April 23, 1999
Mr. Charles Fox
Assistant Administrator
Office of Water
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Subject: Radon Health Risk Reduction and Cost Analysis; Water Docket W- 98-30 (PDF File)
Dear Mr. Fox:
We are providing to the Environmental Protection Agency preliminary views on the agency’s Health Risk Reduction and Cost Analysis (HRRCA) for Radon. As you know, we participated with the agency as a member of the Small Business Advocacy Review Panel for radon last year, and advised the agency on the development of this HRRCA. This is the first HRRCA under the new Safe Drinking Water Act (SDWA) Amendments of 1996. The enclosed analysis by Austin Perez, a student at the UC Berkeley’s Goldman School of Public Public Policy, was written on behalf of this office, and incorporates our viewpoints regarding this rule.
The radon rule is very important to this office and the thousands of small water systems that may be affected by this rule. The SDWA requires an agency proposal to be issued in August of this year. We hope that the enclosed analysis and recommendations will aid the agency in the development of the Maximum Contaminant Level Goal (MCLG), and the Maximum Contaminant Level (MCL).
We have reached three preliminary conclusions, based on the information provided in the HRRCA and other information available to us:
(2) Using EPA’s own data, it is clear that it is more cost-effective to remediate radon in air rather than water, through multi-media mitigation (MMM) programs. The agency should make every effort to ensure that small systems have adequate resources to use such programs to meet the proposed standard (if states do not implement these programs for them).
(3) In the event EPA chooses an MCL that is below 4000 pCi/l, we recommend that the agency establish a simple "default" multi-media mitigation program (MMM). This will permit small systems to implement the less costly and more cost-beneficial MMM program, in lieu of implementing centralized water treatment plans.
Our conclusions are buttressed by several key findings. Using EPA figures, households in thousands of the smallest systems would each pay approximately $400/year or more to treat water in their systems for an expected benefit of only one lung cancer death avoided nationwide (assuming an MCL of 300 pCi/l). Stated in other terms, the household expenditure of 1.5% of the median national income would be used to avoid approximately one lung cancer death in the average smallest water system (25-100 persons served) every 500,000 years! (7,500 systems, over 70 years, 1 cancer death avoided). Under Executive Order 12866, and SDWA, EPA should act to avoid this substantial misallocation of resources, particularly in rural America. Such communities could otherwise use its resources better to remediate radon in the air, or to address other more significant health and environmental problems. EPA has the authority and the responsibility to designate a reasonable MCL, and permit small systems the flexibility of best addressing radon, without imposition of substantial and unnecessary costs.
We hope to continue our constructive and substantial working relationship with the agency in the development of the proposed rule. If you have any questions, please do not hesitate to call me, Kevin Bromberg, or my staff at 205-0964.
Sincerely,
Jere W. Glover
Chief Counsel for Advocacy