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Radionuclide Stakeholder Meeting
MEETING SUMMARY
December 11 - 12, 1997
Hyatt Regency Crystal City
2799 Jefferson Davis Highway
Arlington, VA 22202
Thursday, December 11, 1997
9:00 Welcome, Meeting Logistics & Review of Ground Rules
Peter Bonner, ICF the meeting facilitator, welcomed participants, reviewed
the agenda, and explained the ground rules for comment and discussion
by the participants.
Why EPA is Revising the National Primary Drinking Water Regulations
(NPDWR) for Radionuclides
Bill Diamond, EPA Office of Ground Water and Drinking Water (OGWDW),
gave a 30-minute presentation on why the NPDWR for radionuclides is being
revised. The current rule, which has been in effect for 20 years, covers
a wide range of radioactive elements (i.e., beta () photon emitters, alpha
() emitters, radium) but did not include radon or uranium. Changes to
the rule were proposed in 1991 and again through the Safe Drinking Water
Act (SDWA) Amendments of 1996; the rule must be finalized by November
2000. Three sequential tests are required in order to decide on the appropriate
maximum contaminant level (MCL):
- Feasibility test. The MCL must be set as close to the maximum contaminant
level goal (MCLG) as feasible; carcinogens have a MCLG of zero.
- Protective test. The MCL, according to existing standard 1412(b)(9),
"shall maintain, or provide for greater protection of the health of
persons."
- Benefit/Cost Consideration. The benefit received must outweigh the
cost. The costs considered in adjusting the MCL are greater than the
costs to maintain the current MCL (the no-cost option).
There are many complications to the radionuclides rule, including the
abundance of natural and man-made nuclides, changing health risk estimates,
legal constraints of SWDA, and cost concerns. The goal of the EPA rulemaking
is to substantially maintain current radionuclide levels, correct them
for recent science, and allow for public input via publication of a Notice
of Data Availability prior to the final rulemaking.
Discussion:
Nancy Reilman, Maryland Department of the Environment, disagreed with
the statement that if the current rule was upheld that the cost would
be zero; if the current standards are maintained, there would be associated
costs with regard to a new category of impacted systems.
Mr. Diamond agreed that no cost was an overstatement; there will be new
contaminants that have not been regulated before. [i.e., uranium, which
was proposed in 1991]. These will have to go through the entire process
of cost estimates. For existing contaminants, there has been a suggestion
that because some systems are not complying with current standards, the
cost to these systems should be factored into the cost. However, EPA does
not think this is appropriate because these systems should already be
in compliance. [Note: Changes in monitoring for 228Ra independently
from 226Ra was proposed in 1991 and would affect an additional
number of systems.]
Mitchell Childrey, Virginia Department of Health, stated that new standards
will be applied to non-transient, non-community water works (NTNC), whereas
previously they were only applied to community water works. This contradicts
the no-cost estimate of the present standards. [Note: Inclusion of NTNCs
was proposed in 1991.]
Dori Burg, Residents and Children of DeKalb, IL, brought up the issue
of increased public involvement in the evaluation process. Mr. Diamond
stated that with the 1991 proposal, there was an opportunity for public
comment. At present, public outreach (e.g., holding stakeholder meetings,
using the Federal Register) will be used for the Notice of Data Availability
and the final rulemaking. The rulemaking process and the process of compliance
are different; with compliance, the states inform the utilities with their
obligations. The public may not be involved in the compliance effort,
especially with smaller drinking water systems.
Maintaining or Providing a Greater Level of Protection Under the Safe
Drinking Water Act Amendments
David Huber, OGWDW, gave a 30-minute presentation on "Revising Regulations:
What Does Maintaining or Providing Greater Protection Mean?" The SDWA
Amendments of 1996, Section 1412(b)(9) states that revisions to a primary
drinking water regulation should "maintain or provide for greater protection
of the health of persons." The Senate report on the SWDA links an increase
in the MCL to an increase in the MCLG and states three situations in which
a MCLG can be raised: (1) non-zero threshold is discovered; (2) smaller
margin of safety; and (3) reclassification from carcinogen to non-carcinogen.
The proposed goal for ionizing radiation is zero. If the MCLG were to
increase from zero to something above the current MCL, e.g., with discovery
of a threshold, the MCL would also increase to that same level. The lower
the picoCuries of activity, the smaller the health risk (and the closer
to the zero goal the number is). Conversely, any increase in the amount
of radiation will result in additional relative risk.
For each nuclide, there is an associated risk of disease (morbidity)
and of death (mortality). The 1976 radionuclides rule determined risk
based on risk of death. Current data now allow estimates of risk of disease
as well. Risk of disease is used for chemical contaminants, and the policy
is to target a range of between 10-4 to 10-6. To
harmonize the risks, EPA is suggesting using the upper limit of the risk
of disease for chemicals at 1x10-4 as well as the risk of death
at the level set for the beta photon emitters in 1976, 5x10-5
(rounded from 5.6x10-5). This risk of death level is 50% of
the 1x10-4 risk of disease. The goal is to use the risk of
death or disease, whichever is more protective. Each nuclide has an associated
target organ and percent of fatal cancers. When the fatalities are 50%
or less for a nuclide, the limiting factor in determining the MCL is the
risk of disease level at 1x10-4; if the percent of cases of
cancer for a nuclide is greater than 50%, then death becomes the limiting
factor for keeping the MCL below the target of death of 5x10-5.
In the future rule, EPA will continue to sum the total risks of a group
of radionuclides. For example, EPA would continue to list beta and photon
emitters with corresponding picoCurie (pCi) levels equating to the target
risk. For multiple nuclides, the total risk cannot exceed the target;
i.e., the cumulative fractional risks cannot exceed one. For example,
if the risk level of a nuclide is 5 pCi and the sample has 1 pCi, that
nuclide constitutes 1/5 of the total risk. This
system may be used for alpha emitters and radium as well.
Discussion:
Dan Pedersen, American Water Works Association (AWWA), wanted to clarify
EPA's policy: will the EPA only lower or maintain, but never raise, the
MCL. Mr. Huber said that in general, the current level will be maintained
or lowered. Mr. Diamond, OGWDW, added that there are no absolutes; the
statute gives the Agency the opportunity to change with science. Although
the Agency has not used it, it does have flexibility in policy making.
Jennifer Cox, South Carolina Drinking Water Program, asked if the new
MCLs will be an average value (e.g., measured quarterly), or if there
will be a one time reading. Miguel Del Toral, EPA Region V, Safe Drinking
Water Branch, stated that EPA is looking at that issue and taking comments
in light of current issues that were not factors in 1991 or 1976.
Dr. Robert Rowland, Waukesha Water Utility System, disagreed with the
linear, non-threshold classification of radium. He stated that recent
findings have shown a threshold for radium, below which no life-shortening
effects are incurred. He wanted to know if this information is being considered
with regard to raising the MCLG for radium. Mr. Diamond stated that the
Agency can take threshold standards into account, but they have not found
data to support the position of a threshold existing for radium.
Erik Olson, Natural Resources Defense Council, questioned the cost/benefit
analysis for lowering the MCL and MCLG; if the cost associated with maintaining
the standard is zero, then how will the MCL and MCLG be changed? Lowering
the MCL would always result in increased costs. He also questioned how
long the current process of standard review would continue, and if EPA
was enforcing current standards. Mr. Diamond reiterated that testing was
involved in reviewing the standards. The tests are sequential; health/feasibility
is first and cost/benefit is last. If there is new evidence in terms of
threshold effects, then the standards can be changed. In most cases, however,
cost/benefit is never discussed because health evidence does not support
changing the standards. He stated that existing standards are valid and
enforceable, although states may have some discretion due to uncertainty
in terms of recent science and the current proposal.
Brad Addison, Georgia Department of Natural Resources, Environmental
Protection Division (DNR-EPD), asked if the waste stream disposal costs
and impacts of other environmental regulations are considered in a cost/benefit
analysis? He also questioned whether benefit/cost will be considered for
adjusted gross alpha emitters levels because modification may affect costs
and/or benefits. Mr. Diamond stated that waste costs will be considered.
Mr. Huber indicated that the current (1976) rule is for gross alpha (alpha
emitters including 226Ra) without uranium and radon; however,
the 1991 proposal was for adjusted gross alpha emitters, which
do not include 226Ra. This latter proposal was less protective
than the 1976 rule because it still allowed up to 15 pCi/L of the other
components. Adjustments will be made to the gross alpha standard to maintain
the level of protection based on risk. A simple 15 pCi/L standard represents
a greater risk than originally thought in 1976 for the same nuclides because
individual alpha emitter risks have increased. Benefit/cost assessment
will be considered for nuclides whose risks have increased substantially.
Ms. Burg, Residents and Children of DeKalb, IL, asked if non-carcinogenic
health effects (i.e., birth defects, stunted growth, crumbling teeth,
spontaneous head bleeds) are considered in setting MCLs. Mr. Diamond said
that health effects are considered; these data must be substantiated and
well documented. The Agency believes that there is sufficient documentation
of health effects and has no plans to implement further studies.
Linda Lahey stated that Illinois is using the 1991 proposed regulations
of 20 pCi/L for 226Ra and 228Ra combined. She wanted
to know if EPA was aware of this. Mr. Del Toral answered that when the
1991 proposal came out, Region V developed an enforcement discretion decision
to be used until EPA decided on final action on the 1991 proposal. Although
the standard is 5 pCi/L, Region V has an enforcement discretion decision
in effect with the higher value.
Level of Protection: Reevaluating the Protectiveness of Current Radionuclide
Regulations in Light of New Scientific Information on Health Effects
Lowell Ralston, EPA Office of Radiation and Indoor Air (ORIA), gave a
60-minute presentation on "Radionuclides in Drinking Water: Level of Protection."
The MCL for radionuclides is determined using: (1) a specified target
risk level (TR); (2) a radionuclide-specific risk conversion factor (RCF);
and (3) total drinking water intake. He reviewed the RCFs and how they
are calculated. Intake assumptions, radionuclide activity in the body,
dose amount and health effects, as well as biokinetic, dosimetry, and
risk models, determine the RCF. EPA assumes that radionuclides have a
linear, non-threshold dose-response. RCFs can be modified as the understanding
of radionuclides increases and as the models become more accurate.
Mr. Ralston also reviewed the 1976 and 1991 regulations. The MCLs increased
between 1976 and 1991 because the RCFs increased; however, the level of
protection as indicated by the TR did not decrease during this time.
Discussion:
Ms. Cox, South Carolina Drinking Water Program, wanted to know the key
elements in establishing an MCL. Mr. Ralston stated that the MCL is dependent
on the RCF. Most of the science, which has improved in recent years, goes
into calculating the RCF. When studying differences in MCLs, it is necessary
to look at past RCFs in comparison to current RCFs. This difference explains
the variation between the earlier and current MCLs.
The concept of subpopulations was discussed. It was asked whether there
are specific subpopulations that may be up to an order of magnitude higher
in terms of the risk because of their total water intake or other factors.
Mr. Ralston said that EPA uses coefficients that are age-averaged, and
that each age group has a single exposure level. For example, when EPA
looks at five-year-olds, it uses ingestion amounts and risk factors for
that age and follows the age group through the course of life. Then the
figures are averaged back over time. He added that risk factors change
depending on age. RCFs have not been calculated for specific ranges, i.e.,
zero to five years, but the Agency is looking into that issue. Jerry Puskin,
ORIA, stated that the intake amount of 2 liters/day is very conservative.
He said that it is possible that some people may be more susceptible to
radiation, but this has not been confirmed. It is beginning to be studied
in depth with atomic bomb survivors.
Scott Kirk, Nuclear Fuel Services, said that the EPA Science Advisory
Board's review of the proposed criteria documents for uranium stated that
the proposed standards (170 pCi/L) were conservative and protected the
outliers more than the general population. With models having a margin
of safety, both outliers and general population are protected. There is
a discrepancy in the risk and dose values in Federal Guidance 13 and those
proposed in 1991. EPA was asked to explain the peer review process for
Federal Guidance 13. Mr. Puskin replied that the uranium dosimetry models
in Federal Guidance 13 have changed and were peer reviewed by ICRP. Federal
Guidance 13 has been peer reviewed by members of the EPA Science Advisory
Board, Nuclear Regulatory Commission, Department of Energy, and outside
experts.
Ms. Burg, Residents and Children of DeKalb, IL, asked that the uranium
standards be tightened, because 238U decays to 235U
and then to 226U, all of which are radioactive. Mr. Ralston
stated that tightening the standards is a possibility. He stated that
all forms of uranium are present in drinking water and agreed that they
do present a risk. However, because all forms are present, they must each
be measured and extrapolated back to find out the exact amount of each
component ingested.
Dr. Terry Sandman asked why, in 1976, risks were quoted as mortality,
not morbidity. Mr. Ralston stated that they knew more about mortality
than morbidity at that time. Morbidity includes both fatal and non-fatal
effects, whereas mortality is death. Therefore, using only lifetime mortality
would underestimate the risk. Dr. Sandman asked whether risk models for
226Ra were adjusted for children's increased metabolic rates
(e.g., in relation to bone growth). Dr. Neal Nelson, ORIA, said that age-specific
models are adjusted in individual organs that show biokinetic changes
with age. Dr. Sandman questioned the feasibility of an agency (i.e., EPA)
studying risk in real life situations, in a manner comparable to Finkelstein
in Canada. Mr. Ralston said that a large-scale study would not be feasible
but a meta-analysis, pooling together many studies in a statistical analysis,
would be possible. The EPA, however, has no plans to do such an analysis.
Mark Thaggard, U.S. Nuclear Regulatory Commission, wanted a clarification
on the status of radionuclides: radium will not be changed from 1976 because
a higher number will increase risk, gross emitters may be changed, but
gross beta will not. Mr. Huber, OGWDW, said that given EPA's interpretation
of SDWA, Mr. Thaggard had made a generally accurate assessment of the
status of the radionuclides.
Occurrence of Radionuclides in Drinking Water
Debbie Kopsick, ORIA, began her 45-minute discussion by illustrating
its four purposes: (1) to present nationwide occurrence data for regulated
radionuclides; (2) to discuss co-occurrence of radionuclides; (3) to illustrate
the extent of exposure and present issues related to each radionuclide;
and (4) to identify additional data needs.
Ms. Kopsick discussed the four sources of occurrence information that
EPA currently utilizes: U.S. Geological Survey (USGS) Largest Cities Survey
from 1962, the USGS National Uranium Resource Evaluation (NURE) survey
from 1980, the EPA Nationwide Radon Survey from 1985, and the EPA >
National Inorganic and Radionuclides Survey (NIRS) Survey from 1986.
Ms. Kopsick then discussed the occurrence of 226Ra and 228Ra
in water. 226Ra is an alpha emitter in the 238U
decay series. It is soluble, moves in groundwater, and its occurrence
is not related to the aquifer type. On the other hand, 228Ra
is a beta emitter, and is a progeny in the 232Thorium series.
It is insoluble, does not move through groundwater, and its occurrence
is related to the aquifer type. She noted that the states with the highest
levels of combined radium are Illinois, Wisconsin, Missouri, Minnesota,
and Iowa. Under current monitoring requirements, only half of the public
water systems with combined radium at levels greater than 5 pCi/L would
have been identified. She indicated that 224Ra is not included
in the current MCL standard for radium (although it is part of the gross
alpha standard), and that it is not detected with current monitoring methods
due to its short half-life.
Ms. Kopsick reviewed the pertinent issues associated with beta photon
emitters, alpha emitters, and uranium in water. For beta photon emitters,
210Pb presents a concern because it can pose an unacceptable
risk at a screening level of 50 pCi/L. For alpha emitters, 210Polonium
is possibly the most frequently occurring radionuclide. For uranium, most
public water supplies with high concentrations are very small facilities,
serving between 25 and 500 people.
Discussion:
Baker Hamill, New Jersey Department of Environmental Protection, Bureau
of Safe Drinking Water, asked about the short-lived 224Ra.
He asked whether it was included in the sampling and monitoring schemes.
He went on to speculate that if the sampling time was shortened so that
it could be detected, then more public water systems would be out of compliance
with the combined 5 pCi/L. Ms. Kopsick replied that this would probably
be the case.
A question was asked about testing for 228Ra on a regular
basis, noting that testing for it only when 226Ra is present
at concentrations greater than 3 pCi/L seems inappropriate. Ms. Kopsick
replied that this issue will be addressed during the monitoring discussion.
A question was asked about the occurrence data that Ms. Kopsick had discussed.
It was noted that the data were from 1985 and earlier, and, therefore,
were gathered before the non-transient, non-community systems were included.
It was asked if the number of systems exceeding the MCL standards was
based on the 1985 data only, or if the number had been updated to include
non-transient, non-community systems. Ms. Kopsick replied that the MCL
was based just on community systems data (i.e., pre-1985 data).
Ms. Cox, South Carolina Drinking Water Program, asked why the concentration
levels in samples taken from the same system can vary so greatly from
one sample time to the next. Ms. Kopsick replied that the precipitation
of metals in the wells can cause a surge of radionuclide levels. Mr. Huber,
OGWDW, elaborated that there is actually a quirk in some radium measurement
techniques. If the radium is not measured soon enough, an ingrowth of
radon can occur, causing the measurement level to increase. Zoltan Szabo,
USGS, verified Mr. Huber's statement, noting that there needs to be a
time standard between when the sample is collected and when it is analyzed
to control for the radon ingrowth.
Mr. Ralston, ORIA, clarified that 210Pb and 228Ra
are both naturally occurring beta-emitting radionuclides. Lead 210 is
not regulated. The beta photon standard is applicable only to man-made
emitters and does not include any naturally-occurring radionuclides. He
noted that this oversight may need to be corrected. [The 1991 proposal
included 228Ra in the list of beta photon emitters. It is also
part of the radium standard along with 226Ra].
Dr. Rowland, Waukesha Water Utility System, asked if the databases examined
by EPA reported 40K (potassium) occurrence in the water. Mr.
Puskin, ORIA, replied that there is no excess risk associated with having
40K in the water since it is already present in the human body,
therefore, these concentrations are not reported.
Pat Phibbs, Environmental Health Letter, asked if the costs of waste
disposal from technologies associated with removing contaminants from
groundwater were considered by EPA. Ms. Kopsick replied that they were
considered and will be discussed during the treatment technologies presentation.
Ms. Burg, Residents and Children of DeKalb, IL, asked if EPA was aware
of the data on Tom's River head cancer cases. Dr. Nelson, ORIA, replied
that the nasal cancer cases at Tom's River are not associated with 224Ra
in the water. The types of cancers reported at Tom's River are associated
with chemical contaminants.
Methods and Limits of Detection of Radionuclides in Drinking Water.
Steve Pia, EPA Office of Research and Development, (ORD/ESD), presented
this 30-minute discussion. He began by providing a brief chronology of
the methods rule. In 1976, methods and MCLs were promulgated. In 1991,
a proposal with an expanded list of analytical methods was introduced.
In 1995, the analytical methods were put on a separate track from the
rest of the proposal to meet the needs of the regulated community, and
in 1997, the new rule was released. As a result, 12 new analytical methods
have been added, along with improved specific standards for gross alpha.
EPA has also approved a conservative 234Uranium conversion
factor of 0.67 pCi/g if radiotoxicity becomes an issue.
Mr. Pia discussed the detection limits, costs, and MCLs associated with
the current roster of radionuclides. He noted that as the detection level
of a radionuclide decreases, the cost associated with its detection increases.
With radiochemistry, it is possible to get lower detection limits by having
longer counting times. This, however, decreases the throughput of the
testing laboratory, so they have to increase their costs to cover the
longer counting times.
Mr. Pia identified laboratories in the U.S. and Canada that perform radiochemistry,
noting those ones that perform tests on drinking water.
Discussion
A representative from Maryland noted that the State of Maryland is only
able to perform tests on gross alpha, gross beta, and radon. In addition,
the EPA staff supports the State by performing inspections of laboratories
looking for radiation certification. Mr. Pia replied that with privatization,
the auditing of laboratories will be transferred to private companies.
Mr. Ralston, ORIA, asked about the conversion factor listed for uranium.
He noted that the conversion factor is set for 234U and 238U
to be present at equal concentrations, when in fact their ratios vary
considerably. Mr. Pia replied that the factor is conservative, i.e., it
will give more false positives than false negatives, resulting in the
overidentification of uranium in the drinking water.
Mr. Huber, OGWDW, asked whether the 0.67 pCi/µg conversion factor,
being a conservative number, would underestimate the activity. Mr. Pia
replied that the activity is underestimated, but in the context of determining
gross alpha, a conservative value would result in a lower calculation
of the contribution of uranium to the total alpha. Therefore, when the
uranium is subtracted out of total alpha to determine gross alpha, the
resulting number is higher.
A commenter suggested that with most of the radionuclide methods, a lower
detection level can be achieved by increasing the counting times. Therefore,
the issue of a detection level becomes an issue of how much time and,
therefore money, is spent per sample. Mr. Pia replied that this was true.
Ms. Burg, Residents and Children of DeKalb, IL, commented that if $1/person/year
had been set aside by the State of Illinois over the last 20 years to
remove radium from the drinking water, then the citizens of DeKalb would
not have to pursue their current lawsuit.
Ms. Cox, South Carolina Drinking Water Program, asked if the types of
bottles and preservatives used to collect samples are considered by EPA
when evaluating sampling techniques, to ensure the accuracy of measurements.
Mr. Pia replied that EPA does consider these factors.
Treatment Technologies
Bill Labiosa, OGWDW, discussed the best available technologies (BAT)
and other technologies that have been available since 1976 for treating
radionuclides in drinking water. He also addressed the small systems compliance
technologies and co-treatment practices that EPA will be taking into consideration
in the rule. He emphasized that treatment is always a last resort; other
options include use of alternate water sources and best management practices.
The four BATs proposed in 1991 included: ion exchange, lime softening,
reverse osmosis, and coagulation/filtration. Mr. Labiosa summarized the
removal rate efficiencies of these technologies with regard to various
radionuclides. He also discussed other technologies that may be used for
radium removal (greensand filtration, co-precipitation with barium sulfate,
manganese dioxide coated acrylic fibers or impregnated resins) and the
use of activated alumina for uranium removal.
Mr. Labiosa discussed the issues associated with small systems. Small
systems usually have less experienced operators who do not work full-time
for one system. Intermittent flows in small systems can cause problems
when using some technologies. In addition, a smaller customer base results
in an increased cost per customer. Point of entry and point of use technologies
are being used frequently in small systems and include: reverse osmosis,
ion exchange with selective resins, and activated alumina. In addition,
package plants with remote monitoring that allow "circuit rider operations"
are more frequently being used by small systems.
At the end of Mr. Labiosa's presentation, Bernard Lucey, New Hampshire
Department of Environmental Services, asked for more clarification on
the manganese dioxide coated acrylic fibers. Mr. Labiosa replied that
it is a fiber coated with manganese dioxide that will selectively remove
radium. It is similar to a filtration process. The coating must then be
disposed as a radioactive waste, due to its high concentration of radium.
He added that he has literature on all of these technologies if anyone
is interested.
Mr. Ralston, ORIA, asked if there are co-BATs, and if so, are there advantages
to using co-BATS. He also asked about the number of systems actively treating
for radionuclides in their drinking water. Mr. Labiosa replied that there
are treatment technologies that will remove more than one radionuclide,
and a system would always want to use a technology that can remove more
than one contaminant at a given time. He added that he did not know the
number of systems that are actively treating for radionuclides.
Waste Generating and Disposal Guidelines
Amit Kapadia, OGWDW, discussed the waste generation and disposal guidelines
for radionuclides. He noted the types of waste generated by the treatment
technologies discussed earlier: coagulation/filtration, lime softening,
ion exchange, and reverse osmosis. EPA has a program called SPARRC that
measures wastes generated and the concentrations of radionuclide contaminants
in waste. Disposal methods are available for solid and liquid wastes.
Liquid wastes can be disposed of in surface waters, sanitary sewers, or
injection wells, depending on the radionuclide concentration. At low radionuclide
concentrations, solid wastes can be disposed of in a municipal landfill
or a physical barrier. At high concentrations, they are disposed of on
a case-by-case basis, according to state regulations, or by recovery.
Mr. Kapadia concluded by saying that in 1992 the EPA Science Advisory
Board recommended that OGWDW examine the exposure of treatment plant workers
to radionuclides. The typical U.S. citizen is exposed to an average of
360 mrem/yr of radiation. EPA concluded that at a treatment plant, worker
exposure should be limited to 100 mrem/yr. There are times when personnel
protective clothing should be worn by plant employees. He described the
type of exposure a worker might have if using a specific treatment technology.
Discussion:
Mr. Hamill, New Jersey Department of Environmental Protection, Bureau
of Safe Drinking Water, noted that a couple of small systems in New Jersey
have had problems with waste disposal because sewage systems do not want
to accept the waste. Whether it is allowed or not, they are reluctant
to accept radioactive waste. Mr. Labiosa, OGWDW, replied that EPA is aware
of the problem.
Mr. Ralston, ORIA, commented that well-injection is currently prohibited
as a disposal technique. He added that the Nuclear Regulatory Commission
is conducting a study of radiation exposure to treatment plant workers.
He asked if there are costs associated with the waste disposal methods
discussed. Mr. Kapadia replied that a cost study was conducted in 1991
and that another one will be done during the next regulatory impact analysis.
A question was asked if other environmental laws (i.e., at the state
level) and permitting laws go into effect when radionuclides are concentrated.
Mr. Labiosa replied that permitting laws are definitely considered. State
laws are usually considered on a national level only if they are common
to many states.
Mr. Childrey, Virginia Department of Health, supported the comments about
problems with disposing of radionuclide wastes. He stated that public
reaction to radioactivity makes it very difficult to dispose of this waste.
Teresa Boepple, New York State Department of Health, Bureau of Public
Water Supply Protection, noted that for small systems, there is a concern
with the training of operators. Given that New York is developing new
training guidelines for small systems, she asked if this issue is being
addressed during EPA regulation development. Mr. Labiosa replied that
he would mention this concern to Peter Shanahan who is responsible for
developing the new guidelines.
Ms. Burg, Residents and Children of DeKalb, IL, asked if EPA had considered
the feasibility of using plugs and casings in the well systems, as it
does not create any wastes. Mr. Labiosa replied that treatment is always
the last resort, and that Ms. Burg's example falls under the category
of best management practices.
Brad Addison, Georgia DNR-EPD, asked what constitutes a small systems.
Mr. Labiosa replied that it is any system serving less than 10,000 individuals.
It was asked whether the states currently out of compliance will be granted
funds to help them achieve compliance with the regulations. One state
representative replied that there is a state revolving fund that has been
set up that could be used for such a purpose. Mr. Childrey added that
the top priority of Virginia's fund is an MCL violation. Mr. Hamill stated
that, in New Jersey, local governments would be qualified to receive these
funds if there was an MCL violation.
Facilitated Discussion
A question was raised regarding 228Ra and the scientific evidence
supporting a zero-level MCLG. Mr. Ralston, ORIA, replied that all radionuclides
have the potential to damage cells because they emit ionizing radiation,
thus classifying them as carcinogens. Current models do not recognize
carcinogens as having thresholds, therefore, they must have zero-level
MCLGs. The scientific basis for assigning any radionuclide a zero-level
MCLG was questioned. EPA again pointed out that radionuclides were considered
carcinogens. It is an EPA policy that carcinogens, especially known mutagens,
conform to linear, non-threshold, risk models.
Sylvia Barrett, Metropolitan Water District of Southern California, questioned
how liquid waste containing radionuclides can be dumped into surface water
when that water might be used downstream as drinking water. EPA replied
that state water quality standards and NPDS permits make sure that appropriate
water quality standards are met. These permits would take into account
water quality levels and downstream uses.
Ms. Cox, South Carolina Drinking Water Program, asked if de-watered waste
sludges used in solid waste disposal could be land applied. Mark Parrotta,
OGWDW, stated that this issue was addressed by EPA a few years ago. In
EPA's Suggested Guidelines for Disposal, land application of low level
radioactive waste (i.e., 1 pCi/L to 3 pCi/L) is allowed; however, this
type of application had been met with protest from commenters and the
EPA Science Advisory Board. Land application of radium could increase
exposures in the future and there is insufficient information about how
much would leach into surface waters. EPA chose to be conservative and
not recommend land application; although this issue could be addressed
later after further study.
Joseph Harrison, Water Quality Association, stated that 150 towns in
Region V have radium levels that are out of compliance. In order to correct
this, the water rates would have to be doubled. In these towns, the public
is aware of the problem (i.e., water bills say that radium levels in the
water exceed the limit). The funds needed to correct the problem in one
town would require or exceed the total state revolving fund. The old standard
of 5 pCi/L would not hold up to the cost/benefit analysis applied to the
new standards, but because of Section 1412(b)(9) such analyses cannot
be made. Cost/benefit analysis should be taken into account; there should
also be referendums in individual towns with high radium.
Ms. Burg, Residents and Children of DeKalb, IL, suggested that tax incentive
fund money (TIF) could be used to fix water systems that are not in compliance
with the standards.
Ellen Partridge, Partridge and Niro, asked how many towns had radium
levels exceeding current standards. Ms. Burg said that there were 500
towns nationwide, 70 of them in the State of Illinois.
Mr. Bonner, the meeting facilitator, stated that the presentations focused
on information gathered through surveys and databases. He asked the audience
for suggestions of other data sources that EPA would find useful in establishing
the MCL. Ms. Burg suggested using data on power plants and the radioactivity
they emit. Mr. Kirk, Nuclear Fuel Services, suggested using the CERCLA
database and a database on groundwater contamination for cost information.
Dr. Rowland, Waukesha Utility System, stated that there is a study by
Petersen et al. of bone cancer incidences in areas with high radium published
in two forms: as a journal article and as a monograph. The journal article
suggests that high radium areas have increased bone cancer risks in comparison
to low radium areas, whereas in the unpublished monograph, the incidence
of bone cancer did not differ between high and low radium areas. Ms. Burg
stated that the article Cancer Incidences in Illinois demonstrates
that bone cancer incidence among children is considerably greater in areas
with high radium levels.
Peter Denk, DeKalb Daily Chronicle, questioned Dr. Rowland's theory that
radium in DeKalb's drinking water is negligible and wanted to know the
EPA response to this. EPA had already commented on this; saying that radium
is considered linear, non-threshold and one exposure could potentially
cause damage. Ambika Bathija, EPA Office of Water/Office of Science and
Technology (OW/OST), stated that linear, non-threshold risk is an EPA
policy based on current knowledge and may be changed based on new scientific
data; i.e., future studies may show that there is a threshold for some
radionuclides.
Mr. Hamill, New Jersey Department of Environmental Protection, Bureau
of Safe Drinking Water, stated that animal studies and models are not
as reliable as epidemiological studies, and eventually this issue should
be addressed by EPA. EPA stated that epidemiological studies are difficult
to perform because the exposed populations are not large enough. Meta-analysis
was suggested as an alternative to epidemiological studies, but as of
now, EPA does not plan to pursue this approach.
A question was raised concerning occurrence data versus natural background
radiation; in areas of high radiation such as DeKalb, how does the high
radiation occurrence data compare to natural background radiation across
the country? Mr. Ralston indicated that it would be difficult to make
the comparison without looking at the actual data, but he stated that
this could be done in the future. Ms. Burg read from the ATSDR's Toxicological
Profile on Radium. She said that background radiation is the same in soil,
1 pCi per gram of soil.
Mike Barker stated that, in light of the presentations, there is no legal
or scientific evidence to support weakening the MCLs. Often these standards
are set by PQL (Practical Quantitation Level); however, for most radionuclides,
there is no justification for setting MCLs based on this approach.
Dennis Duffield, City of Joliet, Illinois, stated that for many years
he had been publishing information indicating that Joliet exceeded the
radium MCL. There had been no push to enforce the new standards when EPA
had proposed them. But public hearings were held in every community with
a radionuclide problem, the problem had not been covered up. Mr. Huber,
OGWDW, admitted that there were isolated cases where people were not informed.
Compliance should have taken place within three years after 1976. The
issue now is not whether cost/benefit analysis should be performed for
systems that needed to come into compliance with the 1976 standards; but
rather, whether EPA should maintain or lower the standard. EPA has not
enforced the 1976 standard since 1991 due to the confusion over the 1991
proposal.
Ms. Burg made a comment on the Illinois public hearings; they were held
at the request of the public. Illinois recently published a rule that
it would not require individual hearings to allow variances to "restricted
status" -- which prohibits new hookups to systems not in compliance with
the standards. Rather, Illinois is issuing blanket variances to communities
below 20 pCi/L; any community with radionuclides under this limit cannot
hold public hearings because the community does not need to receive a
variance from the standard.
Friday, December 12, 1997
Costs and Regulatory Impact Analyses for Uranium
Ambika Bathija, OW/OST, began her presentation by explaining the classification
of uranium as a Group A "known human carcinogen" and kidney toxicant.
Since the 1991 proposal, EPA has been reevaluating the Relative Source
Contribution (RSC), the uranium conversion factor from g/L to pCi/L, and
the health effects of uranium. The new data on uranium include:
- A 30%, 50%, or 80% RSC from water rather than the default RSC of 20%
used in the 1991 proposal;
- A conversion factor of 0.9 pCi/L for the uranium MCL in water (for
converting g/L to pCi/L) rather than 1.3 pCi/L used in the 1991 proposal;
and
- A drinking water equivalent level (DWEL) of 70 g/L rather than 100
g/L as proposed in 1991 for determining health effects.
Mr. Huber, OGWDW, presented information about the relative radioactivities
of the two uranium isotopes, 238U and 234U. 238U
is more prevalent and not very radioactive; its effect is on the kidneys
and its mass is the most important determinant of health effects.
On the other hand, because 234U is more radioactive, human
carcinogenity is the health endpoint of concern. When converting measurements
from mass in micrograms to activity in picoCuries, the uranium activity
to mass ratio is important. The risk of cancer incidence for a uranium
MCL at 30 pCi/L and 60 pCi/L and the RSCs resulting in a uranium MCL at
30 g/L and 60 g/L were also compared.
Discussion:
Mr. Lucey, New Hampshire Department of Environmental Services, asked
about the speciation cost for 238U and 234U. In
response, Mr. Ralston, ORIA, stated that an isotopic analysis would cost
approximately $300 and the cost for a fluorometric analysis would be $100
to $150.
A participant asked for clarification on the co-occurrence of radium
and uranium. Mr. Huber responded that generally radium is found in reducing
environments, whereas uranium is found in oxidizing environments. He stressed
that co-occurrence may occur in fractured rock systems, or where wells
were drawing water from several water bearing zones.
Mr. Ralston, ORIA, stated that the proposed MCL for uranium was an actual
cap for the three natural isotopes; 238U, 235U,
and 234U. He clarified that 238U and 234U
are in the same family and occur in equal activity concentrations at equilibrium.
He stressed the importance of knowing the isotopic abundance when converting
from mass to activity.
Mr. Pedersen, AWWA, asked about the activity-to-mass ratio of a system
containing only 234U. Mr. Huber replied that after determining
that a system contained 234U, the measurement would be in picoCuries
to account for the activity. Mr. Puskin, ORIA, added that if a system
contained only 238U, the activity levels would be half that
of a normal mixture.
Mr. Lucey cited uranium occurrence data for approximately 10% to 15%
of the New Hampshire public water systems. He emphasized that the data
fluctuated about 100% to 200% due to seasonal and temporal variability.
Mr. Szabo, USGS, explained the mobility of 234U. He attributed
its mobility to the alpha ionizing radiation causing damage to the crystal
lattice structure of the minerals holding the uranium. The alpha recoil
would allow some of the uranium to escape the crystal structure and enter
the ground water where it is soluble and mobile. In addition, he cited
studies from New Jersey that documented occurrence ratios of two to one
for 234U to 238U.
Ms. Burg, Residents and Children of DeKalb, IL, insisted that the MCL
should consider all the health effects for uranium including those on
the fetus. In response, Ms. Bathija stated that the most sensitive endpoint
for uranium was kidney toxicity. Protecting for kidney toxicity would
also include protection of the reproductive and developmental organs.
Ms. Burg pointed out data from the Atomic Bomb Casualty Commission data
on the effects of radiation on the fetus. Mr. Huber responded that the
radiation effects in that case was probably external gamma radiation,
not internal radiation resulting from drinking water. Mr. Ralston agreed
and added that when developing risk numbers, the health effects associated
with the daughter products and the decay chain were also considered in
the metabolic model.
With regard to the MCLG and MCL, Mr. Hamill, New Jersey Department of
Environmental Protection, Bureau of Safe Drinking Water, suggested reassessing
the final regulation if needed. He also suggested that EPA establish a
regulation which focuses only on those systems that have significant uranium
concentrations.
Mr. Puskin suggested using an RSC of 80% rather than the default RSC
of 20%, as was done in the proposed rule. He suggested also that there
was little difference in the food contribution to total uranium intake
in different parts of the country because the typical diet contains food
from various parts of the country, rather than being home grown. Variations
in uranium intake would be due to local water conditions.
Monitoring Framework for Radionuclides, Both Current and Proposed
Mr. Del Toral, EPA Region V, Safe Drinking Water Branch, explained the
current and proposed monitoring requirements for gross alpha particle
activity (226Ra, 228Ra, and uranium), and gross
beta particle activity. Based on the proposed monitoring requirements,
the limitations of the screening levels were also summarized and included:
- 210Po exceeds the 1x10-4 risk of incidence at
1 pCi/L, which is below the gross screen of 5 pCi/L. In addition, 210Po
cannot be measured as low as needed for compliance purposes;
- 224Ra exceeds the 1x10-4 risk of incidence below
the MCL of 15 pCi/L;
- the gross alpha screen must be analyzed within 48 hours of collection
due to the short half-life of 224Ra;
- a gross beta screen at 30 pCi/L will not measure radionuclides such
as 228Ra, 210Po, and 129I; and
- an additional 500 systems will have to treat once the monitoring is
corrected. The proposal did not require public water systems to sample
for the 228Ra isotope if the 226Ra levels were
between 2 and 3 pCi/L.
Discussion:
Mr. Ralston, ORIA, stated that the issue of decay was important because
isotopes can exist individually without support from the decay chain.
He stressed that although laboratories could back-calculate to determine
the concentration of the isotope during collection, an accurate measurement
may not be possible.
A resident from DeKalb, IL, questioned the effectiveness of extending
the time interval for monitoring from four to five years. She suggested
that EPA regain the public trust before promulgating the regulation.
Mr. Szabo, USGS, presented several overheads demonstrating the decrease
in the gross alpha activity in a collection sample through time. He emphasized
that each sample lost about half its activity within ten days and cautioned
against the use of a gross alpha screen of 15 pCi/L. He recommended a
gamma spectroanalysis or an alpha spectroanalysis for the measurement
of 224Ra. He also stated that the decrease in daughter products
may necessitate individual measurements for both 210Pb and
210Po.
Concern was voiced over the feasibility of a 48-hour turn around when
considering sample collection, shipping, and handling. In response, Mr.
Huber, OGWDW, stated that only systems deemed vulnerable would have to
sample regularly after the initial screening.
What's Next: Possible Strategies for Revising the Radionuclide NPDWRs
Mr. Huber, OGWDW, began his presentation by stressing that EPA's goal
is to expedite the rulemaking. Several alternatives were presented for
the radionuclides (e.g., 210Pb, 210Po) that may
hinder the final rulemaking, such as the publication of a Notice of Data
Availability, placement on the Contaminant Candidate List, or inclusion
in the Unregulated Monitoring Regulation. Mr. Huber stated that proceeding
with the final rulemaking would end the confusion and increase public
health through the establishment of an immediate MCL. The revised rule
would substantially maintain the current levels and include recent scientific
data. In addition, further opportunities exist for public involvement
prior to the final rulemaking, including comment on a Notice of Data Availability,
Internet, E-mail, and possibly an additional stakeholder meeting.
November 2000 was established as the date for the final rulemaking in
the radionuclides in drinking water proposal. Under this agreement, EPA
will have to finalize the regulation for uranium, and with regards to
radium, alpha emitters, and beta photon emitters, finalize the regulation
or state reasons for not taking final action on the proposed regulations.
Discussion:
Mr. Childrey, Virginia Health Department, stated that a survey to determine
occurrence would be more effective than unregulated monitoring. A similar
comment was made by Ms. Reilman of the Maryland Department of the Environment.
She added that the 1996 regulation enables EPA to fund unregulated monitoring
for small systems.
Ms. Reilman stressed several issues including; 1) the use of screening
measures to regulate only systems in noncompliance, 2) a reproposal for
210Po and 224Ra, 3) the upcoming contaminant rule
allowing standardized monitoring which would simplify this regulation,
4) sampling at the point of entry, and 5) the ability to grandfather previous
data. Mr. Huber addressed these issues by clarifying that 210Po
and 224Ra are currently regulated by EPA, whereas 210Pb
is not. Screening methods will be used wherever possible to save costs,
and standardizing monitoring with the chemical monitoring reform is being
looked at by EPA. In response to the final issues, he stated that any
previous data would have to be analyzed to ensure consistency with current
data (i.e., point of entry sampling).
Diane Larsen, Department of Energy, asked how EPA would enforce compliance
with public water systems. In response, Mr. Addison of the Georgia DMR-EPD
indicated that the regulatory programs of each state handle most compliance
issues.
Mr. Ralston, ORIA, asked if all the radionuclides would fall under a
risk level of 5x10-5 mortality. In response, Mr. Huber stated
that EPA is trying to regulate all radionuclides under a uniform risk
level and is seeking input with regard to whether manmade radionuclides
ought to be more stringently regulated.
Mr. Ralston stated that a chemical separation of radium will include
all the isotopes. A similar comment was made by Mr. Szabo, USGS. However,
Mr. Szabo added that an accurate analysis can be accomplished by determining
the individual radiation emissions. A possible method to discern the presence
of 224Ra would be the presence of 228Ra. According
to the New Jersey data, all the samples that had 224Ra also
contained 228Ra.
General Discussion of Future Stakeholder Input
Mr. Hamill, New Jersey Department of Environmental Protection, Bureau
of Safe Drinking Water, encouraged EPA to collaborate with USGS in acquiring
existing occurrence data. He suggested the use of a reproposal to assess
the cost-benefits if the occurrence data on polonium at low levels affected
more than 5% of the public water systems.
Ms. Burg, Residents and Children of DeKalb, IL, stressed sampling at
various times during the pumping schedule and not averaging one point
in time at the point of entry. She also suggested stringent enforcement
by the Federal government to ensure compliance by the DeKalb, IL water
system. She emphasized that the high radionuclide concentration within
her community has resulted in a significant increase in colon, lung, and
prostate cancer.
Mr. Hamill cited the current regulation which authorizes sampling at
a representative point in the distribution system. Therefore, previous
State data are not based on measurements taken at the point of entry or
at the well. He suggested structuring the regulation according to the
Synthetic Organic Contaminant Rule and determining vulnerability by considering
the number of attached aquifers. He suggested determining each aquifer's
vulnerability and recommended that multiple samples not be taken for non-vulnerable
aquifers. A similar comment was made by Mr. Szabo, USGS. However, Gerald
Bever from the City of DeKalb, IL, stated that the radium concentration
fluctuates from below 5 pCi/L to 10.4 pCi/L from nine wells within the
same aquifer.
Mr. Denk of the DeKalb Daily Chronicle asked whether the states should
begin enforcement of the 1976 regulation since the radium MCL would not
increase with the current proposal. Mr. Huber, OGWDW, answered that blanket
enforcement maybe premature because there is the possibility of a lower
radium MCL which could require different treatment than meeting the current
standard. In general, most systems could meet 5 pCi/L MCL with their present
technology and should begin to make plans to comply.
Ms. Lahey asked if subsequent monitoring was needed after initial monitoring
for 210Po and 224Ra to account for fluctuation.
In response, Mr. Huber stated that data are not available regarding single
data points or how data may vary over time. EPA will be collecting and
analyzing information during the next six months. Some repeat monitoring
of vulnerable systems may be required to establish a pattern to ensure
that less frequent monitoring is sufficient.
Ms. Lahey was also a proxy for Gloria Rains who represents ManaSota-88.
The issues summarized by Ms. Lahey included: 1) no scientific justification
for decreasing the radium standard; 2) need for more stringent regulation
of 210Po; and 3) maintaining the current monitoring period
of four years.
Michael Weber of the U.S. Nuclear Regulatory Commission asked that during
promulgation, EPA consider the application of its MCLs to other regulatory
programs, such as groundwater restoration or protection. Mr. Huber replied
that while other regulatory programs may use the MCLs as ARARS (Applicable
or Relevant and Appropriate Requirements), OGWDW could not include such
considerations in its rulemaking. As mandated by the statute, OGWDW is
writing standards applicable to drinking water, not aquifer cleanup.
Dr. Rowland, Waukesha Water Utility System, provided information on the
effects of radium in the human body. According to several ongoing studies,
two malignancies that can be attributed to radium are bone sarcomas and
head carcinomas. An increase in breast cancer also existed in the radium
dial painters; however, there is insufficient evidence to determine whether
the cancer can be attributed to exposure to internal or external radium
(i.e., ingestion or placement of the radium paint at chest level).
Dr. Rowland also addressed the effects of natural background radiation.
According to the NCRP volume 94 document, the average annual dose to the
epithelial cells in bones is 170 mrem, which includes 110 mrem of internally
deposited radioisotopes containing the daughter products of radium and
also 40K. He stated that 40K is the largest single
isotope in the body and was measured at a total body dose of 120,000 pCi/L.
He suggested determining how the proposed regulation will affect the total
body dose received from food and external radiation.
Mr. Huber thanked all the stakeholders for their participation. He indicated
that written comments would also be considered and could be sent to him.
The stakeholder meeting adjourned at 1:30 pm.
Stakeholder Meeting Attendees
Brad Addison
Georgia Department of Natural Resources/Environmental Protection
Division
James Bachmaier
US Department of Energy
Ambika Bathija
EPA Office of Water
Office of Science and Technology
Gerald Bever
City of DeKalb, IL
Teresa Boepple
New York State Department of Health
Bureau of Public Water Supply Protection
Dori Burg
Residents and Children of DeKalb, IL
Mitchell Childrey
Virginia Department of Health
Jeannie Cho
Vicki Cochran
Kilpatrick Stockton
Peter Coon
NAWC
Richard Cunningham
US Department of Energy
Miguel Del Toral
EPA Region V
Safe Drinking Water Branch
Bill Diamond, Director
EPA Office Ground Water and Drinking Water
Dennis Duffield
City of Joliet
Mike Focazio
US Geological Survey
Harold Fuhrman
City of Waukesha Water Utility
John Guggi
EPA NAREL
Baker Hamill, Chief
New Jersey Department of Environmental Protection, Bureau of Safe
Drinking Water
Joseph Harrison
Water Quality Association
William Roy Harrison
US Deptartment of Energy
Scott Hay
S. Cohen & Associates, Inc.
David Huber
EPA Office of Ground Water and Drinking Water
Ben Hull
EPA Office of Radiation and Indoor Air
Amit Kapadia
EPA Office of Ground Water and Drinking Water
John Karhnak
EPA Office of Radiation and Indoor Air
James Scott Kirk
Nuclear Fuel Services
Debbie Kopsick
EPA Office of Radiation and Indoor Air
Ron Kovach
EPA Region V
Max Kukoy
ASDWA
Bill Labiosa
EPA Office of Ground Water and Drinking Water
Diane Larsen
US Department of Energy
Patricia Lawson
National Safety Council
Vicki Lloyd
EPA Office of Radiation and Indoor Air
Bernard Lucey
New Hampshire Department of Environmental Services
Frank Marcinowski
EPA
Corey McDaniel
EOP Group
Jim McFarland
Dr. Neal Nelson<
EPA Office of Radiation and Indoor Air
Erik Olson
Natural Resources Defense Council
Mike Osinski
EPA Office of Ground Water and Drinking Water
Marc Parrotta
EPA Office of Ground Water and Drinking Water
Glenn Patterson
US Geological Survey
David Pauel
EPA Office of Radiation and Indoor Air
Dan Pedersen
American Water Works Association
Pat Phibbs
Environmental Health Letter
Stephen Pia
EPA Office of Research and Development/ESD
Dawn Porto
Designers & Planners
Jerry Puskin
EPA Office of Radiation and Indoor Air
Lowell Ralston
EPA Office of Radiation and Indoor Air
Edward Regnier
US Department of Energy
Nancy Reilman
Maryland Department of the Environment
Edward Regnier
DOE Waste Management Unit
David Robbins
EPA Region 8
Dr. Robert Rowland
Waukesha Water Utility System
Tom Schaeffer
AMWA
Roger Selburg
Illinois EPA, DPWS
Shantini Senanjahe
Nancy Stanley
New Jersey Department of Environmental Protection, Radiation Protection
Programs
Todd Steiner
International Consultants, Inc.
Katie Sweeney
National Mining Association
Zoltan Szabo
US Geological Survey
Mark Thaggard
US Nuclear Regulatory Commission
Chao-Hsiung Tung
SAIC
Sherri Umansky
EPA
Pat Ware
Bureau of National Affairs
Michael Weber
US Nuclear Regulatory Commission
Corry Westbrook
EPA, Office of Ground Water and Drinking Water
Jim York
ASE, Inc.
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Sylvia Barrett
Metropolitan Water District of Southern California
Jennifer Cox
South Carolina Drinking Water Program
Thomas DeGaetano
EPA Region IV
Peter Denk
Daily Chronicle
Jacob Dumelle
American Lung Association of Chicago
Julia Fauci
Northern Illinois University
John Hepperley
Janet Johnson
Shepard Miller, Inc.
Linda Lahey
Ellen Partridge
Partridge & Niro
Fred Pontius
AWWA
Dr. Terry Sandman
Jane Smith
Indiana State Department of Health
Gene Taylor
EPA Region X
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