Human Health Criteria Draft Rule Comments - WAC 173.201A

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Name Human Health Criteria Draft Rule Comments - WAC 173.201A
Category Natural Resources & Environment
Tags ecology, fish consumption, human health, water quality standards, hhc, toxics, implementation
Created 2015-12-18T19:28:16Z
Publication Date 2016-05-20T21:52:21Z

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series e:7rpc-etc2 d:2016-02-03T15:00:30.000Z t:organization="Pacific Groundwater Group" t:name="Janet Knox" m:row_number.7rpc-etc2=1

series e:7rpc-etc2 d:2016-02-07T13:30:49.000Z t:organization=N/A t:name="Norman D. (Norm) Peck" t:comments="Sec. 173-210A-240(5)(b) states, in part, that arsenic (As) is to be evaluated as total As.  In cases where organo-arsines are present, the contribution of those organo-arsines should be subtracted from the total As value, as they bias bioavailable As toxicity upwards.  This is a known contributor to false positives in urinary arsenic testing.  Failure of an As criterion should allow the option to rebut the failure through identification of the contribution of organic arsenical compounds, with due consideration of the few toxic organo-arsines. 
Footnote dd of Table 240: As water column seasonal budgets are known to closely parallel phosphorous (P) budgets in lentic systems that undergo seasonal stratification and overturn, and As dynamics can be accurately estimated with relatively few data points if P dynamics are known.  This factor should be considered in determining whether As seasonal partitioning is ???known???.  As level fluctuations should be evaluated especially carefully in ???peat-bog lakes???, as unusual dynamics may exist (e.g. Des Moines Creek Regional Stormwater Detention/Retention facility S. of SeaTac Airport).
It is my assumption that toxicity for the various dichlorotehylene and dichloroethane isomers is based solely on their individual carcinogenicity.  It is my opinion that an additional correction factor should be included based on their further breakdown into vinyl chloride, which has considerably higher cancer potency.  In most instances the ???di???s are penultimate breakdown daughters of tetrachloroethylene and/or the ???tri???s, with the final and extremely persistent ultimate breakdown daughter being vinyl chloride.  

Since As is known to associate with soil fines, the distinction between suspended and dissolved As may be an important consideration.  
While I support use of the 175 g/day general fish consumption rate as a basis for chronic, long-term exposure risk calculations, use of higher rates for specific populations known to consume higher proportions of fish in their diets should be considered on a local (or specific point-of-harvest) basis where appropriate in setting water quality criteria." m:row_number.7rpc-etc2=2

series e:7rpc-etc2 d:2016-03-09T14:44:55.000Z t:organization="University of Washington" t:name="Marilyn Hair" t:comments="Very glad to see the FCR increased to 175 gr/day and the cancer risk maintained at 1 in 1 million. I support Washington approving the FCR for our state and not leaving it to EPA." m:row_number.7rpc-etc2=3

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Top Records

| :updated_at | name                       | organization                             | comments                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | attachment_1                                                                                                                                              | attachment_2             | attachment_3             | attachment_4             | attachment_5             | attachment_6             | 
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| 1454511630  | Janet Knox                 | Pacific Groundwater Group                |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | [null, null, null, null]                                                                                                                                  | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | 
| 1454851849  | Norman D. (Norm) Peck      | N/A                                      | Sec. 173-210A-240(5)(b) states, in part, that arsenic (As) is to be evaluated as total As. In cases where organo-arsines are present, the contribution of those organo-arsines should be subtracted from the total As value, as they bias bioavailable As toxicity upwards. This is a known contributor to false positives in urinary arsenic testing. Failure of an As criterion should allow the option to rebut the failure through identification of the contribution of organic arsenical compounds, with due consideration of the few toxic organo-arsines. Footnote dd of Table 240: As water column seasonal budgets are known to closely parallel phosphorous (P) budgets in lentic systems that undergo seasonal stratification and overturn, and As dynamics can be accurately estimated with relatively few data points if P dynamics are known. This factor should be considered in determining whether As seasonal partitioning is ???known???. As level fluctuations should be evaluated especially carefully in ???peat-bog lakes???, as unusual dynamics may exist (e.g. Des Moines Creek Regional Stormwater Detention/Retention facility S. of SeaTac Airport). It is my assumption that toxicity for the various dichlorotehylene and dichloroethane isomers is based solely on their individual carcinogenicity. It is my opinion that an additional correction factor should be included based on their further breakdown into vinyl chloride, which has considerably higher cancer potency. In most instances the ???di???s are penultimate breakdown daughters of tetrachloroethylene and/or the ???tri???s, with the final and extremely persistent ultimate breakdown daughter being vinyl chloride. Since As is known to associate with soil fines, the distinction between suspended and dissolved As may be an important consideration. While I support use of the 175 g/day general fish consumption rate as a basis for chronic, long-term exposure risk calculations, use of higher rates for specific populations known to consume higher proportions of fish in their diets should be considered on a local (or specific point-of-harvest) basis where appropriate in setting water quality criteria.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | [null, null, null, null]                                                                                                                                  | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | 
| 1457534695  | Marilyn Hair               | University of Washington                 | Very glad to see the FCR increased to 175 gr/day and the cancer risk maintained at 1 in 1 million. I support Washington approving the FCR for our state and not leaving it to EPA.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | [null, null, null, null]                                                                                                                                  | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | 
| 1460028978  | Elizabeth Hartsoch         | Mrs.                                     | State water quality standards should be MORE protective than federal standards, not less. Let's move this forward!                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | [null, null, null, null]                                                                                                                                  | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | 
| 1460036566  | Robert B. Barnes           | Citizen                                  | I totally agree with the Tribes that the State should adopt higher standards, at east as high as the EPA. The State's track record is dismal. They allowed dams to be built without fish passage which was a law since Washington was a territory. The Department of Transportation has delayed, delayed, delayed on culvert replacement which is a minimum to what they should be doing. Many of their current outfalls go untreated, poisoning the Salish Sea with hydrocarbons and contaminants from the roadway. I was a commercial fisherman in Alaska for 40 years, and I am afraid to eat the fish coming from the Salish Sea. We should be leading, not trailing the EPA for water quality standards. We all live downstream, and our children and grand children expect and deserve better. Thank God for the EPA, the Clean Water Act, the Clean Air Act, the Environmental Impact Statement Process, and the Bolt decision that made Northwest Treaty Tribes co-managers of the fish and shellfish we all consume. We can and should do better!                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | [null, null, null, null]                                                                                                                                  | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | 
| 1460060075  | Valarie Kaser              | Enrolled Makah Tribal member             | It seems as the water is tested, but not the many varieties of clams? We get frustrated when it's closed, then reopened without the shellfish being actually tested. So please do us a favor and test the shellfish. We live on this stuff. It's very important to so many.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | [null, null, null, null]                                                                                                                                  | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | 
| 1460060250  | Judith Biller              | Ms.                                      | We must do better with regards to these water supplies!!                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | [null, null, null, null]                                                                                                                                  | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | 
| 1460477155  | Honorable Margaret Wiggins |                                          | Re: Proposed water quality standards for protecting human health, Chapter 173-201A WAC Dear Ms. Conklin: Thank you for working on this important issue. I am a recently reelected water and sewer commissioner with 18 years of experience. There isn???t much time before you have to make a decision so I am writing as a citizen and not on behalf of my district or its board. The water quality standards for protecting human health, Chapter 173-201A WAC recommended changes need to be linked to actual studies of injury to humans that indicate a need for remediation. Has this provision in the WAC changed? Are we to create a new rule that benefits meter companies that have made test equipment that is more sensitive than the human body? Wouldn???t it be better if they dedicated their R&D efforts to make smaller, cheaper equipment so more agencies can afford it and water gets tested more often in places that have ignored water quality conditions for lack of affordable equipment? The dedicated pollution control people of the MWPAAC committee have been informed of your efforts to change the rule to support certain special interest groups. My concern is not that there is a source of pollution that needs to be regulated, but to put the cost of unnecessary regulation onto the ratepayers connected to the cleanest treatment in the state, the country even, will put the cost out of reach for some people still connected to septic systems. Failing septic systems in the suburbs are a definite hazard to humans. My district, Northshore Utility District, contracts with the King County Wastewater Treatment Division for sewage treatment along with the other 1.6 million residents in the Puget Sound region. I am a regularly attending member of the Metropolitan Water Pollution Abatement Advisory Committee (MWPAAC) monthly meetings that provides recommendations to the King County Executive and King County Council regarding water pollution abatement. MWPAAC???s membership includes 33 other local sewer agencies. Generally, the State has been helpful in supplying high water quality to the citizens, we don???t have the issues here of Flint, Michigan. But trying to put all water treatment into the same category isn???t reasonable, and way too costly. Because King County???s regional service area includes some parts with combined sewer systems, I am particularly interested in the language of the proposed rule as it relates to combined sewer overflow (CSO) treatment plants. The State is proposing to use narrative water quality standards and require a set of best practices specifically for these intermittent CSO treatment plants. These plants are critical investments that move us towards improved water quality. We support the State approach as it will ensure the intermittent need for treating and reducing the total number of these discharges will be protective of human health. The County???s long-term CSO control plan will be successful considering the very high cost of the occasional need for treatment. Please, making rules without actual need for them makes it that much harder for my district to connect those still on septic systems. We have almost 900 customers with sewer available who won???t pay to connect. Sincerely, Honorable Margaret Wiggins | [null, null, null, null]                                                                                                                                  | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | 
| 1461230268  | Clair Olivers              | WA Assoc. of Sewer and Water Districts   | See attached comment letter                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | [application/vnd.openxmlformats-officedocument.wordprocessingml.document, e02a9158-36e1-4906-8945-6f2320db0554, WASWD Comments on WQS 042116.docx, 90019] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | 
| 1461603738  | Kenneth M. Stone           | Washington State Dept. of Transportation | Please see attached comments.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | [application/pdf, 8b5982a4-85d9-4fed-9a16-5a335d985d21, HHC Comment Ltr 042216.pdf, 181669]                                                               | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] | [null, null, null, null] |