ported by the National Cancer Institute in con-
5 juncti n with the Environmental Protection Agency, to study
6 lung, pancreas, and stomach cancer in Louisiana, thus indicat-
ing that we don’t know the answer and are locking for help in
8 solving it.
9 Finally, I would say that if it were not for th
10 massive costs, and we have talked a lot about cost-effectivenss
one could say, although not scientifically justifiad in that
12 the correlations have not been established btwaan organics
13 and cancer, one could go alont with traa nerit processes which
14 did not cost as much and would not be as controversial.
15 I am informed that chioramina treatmant -- and I
16 think you know who informed ma, frcm the discussion aarliar
17 about chioramina treatment -- that it secures a reduction in
18 T1 Ms without sacrificing bacterial control. I would suggest
19 that the group look into it very seriously. A compromise may
20 exist that would solve the two sides of this competitive
21 issue -- perhaps we could use chioramina; the economics would
22 be satjsjfjad and the raduction.of organ±cs accomplished.
23 Thank you.
24 MS. CHANG: Thank you.
25 Dr. Hyman.
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1 DR. HYMAN: I am Edward Hyman.
2 DR. COTRUVO: Excuse rn , may I co snent o
3 Dr. Schiosser’s statement, first?
4 You mentioned something relative to the fact that
5 cartaii organic chemicals did not concentrate in human tissue
6 that you discussed it with Dr. Lassitar. Would you explain
7 that, please?
8 DR. SCHLOSSER: Let me say this. I have always had
9 a hangup about the amounts of this material that we are talk-
10 ing about, these various mater als. Obviously, if human
ii organs, or, for that matter, it doesn’t make any difference
12 about humans —— any food organisms, if they concentrated this
13 material so that when you eat the shrimp or. fish or so forth,
14 you get high concentrations, it would then have the same
15 affect as mercury, let’s say, in tuna fish.
16 You may have very tiny amounts that you could hand
17 la, but if you ate some of the food chain that had high con-
18 centrations, this could easily, in my opiniOn, be d tarmina-
19 tive. Perhaps dogs in the area, drinking the water, or per-
20 haps humans, and see what levels we have in there.
21 If these concentrations were high, and higher than
22 the concentration in water, I would then become very cor.carne
23 an perhaps change my position in thIs whole matter.
24 DR. COTRUVO: As I recall, Dr. Lassitar reported he
25 found chloroform and other,: halogenated compounds in the blood
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1 stream.
2 DR. SCHLOSSER: He impcrted some cn umbilical cord
3 stuff. Tile question is that he finds it, but he is not sayinç
4 this is concentrated, that is, in percentages that era higher.
5 . I asked him about this, and he said, “Yes,” ha
6 thought this was very valid and they ware’ beginning to work
7 on this. I don’t kncw whar&hais with this.
8 DR. COTRUVO: There were other studies which have
9 shcwn, for example, PCBS or DDT, and other ccmpcunds like that
10 are found in human milk and human ad pose tissue, and also in
11 aquatic animals and so forth.
12 DR. SCHLOSSER: You are talking n w about such foreig
13 substances that I think, in terms of control, it will not be
14 a great problem in terms of controlling pesticides, let’s say.
15 These things, I grant you, will continua in a circle; but I
16 think the answer to that is cut them off.
17 DR. COTRtJVO: Those are among the chemIcals covered
18 in this regulation by the granular carbon requirement.
19 DR. SCIILOSSER: I have never seen the studies that
20 tell me that this concentration is severely great in terms
21 of the list, let us say, that Upton has -- that list Upton had
22 appended to his notes.
23 DR. COTRUVO: Levels of PCBs in human milk have bean
24 seen at levels which have caused affects in animals exposed to
25 a similar amount, monkeys, for example.
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1 MS. CIIANG: I don’t think that there is --
2 DR. SCIILOSSER: PCBs get in the envir nrn nt in quit
3 a different way. Didn’t a lot of this get in the environment
4 through an accident with feed stocks?
5 DR. COTRtJVO: They are very ccn monly distributed in
6 the environment.
7 DR. XtJZMACK: You are thinking of polybrorninatad
8 biphenols. Polychiorinated biphanols are vary similar, very
9 widespread in the environment.
10 DR. COTRtJVO: You did mention the chioramina sltue-
11 tion.and the: disinfection effect of this. Mr. Brod nann did
12 not show that virus levels in water that was treated only by
13 chlor3mines ware very, very low .. He did not shcw there was
14 any difference in virus levels between ch1or mine treated and
15 water treated by other disinfactants. He did not do those
16 studies, but what I am saying is, would you be concerned,
17 given the likalihcod that viruses would survive longer in the
18 presence of chioraminas, rather than with thar disinfcc .nat
19 DR. SCHLOSSER: That is an iffy question. First cf
20 all, I am no expert about chioramine. I just hear the dls-
21 cussicn and suggest that this may be a way out of our dilemma,
22 to bring both groups together. As far as the viruses are
23 concerned, I would have to give that some thought. What you
24 are saying is, how bad do I worry about viruses in drinking
25 water? -— The question is, can you avar be free of viruses,
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1 even at tha extant of holding down your bectaria contamination
2 MS. CHANG: Could we move on at this point?
3 Dfl. SCHLOSSEP : This is an iffy question. I would
4 have to give that a lot cf -—
5 MS. CHANG: Thank you, Dr. Schloss .r.
6 Dr. Hyman, would you explain how you will proceed --
7 with your slid s and so on?
8 DR. HYMAN: les.
9 MS. CI!ANG: Do you have a written statement with you
10 DR. HYMAN: No, I don’t; and this is th first I
ii heard of it.
12 I am Edward Hyman, and I am a practici ig physician.
13 I am not a manthar of the Sewerage and Water Board of New
14 orleans, and I am not assoc atad with them.
15 I was asked to review the problem, bac use I have
16 exposure to patients with cancer and have some understanding
17 of their problems.
18 MS. CHANG: Who were you asked by to appear?
19 DR. HYMAN: Some citizens in New Orleans, who
20 introduced ;me to Mr • Brandt and the Water Board, and ask ad me
21 to review the problem myself and come up with my own answer.
22 I depend upon the same public that watches you on
23 television for my income.
24 I also attend to persons who have had liver failure
25 due to haloganatad hydrocarbons, for example, trich1oro thana.
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1 That was one Gov rnrnant ag cias askad the hospitals to
2 raplace ether with, and now thsy see tha: it causos ca c r.
3 I had 30 years in the laboratory and ncrs sciantific
4 background than many physicians. I ias ask d to icok a th
5 prob1 zn, right or wrong, of what we wee on talevis on, such as
6 our friendly engineer visiting —- is it right or wrong, or
7 what is going on?
8 Is it true that anybody who opposes this is some
9 dirty person who wants to support dirty drinking water, or are
10 there other reasons?
11 finally, to compare this with other health efforts,
12 because this is where I live - - in doing so, I believe you wi 1.
13 remember that I testified on March 29th in New Orleans after
14 a brief look at the problem, and - - I have continued to revia
15 the problem and have coma up with hardly any different con-
16 clusions,; although things have changed.
17 The evidence that anything in our drmnk ng water
18 causes cancer is meager, at best, and pathetic, at most.
19 Too, there is a sLgnificant risk, unless thoroughly
20 controlled, that the granulated activated charccal - - which
21 I am familiar with and have worked with in the laboratory ion
22 ago - — I solatad a hormone on that over 20 years ago - -
23 a risk in bacteria which has bean brought up, and the bacteri
24 avidentally live on organic substances absorbed onto tha car-
25 bon.
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1 I think in your Pederal reaulation! you have &n
2 error concerning the displacemer.t of organic substances frcin
3 carbon. I ret mber c1 .ar1y how you displace carbon by dis-
4 placing aldostarone from carbon with higher alcohols and high r
acids.
6 inally, the metals problem, which I see has bean
7 treated since March 29.
8 May I have the first slide, please?
9 (Slide parsentation)
10 DR. 111MM: Pirst, the evidence th our drinki: g
11 water has anything in it causing cancer -- I find nothing in
12 the world literature to support that. In the one study, lag-
13 itimately published by Dr. Harris and Dr. Epstein, it says,
14 “While statistical studies cannot by themsalves establish
15 causality, this regression study supports the hypothasis
16 that there is a link between carcinogens,” that is fair.
17 First, in an overview of the problem, the thing
18 that correlates with cancer is age, and that is a beautiful
19 correlation, and you don’t need a computer to draw a line
20 through those points. As we get an older and older populatic.,
21 you may expect more cancer; and if you don’t sea more cancer,
22 we are doing something right.
23 In going over these evidences for cancer, which hav
24 bean cited on my television sat by the visiting angineer --
25 ha says the Tulane study supports it, and this isn’t true.
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1 They put th same qu sti nab1 data in tha computer on a
2 similar program and got a similar readout. Then they went
3 back, like honest sciantists, to correct the input, mar y fac-
4 tors invo1v d, and they came to th conclusion that you can’t
5 be sure that anything is going on because they can explain
6 at least half of the daviation from chance.
So the University of North Carolina and Hogan, at
8 the national Institute of Environmental Health Sciences, each
9 found that the output of the computer is a function cf how
10 the computer was weighted -- a batter word is “rigged”.
11 If you are to weight a computer, or if you are to
12 set up a mathematical model, you are ipso facto, declaring
13 that your results will be dependent upon that mathematical
14 model. You are essentially declaring the outcome, and then
15 you will discover what the outcome is.
16 As I pointed out in New Orleans, prcof that two
17 things exist is not causation... An example I gave is parityhcs
18 They are worn by women and cancer of the breast occurs primari
19 ly in woman; thus, pantyhose with correlate with breast cancer
20 but this does net prove that pantyhose causes cancer of the
21 breast, or vice versa.
22 Buntion, and his colleagues at the University of
23 Cincinnati, found a weak relation between chloroform in water
24 and cancer, but they were not w ll!ng to speak of causation;
25 and the editor of the Journal reinforces their thoughts
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1 strongly.
2 One EPA study of McCabe found no correlation betwea
3 the non—purgabla total organics, but found this n ar scatt. r-
4 grwn f3r chloroform v .rsus the cancer i st, c xpr ss d a
5 ratio, and I think you need a computer c draw J l.Ln .
6 If you take this point cut arid that point out, the
7 probability of this occurring by chance goes up over five f ci
8 Than, if you look at Hogan’s report, you find that
9 if you take the chloroform dot ina’ion in one study, Region
10 !ive, and compare it in the seine study with the Norris study,
11 used in McCabe ’s study, you don’t get a very good correlation,
12 an excellent correpondence, right on a 45 degree slope.
13 This scattergran, with low correlation, itself is a
14 study. Hogan brings up the question that if you use this
15 point which is 127 for chloroform, why not use 50? If you ha a
is your choice of what to use, you might be able to get a’l ost
17 any correlation you want, perhaps with pantyhose.
18 However, Hogan also points out that now, with these
19 variations and studies, let’s extrapolate that 25 years to th
20 origin of cancer.
21 In review of the literature, I find a million-fold
22 better correlation between the meat consuption and the incide
23 of cancer. Here the probability is .00000002; that is an
24 awful lot batter. It is a million times better correlation
25 than the chloroform, and I guess we should stop eating meat.
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1 At a meeting hare in Washington a ccupla of months
2 ago, I discovarad thare is an equally good ccrr latio batw =
3 the fats ingestad in mala and female, on the lower half of the
4 graph, and the inc denca of canc r. I guess we have to stop
5 eating fat, also.
6 Then, in a very delightful study published in the
7 Journal of the National Cancer Institute in 1974, I find
8 100,000—fold better correlation between consumption of beer
g and rectal cancer. This is 100,000 times batter than the
10 correlation with chloroform and drinking water.
11 I hasten to point out that the water for this beer
12 has bean filtered through granulated activated carbon, as I ant
13 reminded. Furthermore, the little bit of correlation that
14 Jonas saw at the university of North Carolina - - got with th
15 drinking water, if that ware corrected for bear in an open
16 population, perhaps that would e1 minata any residual correla-
17 tion.
18 We have several quite concerned as to methodology,
19 how you are coming to these conclusions. We looked at the
20 incidence of cancer, as reported by tha xnarican Cancer Soda ‘
21 Hare, the incidence of cancer of the uterus has been falling
22 year by year, and we have heard some remarks about this; but
23 this is due to the hysterectomies, removal of the uterus in
24 young woman. We hav, heard this caflad unnecessary surgery.
25 Perhaps we should call it preventive medicine,
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1 b caus that canc6r will n var bacom m 1ignan , n v r b c m
2 caZc r of the uterus. Co1o ar d r ctal canc r, although wa
3 drink more and more pol1ut d water, that incid nce is fa1li g.
4 Stcmach ca c& ir. stanca is falling; br ast c ncar is s ayi g
5 status quo.
6 I don’t think that is an enormous rise from xcessi;
7 polluting, and we have been polluting for more than 20 years
8 nOW. In men, there was a sharp rise in cancer of the lung,
9 and we though, as scientists, since everything is caused by
10 environment, we ought to do something about it.
11 Let ma bri fly tell you what we did. Wa found that
12 pollutant in the environment that does it is the pollutant
13 IT in our environment, and here is cancer of the lung incidanc
14 and I don’t think you need the computer to draw the line
15 through those points. I am wall aware that IT will eat your
16 guts out like a malignancy, but this is the first damonstrati
17 that the Income Tax causes lung cancer in man.
18 Perhaps Mr. Jarvis will help us cure lung cancer
19 in man. It is the same methodology and this is the control.
20 On March 29th, I pointed out that oven the purest
21 carbon used in food, the chemical Codex - - and, by the way,
22 at that time, when I asked the question, you had no criteria,
23 no specifIcations for the carbon to be used.
24 There they give arsenic three parts per million,
25 heavy metals, 40 parts per million, lead; and I asked the
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1 question, What happens when you put 28 pounds laad in N w
2 Or1 ans’ drinking watsr every w’aak? And I got a blank. I rn
3 glad tQ sea progress has occurred. There w s an xparirn nt
4 by Dr. Harris, dons about two w ks 1at r, April 11th, 1975,
5 in which he did a study of passing water thrcugh carbon and
6 shcwed that in a passage through virgin carbcn, there is a
7 drop in the concentration.
8 And as I point out in Dallas, I learned that waste
9 disposal - - they pass it through carbcn and load concantratio:
10 -— increases. I don’t know where the lead comas from; .t says
11 INC there. I am happy to sea in the Pederal regulations, cur
12 naw medical journal, you are now going to ccntrol. -- 60,000
13 payments a year and 10 commandments put on one side of the
14 law. I would point out to you in the Codex, they usa water
15 extractabj.as to determine heavy metals; and I wculd ask that
16 you continua your modifications and put a mcra appropriate
17 index.
18 The water extractable and initial passage of metals
19 through the virgin carbon are inappropriate criteria, and the
20 reason is this, Eirst, what we are using -- let’s remove con-
21 fusion introduced by our visiting engineer, The stuff ccmas
22 from b±tuminous coal. Hera is f 1trasorb, bituinous-based
23 granular carbon. I think that is the Calgon Corporation, and
24 those are the major suppliers. It comes from bituminous coal,
25 Wa are told we have this plant in operation on
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1 talavisioi. My patients ware told, a d the public is made to
2 bali ve, and a lOt of persons get emotional abcut it, that
3 there ar plants all cvar this ccuntry doing this. In Nitro,
4 nest Virginia, we ware told on vid otapa that it was reg r3t
5 ing so frequently; we have a rncdal to go by. So w checked
6 the question here wLth the people who took the plant down in
7 Nitro, West Virginia, and we avidantally don’t have any pra-
8 dedanca for this in thIs country, despite what has been said
9 in the public media.
10 I think it is a terrible error to stampede pc.opla
ii in the public media and create public opinion that way.
12 I think a more appropriate modal, if you are going
13 to recycle and lose 10 percent of the carbon each time, is to
14 Start with a piece charcoal that you assume is laden with
15 whatever heavy metals are in there, and as part of the spaci-
16 fication, I hope you are right.
17 As 10 percent of the carbon is lost, maybe goes off
is as pollution in the atmosphere, and the rest of the heavy
19 metals remain, Eventually, carbon is burned up into ashes,
and in each cycle it is returned to the drinking water, and
21 that heavy metal is now free in the drinking water.
22 I think your model must take that into consIdaratior
23 In this regard, and whereas I realize that comments
24 are inapproiriata, I point out your latter of December 23rd,
a memorandum to the Secretary of HEW, written by the Uatiozial
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1 Institute of Envir z manta1 Health Sci.ntists, Dacaither 23, 19 7,
2 a1 d in this le-ter there is great co carn f xactly that.
3 This is in rsply to tha increased use of bituminous coal fc
4 energy, and what is the impact n health of dci g this.
In there, there are six issues that urgently need
6 attantiQn. One of them is that trace elements may migrate
into the water. That is signed by the seine David Rail, that
8 we hear about, the ChaIrman.
Major elements of consensus, trace elements, raduio-
10 nuclides in coal, elements in the biosphere and they will be
1 1 in fly ash and leach into our drinking water -- the health
12 affects and the taxt of it -- there is reasonable concurrence
13 that w ine trace contaminants in coal may constitute health
14 problems from either direct toxicity or rIsk of cancer, mar-
15 cury, cadx ium, and lead, and so forth, fly ash, isachate,
16 potential contamination of drinkIng water supplies.
17 I am glad to find other people concerned. But in
18 these proposals you are not going to take the chance that .t
19 will go in upstream, but you will, put in in downstream of the
20 filter, and I und rstand the filter will be removed.
21 MS. CHANG: Dr. }Iyman, would you please summarize.
22 DR. HIMAN: I am almost finishad. The report is
23 just loaded with such references, and I wIll race through
24 those -— and back to this reference, this m3dai. Y u find, a
25 you look at the data for bituminous coal, 28 pounds par cycle
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I for N w orl ans would not be thd tcp -— 126 par cyc1 is th
2 top, and that is 60 xnicrcgrans of lead a day per persc ;
3 arsenic, 8.7; uranium, .33 micrograms, ac.d s forth. These
4 ;wo x v b e corrala:ad w -h c nc r in the s .rne k r cf
5 statistical study, and that is in the rsfaranca given by the
6 National Cancer Institute. They have the coefficient’s corr 1
7 ation, arsenic, cadmium, chromium, nickel, and so forth, and
and 4B 8 they are all in there.
s 5A 9 Tan percent of added cadmium -- you have a nice cor
10 relation with cancer in colon and r ctwn. Lead, though y u
11 are staying below the level, the National Acadazny of ScienCe
12 suggests the level be lowered; lead to be added will cause a
13 asur la rise in the blood lava], in children, and the
14 National Academy of Science pointed out what most physicians
15 know, that there is no low level for infants and children.
16 In other words, we don’t know how many dumb childra
17 we are raising in old neighborhoods that have lead in their
18 plumbing. I am not sure we want to add more lead, and I
19 think there should be great safeguards for that.
20 In summary, I believe we have had enough of these
21 quickie experiments that I have seen go on since March of thi
22 year. We have had enough of the quickie, Mickey iOUSe experi
23 mants. If there are no specs, if the lead gets in there ij
24 concentrations available for the charring, we can causa an
25 epidemic of heavy metal poisoning; we can cause an epidemic
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fo r ,e
STATE OF TEXAS
DEPARTMENT OF HEALTH
Hearing — July 11 and 12, 1978
Washington, D.C.
My name is Charles Foster, I am Director of the Division of
Water Hygiene of the Texas Department of Health. Our Division is
the primary enforcement agency for our State as designated by
acts of our Legislature and more specifically by our Governor.
These statements are made since the voters of Texas ultimately
pay the cost of providing drinking water and will rnake the final
decision as to the quality of drinking water which will be providedC
For the past thirty yearc have been employed in the environ-
mental health field which teaches that the prevention of disease
is more desirable than curing a disease. Prevention not only
eliminates the pain and suffering, but does not subject the
individual to economic disaster. Our staff has reviewed with
considerable interest the material contained in the Federal
Register of February 9, relating to trihalomethanes in drinking
water. We have participated in numerous discussions with members
of the Environmental Protection Agency staff; read the Academy of
Science report; discussed the potential problem among our own
staff of chemists, virologists, physicians, and engineers. .
eteâ- /e have had varied responses 4 em wjth j - th
, “Phi’ ‘
Since we were represented at the 1 earing in Dallas, we have
only a couple of additional comments U 2 mough we are far from
convinced of the need for these new regulations, let’s assume to
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be true the premise that there is a significant risk to human
health from ingesting water containing organic compounds which
cause cancer from immense doses in laboratory rats. The treatment
technique prescribed in the proposed regulations poses two or
three potential problems. In the beginning only large plants
will be required to provide granular activated carbon in their
filters. Individuals living in communities of less than 75,000
population will not have benefit of the trihalomethane removal.
Because of the cost of the material it rtrnst be regenerated or
reactivated. Presently this is accomplished by heat; where will
the wastes from regeneration go? Should steam be used, the waste
will no doubt be classed as “hazardous” in view of the proposed
definition that wastewater containing ten times the Maximum
Contaminant Level of the Interim Primary Drinking Water Regula-
tions is “hazardous.” Dry heat will probably produce potential
air contaminants. These waste disposal costs must be considered.
Another problem that has not been successfully addressed is the
determination of effectiveness of the activated carbon during its
use. One reason given for prescribing a treatment technique was
to minimize the testing for organics in the water. It appears to
us that similar testing will be needed also to determine if the
activated carbon remains useful. Our experience, though limited,
indicates a considerable variation in the life of carbon columns
when used for test and odor control in drinking water. ‘ie must
assume similar problems when removing other organic chemicals.
Another part of the proposal to which we object is that of
prohibiting the use of chlor mines as a primary disinfectant.
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This appears to be a deliberate attempt to exclude a ressonable
way to prevent the formation of TH 1’s. There is at least one
large (300,000 population) community in our state which is served
by a municipally—owned system which uses chioromine treatment.
Both ammonia and chlorine are added simultaneously as the water
enters the plant. ere follows conventional treatment, in-
cluding chemical mixing (alum, iron salts and lime softening)
coagulation, sedimentation and filtration. Normally no further
chlorine is added. A chioromine residual is maintained at about
0.8 rag/i throughout the distribution system. This treatment was
prescribed by the, late Dr. Schock, a chemist of some reputation
in his time, in 1923. Our brief sampling indicates that total
trihalomethanes six days from the treatment plant were about ten
percent of the proposed limit of 100 micrograms/liter. Chlorina-
tion of the raw water to a free residual produced THN’s about two
and one—half time the proposed limit. n Texas all surface water
for drinking purposes receives “complete” treatment. Some of the
precursors may be removed in the treatment process . ‘ he point I
make is that in some instances chioromines have been demonstrated
to be effective in the removal of bacteria though the high pH
from the lime may contribute to the bacteria kill, and at the
same time drinking water is provided which is relatively free
from the “dreaded” ‘trihalomethanes. If there is a need for THM
free water, ‘why not use an economical way to prevent their forma-
tion. Incidentally, I believe it reasonable to predict that this.
community water supply has been relatively free from THM con-
tamination since 1923; it might be interesting to study the rates
of hepatic cancer in contrast to a community having THM’s over a
long period of time.
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In conclusion, let’s go back to my beginning statement
relating to the need for the regulations based upon health
effects. The National Academy of Science report did not recom-
mend establishing a Maximum Contaminant Limit for chloroform, nor
brornoforin, nor total trihalomethanes, nor is there anywhere
demonstrated a basis for the limit of 100 parts per billion total
trihalornethanes. Perhaps it should be 100 parts per trillion, or
100 parts per million. I’m reminded of a comment by Professor
Abel Wolman in which he described a court decision based upon
looking “... down a dark tunnel and at the end seeing a light
...“, the facts of the case having no bearing on the decision.
An Assistant Surgeon General of the Public Health Service in
his letter of May 31, has stated that based upon the NAS report,
‘... there is no “safe” dose ...“ This section of the report
covered about ninety pages; there must be something more. Also,
I’m concerned about the safe dose because the next sentence of
the letter states, “Concerning chloroform, the report stated, “it
is suggested that strict criteria be applied when limits for
chloroform in drinking water are established.” Does the reference
to “safe” dose apply to chloroform? Now, if there are significant
health hazards why not allow a method of preventing the formation
of ThM’s through chioromine disinfection. we are convinced that
under certain circumstances chioromine treatment has been demon-
strated to reduce the formation of tàtal trihalomethanes and at
e
the same time provide a bacteria safe water. The costs of such
treatment are a pittance compared to the use of granular activated
carbon. In this manner all citizens could have the “benefits” of
low THM’s. - 4 —
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1 MR. ROBECK: In that regard, Mr. oster, how do you
2 sea solving the trihalornathanas in ground water cities in
Texas? Do you think the chiorarnina route is what you would
go along with, based on what you just described?
5 MR. POSTER: There is only one way-- ther, was oñl
6 one study’-in East Texas, and we found a lot of things in that.
7 I don’t know what they were, but this well, was near our sista
8 state, where there was oil drilling; oil well drilling occurr d
very recently. The well, I believe, was finally abandoned.
10 The water was of such quality that it was not useab-
11 le. I really don’t know what it had in it.
12 MR. ROBECK: Beyond that, as I recall, Professor
13 Glaze’s work showed several surface systems and rather sucI
14 as: Marsha1F .and rather large towns --
15 MR. POSTER: If they could go to chioramine, I thin]
16 they could pretty we] ,1 take care of their problem, I think.
17 I don’ t know. I think this is something that should be left
18 open for us to try.
19 MR • ROBECK: That is why I was wondering what the
20 Texas Health Department’ s position might be in regard to thosu
21 kinds of raw water sources and the use of chioramine.
22 MR. POSTER: We have some 250 sources of surface
23. water in our community that uses surface water.. ‘Al1 of- these
24 are not as large as the city of Houston, Dallas, Port Worth,
25 Marshall, Texas. It probably has about 10 to 12,000 populatic
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1 but we have many, many systems in Texas that use surface water
2 MS. CHANG: Thank you for coming and waiting.
3 Richard Schauar, pleas..
4 S’rATEMENT OP RICHARD L.SCHAUER, .Ph .D, MANAGER
5 CHEMICAL REGULATORY SERVICES, ICI AMERICAS INC.,
6 WILMINGTON, DELAWARE
7 DR. SCHAUER: I an Richard Schauar, Manager of Chen%i
8 cal Regulatory Services, Id Americas.
9 At previous hearings, and again today, many people
10 have expressed concern that harmful materials would be leache
11 out of activated carbon by potable water and would pose a
12 hazard to the public.
13 My purpose is to correct the misunderstanding assOc
14 ated with these so-called extractable materials, but, first,
15 I will tell you about some of the properties of activated car
1.6 bon, then present some historical information, and finally
17 relate some of the experiences people have had using activate
18 carbon for the purification of drinking water, pharmaceutical
19 and foods.
20 What is activated carbon? Activated carbon is a
21 black, tasteless substance which varies in particle size frost
22 a fine powder to cours. granules, depending upon its intended
23 use. Por water treathent, both powdered and granular carbon
24 are used. It is insoluble in water and inorganic solvents.
25 Activated carbon should bs. thoug i.t of as a rigid
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1 sponge. Lignite and bituminous coal are the main materials
2 used to manufacture granular activated carbon for potable wate
treatment. During manufacture, the volatile materials are
driven off leaving a large surface area within the internal
pores.
6 For liquid phas. carbons, such as would be used for
‘ water treatment, the surface area ranges between 450 to 1800
8 square meters pr grain with pore volumes of 0,7 to 1.8 ml pr
grain. Activated carbon is an excellent adsorption media
10 becaus. it is one of the few solids that can provide such
large surface area par unit weight or unit volume at relative
12 low cost.
13 Adsorption is th. process whereby a surface accumu—
14 lates and retains molecules or ions coming in contact with it
15 The adsorbed layer is only on. to several molecules deep, but
16 since activated carbon has such large surface areas, signific ‘
17 quantities of impurities can be adsorbed by moderate amounts f
18 carbon.
19 When it becomes loaded with impurities, activated
carbon can hav, its original adsorptive capacity restored by
21 thermal treatment.
22 Historical background: Modern activated carbon da a
23 back to 1900 when a German patent was issued for the manufac-
24 ture of steam—activated carbon from carbonaceous raw mater ial
25 Th. first significant use, in about 1909, was for sugar
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refining.
2 U sags to control tastes and odors in potable water
began in American in 1929 with powdered grades. About 15 yea
ago, water treatment began to use granular forms and this ap-
plication continues to grow.
6 Today, there ar. many foodstuffs and pharmaceutical
products that are purified with activated carbon. Some of th
8 foods are corn syrup, tro, cane and beat sugars, water
for bear and soft drinks, fats and oils. Purified dxtros. i
10 also used to make intravenous injection solutions.
11 Activated carbon is used to purity antibiotic prep
12 ations. Thus, our lives are dependent upon activated carbon
13 for removing impurities from a wide variety of essential prod
14 ucts.
15 Let’s take a closer look at potable water treatment
1.6 The U • S. Public Health Service, a Government agency, and the
17 American Water Works Association, an industry group, have
18 stab1ish d standards that affsct the use of activated carbon
19 for treatment of potable water.
20 Our activated carbon nests the AWWA Standard B604-7
21 This tandárd.precludes using any type of activated carbon th t
22 is capabl. of producing deleterious effects upon the health 0
23 those consuming the water • Most water treatment plants that
24 purchase activated carbon, purchase to meet these standards.
25 Our activated carbon sold for water treatment is
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1 acid washed to remove extractable materials. This treatsant
2 extracts greater quantities of impurities than the washing
with water such as is encountered in water treatment plants.
When put into use, activated carbon is transported
in a slurry form to load the columns. It is backwashed for
6 about 30 minutes to remove the fine material and then the flow
7 of water is reversed with clean water being sent out to con-
8 Burners.
9 Food and pharmaceutical quality control: The manu-
10 facturars of food and drug products are under tremendous pres-
sure to insur, that their products are of the highest quality.
12 Production lin, problems or product recalls would be disastrou
13 Therefore, very strict quality control procedures are enforced
14 Furthermore, since many of these products serv, as
15 starting materials for other manufacturers, additional quality
16 control checks are made. Very detailed records are kept on
17 these tests. Nøthing is used in these plants which would
18 jeopardize product quality. Activated carbon is their princi-
19 pal purification media.
20 They say experienc, is th. best teacher. Statements
21 wars made at previous hearings in which the accusation was
22 made that inorganic materials could be leached out of activate
23 carbon while being used for water treatment.
24 Our experience has been that in over 10 years of us6
25 of activated carbon for potable water treatsent, ther. has no
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been a single case reported to us of extractable materials
2 being imparted to the water being treated.
Over 50 million pounds of activated carbon are used
‘ each year in the production of foods and pharmaceuticals. Th
conditions under which this processing i done, such as higha
6 temperatures and lower pH ‘s are more favorable for extracting
‘ inorganic materials from activated carbon than would be an-
8 countare 1 in water treatment plants.
1 ’i ” 1 toring of the quality of these high value food
drdg’ products has demonstrated that heavy metals are not
11 released from the carbon. In the case of corn syrup, the isv 1
12 of lead was reduced when the syrup was treated with activated
13 carbon.
14 Activated carbon has b*n used to treat th. waste
15 from caustic-chlorine plants to remove the mercury which
16 escaped from the cells. Also, we know of one case where acti
17 veted carbon was used to remove mercury from drinking water.
18 In conclusion, few other substanc*e have the adsorp
19 tive capacity, the regeneration characteristics and the rela-
tively low cost of activated carbon. Purthrmore, experience
21 acquired over the last 60 years has demonstrated that activate
22 carbon, even when used under the harsh operating conditions
23 involved in the manufacture of foodstuffs and pharamc.uticalsI
24 did not contaminate these very valuabl, products with inorgan.
25 matsx jals, but rather even extracted substances such as lead
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and mercury.
2
In the sane way, use of activated carbon for the
filtration of potable water will not lead to increased levels
of extractable materials, but it will help to provide the
American public a who].asoma supply of drinking water which is
6 free of unwanted contaminants.
MS. CHANG: Thank you.
8 tiiere any:quastions?
DR. COTRUVOs One question, Dr. Schausr, do you have
10 an specific information on reactivated carbon, carbon that
may have picked up some additional substances from the water?
12 Is there any additional propensity of those materials to be
13 retained on the carbon, or eventually lost into th. water; fo
14 whatever product the carbon is treated?
15 DR. SCHAUER: You mean while it iø in use or after
16 it was regenerated?
17 DR. COTRUVO: After reactivation.
18
DR. SCHAUER: I believe the regeneration process,
19 which occurs at high tempratur., would drive off any organic
20 materials It would leave just the activated carbon.
21 DR • COTRUVO: What about inorganics? Are they fur-
22 thar removed in the acid wash?
23 DR • SCHAUER: No, the rsgnarated carbon, I don’t
24 believe, would acid washed, but it would b back washed
25 for 30 minutes to remove fins materials. I believe that the
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1 inorganic materials, which are on the surf ace, probably would
2 be l chad out with the back wash.
3 DR COTRUVO: Any that survived the riaactivat.ion?
4 DR. SCHAUER: Right.
5 DR. KflZM CK: There was a comunent made earlier, sug-
6 gesting that there was likely to be benzopyren., or tather
7 polyaromatics in the carbon as it was produced, and som . of
8 this could conceivable get in the water. Do you hav, any
9 data on that question?
10 DR. SCIIAUER: The temperatures at which activated
11 carbons are made is generally in excess of 100 dagress; and I
12 believe that benzopyrsne would probably be destroyed at those
13 higher temperatures. I don ‘t believe there would be a probi
14 MR. KIMM: Did I understand you correctly to say
15 that GAC, used in water treatment plants, would, in fact, meet
16 the Codax reqUirements?
17 DR • SCHAUER: No, the AWWA standard.
18 MR • K 1MM: Would they also meet the Codex require-
19 mants?
20 DR. SCHAUER: I am not sure of that. My colleague,
21 who has long experience, says, “Yes, it would me. the Codsx.
22 specifications.”
23 MR. 1(1MM: Is there any data along those lines?
24 DR. SCHAUER: We can supply it.
25 MR. 1( 1MM: I think any hard data you all might have
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1 along these lines would be helpful. to us.
2 DR. KtJZMACK: Particularly whether there are adequat
supplies of carbon meeting the Codex requirements that would
4 be sufficient to satisfy that relation we ara talking about.
5 DR. SCHAUER: We can supply those data.
6 MR. ROBECK: Do you have any data on what comes out
7 of this tax, so to speak, during activation or reactivation;
8 and do you have a way of preventing any obvious loss of fines
9 or of gases when you manufacture your carbon?
10 DR. SCHAUER: I don’t believe I could answer that
11 question at this time. I could consult and probably provide
12 those ansers.
13 MR. ROBECK: Anything you have in the way of informa
14 tion about th. of f gases that were raised earlier today would
15 be helpful.
16 DR • SCHAUER: We will try to answer your question.
17 MS. C RANG: Thank you very much.
18 Is Donald Kemp here?
19 STATEMENT o DONALD W. KEMP, Ph.D., REPRESENTING
20 METCALP & EDDY, INC., BOSTON, MASSACHUSETTS
21 DR. KEMP: I hav. an abridged version.
22 My name is Donald Kemp, and I am representing
23 Metcalf & Eddy, Inc. at these hearings. Metcalf & Eddy is a
24 consulting engineering firm which has provided environmental
25 services f or water and wastewater treatment for over 70 years.
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1 The firm has considerable experienc, in the application of
2 activated carbon technology for water treatment.
3 Wa have designed one of the largest activated carbon
4 adsorption and regeneration systems in the country, and have
5 conducted many activated carbon pilot studies within the last
6 few years.
7 Utilizing this background, Metcalf & Eddy has evalua
8 ed th. proposed regulations and supporting source documnts.
We have concluded that the 18 months does not, in our opinion,
10 represent an adequate time to conduct effective pilot programs
ii and design the subsequent carbon treatment systems for the pr
12 jected number of cities requiring such systems.
13 Further, we don’t believe adequate tim, has been pr
14 vidied for the transfer of knowledge within the engineering
15 community regarding the application of activated carbon for
16 trace organic control.
‘7 Finally, we submit that additional effort and time
18 is required to further defin, procedures for conducting effec
i tive pilot programs, and to evaluate techniques that may
20 reduce the cost of carbon regeneration.
21 Wa believe the proposed regulations can be modified
22 to address these factors without jeopardizing th. objectives
23 of the regulations. Metcalf & Eddy plans to offer altarnativ
24 approaches for consideration, which we believe would strength a
25 th. proposed regulations.
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1 Initially, we would lik, to focus our remarks on
2 thre. specific issues on which EPA requested comment. These
are the soundness of the three effluent criteria, the proced-
urea for obtaining a variance, and the adequacy of the 18-mon
period for designing a carbon system.
6 Our first comment is on soundness of the three eff 1
ant criteria. Metcalf & Eddy believes that 50 percent TOC
8 removal and the 0 .5 micrograms per liter of volatile halogena
ed organics -- excluding trihalomethanis - - criteria represen
10 a reasonal)1i approach to establish initial treatment objectiv
for the control of synthetic organics.
12 These limits can be made more or less stringent as
13 additional data is developed, on a national basis. However, W
14 believe an effluent criteria based 0r4 an increas. on 05 mg/i
15 of TOe is not an effective criteria for controlling the dis-
16 charge of toxic synthetic organics, and could lead to higher
17 treatment costs if adopted as a national standard.
18 Metcalf & Eddy recommends consideration of alterna-
19 tive measurement techniques to monitor f or break-through of
toxic organics. Procedures ar. available for extraction and
21 measurement of the less volatile toxic organics by gas chrome-
22 tography. They are being employed for trace organic control
23 in wastewater applications and could be utilized in this appU
24 cation.
Additionally, TOC1 and liquid chromotography
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1. techniques are available. Any of these would provide a more
2 positive measurement of toxic organic break-through than the
3 proposed TOC measurement.
4 Variances procedures of synthetic organics: Metcalf
5 & Eddy believes the procedures described for obtaining a van-
6 ance should be defined more explicitly and integrated into an
7 overall program to control th. trace organics in drinking
8 water.
9 The regulations do not define th. basis for estab-
10 lishing whether or not a significant degree of contamination
ji exists in a water supply. It is highly likely that some of th
12 chemical species listed in Table 1 of the proposed regulations
13 can be found in many water supply systems if sufficiently san-
14 sitive analytical methods are employed.
‘5 We fell that concentration limits shci 1d b specifie
16 We also believe the regulations shou1d be modified to allow
time for a monitoring program to be initiated for those cities
18 whre contem d nation is detected.
19 Our third cc nnt addresses th. design schedule for
carbon treateent. Metcalf & Eddy ‘s review of the activities
21 associated with conducting a pilot program and designing a
22 caxbøn trea nent system show that a time period in excess of
the proposed 1.8 months would be required. Based on our expar±-
24 ence in designing carbon pilot programs, we have estimated th4
25 time required to complete the major task elements as follows:
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1 PILOT AND DESIGN PROGRAM ACTIVITIES TIME (months)
2 a. Water sampling and characterization 2-4
3 b. Variance assessment 1-2
4 c. Preparation of pilot testing facilities 3-4
5 d. Operation of pilot units 6-8
6 a. Determination of design criteria 3-4
7 f. Detailed system design 12-14
8 Total 27—36
9 Because of the time fram. necessary to construct
10 these systems, Metcalf & Eddy recommends that the proposed 18
ii months to design a system be extended to 36 months. We fell
12 this extended schedule would &nahle a cost-ffsctive system
13 to be designed. A more...coinplicatad schedule would increase
14 the risk that an overly conservative or inadequate design wou
15 result.
16 Recomiflefldaitofls for additions to proposed ragulatio
17 Metcalf & Eddy has reservations about the rapid pace by which
18 approximately 70 cities would have to design and construct
19 large scale carbon treatnent systems. Design deficiencies
20 ± esultad - in tial y when’ activatd carbon.. tachno1og was trans -
21 ferred from use - in the s iqar procesBing industry to a waste-
22 water application.
23 • The proposed use of activated carbon for water treal
24 ment is not only a new application, but an additional degree
25 of complexity has been added. This is associated with opsratj
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1 a full scala carbon system for control of trace levels of spa-
2 cific organic species which has not been accomplished bafore
in this country —— except in a few cases for phenol control.
Research is currently being conducted in both the
private sector as well as within divisions of EPA to assess
6 carbon effectiveness in this application.
We believe that more time should be provided before
8 the affected cities respond with the design of full-scale
activities. Our concerns with the proposed schedule include
10 the following.
11 Oile; the adequacy of the existing engineering capac
12 ity with the experience to design 60 to 70 activated carbon
13 systems within the proposed schedule.
•14 Two; the lack of carbon pilot data for different
15 effluent criteria, relating the regeneration frequency to the
16 carbon bd depth.
17 Three; the lack of available tim. to incorporate th
18 results of on-going research which could reduce the treatment
19 costs.
20 Metcalf & Eddy suggests that the proposed regulatio a
21 be expanded to include an initial effort to address the above
22 elements to ertcurs that effective carbon treatment systems ar
23 designed. We recommend th. following two activities for your
24 consideration:
One; National Carbon Pilot Studies -- it is -
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i recoimnanded that these pilot studies be conducted at key loca-
2 tions across the country to provide a wide spectrum of carbon
3 performance under different test conditions • These pilot
4 studies should include the following program elements:
5 A —— Assessment of carbon regneration. This would
6 include studies to establish whether or not the adsorption
7 carbon effectiveness is lost upon successive regeneration, and
8 regeneration pilot studies with exhausted carbon to define
9 design criteria for sizing a rsg.n.ration. furnace.
to B -- Multi-point pilot studies with two types of
11 regenerated carbon in parallel, pilot trains with multiple
12 sample points to allow the rats of carbon exhaustion to be
13 determined as a function of carbon bed depth.
14 C -- Cost/performance assessment. This activitiy
15 would focus on developing operating curves from the pilot data
16 that relate the size of the regeneration system to the size of
17 the adsorPtiOn system so that the point of minimum cost can 1e
18 establiShed. This would enable an economic assessment to be
19 made regarding moving bed versus fixed bed.
I) — Development of carbon transport techniques.
21 ThiS effort would be directed at developing procedures to
22 economicallY remove carbon from sand filters for carbon regn.
23 ation.
24 TWO; Large Scale Demonstration Studies -- it is
25 reco,mendsd that several large-scala pilot and/or full-scale
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I plants be constructed and operated for demonstration purposes
2 to evaluate design alternatives and to examine operational fac
3 tors that may be unique to water treatment as opposed to waste
4 water treatment.
5 In particular, it is recommended that a moving or
6 pulsed carbon bed b evaluated to establish whether it would
7 be more economical to operate than a fixed bed, and to estab-
8 lish whether adequate control of trace organic lav*la can be
9 achieved.
10 These actions will enable the following objectives
ii to be realized:
12 One; provide a comprehensive data base to enable
13 effective design decisions to be made.
14 Two; provide the time required to increase the
5 engineering capacity for the design of the projected number of
16 carbon treatment systems.
17 Three; enable results to be considered from on-going
18 evaluatiOns of less expensiv, regeneration furnaces.
19 pour; estalbish whether or not alternative analyti-
cal measurement chniques should be utilized to measure the
21 effeCtiveness of carbon trsatmnt.
In summary, Mtcalf & Eddy recomnznends that the
23 scheduiC for the design of carbon treatment facilities be
24 to allow the results from national pilot studies to
25 be asse ssd and digested by the engineering community. jg
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‘ effort would add an additional one to two years to the schad-
2 ula.
If some of the cities affected by the proposed regu-
lations are included in these activities, then the impact of
the schedule extension would be reduced as the citiàs could
6 utilize the data in the design of their own trea ent system
Further, partial protadtion can still be realized if sand is
8 replaced by activated carbon in the existing sand filters.
9 This interim measure with sand filters may prove to
10 be a viable alternative, depending results obtained during
11 pilot and demonstration studies.
12 (Th. full statement follows:)
13
14
15
16
17
18
19
20
21
‘ :9
23
24
25
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METCALF & EDDY, INC.
50 STANIFORD ST.
BOSTON, MASS. 02114
COMMENTS ON EPA ’s INTERIM PRIMARY
DRINKING WATER REGULATIONS
presented by Donald W. Kemp, PhD
of the Metcalf & Eddy staff.
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Metcalf & Eddy is a consulting engineering firm which has pro-
vided envirOnmental services for water.and w teWater treament for
over 70 years. The firm has considerable experience in the applica-
tion of activated carbon technology for water treatment. We have de-
signed one of the largest activated carbon adsorption and regeneration
systems in the country, and have conducted many acti’ ated carbon pilot
studies within the last few yearsL
We have learned that proper design of an activated carbon pilot
program is critical in establishing criteria for the design of a full
scale treatment system. Failure to develop an effective program can
result in a system with excessive costs or one that is unable to meet’
the treatment objectives. As an example, in the last two years Metcalf
& Eddy provided engineering services to correct deficiencies in two
activated carbon systems that were not functioning properly. in one
of these assignmentsi we designed an alternative treatment System to re-
place a multi_million dollar ca n adsorption and regeneration system.
utilizing js backgrOUfl , tetca1f & Eddy has evaluated the prà—
posed regulations and supporting source documents. We have concluded
that the 18 monthS does not, in our opinion, represent an adequate
time to condUCt effective pilot programs and design the subsequent car-
bon treatment systems for the projected number of cities requiring such
systems. Further, we don’t believe adequate time has been provided for
the transfer of flowledge within the engineering community re ding
the application of activated carbon for trace organic control We feel
that without a transfer of this technology, insufficient enginefring
Capacity wi].l exist for the design of the approximately 70 activated
carbon systems that are projected to expand the existing data base.
Finally, we submit that additional effor1 nd time is required
to futher define procedures for conducting effective pilot programs,
and to evaluate echfl1q S that may reduce the costs of carbon re-
generation.
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(2)
We believe the proposed regulations can be modified to address
these factors without jeopardizing the objectives of the regulations.
Metcalf & Eddy plans to offer alternative approaches for considera-
tion, which we believe would strengthen the proposed regulations.
Initially, we would like to focus our remarks on .b.oo-c specific
issues on which EPA requested comment. These are the soundness of the
three effluent criteria, the procedures for obtainin g a variance, and
the adequacy of the 18 month period for designing a arbon system.

Is CA)
Soundness of The Three Effluent Criteria
Metcalf & Eddy believes the 50% TOC removal and the 0.5 micro—
grains per liter of volatile halogenated organics (excluding tn-
halomethanes) criteria represent a reasonable approach to establish
initial treatment objectives for the control of syx thetic organics.
These limits can be made more or less stringent as’ ’additionai data is
developed on a national basis. However, we believe an effluent cri-
teria based on an increase on 0.5 mg/i of TOC is not an effective
criteria for controlling the discharge of toxic synthetic organics,
and could lead to higher treatment costs if adopted as a national stan . .
ard.
The proposed regulations specify that an increase in the TOC
effluent value of greater than 0.5 mg/i compared to the initial ef-
fluent value, provides a means to indicate when the carbon is becom-
ing saturated with respect to removing potentially toxic organic corn—
ponents Metcalf & Eddy concurs that an increase in the effluent TOC
concentration could be due to saturation of the carbon. However, it
could also be due to an increase in the organic load applied to the
carbon adsorber and/or a change in the relative distribution of the
organic chemicals in the water source due to factors such as rain
events and seasonal changes.
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(3)
If the relative concentration of weakly adsorbed organic species
increases, then the percent TOC removal would decrease. If these non—
sorbable species are non-toxic, then the use of the 0.5 mg/i TOC cri-
teria would result in premature regeneration of the carbon. Conversely,
if the weakly adsorbed species are toxic then regeneration should take
place before an increase in 0.5 mg/i of TOC occurs.
If the influent organic load changes accordingl j, assuming the
same relative, composition of chemical species. This is a result of
the dynamic equilibrium conditions existing within the carbon. For ex-
ample, if the carbon run is initiated with a relatively high organic
load that decreases during the run, use of the 0.5 mg/i TOC criteria
would result in a longer run than if the converse condition existed.
Since the regeneration cycle in these cases is a function of when the
run was initiated and not the degree of saturation of carbon, the use
of the 0.5 mg/i TOC criteria does not provide an ac’urate means to con-
trol the discharge of toxic organics.
An improvement in the proposed criteria cah be made expressing
a criteria based on a percent change rather than an absolute change.
Further, the TOC criteria should stipulate measurement of TOC after
filtration with a filter less than 0.2 microns to eliminate the con-
tribution from organic solids or carbon finesp..
Metcalf & Eddy recommends consideratior f alternative measure-
ment techniqUeS to monitor for break-through of toxic organics. Pro-
cedures are avilable for extraction and measurement of the less vol-
atile toxic orgafliCs by gas chromatography. They are being employed
for trace organic control in wastewater applications and could be
utilized in this application. Additionally, TOC1 and liquid chroma-
tography techniques are available. Any of these would provide a more
positive measurement of toxic organic break-through than the proposed
TOC measurement
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(4)
2. Variance Procedures for Synthetic Organics,
Metcalf & Eddy believes the procedures described for obtaining a
variance should be defined more explicitly and integrated into an
overall program to control the trace organics in drinking water.
The regulations do not define the basis for establishing whether
or not a significant degree of contamination exists i a water supply.
It is highly likely that some of the chemical species 1 ].isted in Table
1 of the proposed regulations can be found in many water supply systems
if sufficiently sensitive analytical methods are employed. We feel
that concentration limits should be specified. We also believe the re-
gulations should be modified to allow time for a monitoring program to
be initiated for those cities where contamination is detectedL The ob-
jective of the monitoring program would be to characterize variations
in the contaminate concentration and to identify the source of con-
tamination. This monitoring program could be integ ated into a field
pilot program to provide a basis to define the expe imental conditions
of the pilot effort and to establish which toxic. chemicals can be con-
trolled at the discharge source.
3. Design Schedule for Carbon Treatment
Metcalf & Eddy’s revie f the activities associated with con-
ducting a pilot program and designing a carbon treatment system show
that a time period in excess of the proposed 18 months would be re-
quired. Based on our experience in designing carbon pilot programs,.
we have estimated the time required to complete the major task elements
as fol1ows: j
Pilot and Design Program Activities Time ( mont1
a. Water sampling and characterization 2-4
b. Variance assessment 1—2
c. Preparation of pilot testing facilities 3—4
d. Operation of pilot units 6-8
e. Determination of design criteria 34
f. Detailed system design 12-14
27—3 6 ?
Total
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(5)
The preparation of pilot facilities includes the following tasks:
isotherm screening for carbon selection; construction of the pilot
test system; installation of on—side analytical facilities; and
preparation of an inventory of regenerated carbon. The time for
operation of the pilot system is based on the need to measure the
influence of seasonal effects and to allow time for minimum of
three pilot runs for data verification. The three o four months
for defining design criteria incorporate a cost-performance assess-
ment based on the pilot data. /
Based on the above assessment, Metcalf & Eddy recommend / at
the proposed 18 months to design a system be extended to 36 months.
We feel this extended schedule would enable a cost-effective system
to be designed. A more compacted schedule would increase the risk
that an overly conservative or inadequate design would result.
RECOMMENDATIONS FOR 1.DDITIONS TO PROPOSED REGULATIONS
7
Metcalf & Eddy has reservation about the rapid pace by which ap-
proximately 70 cities would have to design and construct large scale
carbon treatment systems. Design deficiencies resulted initially
when activated carbon technology was transferred from use in the
sugar processing industry to a wastewater application. The proposed
use of aôtivated carbon for water treatment is not only a new applica- .
tion, but an additional degree of complexity has been added. This is
associated with operating a full scale carbon system for control of
trace levels of specific organic species which has not been accomp—
lished before in this country (except in a few cases for phenol con-
trol). Research is currently being conducted in both the private
sector as well as within divisions of EPA to assess carbon effectiv—
ness in this application.
We believe that more time should be provided before the affected
cities respond with the design of full-scale activities. Our con-
cerns with the proposed schedule include the following:
1. The adequacy of the existing engineering capacity with
the experience to design 60—70 activated carbon systems
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(6)
within the proposed schedule.
2 . The lack of carbon pilot data for different effluent
criteria, relating the regeneration frequency to the
carbon bed depth.
3. The lack of available time to incorporate the results
of on—going research which could reduce the treatment
a
costs. ,1
Metcalf & Eddy suggests that the proposed regulations be ex-
panded to include an initial effort to address the above elements
to ensure that effective carbon treatment systems are designed. We
recommend the following two activities for your consideration:
1. National Carbon Pilot Studies
It is recommended that these pilot studies be conducted
at key locations across the country to provide a wide spec-
trum of carbon performance under different test conditions.
These pilot studies -should include the fo].lowipg program
elements: /
a. Assessment of carbon regeneration
This would include studies to establish whether or
riot the adsorption carbon effectiveness is].ost upon
successive regeneration, and regeneration pilot studies
with exhausted carbon to. define design critfria for
sizing a regeneration furnace.
b. Multi—point carbon column studies
These include pilot studies with two types of re-
generated carbon in parallel pilot trains with multiple
sample points to allow the rate of carbon exhaustion
to be determined as a function of carbon bed depth.
C. Cost/Performance Assessment
This activity would focus on developing operating curves
from the pilot data that relate the size of the regenera—
tion system to the size of the adsorption system so that
the point of minimum cost can be established. This would
enable an ec6nomic assessment to be made regarding moving
bed versus fixed bed.
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(7)
d. Development of carbon transport techniques
This effort would be directed a developing pro-
cedures to economically remove carbon from sand
filters for carbon regeneration.
2. Large Scale Demonstration Studies
It is recommended that several large—scale pilot and/or
*
full-scale plants be constructed and operated for demon-
stration purposes to evaluate design alt ernatives and to
examine operational factors that may be unique to water
treatment as opposed to wastewater treatment. In par-
ticular, it is recommended that a moving or pulsed carbon
bed be evaluated to establish whether it would be more
economical to operate than a fixed carbon bed, and to
establish whether adequate control of trace organic levels
can be achieved.
These actions will enable the following objectives to be realized
1. Provide a comprehensive data base to enable eff ctive design
decisions to be made.
2. provide the time required to increase the engineering capacity
for the design of the projected number of carbon treatment systems.
3. Enable results to be considered from on—going evaluations of less
expensive regeneration furnaces.
4. Establish whether or not alternative analytical measurement tech-
niques should be utilized to measure the effectiveness of carbon
treatment.
In summary, Metcalf & Eddy recommends that the schedule for the
design of carbon treatment facilities be extended to allow the results
from national pilot studies to be assessed and digested by the engin-
eering commUnitY. This effort would add an additional 12 years to
the schedule.
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(8)
If some of the cities affected by the proposed regulations are in-
cluded in these activities, then the impact of the schedule extension
would be reduc d as the cities could utilize the data in the design of
their own treatment systems. Further, partial protection can still
be realized if sand is replaced by activated carbon in the existing
sand filters. This inter xn measure with sand filters may prove to
be a viable alternative depending results obtained during pilot and
demonstration studies.
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1 MS. CHANG: Thank you.
2 DR. COTRUVO: Prom an engineering point of view, or
3 a technical operating point of view, do you sea any major
4 problems in replacing sand in existing filters and whatever
5 transfers would have to occur? Is that a significantly more
6 complex engineering problem in removing carbon out of sand
7 filters?
8 DR. KEMP: Let me address that in two ways. First,
9 as far as the utility of putting carbon in existing sand fil-
10 tars, one of the drawbacks is shop retention time, and this
11 can be offset by removing the carbon at an increased rats for
12 regeneration purposes.
13 I am riot sure adequate studies have been dons to get
14 realistic operating curves that relate the rate of exhaustion
15 of the carbon as opposed to the carbon bed depth. If this is
16 done, there may be a situation where it would be more .conomi-
17 cal. to absorb their operating costs, to realize the capital
18 savings that would occur by using existing sand filters.
19 As far as removing the carbon, I am familiar with
20 the activities being conducted at Philadelphia, and their wor
21 suggests that they may have a viable solution using existing
22 sand filter beds. They have explored alternatives and find
23 that they are at an impasse in figuring how to get carbon out
24 of existing filters, which are based upon a Leopold drain
25 design.
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?rain that assessment, there may be inadequate mectlar
2 ism for getting the carbon out of an existing sand filter.
3 MR • GUUJTHIER: iou mentioned the fact in your
4 written testimony you have ex+angive experience in the use of
5 activated carbon technology for water treatment. Is that
6 drinking water treatment, or primarily wasts iater?
7 DR. KEMP: No, it is primarily wastewater.
MR. GLhUTHIER: Have you dons any pilot Btudies or
9 preliminarY design work in the drinking water area?
10 DR. KEMP: No, sir; we have done one or two studies
i on water, use of carbon in water, but it has been directed foi
12 taste aiid odor type objectives and not control of toxic
13 organics.
14 MR. KI)*1 Has you fi has an opportunity to revis
15 the recuiunsndations on how to conduct those pilot studies con
16 tamed in the treatment guide?
17 DR. KEMP: Yes, I hay, done an extensive evaluation
Is on that.
19 MR. KIMM: Do those principles and guidislineg on ho
to do it appear to be reasonable?
DR. }CEMP I think there could be an improvement in
)2 ias of the t*ChnicP 5 suggested. In particular, there may b4
23 some jg erstandiflg Ofl how tO US C the R value, perhaps. it
24 appearS that what has been done there is to relate the cost
25 of treatmflt to a given retention tins • no
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1 correlation between establishing a relationship between the
2 rate of exhaustion and the lengths of the carbon bed, and that
3 can only be done by pilot experiments; and that can only be
4 done by deriving an operating curve, which can only be done by
5 having several sample points to be monitored in your carbon
6 train.
7 Moat of the data I have been exposed to has been
8 derived from single—point masuremnta, and only recently Mv
9 multi-point data started to be approved. I don’t se. any cvi-
10 dance of the engineering community using a multi-point data
11 try to develop operating curves to relate exhaustion rate to
12 exhaustion bed depth
13 This is a common practice in wastewater application
14 to design a’systea, becaus, that operating curv, is what you
15 use to find the minimum cost. I don’t see any evidence that
16 that realization is being considered for .stiiating coats for
17 carbon trsataent. In fact, th. costs may be high or low,
18 because you really don’t know where you are on that operating
19 curve.
20 Somewhere on that curve, the costs ar. minimized,
21 and data based on a single point -- you could be on ithar
22 side of that cost curve. I think that is one example where
23 some additional insight should be provided to the -- communi.
24 DR • COTRUVO: I think Dr • Rice, this afternoon, sai
25 that he felt that perhaps a longer operating time for the
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1 pilot plants would ba necessary in order to collect sufficienc
2 data, to scale-up. Ha was talking on the area of one and a
3 half to two years. I see your estimate is six to sight
4 months for operation of pilot units.
5 DR. XEMP I I think that represents a minimum time
6 frame. I think if you look at the reality of the situation,
that six to nine. :months was derived on the basis that you need
8 a minimum of six months to obtain the seasonaL effects • You
need an additional period of time to develop a multi-reganara
10 carbon, which you should use to conduct pilot studies.
11 If everything goes right, you can get done with in
12 one year -- three or four months to get your inventory prepar
ed, and during that time, doing preliminary screening with
14 bench—scale pilot studies and isoton. work, which will sat th
15 sce ia for on—site demonstration work, which, if conducted
16 properly, can be accomplished within the six to nine month
17 period of time.
I would submit that an engineering firm unfamiliar
19 with these techniques -- it would take substantially longer
to do so. Again, the six to nin, months assumes roughly thrad
21 pilot runs for data verification; and you might need four or
22 five, because the analytical precision of son. of thess tech-
23 niquss remains to be proven.
24 There is a lack of capacity in a commercial labora-
25 tory system, and you may have to build into an old laboratory
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1 capability to provide the variability you naed, and that would
2 add time to get that capacity on board.
3 MR GLAUTHIER: Dr. Kemp, have you had a chance to
4 review any of the cost estimates prepared for EPA, especiaLLy
5 those produced last week? Arid, if so, do• you have any cor unen
6 on then ?
7 DR. KEMP: I have reviwed them, and I have no corn-
8 ment. I am not associated with various design cost factors
9 to make a comment on that. I have reviewed them, but I don’t
io feel I can carunent.
11 MS. CHANGi Thank you very much.
12 Is David Russell here?
13 STATEMENT OP DAVID G. RUSSELL, BOARD MEMBER,
14 PAIRPAX COUNTY WATER AUTHORITY, PAIRPAX COUNTY,
15 VIRGINIA
16 MR. RUSSELL: My name is David G. Russell, and I am
i7 a Board Member Of the Pairfax County Water Authority, located
is in Pairfax County, Virginia.
19 I am sure some of you have drunk some of our water.
2o I was appointed when the Board was expanded in 1976 • On. of
21 my concerns, prior to my appointment -- and remains a concern
22 today -— is the quality of this drinking water for the 600,00
23 people we serve.
24 In 1969, I am told that the water resembled Coca-Co
25 which was caused by the Authority trying to cleanse water
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without flooding the treatment plant. In 1970, we were told
2 that the water supply would turn into a sewage lagoon unless
3 drastic corrective measures ware taken.
In 1976, the Virginia State Health Department report
ad that polio viruses had been identified in th. finished
6 wa er. H wever, there were no cases of polio reported. In
1977, we were told by th. press that the chloroform in our
8 water exceeded the highest safety threshold suggested by EPA.
At a meeting to discuss this finding, attended by
10 Dr • Cotruvo of EPA, Dr. Robert Ho in. from VP I, and Oscar Adam
1 from the Virginia Health Department, several Board members
12 repeatedly joked and laughed about the chloroform levels and
13 compared the levels with a drop in 50 barrels of gin, and “W*
14 don’t sea bodies lying in th. gutter, so let’s not panic.”
15 Dr • Cotruvo pointed out that ha hopd w were not
16 mInimizing the problem and we should not laugh at all. I
17 didn’t laugh than, and I aa even mor. concerned now as our
levels continue to exceed 100 parts.
19 The Authority has taken steps to remove the chloro-
20 form from the finished water, and we ar. in the process of
21 making modifications, which will, relocate the point of applic
22 tion of chlorine at an estimated cost of $200,000.
23 Even after these modifications are made, I don’ t
24 believ, our levels will go below this recommended proposal.
25 More needs to be done. Th. quality of our raw water, which
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1 coins from the Occoquan River, is nothing to brag about, as it
2 continues to become more polluted each day from urban runoff.
3 The State Health Department says they are conc rnad
4 about our raw water supply, but where is the concern when it
5 comes to our finished water? I art told they oppose these pro—
6 posed rules and guidelines, and where is our Stats Water Con-
7 trol Board?
8 Our Water Authority Board, by a vote of 6 to 2, went
9 on record opposing the EPAproposed organic standards. On
to May 2nd, after hearing from its consultant, Dr. Carol Morris,
ii it decided to reconsider its position.
12 On July 6th, the Authority deferred taking any
13 action, and I am hopeful they will reconsider or consider
14 action at a later date. I feel it is im for action, and I
15 don’t like picking up Good Housekeeping and reading, How
16 Safe is ‘four Drinking Water? TM and seeing the Authority listed
i7 in the top ten with the worst water.
18 I don’t like reading that our water can cause cancer
19 and I don’t like reading that the Occoquan is not suitable fox
20 fish life. I don’t like rsw irtg that nitrogen in our raw vatE
21 has st*&dilY increased since 1969 in spits of improved treat—
22 m*nt.
93 In the July 6th Pederal Register, EPA answered many
24 of the qustions raised thus far; and I support the proposed
25 regulatiOns to COUtXO1 organic chemical conteMnants in our
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i water, as the public must be protected from the dreadful dig-
2 ease called cancer.
3 Thank you.
4 MS. CHANG: Thank you for coming.
5 DR. COTRUVO: 4r. Russell, I was just wondering wha
6 kind of public response you have been receiving over the past
7 year or so. Are you hearing from them? Are they encouraging
8 action, or are they concerned about costs?
9 MR. RUSSELL: I think the public -- I won’t say
io they are ignorant; I think they are concerned. I have receiv
ii calls -- probably received more calls since the article appear
12 ad in Good Housekeeping. The Supervisor from Fairfax County
j3 has told me that her office has received a number of calls,
14 basiCally because, I believe, the Good Housekeeping report --
15 the water was in Annandale • It should have bean reported in
16 Fairfax County.
Nevertheless, people are concerned, and I have had
18 pØpl8 call me • I think it is a matter inunication with
19 t1 e Water AuthoritY to the public. The press has done a good
job in reporting the levels. The most recent levels, that I
21 got today -- I think we had one high point of 155 parts at on
22 location.
23 I am told after. we make some of these modifications,
24 that these modifications will only reduce the chloroform
25 levels by something like 30 percent. t have also bean told
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1 that the cost figures which you all, have made public are not
2 necessarily right. But I believe they are, based on the infor
3 rnation that I have read, which you all have published.
It is going to cost us a lot of money, becauso our
5 water is so dirty -- it is filthy. And I have made every
6 attempt -- f or instance, the State Water Control Board racenti
7 passed a resolution that they do a study on the Occoquan Polic
8 I hope they don’t downgrade that policy, but I suspect they
9 probably will.
10 We were also told years ago that it was the sewage
nd SA l causing all the pollution in the Occoquan.
s SB 12 It has now been reported that it is the urban enviro
13 ment, the urban environment pollutes 75 percent of the Occoqua
14 Reservoir. I am concerned about providing good quality water
15 to the aitizens of Fairfax County and the citizens of Prince
16 Williams County and Citizens of Alexandria. I take it very
17 seriously, and I think the public wo ild be willing to pay the
18 price, provided it ii kept low, and I think it is kept low;
19 based on the previous projections, it runs about $26 p .r year
20 per family.
21 I am willing to pay it, and’:! think the people in
22 Fairfax County are willing.
23 DR. KUZMACK: Is it your estimate that Pairfax will
24 have to use carbon to meet the TUM?
25 MR. RUSSELL: I donet think we have a choice.
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1 MR. ROBECK: I understood some of your people --
2 Mr. Cameron, for instance -— was considering the use of ozone.
3 Do you know if there were any estimates being made on COStS
4 of that alternative?
5 MR. RUSSELL: I hay, been pushing ozone since the
6 t .ic].es appeared. I think it was in one of the trade maga-
7 zines. I read what Europe has done with ozone and the COB,
8 or something Like that. I was intrigued by what I read there.
9 I am not a chemist; I am not a doctor; but what I am reading
10 and seeing what the Europeans have done, I am usually in the
11 minority on our Water Board, I don’t know why, when it CU S
12 to the quality of the Water, but I take it very seriously.
13 MR. ROBECK: I think there nay be some continued
14 discussions with your people:.on the options.
15 MR. RUSSELL: I hav, asked; in fact, I have bun
16 pushing very hard to do some testing with ozone, and I am told
17 that it is very costly. Again, I am not an expert at Costs
18 as far as ozone and granular activated carbon, but I am told
19 it is very costly and would surpass th. granular activated ca
20 bon costs.
21 But, based on the costs I have seen, I think it
22 might b even cheaper.
.23 MS. CH NG: Thank you.
24 Twa gentlemen from Houston, Audrey LoP argue and Sam
25 Dickson.
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1 STATEMENTS OF SAM B. DICKSON, ASSISTANT DIRECTOR OF
2 PUBLIC WORKS, IN CHARGE OP WATER DIVISION FOR THE
3 CITY OF HOUSTON, TEXAS; AND AUDREY LaPARGUE,
4 ASSISTANT MANAGER, SURFACE WATER, CITY OP HOUSTON.
5 MR. DICKSON: I am Sam B. Dickson, Assistant Dirac
6 of Public Works, Lu charge of Water Division for the City of
7 Houston. Mr. LaParg *wi11 speak of our investigations and so
8 forth a litti. later on, but I would lik, to sat the stage.
Houston has bean pumping water for 150 years. Righ
10 now we serve 2 to..2.4 mil1ion p.op1e in the area. The west
ii part of the City of Houston will not regulation, the raguiati
12 we are talking about, because it is on wellS; but the east si
13 will.
14 I was very interested in listening to Mr. Kinun, when
15 he said we will take annual averages. If we annually average,
16 we don ‘t have to worry about anything in Houston, because we
17 take half from wells and half from surface water and put it
18 all together once a year, and then w& are down below your
19 flLifliZflufltS.
20 But this is not what you are talking about. Basical
21 ly, I have to agree with my colleagues from California. We
22 are a resonsible industry. What has really stuck in th. craw
23 of the water people is that without consulting the industry,
24 some stringent regulations hay, been proposed. And now we
25 find ourselves in a rather difficult task of supplying our
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1 •xpe tise through public hearings in opposition to these regu-
2 lations, and that is not what we are in business to do.
3 The proposed regulations are couchâd in such vague
4 langnage, such as “the Director is convinced” or that “thesa
5 compounds may cause a health hazard, that maybe we ought to
6 relook at them”.
7 we really think, and I am talking about Houston righ
8 now, that we should get together and work this out. I think
9 we can. I think the whole industry would welcome doing this.
10 To do this, EPA should modify these existing proposed regula-
11 tions and use them as an interim guide until more scientific
12 facts can be developed.
13 What we need to do, the water industry and EPA, is
14 to get together and share our .xp.rtise. The “regulators” --
15 and I will put that in quotas - - need to get data from the
16 operatOrs who have to do this 24 hours a day. They can ‘t stop
17 they know it has to happen.
18 One of the biggest things w have to do is to obvi-
19 ate the possibility of citizen groups who feel emotionally coir
20 p*ll d to act without scientific knowledge. The articl, that
21 was alluded to in the Good Housekeeping - - ther. was a little
22 old lady -— and I had to find out how old she was; she was 70
23 years old -- she called ma up and was sure that all 700 of th
24 people who lived around her were going to die of cancer,
25 becaUSe Good H g$kI*piflg said she was, because Houston is in
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the upper four of the article that came out in the July issue.
2 We are being tried by propaganda and don’ t even kno i
3 what is going on half the time.
4 On. of the things we have to do -- and this is,
again, what the California people voted on -- is to determine
6 that the present rules and regulations being promulgated are
within the intent of the legislative branches when they pass
8 the rules, or the legislation that sets you all up, or any
9 other thing.
to I think this is the gut issu. you have in California
ii on Article 13. If we have to have this type of regulation,
12 then they should be reasonabl. and proper, and they should be
13 based on facts instead of presumption. We need to get the
14 public into this, and we need to explain to them what w are
5 talking about. And if it is a problem, then we have to
16 explain to them that it is not as urgent as has been indicated
by s e people from the EPA.
18 have drunk watsr in the City of Houston for 57
years, and I don’t know that I have cancer yet. This is a
part of the things we have to look at.
21 What about the snvirom enta1 impact statements? If
we build a plant, we will have to make one. You can arbitrar
ly say, “You don’t have to make an impact statement of any
24 nature,” but if we build a plant, caused by your regulation,
we will have to write an impact statement.
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I Mr. Kii un was very interested in timing for th. time
2 frame of this. It takes three to five years to build a plant.
3 I don’t care if everything goes exactly right; it will taka
4 three to five years before you get a plant on stream. This is
5 what you have to look at.
6 We have to live; we can’t live on Government esti-
7 mates, going back to your presumption on cost estimates. We
8 have to live with the bonds that we wall and for the length
9 of the bonds, and our estimates have to be what it is going tc
10 cost us and not somebody’s idea of what it might cost us. That
ii is the basic premise that we live by.
12 All I can say is that no matter what happens with
13 these regulations, Houston is going to continue to giv, good
14 potable water to the people they serv.. That is what we are
i5 in business to do. and no mattr what kind of outside intersa
16 are trying to force things for us to do, we will produce good,
17 clean potable water, period.
18 MR • L ARGUE: Thank you, Sam,
19 My name is Audrey LPargus, Assistant Manages,: Surfa a
o Water, city of Houston.
21 I would lik, to present this statement on behalf of
22 the City Of HoustOn. The City of Houston has historically
“3 d*moflstrat a conscientious concern and effort to produce a
24 safe, high_quality and economical drinking water for its
25 citizenS.
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1 We point with pride to the fact that, since the
2 initiation of chlorination procedures into our system during
the 1920’s, not ona case of typhoid has been traced back to
4 the city of Houston drinking water supply. Houston was thu
5 first city in the State of Texas to initiate advanced technol-
6 ogy in handling waste solids from the surface water treatment
7 plant, We currently have the most advanced analytical labora-
8 tory equipment available for bacteriological and charnical
9 analyses.
10 The City of Houston has participated in three
11 national organic reconnaissance studies. Since the inception
12 of these studies, Houston has carried out an extensive progr 1
13 in determining the measures that may be necessary to meet the I
14 proposed EPA standards.
15 Prom this results of this extensive research we feel
16 that the surface water plant -- producing 45 percent of the
17 potable water for th. citizens in the Houston area -- can
18 meet the 3.00 part per billion total trihalomethana, THM,
19 requirement with treathent adjustnents rather than the requiri
20 us. of granular activated carbon, GAC
21 Initially, we would like to point out..thers are soim
22 areas of the proposed regulations that need further clarif ice
23 tion:
24 One; the use of the word primary” as related to th
25 application of chlorajninss: DoeS this mean initial or princi
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1 treatment? From the results of our studies, chorazninas have’
2 been found to be an excellent means of significantly reducing
3 the trihalornethane levels. Additionally, we would like to
point out that by the use of chioramines as a pre-disinfectant
the THM can be reduced without any effect on the bacterial
6 quality during the tratment process.
Two; the proposed regulations state that the raw
8 water supply should b the basis for design criteria for the
9 operational performance of the granular activated carbon con-
10 tactors • GAC contactors are required to be used in th. post
11 treatment process of water. It would appear the design crit
12 Ia should be based upon water which is to be carried to the
13 GAC contactors for treatment. Obviously, this parameter
14 should have a significant bearing on contactor design.
15 Three; plants that are currently using polymers in
16 their treatment train may experience difficulty in maintaining
17 and controlling the .5 mg/l total organic carbon limit increas
18 in the filter effluent of fresh reactivated carbon. Polymer
19 dosage changes in treatment may effect this TOC value. The
20 elimination of this criteria needs consideration.
21 Undr a grant from the Environmental Protection
22 Agency, the National Academy of Science was instructed to
23 make a scientific judgment concerning drinking water. This
24 study states, The protential for existing concentrations of
25 organic pesticides and organic contaminants in drinking water
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1 to adversely affect health cannot be answered with certainty
2 at this time.”
3 It . further said, “There is no hard evidence that low
4 oral exposure to any of these chemicals produces cancer.” Th
EPA is, of course, using this National Academy of Science
6 study as one basis for including thiS control of orga.nics unde
7 the Safe Drinking Water Act.
8 To any researcher, some serious questions must be
9 asked if opposing viewpoints can make reference to the same
10 scientific document as support for their individual viawpoin
In contrast to the National Cancer Institute report,
12 the Xansas Deparbnant of Health and Environment in evaluating
13 a 40—year study states, “. . .it has revealed no evidence of
14 higher incidence of cancer risk to the liver and kidneys for
15 those who drink treated river water than those who drink gro
16 water low in organics”
17 The Environmental Protection Agency has raised a
18 question concerning the carcinogenic nature of organics in
19 drinking water which appear to be contrary to a number of
20 extensive studies that have bun carried out to date concern-
21 ing this question.
22 It-. would appear that the EPA would add more support
23 and credibility to their position if more concrete evidence
24 could have been obtained through extensive pilot plant studie
25 to determine the true effectiveness of GAC filtration from
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1 existing water trsab tent facilities before initiating these
2 questionable reconmtendations.
3 Houston has carried out an elaborate study program
4 that addresses itself directly to this problem. Therefore,
5 the City of Houston would Like to register the following
6 objections to th. proposed regulations based on our research
7 and careful evaluations:
8 One; these regulations, as currently proposed, inclu •
9 only those populations centers of 75,000 or greater. We fSCl
10 that thes, requirements should include public water supply
ii systems with under 75,000 customers as well.
12 Moreover, it is inconceivable that these requiraman
13 should not include all of the major metropolitan centers of
14 this country, such as the Great Lakes area.
15 Two; the City of Houston would also like to raise an
16 objection to the prescribed treathent techniques; particularly
17 to the parameters concerning the operation of granular activat
is sd carbon filters.
19 A -— The .5 mg/l allowable for volatile halogenated
20 organics is below the capability of cost-effective activated
21 carbon process performance. As written, this criteria appears
22 to be a maximum contamiLTiant level, MCL, as well, and would poe
23 difficult analytical determination problems for some municipal
24 systauis.
25 B -- The upflow-typa contactors would be the most
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1 feasible and practical design for the Houston Water Purifica-
2 tion Plant. Our research indicates that the 50 percent TOC
reduction becomes unreliable in this type of design. This
unreliability becomes even more variable as th. filter run is
extended.
6 I would like to ask if EPA has investigated the
‘ effluent-flow design filter We have gotten the upf low-type
8 design filter. We have gotten some information, and we would
like to exchange information.
10 C -- We feel that the 0.5 mg/i total organic carbon
11 limit increase in filter effluent of fresh activated carbon i
12 unrealistic. Especially for those plants that are using poly
13 mar treatment either as a primary coagulant or as a filter ai
14 Also, reduction of GAC efficiency may be realized due to
15 “blinding” as a result of the use of certain polymers.
16 It is not uncommon to find some plants using 10 to
17 15 parts of polymer. I believe EPA studies are considerably
18 less than that.
19 Three; the requirement to replace existing filters
20 with granular activated carbon as an interim control measure
21 would be Of little or no value at City of Houston treatment
22 facility. Contact times in our existing facility are in the
23 neighborhood of three to four minutes.
24 Thus, little organic removal would be realized. Thi
25 method would also require unrealistic regenration or
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1 replacement schedules. Under the presently proposed design
2 parameters, filter regeneration would be necessary after each
3 10 days of operation, or some two filters each day out of sar-
4 vice.
5 For a plant that is continually operating 50 to 75
6 percent over design, this would be an unnecessary hardship.
7 The financial burden would be approaching $25 million a year
8 in operational costs.
9 Based on current chemical costs, we are talking
10 about an increase of 1.740 percent, or a dollar value of
11 $342 per million gallon increase in our chemical costs.
12 Four; our experience and research shows that the
13 standard plate count, SPC, is not necessarily a more sensitiv2
14 microbiological quality indicator while treatment modificaUox
15 are being introduced. We feel this gross determination should
16 not be included as an indicator of water quality.
17 Five; The EPA has proposed a number of cost paraxnet-
18 ers for CAC treatment; however, we have found that these cost
19 estimates are considerably lower than what we anticipate for
20 Houston. With this in mind, we have some serious doubts as
21 to whether the nationwide figures reflect actual values.
22 Our initial investigation indicates that Houston
23 could require a rate increase of some 30 percent for the
24 installation of GAC contactors. The initial capital cost for
25 GAC treatment would be approximately $50 million, with an
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annaul operational cost of between $10 and $12 million.
2 A cost of this magnitude would increase our present
3 operational budget by nearly 300 percent. We feel that to
4 assume these costs based on unqualified data would be an
5 unnecessary expense at this time.
6 Six; the proposed regulations have made reference
7 to the “purity of chlorine”. We feel strongly that this area
8 needs considerably more investigation and study. We have not
9 completed our studies in-this area; but, to date, our studies
10 indicate more strict control should be instituted on the use
11 of carbon tatrachloride.
12 Since the report was prepared, we have done add.itior
13 al work with chlorine, and we don’t see that there is a lot of
14 other trace organics in chlorine. We are in pretty good chap ,
15 it appears, on chlorine.
16 This contaminant has besn found in chlorine, since
17 it is widely used in the maintenance of chlorine containers.
18 We f1 that more strict and rigid requirements should be
19 placed upon th. manufacturers of chlorine to insure minimum
20 contamination.
21 Seven; the use of granular activated carbon has beer
proposed as the method of choice for the removal of trihalo-
23 methanes. Based upon our data, the removal of chloroform on
24 our pilot unit with a 16-minute detention tima averages only
some 40 to 50 prcent.THM removal and only 30 to 40 percent
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1 for chloroform removal.
2 For this level of removal, some serious questions
3 must be asked on the cost-effectiveness of this method of
4 treatnent.
5 Eight; once C,AC filtration has been carried out, ou
6 data raises some doubt as to the effectiveness of precursor
7 removal. The treated water carried through our GAC pilot
8 filtration unit and then chlorinated with as littl, as 0.6 ppn
9 results in sans 30 to 35 percent increase in trihalcxtethanss.
10 Since th. above analyses were made on a quenched sample, tar-
11 minal THM could be somewhat higher.
12 Mime; th. proposed requirements indicated that an
13 even lower trihalomethane ma thnum contaminant level will be
14 considered. From our studies, we feel that those systems that
15 have a 100 parts per billion THM will be unable to reduce thas
16 levels to 10 parts per billion, and will even have difficulty
17 in controlling to the 50 parts per billion effectively.
18 Ten; apparently, the EPA has not fully investigated
19 the problems that polymer treatment will have on GAC contactor
20 Polymer dosages of 10 to 15 parts per million ar. not uncotamor
21 in our area.. At thes. dosage levels, rapid deterioration of
22 GAC efficiency can be expected, resulting fran this Nblinding
23 or fouling of the carbon.
24 It should be noted that a number of industries in
25 our area c*nnot use polymer coagulation treatment due to the
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I “fouling” problems encountered in ion exchange. resins. The
2 humic and fulvic substances are reported as precursors for
3 trihalornethane production and have bean studied extensively by
4 manufacturers of ion exchange resins.
5 These studies show considerable NfoulingN by these
6 organic colloidals does occur. Our data indicates similar
7 fouling ” can be a significant problem with GAC filtration.
8 Eleven; the Safe Drinking Water Act turbidity
9 requirements in some plants may only be mat by the use of
10 polymer as a filter aid. Especially in those plants that us
U mixed bed or dual media filters..
12 Even at extremely low dosages, 0.001 ppm to 0.005
13 ppm that are required when used as a filter aid, considerable
‘4 “blinding” can result; thus shortening filter runs. Csrtain1
15 those plants using higher polymer dosages could expect consid-
16 arabIc difficulty in efficient CJC operation.
17 Twelve; organic and metal contaminations of granula.i
18 activated carbon have been noted by a number of researchers.
19 To date, our laboratory investigations have not bun able to
20 confirm that the heavy metals would be a significant problem.
21 We ar. currently evaluating the organic contaminants that somi
22 researchers hav, reported present in GAC • Our very pr.limin-
23 ary reports indicate an increase in organics indicating furthi
24 study may be necessary.
25 Houston, like so many other cities over the entire
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1 United States, is faced with growth and capitalization probl’
2 The expenditures required to meat these regulations can wall
3 be used to expand and upgrade water treatment and distributio
4 facilities improve operator certification, and expand train-
5 ing programs.
6 The regulations, as currently proposed, would place
7 an unnecessary hindrance to carry out these objectives.
8 The City of Houston -— because of interest and con-
9 cern for its citizens —— has carried out and will continue to
10 study, all areas of organic contamination. The Surface Water
ii Section of .;.the City of Houston is one of the very few treat-
12 merit facilities that carries out a weekly monitoring program
13 of our entire 3,600—square-mile watershed.
14 Fe municipalities can boast of having such an exten-
15 sive and complete monitoring program. This program is carried
16 out, and has been for many years, to meet and prevent any
17 major health or water treatment problems.
18 Wa in Houston feel that the EPA has also made an
19 attempt to meet major health problems in many areas in our
20 environment. The City of Houston, however, feels that the
21 proposed regulations concerning organics do not represent good
22 judgment based on sound analytical results.
23 There appears to be vague assumptions based on
24 questionable documentation. The EPA cannot be criticized for
25 responding to special merest groups; but a hastily prepared
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1 document based on inconclusive evidence can only undermine the
2 credibility of the EPA.
3 It should be admitted that any toxic substance in
4 drinking water cannot be allowed; however, blanket treatment
5 by granular activated carbon without specific identification
6 of individual system problems is also intolerable. This
7 ccm es even important when such an incredible amount of
8 expense will have to be borne by the municipalities and their
9 citizens.
10 In summation, with the above obj actions in mind, the
11 City of Houston would urge the Administrator of the Environ-
12 mental Protection Agency to seriously reconsider the tinpismen.
13 tation - - in their present form -- of the proposed regulationS
14 of organics in drinking water.
15 Houston recognizes the importance of environmental
16 management in protecting th. health and welfare of its citi-
17 zens. But, we also have only so many dollars and so much
18 huF’an energy • What we need is more concern for environmental
19 prOgrams that take into account what is really necessary to
20 protect the consumer, what is financially possible, and what
21 is technically sound.
22 Water is a manufactured commodity, and its produc-
23 tion is a vital industry t0 this nation. We in Houston will
24 continue to produce a safe, high-quality, economical drinking
25 water for Our citizens.
(the attachments to the statement foll i:)
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SUMMARY OF INVESTIGATION STUDIES
SURFACE WATER SECTION
CITY OF HOUSTON
The City of Houston has made and is continuing an in depth study of the control
and removal of organics in potable water. The following information is only a very
gross overview of the most important areas under investigation.
The first item of interest was to establish a method of determining precursor
levels. Hopefully to enable one to predict, with reasonable accuracy, the potential
for THM formation. The parameters considered included turbidity, color, TOC, UV
absorbance, temperature, fluorescences, and NPTOC. Only the NPTOC and flucrescences
indicate some degree of predictability.
The second major area of investigation included various disinfectants available
for potable water treatment. This study included ozone, chlorine dioxide, potassium
permanganate, chioroamines, and ferrates. Chloroamines were found to be the most
practical and effective disinfectant capable of controlling 1KM formation.
The third area of study was to determine various alternatives to organic
removal, particularly the THM compounds. Under investigation for 1KM removal methods
were powdered activated carbon, aeration, granular activated carbon and various resins.
As indicated in the policy statement GAC could not be considered an effective method
for the control of haloforms. The most effective method investigated to date has
been a Rohm — Haas Resin XE 340. Up to 98% 1KM removal was realized and early cost
calculations appear to be attractive as well. This resin will not, however, meet
the TOC removal design criteria.
Also a number of special studies were undertaken such as organics in bulk
chemicals used in potable water treatment. Only chlorine may warrant further study.
Since much of the potable water consumed is used in the form of’ tea, coffee or in
food preparation; the removal by simply boiling of water was found to be an extremely
effective method of THM removal. A 99% .removal was realized after only 5 minutes of
boiling in an open container.
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II
As stated earlier, the City of Houston will continue in its efforts to provide
a safe and economical supply of drinking water. We also are dedicated to maintaining
these goals thru continued research and development.
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A COST ANALYSIS FOR THE CONTROL
OF ORGANIC CONTAMINANTS IN
DRINKING WATER
I. Cost calculations for Interim Granular Activated Carbon.
The City of Houston has two surface water treatment
facilities currently producing some 150 MGD of potable water.
The Interim treatment requirement of replacing existing
sand filters with GAC would result in an exorbitant treat-
ment cost.
To replace the sand with 214 Inches of GAC in 20 filters
that have a combined volurnn of’ 50,000 cubic feet would
require 1,250,000 pounds of carbon. For off site regeneration
at $.53 per pound cost would be in excess of $214,000,000.00
dollars per year. This represents an increase of $3142.00
per million gallons and a chemical cost increase of 17140%,
based upon a 10 day regeneration cycle.
II. Cost Calculations for GAC post contactors.
Based on a 200 MGD production of potable water the
use of’ post GAC treatment reflects a carbon requirement
of nearly 6,000,000 pounds. This quantity reflects only
those contactors in service and does not take into considera-
tion carbon necessary for standby service and regeneration.
A contact time of some 12 minutes at the flow rate
of .59 gpm/cu. ft. indicates a regeneration cycle every
two months. Regeneration and O/M cost either In or off
site would result in an annual treatment budget increase
in excess of $11,000,000.00. Of course, a capital outlay
of $50,000,000.00 for post contactors and regeneration
facilities would be required.
Post contactor operation cost Including carbon re-
placement would reflect a 1300% increase over 1977 chemical
treatment cost.
III. Cost Calculations for Resin Treatment.
Rohm & Mass Resin XE 3140 proved to be an effective
method to remove haloforms. Initial cost of $10.00 per
pound are considerably high but extremely low media re-
placement would be realized. Additionally regeneration
cost and amount required would be considerably less due
high flow rates and steam regeneration. Capital outlay
requIreme and O/M cost appear to be some 50% to 60%
less than GAC. Even with a 98% THN removal and taking
other cost saving into consideration. Chemical treatment
COSt would be increased somewhat over 1,000%, based on a
flow rate of 3 gpm/cu.ft.
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IV. Cost Calculation for City of Houston Proposed Treatment
Alternatives.
By the use of chlorajnines and caustic soda the City of
Houston should be able to maintain compliance with the
proposed 100 ppb THN. Thi.s treatment train is the most
cost effective method Investigated to date.
Chemical cost would be increased some 70 over 1977
chemical treatment Cost. Essentially no capital outlay
would be required and minimal operational and maintenance
cost.
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CI f OF HOUSTON
PUBLIC WORKS DEPARThENT
SAN JACINTO WATER SYSTE 1
LP BORATORY
Subject: Cost Calculations for Interim GAC Treatment
The interim plan is to replace the existing filters in the plant with 24”
of granular activated carbon.
I. Design Parameter: Based on .5 TOC increase as is currently being proposed.
II. Physical Parameters:
A. Carbon (Filtrasorb 400) (Ref. 1)
1. Bulk Density: 25 Ths/cu ft
2. Cost: $.6]. per pound
3. Regeneration Cost: $.53 per pound
4. 10% loss during regeneration
B. Plant I
1. Surface Area: 1500 sq ft/filter
2. 12 filters
C. Plant II
1. Surface Area: 880 sq ft/filter
2. 8 filters
III. Volume & Quantity Required
Voj.unte(cubjc feet) Pounds
per filter total per filter total
Plant I 3,000 36,000 75,000 900,000
Plant II 1,760 14,080 352,000
Total 50,080 1,252,000
IV. Carbon Movement & Regeneration
Based on the .5 TOC increase the GAC would need to be regenerated every
10 days. This means two filters per day would be regenerated. Eight
days one large & one small filter would be regenerated and two days two
large filters would be regenerated.
Carbon Movement
Cubic Feet Pounds Trucks Replacement or
Loss
Day 1—8 4,760 119,000 3 11,900
Day 9—10 6,000 150,000 4 15,000
Per Year 1,828,000 45,698,000 1143 4,570,000
V. Cost Estimates for GP.C
Based on $.61 per pound new GAC and a regeneration cost of $.53 per pound (Ref. :
Initial Cost: $763,720
Regeneration:
1. 0ff site $24,220,000
Total first year cost: $24,984,000
2. On site
The cost to replace lost GAC would be $2,800,000. Other costs
would be labor, power, and construction of regeneration facilities.
These numbers are not readily available at this time but would be
appreciable.
References: 1. Calgon Bulletin #20—68, 2. Calgon Representative—Week of June 19, 1978
Prepared by: Carl V. Henriques
July 6, 1978
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CITY OF HOUSTON
PUBLIC WORKS DEPARTMENT
SAN JACINTO WATER SYSTEM
LABORATORY
subject: Cost Calculations for CAC Post Contactors
I. Design parameters: Based on .5 TOC increase as is currently being proposed.
[ I. Physic 1 parameters:
A. Carbon: (Ref 1 & 2)
1. Bulk density: 25 lbs/cu ft.
2. Cost: $.61 per pound
3. Regeneration cost: $..53 per pound
4. 10% loss during regeneration
B. Plant:
1. 200 MCD (Plant to be upgraded starting January, 1979)
III. Volume & Quantity required
Flow .59 gpm/cu ft 1.0 gpm/cu ft
Cubic feet CAC 236,000 139,000
Pounds GAC 5,900,000 3,475,000
IV. Carbon movement and regeneration:
Based on .5 TOC increase the CAC would need to be regenerated every 2 months
or six times a year. This means between 20,850,000 and 35,400,000 pounds of
GAC would need to be regenerated per year.
V. Cost estimates for GAO
Based on $.61 per pound for new GAC and a regeneration cost of $.53 per
pound (Ref 2).
Initial cost: $3,600,000 — $2,120,000
Regeneration:
1. 0ff site: $11,051,000 — $18,762,000
(The lower cost represents a loading of 1 gpm/cu ft whereas the higher
cost is for .59 gpm/cu ft).
Total first year cost: $13.17 million for 1 gprn/cu ft or $22.36
million for .59 gpm/cu ft.
2. On site: The cost to replace bost GAC would be $1.27 million for
1 gpm/cu ft or $2.16 million for .59 gpm/cu ft. Other costs are not
readily available at this time.
eferences:
1. Calgon Bulletine 1/ 20 - 68
2. Calgon Representative — Week of June 19, 1978.
epared by: Carl V. Henriques July 6, 1978
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CITY OF HOUSTON
PUBLIC WORKS DEPARTMENT
SAN JACINTO WATER SYSTEM
LABORATORY
Subject: Cost calculations for Ambersorb XE 340 Contactors
One possible a1ternative for GAC is the use of a resin similar to XE 340.
The following is a cost analysis of its use.
I. Design parameter: Based on the removal of total trihalomethanes’
II. Physical parameters
A. Ambersorb XE 340 (Ref 1 & 2)
1. Bulk density; 37 lbs/cu ft.
2. Cost: $10 per pound
B. Plant
1. 200 MCD (Plant to be upgraded starting January, 1979)
III. Volume & Quantity requirements
(Flow rate of 3 gprn/cu ft manufacturers recommended. 10 gpm/cu ft
approximates % removal of CAC.)
Flow (gpm/cu ft) 3 10
Volume (Cu ft) 46,300 13,900
Pounds XE 340 1,710,000 514,300
IV. Movement and Regeneration
Since the XE 340 is regenerated by steam rather than incineration there
is no movement of the media. A contactor is taken out of service and
steam is run through it until it is filled with steam. Then steam is
continued to be passed through until two bed volume of condensate has
been recovered.
V. Cost estimates for XE 340
Flow (gpm/cu ft) 3 10
Cost for XE 340 $17,100,000 $5,143,000
Annual regeneration cost (steam generation only) by Natural gas —
based on 30 day cycle $266,000 $80,000
Approximate first
years cost $17,300,000 $5,200,000
References:
1. Rohm & Haas Pub. lE—231
2. Rohm & Haas Representative
Prepared by: Carl V. Henriques July 6, 1978
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CI OF HOUSTON
PUBLIC WORKS DEPARTMENT
SAN JACINTO WATER SYSTEM
LABORATORY
Subject: Cost Calculations for Chiorarnine - Caustic Soda Treathent
I. Design Parameters: Rather than altering the plant or the incorporation of
large contactors, we would prechiorinate with chiorainines and also add
chloraxrtines in the clear well. We would then add Cl 2 for free residual
leaving the plant. Rather than lime for pH control we would use caustic
soda in the clear well.
II. Physical Parameters
1. 200 MCD (Plant to be upgraded starting January 1979)
2. Chioramine
a. 3ppmtoraw
b. 2 ppm to clearwell
3. Caustic soda — to pH 9.0 in clearwell (13.5 mg/i based on lab experiment)
III. Volume & Quantity Required
Per Day Per Year
Caustic 45,000 lbs 16,400,000
Chlorainjnes
].. Pre 5,000 lbs
2. clearwe],l 3,300 lbs
Total 8,300 lbs 3,030,000
IV. Cost Estimates (Ref. 1) Unit
Pounds Cost Cost
Caustic 16,400,000 $3.69/cw $605,000
chloraxnine 3,030,000 $300/Ton $455,000
Total Cost $1,060,000
Reference: 1. Cost figures reflect current prices
Prepared by: Carl V. Henriques July 6, 1978
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ULAR ACTIVATED CARBON
PILOT STuDY SUMMARY
For the past eighteen months the City of Houston has been involved in
studies for the removal of haloforms, a number of pilot filter runs was
investigated.
The basic GAC filter design included both upflow and downflow filter
operation. The filter bodies were constructed from A WA approved PVC with
a two and a half inch inside diameter. Twenty-four inches of Calgon
Filtrasorb 400 was supported by eight inches of gravel on a wire screen.
Flow rates were adjusted to various detention times to apporxiznate interim
and post contactor GAC design requirements.
Analytical data was collected at least twice weekly and in many cases
daily analysis were made. The analytical data included TTHM, TOC, and
turbidity run routinely. Other special analysis were run on a less
frequent basis.
As a result of these investigations for in the interim GAC proposed
requirements, a five to twelve day regeneration cycle would be necessary.
This regeneration frequency was based upon a .5 TOC increase of filter
effluent. A ten day cycle appeared to be the most frequent cycle time.
Even after the TOC breakthrough, TTHM removal was still realized for an
additional ten to twelve days before a chloroform breakthrough. TTHN removal.
averaged 46.7% for all runs; chloroform average of all runs was 34.6%.
The upflow filter design, being more pratical at the Houston Water
purification Plant, was run with a sixteen minute detention time and flow
rate of .47% gpxn/cu ft/mm. The T’ removal was similar to downf low
units with a 45.5% reduction, Chloroform removal was slightly higher at
37.6%.
one area that does need further study is that TOC breakthrough did
-------
Not occur. TOC values were varjble and unreliable, but some two months
operation was realized before chloroform breakthrough did occur. ‘bc design
parameter for an upf low filter may not be of value.
Precursor removal was also found to be very poor. If the GAC filter
effluent was then chlorinated, by less than 1 ppm, chloroform levels
would increase significantly.
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Houston Water
Purification Plant
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City of Houston
Department of Public Works
Water Division
Turner Collie & Braden Inc.
Consulting Engineers
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HISTORY OF THE PLANT
Left: Settling Basin Overflow Weirs
Below:Overal/ View Houston Water
Purification Plant.
Construction of the Houston
Water Treatment Plant was begun
on an 82-acre tract in early 1952.
The plant, placed in service in
1954, was designed for a nominal
capacity of 50 million gallons per
day (mgd) and a peak capacity of
80 mgd but was equipped for only
33 mgd. In subsequent years,
pumps were added to improve re-
liability, and in 1968 equipment
was installed for the full 50 mgd
flow.
Increased emphasis by state
and federal regulatory agencies on
treatment and disposal of waste
products generated by water treat-
ment plants led to the construc-
tion of an alum sludge dewatering
facility in 1973. This facility has a
nominal capacity of 48,000 pounds
per day of dry alum sludge, and
was placed in operation in 1975.
The need for additional water
treating capacity, brought about
by Houston’s sustained growth
through the 1970’s, resulted in the
construction of a new treatment
module, with a nominal capacity
of 50 mgd, adjacent to previously
existing treatment units. Con-
struction of the plant was begun
in 1974 and was completed in
1977. Sludge dewatering facilities
were also expanded to accom-
modate increased quantities of
sludge generated by the new water
treatment module. Construction
of these facilities (described in a
later section) was begun in 1975
and completed in 1977.
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THE TREATMENT PROCESS
The plant is a conventional
water treatment facility utilizing
chemical conditioning of raw
water, rapid mixing, flocculation,
sedimentation, and filtration. The
basic coagulant is alum, and acti-
vated silica is added as an aid to
flocculation. Activated carbon and
chlorine can be introduced, as re-
quired, to deal with occasional
objectionable tastes and odors.
Lime is employed to stabilize the
finished filtered water. The latest
developments in industrial design
have been blended with time-
proven principles of municipal
water treatment to produce a
facility which combines the
benefits of operational efficiency
and economy.
.,..
• -.-. . . . . 5 5 ._
I
- -— • - -
i-. :. . . . . •...
-
Settling Bas in5
Chemical Building and Rapid Max - ‘
Low Lift Pump Station
-.: -: . .
- •. .;
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-. • • . .
- I: ’
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Sludge Thickeners
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Sludge dewatering operations
embody similar principles to
assure cost-effective operation.
Pressure filtration was selected as
the most economical and efficient
system for dewatering of the
plant’s wastes, based on extensive
study of available methods. Waste
sludge is withdrawn from the
settling basins and pumped to
gravity thickeners. Thickened
sludge is then dewatered in
pressure filters. Lime is added as
a conditioning agent, and the filter
plate elements are pre-coated
with diatomaceous earth. Finally
the dewatered sludge is hauled
by truck to a land fill site.
M ’ ftJl
Ground Storage Tanks
Distribution Pump Station
.—. 1 • -
- ‘.f
—
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Filter Pres s
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OPERATIONS
A. Raw Water Pumping
and Conveyance
Water to be treated is pumped
from Lake Houston and flows
through a concrete-lined canal
approximately 14 miles to the
plant site. The water is then
pumped into the plant by eight
low lift pumps.
B. Chemical Addition
Chemical storage and feed
facilities are major components
of the plant. Coagulation and dis-
infection are the two primary
functions of chemical additives.
Taste and odor removal, pH ad-
justment, and fluoridation may
also be accomplished through
chemical feed. Chemicals and their
uses are summarized in the table
below.
WATER TREATING CHEMICALS
Name Function
Alum
Caustic
Activated Silica
Activated Carbon
C. Rapid Mix and Flocculation
These steps are required to
blend chemicals with the water
and to assure that flocculation
(formation of settleable particles
from the combination of chemi-
cals and contaminants) occurs.
Speed of the large paddles which
Approximate Daily Usage
50,000 lbs/day
Intermittent
Color and turbidity removal
pH adjustment
Aid in color and turbidity removal
Taste and odor removal
Polyelectrolytes Color and turbidity removal.
sludge thickening
Lime
Hydrofluosil cic Acid
pH adjustment, sludge treatment
Fluoridation
Chlorine Disinfection
1,500 lbs/day
Intermittent
Intermittent
20,000 lbs/day
Not presently used
7,500 lbs/day
1,000 lbs/day
gently agitate
adjustable.
D.Settling Basins
The five large settling basins
provide sufficient time for con-
taminants and chemicals to fall
to the bottom where they are
scraped to hoppers by two large
rakes in each basin and pumped
to sludge handling facilities. Each
basin holds approximately 5 mil-
lion gallons of water.
E. Filters
Twelve rapid sand filters con-
tain 30 inches of sand and gravel.
Eight high rate filters contain 30
inches of coal, sand, garnet
and gravel. Contaminants trapped
by the filters are removed by back-
washing with clean water, Nine
i . 4
the water is
Diatomaceous Earth Sludge dewatering aid
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pumps of varying sizes convey
treated water from the filters to
storage tanks.
F. Ground Storage Tanks
Five steel ground storage tanks
have a total capacity of 25 million
gallons. Treated water is held in
the tanks and withdrawn as
needed to meet distribution
system needs.
G. Distribution Pumps
Seven pumps convey stored
water to the distribution system.
Adequate line pressure is main-
tained by these pumps which have
a total pumping capacity of
approximately 240 million gallons
per day.
SLUDGE TREATMENT UNIT
OPERATIONS
Completion of the plant’s
alum sludge dewatering units — the
largest such facilities in the nation
—marked a first for Texas in water
and waste technology. As part
of the second plant in the country
to use filter presses, these sludge
dewatering facilities were con-
structed to meet the requirements
of the Texas Water Quality Board
and built entirely with City of
Houston water revenue funds.
Major components of the
sludge treatment operations are
described in the following
paragraphs.
H Thickeners
Three gravity thickeners re-
ceive sludge pumped from the
the sludge.
I. Filter Presses
Four high-pressure filter
presses dewater the thickened
sludge, producing compacted
sludge cakes. Lime and diato-
maceous earth are the chemicals
used in the dewatering process.
J. Sludge Disposal
Dewatered sludge drops from
the presses to trucks, which haul
the product to a disposal area on
the plant site. The dried material
can be used as fill material for
various types of construction.
G.
H.
Polyelectrolytes can be fed to
improve settling characteristics of
bottoms of the five settling basins.
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Houston Water
Purification Plant
City of Houston
Nominal Plant Capacity: 100 mgd
Maximum Plant Capacity: 155 mgd
Major Equipment:
Low Lift Pumps (8)
Total capacity: 137,700 gpm
Rapid Mix Units (6)
Four 25-hp mixers
Two 15-hp mixers
Total volume: 95,000 gallons
Flocculators (5)
Four paddle wheel units
One radial turbine blade unit
Total volume: 4,250,000 gallons
Settling Basins (5)
Two collector mechanisms, each
basin
Total volume: 21,800,000
gal Ions
Filters (20)
Twelve sand/gravel beds
Eight multi-media beds
Vitrified clay underdrains
Total surface area: 25,040 sq. ft.
Surface wash rate: 0.75
gpm/sq. ft.
Backwash rate: 18 gpm/sq. ft.
Wash Water Pumps (2)
Total capacity: 9,750 gpm
500,000-gallon storage tank
Transfer Pumps (9)
Total capacity: 183,000 gpm
Ground Storage Tanks (5)
Total volume: 25,000,000
gal Ions
Chemical Feed and Storage:
Activated Silica
Three 250-gpd silactors
16,000-gallon storage tank
Caustic
Two 250-gph volumetric feeders
1 6 ,000-gallon storage tank
Chlorine
Seven solution feeders
Total capacity: 21,000 lb./day
Railroad tank car and ton
cylinder storage
Hydrofluosilicic Acid
Three 12-gph diaphragm pumps
Two 1 O,000-gallon storage tanks
Alum
Four 250-gph volumetric feeders
Three 20,000-gallon storage
tanks
Three 16,000-gallon storage
tanks
TurnerCoIIie Braden Inc.
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Lime
Four slakers: two 1,000 -lb/hr.,
two 750-lb/hr.
Three 111 ,000-lb. bulk storage
silos
Activated Carbon
Two 16,000-gph volumetric
feeders
Equipment Suppliers:
Low Lift Pumps
FMC Corp.
Rapid Mixers
Mixing Equipment Co.
Jeffrey Division,
Dresser Industries
Flocculators
Jeffrey Division,
Dresser Industries
Envirex
Settling Basin Mechanisms
Dorr-O liver
Link-Belt
Walker Process
Filters
Neptune Micro-Floc
Filter Underdrains
F.B. Leopold Co.
Washwater Pumps
FMC Corp.
Transfer Pumps
FMC Corp.
Activated Silica Feeder
Wallace and Tiernan,
Caustic Feeders
Worthington Corp.
BI F
Chlorine Feeders
Fisher & Porter Co.
Fluoride Feeders
Plastonics, Inc.
BIF
Alum Feeders
Worthington Corp.
BI F
Omega
Lime Feeders
Bl F
Omega
Carbon Feeders
Robbins & Myers, Inc.
Omega
Inc.
Two 40,000-lb. slurry tanks
ALUM SLUDGE
DEWATERING FACILITY
Nominal Plant Capacity:
96,000 lb./day dry alum sludge
Major Equipment:
Filters (4)
92 plates each: diatomaceous
earth precoat, core blow and
hydraulic closing mechanisms
225-psig pressure differential
Thickeners (3)
110-ft. diameter units
Sludge Feed Pumps (6)
Each unit: 200-gpm capacity
Chemical Feed and Storage:
Lime
Two slakers, 2,250-lb/hr.
capacity
Three slurry feed pumps, each
200 gpm
5,000-cu.-ft storage silo
Precoat (Diatomaceous Earth)
One 150 -lb./min. screw feeder
9,000-cu.-ft. storage silo
Polymer
Five 26-gph metering pumps
2,000-gallon polymer day tank
Filters and Appurtenances
Passavant Corp.
Thickeners
Envirex
Walker Process
Polymer Feed Facilities
Interpace Corp.
Sludge Pumps
Robbins & Myers, Inc.
Filtrate Pumps
ITT Marlow
Precoat Pumps
Goulds Pumps, Inc.
Lime Feed Facilities
BIF
Equipment Suppliers:
Goulds Pumps, Inc.
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1—373
1 DR. KUZMACK: Did I understand you to say that
2 Houston could purport to the -— 100 parts per billion TH 4?
MR. LePARGUE: What we are proposing is chlorine
treatment, prechlorination with chlorainines.
DR. KUZMACK: Aside from the question of chloramina,
6 on which we have had several comments today, the impression
seemed to be given in your statement that you thought the
8 regulations would require the use of GAC for THM control and
referred to it as the treatment of choice.
10 I think we would look at it as a last resort. If
THM levels could be complied with using a lass expensive meth
12 od, utilities could do that.
13 MR. LaPARGUE: The regulations, as proposed, do not
14 allow this, isn’t that correct?
15 DR. KUZMACK: Yes, they do.
16 MR • KIMM: There are two parts to the regulation.
17 THM is a number, and like any other number, it is up to the
18 utility to find any way of getting there. In your case, the
19 state, having primacy, and looking over your shoulder and say
20 ing, “That is th. way to do it..” The only way you would get
21 caught in GAC is if you had significant inorganic materials
22 in the raw water.
23 MR. LeFARGUE: In our stud±es, we have indications
24 that we can reduce the total trihalomethane levels to one-
25 tenth • There is a problem -— we have looked at chloraminss i
Acme Reporting Company
202) 62o 4eee
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1—374
1 elevated dosage, six to eight parts, and than it appears to
2 be a problem with the THM.
3 DR. KUZMACK: What are your THM levels?
4 MR. I 1 aFARGUE: One hundred and thirty-three, as of
5 last Priday.
6 MR. 1 (1MM: You are 133, and you think you can get
7 that down to 10 percent, 13, by using chioramines and that, in
8 fact, would be updating the bacteriological --
9 MR. LaPARGUE: Certainly; we found no real defense.
io we have to prechiorinats. One day I stopped chlorination
11 ahead of the plant. Within nine hours, we had such severe f ii
12 tar clogging development that we were washing filters; as soon
13 as we filled our wash water tank, we got into another serious
14 problem, as a matter-of-fact, by cutting of f chlorine complete
15 ly, and just within nine hours.
16 we have to prechlorinate; there is no way we can get
17 out of it.
18 MR. GLAUTHIER: Would you explain your plant setup
19 a little bit?
20 MR. LePARGUE: There is also in the report the con-
21 figuration of the plant, and it gives parameters concerning
22 the plant.
23 MR. GLhUTHIER: One of the things confusing about it
24 is a description of one plant, and yet you speak of two source
25 MR. LePARGUE: They are on the se ine site. We have a
Acme Reporting Company
(202) 8264860
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1—375
1 plant that was complete in 1954 and one completed about 18
2 months ago. Plant One, being the older plant, we plan to up-
3 grade beginning ‘79, and we will have a total capacity of 200
MGD.
5 Right now, we are pumping 150 out of a 250 MGD plant
6 By the time we get around to 200 --
7 MR. GLAUTHIER: Are the two plants going into the
8 same distribution system?
9 MR. LePARGUE: Yes; but we are furnishing water to
10 a number of municipalities in and around Houston.
11 MR. GLAUTHIER: What would happen to you, in the
12 sense of this regulation? Is the water mixed, and are really
13 getting a THM level of half of what you were talking about?
14 MR. LeFARGUE: Predominantly, it is southeastern,
15 eastern, downtown areas. We are pushing more towards the
16 southwestern part of town • There are points where they are
17 mixing, but they change.
18 MR. DICKSON: We have a real problem down there in
19 that we anarea of coastal subsidence. All the oil has bean
20 taken out of the oil mines we hay, down there, and some water
21 has been taken out of aquifers above that. We have areas
22 around the Galveston Bay where the Exxon Refinery is. The
23 land elevations have gone down approximately 8 to 12 feat.
24 we have a political subdivision called the Galvestor
25 Harrison County Soil subsidence District that says, “No, you
Acme Reporting Company
(2O2 628-4888
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1—376
1 can’t do that anymore.” This is one of the real keys to their
2 operation; we are taking little towns around there. Some
aren’t so little -- Galveston and Pasadena are not little, but
we are supplying water to them, open their wells, and providi
5 surface water to them instead of ground water.to alleviate th
6 subsidence problem. And that is another one of the things we
have in the Houston area.
8 We are now in the Trinity River and moving water
from the Trinity River. My next jump will be east to the
10 1achez River, and that will be shortly. I will be out of
water in the west and of Houston in about two years, and that
12 is where we use wells.
13 I can’t get the surface water to the wells, no dis-
14 tribution system.
15 MR. GLAtJTHIER: Depending upon the costs of the
16 discussion and the need for treatment in Houston, if you go
‘7 further with the cost estimates, we would like an opportunity
18 tO discuss them in some detail. I notice you have prepared
19 them very recently and may not hay, had as; much time to go
20 over all the details as you would like.
21 Some pieces of th. documentation are not really corn
22 plete, and we notice that there era some assumptions that we
23 would like to discuss. Por example, maybe you have not taken
24 adequate credit for carbon that you returned to a carbon menu
25 facturar, if you were having it regenerated off-site.
Acme Reporting Company
2O2 628-4988
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J.— 377
1 MR. LePARGUE: The cost you see reflected in that
2 report was taken from a manufacturer of carbon • The rogenera
3 tion cost reflects replacing that carbon; that is part of tha
4 cost.
5 MR. GLAUTHIER: The other thing we found in our
6 discussion with some of the other systems is the sizing, the
7 amount of carbon actually put in and the size on the contacto s
8 is a significant determinant of the cost. I notice you have
9 assumed that not only would you size those to the design capac
10 ity of the plant, but you would also regenerate the carbon
ii still every two months. I think there is a trade-off there.
12 If you go to more carbon, than you actually need for
13 water you are putting through every day, you would actually
14 experience longer carbon bedlife.
15 MR. LePARGUE: This is true, but we are already tal1
16 ing about 6 million pounds initially, which is a considerable
17 amount of carbon.
18 MR. GLAUTHIER: That is for a 200 MGD plant.
19 MR. LePARGUE: That is what we will be.
20 MR. GLAUTHIER: That is right, but your average flo’
21 is less than that.
22 MR. LePARGUE: As I tried to explain --
23 MR. DICKSON: I don’t know if we can explain the
24 average flow. •The.higheat HOustofl:pump,. everything, up until
25 this year was 368 million gallons a day. On the 23rd of May
Acme Reporting Company
(202) 62$.488
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l—378
1 of this year, we pumped 372 .3 million, and that is not even
2 hot weather. We are just getting into hot weather, where pso
3 pie irrigate their yards and things of this nature. It was
4 getting critical back in May, and thank goodness it rained,
5 and rained in our watershed and filled up both of our lakes,
6 Lake Houston and Lake Caddo.
7 This is our problem. wa.have; our service area is
8 growing at the rats of 7,000 folks a month, and it is a movjn
9 train; and we are tying to run to catch up with the thing and
10 it is getting out of hand.
11 MR. LeFARGUE: If I may address myself to your ques-
12 tion, we have two plants, Plant One and Two, each 50 MGD
13 plants in our current average production, between 140 and 150
14 million gallons a day. By the time we complete this expansio
15 to 200 MGD, our peaks each year have become the average for
16 next. Last year we peaked out at around 150; we averaged 119.
17 Wa are going higher this year. We are 50 to 75 per-
18 cent over design right now, so we will have to have 200 MGD.
19 MR. GLAUTHIER: I appreciate your comments. I spent
20 a fair amount of time in Houston, and I understand what you
21 are saying. We would like a change to talk to you in more
22 depth about it later on.
23 MR. LaPARC UE: There is one other question, if I ma
24 ask the panel. We have done a lot of work with a number of
25 resins, and there is one resin which is in the report that
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1 appears to be of some value. I would like to know if you have
2 had any experience with this resin.
3 It is an axperimental .rasin, not commercially avail-
4 able right now, but we are experiencing up to 98 percent
5 removal of total trihalomethanes, but there is not TOC raduc-
6 tion with this resin. It is a marvelous thing, does a great
7 job.
8 DR. KUZMACK: The TOC reduction would only apply
9 for the synthetic organic portions of the regs.
10 MR. LaFARGUE: I realize that, and there are ques-
11 tions we have in the upf low design, and I also have that info
12 nation, because there is some variability. Have you all look d
13 at an upf low-type design?
14 MR. ROBECK: Yes; that has bean looked in in the
15 wastewatar area, too, as you know. Europeans have icoked at
16 it. It allows a certain amount of fines o come over. You
17 have to follow with a sand filter or something.
18 MR. LeFARGUE: The flow rates we are looking at --
19 I don’t believe you would have that problem. In order to get
20 the extended runs you wars talking about, half a gallon per
21 cubic foot per minute, and they get these two-month runs, so
22 we don’t have that problem. But you have the infoxnation.
23 MR. ROBECK: Yes, we ought to get together.
24 MR. LePARGUE: There are a nuiriber of other things.
25 MR. DICKSON: That is all we ask: Help us out; we
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1 will help you out.
2 MR. LaPARGUE: We have an awful lot of information
3 we hava accumulated; we have even boiled the water, and find
4 you move 99 percent in five minutas in an open container.
5 MS. CHANG: Thank you very muChe
6 Mr. Kermit Mangun, please.
7 STATEMENT OF KERMIT A . MANGUN, SUPERINTENDENT OF
8 HATER PROCESSING, BOARD OP PUBLIC UTILITIES,
9 KANSAS CITY, KANSAS
10 MR. MANGUN: I am Kermit Mangun, Superintendent of
ii Water Processing in Kansas City, Kansas.
12 The Board of Public Utilities, located in Kansas
13 City, Kansas, operates a 60 MGD municipal water plant which
14 serves a population of 180,000. Its only source of supply is
15 the Missouri River, which can provide all of its needs for th
16 foreseeable future.
17 Our laboratory has worked for many years with the
18 Public Health Service on many programs. It was on e of 33
19 laboratories in the Country selected in 1956 to evaluate the
20 use of the membrane filter technique. It also participatad
21 in the Water Quality Basic Data Program from 1958 through 197
22 We are in agreement with most of Part in -- The
23 National Interim Primary Drinking Water Regulations. We are,
24 however, very much opposed to both parts of the proposed amend
25 mants concerning control of organic chemical contaminants
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1 which set the maximum total trihalornethanes at 0 .1 mgs. per
2 liter and requires the use of granular activated carbon to
3 reduce the level of synthetic volatile organic chemicals in
4 finished drinking water at not more thatn 0.5 micrograms per
5 liter.
6 It is felt that the use of statistical axtrapolatior
7 models, derived by using massive doses on rats, is not a valid
8 means to determine an adverse or harmful effect on humans . Ir
9 a paper co-signed by Leroy Stratton, Associate Director of the
10 Illinois Department of Health, and by Ira Markwood, P.E. Mana-
11 ger of the Division of Public Water Supplies of the Illinois
12 Enviroi inental Protection Agency, noted that the same massive
13 doses on dogs, over a seven—year period, had no detectable
14 effect,
15 Thus, it is not justifiable to require the public
16 to spend millions of dollars to carry out this program on the
17 basis that these organics may have an adverse effect on a per
18 soil’s health.
19 In Part I, dealing with the trihalomethanes, it has
20 been suggested that they could be reduced by altering the
21 point of chlorination. This is not possible at our plant,
22 since it has always been added at the optimum location, betwe ri
23 the secondary and tertiary basins. This provides ample chior
24 me detention time prior to filtration.
25 Thus,,if the THMs are to be reduced to the proposed
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1 arbitrary 0.1 mgs. per liter, it will be necessary to change
2 disinfactants or use an absorbent such as activated carbon.
3 This is alluded to on page 5766, paragraph 5 of the February
4 9th proposed rules.
5 In previous correspondence, it was related that it
6 was not necessary to use it. The use of carbon will be dis-
7 cussed later. We are also opposed to the public notification
S requirement, when the 0.1 mg/i maximum is exceeded. Each
9 written notice to our customers would cost the utility about
10 $10,000. This money could be used in a much better way and
11 is a waste of public funds. The 0.1 mg/i of THN should be a
12 goal, rather than a requirement.
13 The affects of Part II, requiring the use of activat 1
14 ed carbon on our utility, would be as follows. In our 60 MGD
15 plant, operating at the present average daily rate of 35 mu—
16 lion gallons, the annual cost of carbon alone would be
17 $3,354,000 par year. This is based on replacement every 60
18 days, which may not be often enough, according to some find-
19 ings.
20 To this must be added the cost of labor and equipmen
21 to handle it, plus the cost of continual tasting to determine
22 when each, or possibly a group, of filters are exhausted.
23 This would add another $500,000 a year, for a total of
24 $3,850,000. This would addan additional cost of $72.30 p
25 year to each of our metered customers.
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The above figures were based upon replacing filter
2 sand with carbon. It is very doubtful that this type of
3 application would be satisfactory at our plant, because the
4 30-inch filter bed of carbon would only give a 12-minute con-
5 tact time.
6 The other method,which uses post contactors, would
7 require 50 twalve by thirteen foot pressure vessels. The
8 estimated capital cost for this type of installation would be
9 well over $15 million. They would have to be enclosed in a
10 building to prevent freezing, require a complete set of pump-
11 ing facilities, as well as an elaborate piping system.
12 The annual operating cost of this system plus capi-
13 ta). cost amortization would cost each customer an additional
14 $91.68 per year over his present bill. Such a sizable charge’
15 would surely cause a customer revolt, against the EPA and the
16 utility management, when it became known that the necessity
17 for tha expenditure was based on rat experimentation which ha
1.8 not been proven to be harmful to humans at these low lavals.
19 It is’•very evident that prior to rushing into any
20 such costly program as the proposed amendment to the National
21 Interim Primary Drinking Water Regulations, a great deal more
22 research should be made into the health effects of these
23 organic compounds at low levels. In addition, extended pilot
24 studies should be made on different treathent methods.
25 MS. CI ANG: Thank you.
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MR. GLAtJTHIER: I have a question for you. The 60
2 MGD, is that the design capacity of the plant?
MR. MANGUN: Right.
MR. GLAIJTHIER: S at is your average production?
5 MR. MANGUN: I stated in hare it is 33 right now,
6 and that is what the figures ware based upon.
7 DR. KtrZMACK: I would agree, if we thought the costs
8 ware that high, I think we would probably not have made the
9 proposal. Our estimate would be that the cost would be sub—
iC) stantially lower, and that is something that will have to be
11 sorted out.
12 MR. GLAtJTHIER: What was the source of your cost
13 estimates?
MR MANGUN: This is based on the cost of the size
15 of the filters we have and the carbon in the filters.
16 MR. GL UTHIER: Could you supply more detail on the
17 calculations for us?
18 MR. MANGUN: I can’t, not right now
19 MR. GLAUTHIER: During the comment period.
20 MS. CHANG: Let’s move on to the last two speakers.
21 Thank you vary much.
22 Richard Wade.
23 STATEMENT O RICHARD L. WADE, DIRECTOR, DIVISION O
24 ENVIRONMENTAL HEALTH, MINNESOTA DEPARTMENT OE HEALT
25 MR. WADE: My name is Richard Wade. I am Director
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1 of the Division of Environmental Health for the Minnesota
2 Department of Health. One of my responsibilities is the
3 administration of the Safe Drinking Water program for Minne—
4 sota. The State of Minnesota has primacy under the Safe Drink
5 ing Water Act and has made significant progress in its imple—
6 mentation.
7 Having the enforcement responsibilities, and the
8 anticipation of being charged with the implementation of these
9 proposed changes to the regulations regarding organics in
10 drinking water -— 43 Pederal Register 5766 on P’ebruary 9, 1978 i
11 --. are of direct concern to our Department and the State of
12 Minnesota.
13 Because the drinking water programs in Minnesota ara
14 located within the health agency, we have a special interest
15 in environmental, interaction with health. Knowing that any
16 significant improvements in health will be provided through
17 batter control of disease and agents detrimental to health, we
18 have vormed a special study unit within the Division to look
19 at environmental health problems.
20 This unit consists of physicians, epidemiologists,
21 toxicologists, chemists, and engineers who work on environmexit
22 al. health issues which may affect human health. With this
23 level of health concern and expertise, we have reviewed the
24 proposed regulations with the justification for promulgation
25 and believe development of such regulations is not justified
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1 by the available health information.
2 It seems obvious that any significant advancement i
3 the reduction of cancer will have to be, in part, through
4 environmental control. Congress, in the passage of Public
5 Law 93—523, the Environmental Protection Agency, and supporte s
6 of these regulations, all desire increased control of cancer-
7 causing agents, and believe the reduction or elimination of
8 organics in drinking water will provide a partial solution to
9 the issue.
10 No responsible health official could disagree with
11 this notion. The Minnesota Department of Health endorses the
12 concept of controlling environmental factors where adequate
13 information justifies such control.
14 Many of the positions which have been offered to
15 date contain arguments supported by the State of Minnesota.
16 We are particularly supportive of the position of the State
17 of Illinois - - Position on Proposed Regulations for Control
18 of Organic Chemical Contaminants in Drinking Water, the
19 American Water Works Association, and the Conference of Stats
20 Sanitary Engineers.
21 Our specific concerns and reasons for opposing por-
22 ticns of the proposed regulations as well as suggestions for
23 revisions are as follows:
24 One; the maximum contaminant level for trthalometh-
25 ane should be deleted and replaced as a goal. While we are
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1 not questloing the fact that there may be a risk to human
2 health associated with the ingestion of trihalornathanes, we
3 do question the numerous assuinptions,guessas, and extrapola-
4 tions which have been used to justify the maxixnuin contaminant
5 level at 100 micrograms par liter.
6 We do not believe that existing data based on con-
7 flicting animal experiments and epiderniological studies done
8 to data can justify the development of such an absolute stand-
9 ard.
10 We could support the requirements that community
11 supplies monitor for trihalomethanas according to the proposed
12 regulations. Such monitoring would produce extremely useful
13 data. Setting 100 micrograms par liter for trihalomethana as
14 a goal to be achieved by all community water supplies would
is encourage supplies to make changes necessary to bring their
16 supplies below that level.
17 States would then have an opportunity to work with
18 the smaller or reluctant communities -- those with limited
19 expertise and/or resources —— in a helpful and non-adversary
20 capacity to encourage them to take the necessary steps toward
21 the reduction of trihalornethanes in their finished water.
22 As long as the info rnation underlying the risk pra-
23 dictions is as sketchy as we believe it is, regulatory agancia
24 are going to have considerable difficulty in forcing cornmuniti s
25 to comply. We would welcome the opportunity to exercisa4 our
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1 capabilities of persuasion. Such efforts would be much more
2 productive than expending resources in launching a strict
3 enforceinent program.
4 We believe that if U.S. EPA promulgates the regula—
5 tion as drafted, the integrity of the entire Minnesota water
6 supply program will be threatened. We would find it very dif-
7 ficult to promulgate and enforce this regulation if adopted by
8 EPA based on the information available to date.
9 Two; 4e object to the imposition of additional
10 microbiological contaminant sampling and analytical require-
11 ments as proposed in Section 141.21, subsection (i), because
12 we believe that it is unnecessary. Public water supplies are
13 already required to monitor for coliform bacteria, and many
14 are doing additional microbiological monitoring for control
15 purposes.
16 Any additional monitoring requirement should only
17 be imposed by the aqent with primacy, at that agent’s discre-
18 tion. In the seine vein, we recommend deletion of subsection
(k) prohibiting the use of chiorantines as a primary disinfect-
20 ant. States with primacy have experience in these areas and
21 should be allowed to exercise their judgment accordingly.
22 Three; with regard to the proposed required treat-
23 ment technique, we are opposed to the rule in its entirety.
24 We fully agree with American Water Works Association that
25 I Subpart P of Section 141 should not be adopted. Wa oppose it
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1 adoption because we are not convinced that the imposition of
2 such a requirement will have only the beneficial effects
3 emphasized by U.S. EPA.
4 We fe al that at this time there is far too little
5 pilot plant information available to justify adoption of the
6 rule. The difficultias irtheránt.in extrapolating data from
7 pilot plant design and operation to full-scale plant design
8 and operation are well known to all persons experienced in thi
9 field.
10 We strongly urge, therefore, the construction of
11 several full-scale plants by the allocation of research and
12 demonstration grants for the practical development of the
13 needed new treatment technologies. There is simply not
14 enough data regarding many aspects of the proposal, including
15 efficacy of removal of synthetic organics, regeneration time,
16 cost of installation, operation and maintenance, affect on
17 water quality of GAC as an absorbent for non-organic rnatgrial5
18 possibility of microbial contamination, necessary disinfzctior
19 practices, and efficacy of prescribed monitoring techniques.
20 Until additional information is obtained regarding
21 these unknowns, some of which may create health risks as sari-
22 ous as those sought to be eliminated, there is no justifica-
23 tion for imposing such a:rule on 300-plus community water
24 supplies.
25 In addition, the rule as proposed requires an
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1 unjustified expenditure of resources by those community water
2 supplies which will not have to install GAC. If indeed it is
3 true that of the 300-plus community water supplies likely to
4 come under the proposed rule, only 50 of them are expected to
5 have to comply with the requirement to install GAC, why make
6 the remaining 250 go through the exercise and expense of apply
7 ing for a variance.
8 This techniques of having 250 community water sup-
9 plies prove a negative, i.e., guilty until proven innocent,
10 seems to be a poorly thought-through procedure for the purpos
11 of imposing certain criteria on only 50 community water sup-
12 plies.
13 If the criteria are so clear as to allow U.S EPA to
14 assert that only 50 community water supplies will have to
15 install GAC, then it would be much more straightforward for
16 both community water supplies and regulatory agencies if the
17 selection criteria were prescribed in the rule.
18 Another argument against adoption of the proposed
19 rule lies with the credibility of U.S. EPA’S OWfl projected co t
20 estimates. Given the degree of uncertainty which underlies.
21 so many of the factors which influence the effectiveness of
22 GAC, it is highly unlikely that US. EPA’s cost estimates,
23 including those in the recently published “White paper”, are
24 reliable.
25 Congress required that costs be taken into account
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1 when new regulations are proposed. While on their face, EPA ’s
2 estimates might not seem to be exorbitant on a per family basi.
3 EPA’s estimates are nevertheless only averages and there may
4 well be instances where true costs for a f w communities will
be prohibitive.
6 Minneapolis, fOr instance, has estimated that the
total capital cost for complying with the regulation will be
8 $34.3 million. Annual operating cost and debt retirement
9 resulting from compliance is approximately $8,510,000 or
10 $83.43 per consumer connection. This cost will reflect a
11 68 percent increase in water rates for the City of Minneapolis
12 Until more information is obtained regarding the
13 desirability and consequences of the use of GAC to remove syn
14 thetic organic chemicals from drinking water, we feel that an
15 rule imposing a requirement for the use of such a material at
16 this time is premature and wholly unjustified.
17 MR. 1<1MM: I think you are -- from previous dis-
18 cussions -— looking at health effects research. Is anything
19 going on in health effects research that would give you the
20 definitive, or more definitive, certitude on the magnitude of
21 low-level effects on cancer rates?
22 MR. WADE: As one of the previous persons testifyinc
23 responded, the science of health risk . assessment is both an
24 art and a science. The postulates that it is being based upor
25 are coming clearer into focus in the next six months, year, o
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I two years, and it certainly will assist us.
2 Further epid miological research, I think, is neede
3 and that research is now in the process of being done. I
4 think the whole are of health risk assessment, whether one
5 uses probitive models or one—hit models, or whether the
6 assumption is in postu].atas.you:want to advance, is an avolv-
7 ing art; and we have to be cautious when we develop ragulato
8 programs and set absolute numbers and standards based on what
9 I see as an evolving art.
10 I don’t have any qualms whatsoever with basing regu-
11 lations on animal experimentation or epidemiological evidence.
12 The material we have received to date seems to indicate, “Yes,
13 there is a problem. We have to control trihalomnethanes,
14 especially chloroform.” Our concern is how fast we move in
15 that direction, and do we sat a number, and at what level do
16 we set that? I don’t think we have the information now.
17 MR. KIMM: As the statute now stands, saying that,
18 yes, the indirect evidence we have on the animal studies and
19 the pattern of the epidemiological studies - - knowing some—
20 thing about, that there are technologies available for tn-
21 halomethane control, in particular, that are understood and
22 have been applied in large scale; and there is no question
23 about the effectiveness.
24 Under the statute, I don’t think we would have much
25 choice but to move in a regulatory fashion, rather than a
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1 goa-l that.you are talking about. That would not seem to be
2 a vehicle available to us, given the other assumptions we have
3 gone back and forth on.
4 The second part of that is just as troubling, and
5 that is, if we in forging our approach, which is cn tha table
6 for discussion, would limit it to the large systems, b causa
7 we felt there would be the need for the presence of technical
8 assistance from the states and some degree from us on changes
9 in disinfection practices to assure that we don’t inadvertenti
10 stumble onto serving up bad water.
11 I am not sure that I understand the thrust of your
12 recommendation that if we went all systems at once, wouldn’t
13 we be thoroughly compounding and stretching to the absolute
14 limit the finite capacity of the states, plus EPA, to provide
15 that kind of technical assistance in the transition period?
16 MR. WADE: Philosophically, I have real problems
17 when I look at the information and see that there is good
18 evidence that there is an adverse health effect -- at least
19 one is very suspicious, based upon the information, that there
20 is an adverse health effect.
21 If the justification for control and establishing
22 the 75,000-plus is purely an.economic question of what size
23 community can support that kind of system, than I have real
24 problems with excluding most people in communities less than
25 75,000 from th same degree of protection.
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1 Before we start any control on any community, we
2 have to include some monitoring efforts on less than 75,000
communities. If we have communities of 20,000 people that ar
400 micrograms or 350 micrograms, I think we should be start-
ing to look at technologies to apply to small-scala plants
6 and not only the large-scala plants.
MR. KIMM: In fact, the proposed regulations have
both the large systems starting monitoring in the next cate-
gory, 75,000 to 10,000. doing that monitoring, a very strong
10 encouragement that anyone found to grossly exceed the standard
get together with their state and start dealing with those
12 problems.
13 we were not expecting that they would be the types
14 of problems on technology and cost, scaling it down to a
smaller system for THM control. And when you talk about GAC
16 processes, they will become much more difficult to scale down
17 as we go along, because you are talking about more complicated
18 process changes.
19 We thought that proposal dealt with concerns you
20 were describing.
21 MR. WADE: I guassed:;our::reading::of:it, the focus
22 would be on control and regulation of those communities,
23 75,000-plus with monitoring only being done on the smaller
24 communities.
25 MR KIMM: Until such time, which would, in fact,
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1 provide in the first year a good profile of THM everywhere,
2 or at least in systems larger than 10,000, which take the
3 universal 390 that are bigger than 75,000 and 2300 in the next
4 category. Between the two of them, they constitute the vast
5 percentage of all the people in the United States.
6 MR. WADE: I think the integrity of the -- from the
7 states’ perspective, the integrity of the water supplies pro-
8 gram is at stake, and I believe -— though I am convinced that
9 the health side of the information, I am much lass certain on
10 the cost, the effectiveness, or the demonstration of control.
11 MR KIMM: Let’s turn to the second side of the rag,
12 where you said there is not enough pilot data. We sharadthat
13 view, because we wrote a rag with phased implementation pro-
14 gram that would have pilot studies in each and every impacted
15 system to assure that detailed data was developed to that
16 specific site and whatever long-term solutions, in terms of
17 GAC installations, actually tailored to the raw water.
18 MR. WADE: It would seem more probitiva to look
19 across the country at those supplies that had the major prob-
20 lem and select of five or six of those and put in extensive
21 money in development and research and tasting on those before
22 you go ahead with a nationwide regulatory effort.
23 DR. COTRtJVO: I have one question. On the large
24 system-small system issue, would you feel more comfortable if
25 the regulation were universally applicable, if there was a
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1 set phase—in schedule that ran over the next five to ten years
2 and incorporated factors of size and other things?
3 MR. WADE: I think so. I think from two perspective
4 One, it would give equal protection of what we think is a real
s problem, á health problem; and, secondly, it would give the
6 ultilitias a better idea of where you are going next year or
7 five years from now, or as long in the future as one would
s care to put in regulation.
9 MS. CHANG: Thank you.
10 We have one more speaker, Bill Breen. Is he here?
11 STATEMENT OF BILL BREEN, MARKETING MANAGER FOR
12 ACTIVATED CARBONS, WESTVACO CORPORATION;
13 ACCOMPANIED BY JIM DRAKE, SALES MANAGER FOR WATER
14 QUALITY APPLICATIONS OF ACTIVATED CARBON, AND
15 DR. BILL KORNEGAY, TECHNICAL DIRECTOR FOR
16 ACTIVATED CARBONS, BOTH OF WESTVACO CORPORATION
17 MR. BREEN: Thank you very much.
18 My name is Bill Breen. I ala Marketing Manager for
19 activated carbons for Westvaco Corporation. I am accompanied
20 by Mr. Jim Craka, Sales Manager for water quality applicatiori
21 of activated carbon:, and Dr. Bill Kornegay, our Technical
22 Director for activated carbons.
23 At Westvaco, we rnanufactura both powdered and granu-
24 lar forms of activated carbons. We have been the leading sup-
25 pliar of activated carbons for drinking water traatn€nt since
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1 we pioneered this application in 1930, and we are the world’s
2 largest producer of activatad . carbon.
3 Most of the activated carbon used for drinking watex
4 treatment over the years has been PAC, primarily for taste and
5 odor control. Still today, about 87 percent of the carbon
6 used to treat drinking water is powdered carbon. The proposed
7 EPA regulations, on the other hand, call for installation of
8 GAC columns to remove synthetic organics.
9 Naturally, we hope to sea increased use of our prod-
10 ucts in the water treatment field. But we also share the con-
11 cams of our customers, the water utilities, who want to make
12 sure they will be getting their money’s worth when they face
13 the additional financial burdens implied by the proposed ragu-
14 lations.
15 To the average, municipality, money is a scarce
16 resource. The close call with bankruptcy of our largest city,
17 New York, drove that point home not long ago. And at cities
18 all over the U.S., we as the leading carbon supplier have
19 heard the story more and more in recent years: “We could put
20 out better water, but our chemical treatment budget is limite
21 and chemical prices have gone up greatly.”
22 Several cities even tall us that fiscal constraints
23 now force them to produce lower quality water than they did
24 just a few years ago. I daresay the average citizen of this
25 great country believes that the water we drink is the best it
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1 could be, unaware that the pervasive principle of economic
2 scarcity applies to the water we drink as well.
3 The truth is that most water utilities possess the
4 means to put out better water than is usually being produced.
5 And the real shame of it all is that the added cost of puttin4
6 out batter water now only boils down to $1.00 to $1.50 per
7 person per year.
8 Anyone who travels around the country notices that
9 water quality leaves something to be desired. Powdered carbon
10 has been since 1930, and still is, the münic pality s best
11 defense against undesirable water caused by taste and odor
12 bearing organics.
13 It is ironic that consumption of powdered carbon by
14 municipalities has declined since-passage of the Safe Drinkin
15 Water Act in 1974, from the levels of usage in the 1960s and
16 early 1970s. More ironically, the usage of powdered carbon
17 by some of our largest cities, which are th3 chief targets of
18 the regulations proposed February 9, has declined even more
19 substantially since 1974.
20 Por example, two of the nation’s five largest cities
21 which purchased an average of 700 tons of PAC per year in 197
22 1972, and 1973, used less than 200 tons per year on average in
23 1975, 1976, and 1977. Two other very large cities each averag
24 ad 400 tons per year in 1971, 1972, and 1973, but one of them
25 only averaged 55 tons per year in 1975, 1976, and 1977, and
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1 the other has eliminated the use of powdered carbon.
2 Even the water plant right hers in D.C., which is
3 run by the U.S. Government, by the U.S. Army Corps of Engineer 1 s,
4 which used an average of 132 tonsper year in 1971, 1972, and
5 1973, has averaged only 13 tons per year in 1975, 1976, and
6 1977.
7 These cities are not the only ones that have reduce
8 PAC consumption considerably, and I should definitely allow
9 as how in some cases, improved raw water quality, as in the
10 Great Lakes, has permitted good quality water to be produced
11 with less PAC.
12 And there are indeed a number of major rnunicipaliti s
13 that are using as much or more PAC, and producing water as
14 good or better than ever, such as Norfolk, Dallas, Louisville,
15 Philadelphia Suburban Water Company in Bryn Mawr, Pennsylvani
16 and the Wilkinsburg-Penn Joint Water Authority outside Pitts-
17 burgh, not to name them all.
18 But overall, we estimate that municipalities nation
19 wide used as much as 20,000 tons of PAC in the 1960s and earl
20 1970s, whereas the total market for PAC in drinking water tre t-
21 ment has now shrunk to around 15,000 tons. A lot more water
22 is produced now than back then.
23 Prom this ..standpoint, it could be said that the
24 Safe Drinking Water Act has, to data, acted in reverse.
25 Further, while Westvaco continues to market high
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1 quality PAC:exceeding;-all standards by the American Wat.ar Wor . S
2 Association, as much as half of the market is now served by
3 lower quality carbons which do not even meet AWWA’s recommend
4 ed minimum specifications.
5 For example, papermill fly ask is crushed, screened
6 and shipped as PAC, but this material typically falls below
7 the recommended minimum Iodine Number of 500, where our Aqua
8 Nuchar exceeds 700 Iodine Number. And lignite-derived carbon
9 designed for industrial decolorizing applications are typical
10 ly inferior for drinking water treatment.
11 Therefore, municipalities on average, most notably
12 some of the larger ones that are amont the 50 or 60 most
13 likely to be required to install GAC, either by buying lass
14 PAC, lower quality PAC, or both, are producing less palatable
15 water, probably containing more organics, than was the case
16 prior to the passage of the SDWA. That is the irony.
17 Compounding the irony is the fact that the proposed
18 drinking water regulations, if promulgated for example on
19 January 1, 1979, will not result in GAC treatment by most of
20 the 50 or 60 cities most likely to be affected until January
21 1984, and that will be the result of significant capital inve t
22 ment in carbon columns, carbon regneration facilities, and th
23 GAC itself.
24 Most of these cities are presently equipped to feed
25 PAC, and could therefore, with no capital investment,
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immediately go a long way toward accomplishing the desired
2 results of the proposed regulations by feeding a minimum dos-
age of PAC continuously.
4 At Westvaco, w have developed a new PAC, Aqua Nuch
5 II, which retains the excellent taste and odor removal char-
6 actaristics of our standard PAC, Aqua Nuchar, but also is
7 effective in removing organ.ic precursors to trihalcmethanes,
TEMs.
9 or example, in April, we conducted a full-scale
10 plant trial of Aqua Nuchar II at the Cresent Hill plant of th
11 Louisville Water Company. The tests showed that continuous
12 feeding of 25 ppm of Aqua Nuchar II, which would cost $4 mu-
lion par year, will not only reduce organic precursors to
14 THNs sufficiently well to comply with the 100 ppb MCL for TH ME
15 but Louisville’s Superintendent of Treatment also believes tha
16 it will achieve the reduction in synthetic organics that
17 Louisville estimates will cost that city $100 million in capi-
18 tal inves nent for a GAC system.
19 Aqua Nuchar II may not achieve the same results in
20 avery city, but we have no doubts htat continuous feeding of
21 high quality PAC will produce better water sooner until GAC i
22 installed under the proposed regulations.
23 We are not recommending that any part of the propos d
24 rebulations be stricken. Rather, we recommend an interim
25 measure calling for continuous feeding of from 3 to 10 ppm of
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PAC having a minimum Iodine Number of 700, and meeting all
2 other specifications recommended in AWWA standard B600-78,
3 commencing on the day of promulgation of the proposed ragula-
4 tions, and. continuing at least until a batter economical math-
5 od is found and installed.
6 Again, money is tight in the average large municipal
7 ity, and it is sad but true that many cities are fiscally con—
8 strained from producing water that is as good as it presently
9 can be. The reduction in PAC usage since passage of the SDWA
10 shows that this is so.
11 So the only way that water quality can be signif 1—
12 cantly improved near-term is by regulation, and the regulatio s
13 proposed will not effect better water until anywhere from 18
14 months to five years from the date of promulgation.
15 What will the cost be of our Prorosed interim meas-
16 ure? I comilad a list of 61 water systems, including 27 of a
17 nation’s largest cities, plus all of those cities determined
18 by the NORS survey to have either a THN or a synthetic organi
19 problem.
20 These 61 systems serve 52 million people, and pump
21 an average of 15,500 million gallons of water per day. Con-
22 tinuous feeding of 3 ppm of our Aqua Nuchar II would cost the a
23 systems a total of just under $60 million per year, or only
24 $1.14 per person per year.
25 We know that at least 33 of these systems, serving
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1 25 million customers and pumping 10 billion gallons of water
2 per day, are presently capable of continuously feeding at
least 3 porn of PAC. That would cost $1.55 per person per yea
4 we feel that this is reasonable and worthwhile, and
5 consistent with the proposed regulations. For example, many
6 cities will find that continuous feeding of high quality PAC
will be the answer to Part I of the regulations, calling for
8 aiiMCLorTHMs.
9 PAC used before chlorination can be an effective way
10 to remove the precursors to THMs before they are formed. And
11 regarding Part II, while it is unlikely that a low dosage of
12 3 ppm of PAC will accomplish the same result as GAC columns,
13 at least better water will result during the five-year interim
14 leading up to the day the GAC columns are put into service.
15 Finally, with regard to the installation of GAC ccl-
16 uinns, which EPA estimates in their recent white paper will
17 effect 61 water supply systems, we feel that some detailed
18 thought should be given to the timing of those installations.
19 If the regulations are promulgated on January 1, 1979, and
20 GAC columns are to be operational by January l , 1984, then it
21 is reasonable to assume that most affected systems will not
22 want to buy their GAC until late 1983.
23 While we agree with Temple, Barker and Sloane’s con-
24 clusion that adequate GAC production capacity exists to suppl
25 the needed carbon, it will not be possible for this to be
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I accomplished ma matter of two or three months. We think that
2 a staggered implementation, perhaps over a three-year period
:3 with the last system being installed in January, 1984, should
4 be considered.
.5 And during the interim, our powdered activated carb
6 proposal will provide an economical and effective alternate
7 method until the GAC is installed. PAC has been used by inunic
8 ipalities since 1930, so it is definitely proven technology,
9 which can be applied by most cities right now without capital
10 investment.
11 Thank you.
12 DR. KUZMACK: Today there have been statements made
13 about possible adverse effects of activated carbon, including
14 leaching of metals, leaching of polynuclear aeromatics and
15 similar sorts of things. Do you have any data concerning this
16 I think it would improve our ability to evaluate those corn—
17 rnents.
18 MR. BREEN: In looking at the leaching of metals,
19 we have taken a look at the metals in the carbon and the
20 material which leaches from the carbon. All the carbon sold
21 by Westvaco into the potable water market due meed Codex, as
22 stated in the National Academy o Science cod Chemicals,
23 Codex, Second Edition, 1972.
24 In addition, if you take a look at the metals leach-
25 ad from the carbons, you will find that something on the orde]
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of 2,730 tons of carbon must be added per million gallons of
2 water in order to exceed any of the interim drinking water
standards governing the metals.
DR. KUZMACK: Can you provide the basis for that
calculation?
6 MR. BREE : Yes, we can.
7 MR. XIMM: Similarly, if you’ have any operating
8 experience with THM reductions, we would be anxious to see
that.
10 MR. GLAUTHIER: Have you had a chance to review any
11 of the cost estimates, particularly those regarding reganer-
12 ation? And do you have any comment on them, if you have?
13 MR. BREEN: No, I haven’t.
14 MR. KIMM: Would you be kind enough to take a lock
15 at that data and perhaps submit something later on, since
16 obviously you all may know a thing or two about regenerating
17 carbon.
18 MR. BREEN: We would be glad to.
19 MS. CHANG: Thank you very much.
20 That concludes the hearings for this evening.
end t5B 21 (Whereupon, the hearing was concluded at 10:10 p.m.)
ji
23
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