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AMWA Comments on EPA's Proposed Radon Rule

AMWA Comments on EPA’s Proposed Radon Rule 2/10/00 The Association of Metropolitan
Water Agencies (AMWA) is proposing an alternative approach to the EPA’s
proposed Radon Rule (64 FR 59246) which has the potential to reduce the risk of
radon exposure to a greater extent than what is currently being proposed. The
association suggests that by defining 4000 pCi/L as an MCL and 300 pCi/L as an
Action Level, water systems would be encouraged to participate in a Multimedia
Mitigation (MMM) program, an approach both EPA and the National Academy of Sciences
say will reduce risk the most.

According to EPA’s proposed rule, their preference is for water systems
to participate in a MMM program to reduce exposure from indoor air. But the
way the proposed rule is written, it provides a disincentive for systems to
participate in MMM programs by giving the impression that water systems are
seeking to avoid the seemingly safer MCL. In other words, risk communication
challenges presented by the proposed rule could undermine EPA’s objective
of reducing radon from indoor air.

AMWA’s Recommendations for EPA Proposed Radon Rule AMWA made three major
suggestions in their comments to EPA on the Proposed Radon Rule: adopt an alternative
regulatory framework proposed by AMWA; simplify the Multimedia Mitigation (MMM)
program concept to ensure state-sponsored programs; and develop guidance and
other technical assistance to implement the final rule.

Alternative Regulatory Framework In the proposed rule, water systems may choose
to comply with one of two regulatory options: (1) a Maximum Contaminant Level
(MCL) of 300 pCi/L or (2) an Alternative MCL (AMCL) of 4,000 pCi/L for systems
that would participate in a MMM program. The use of two separate standards presents
water systems with serious risk communication challenges.

Specifically, if a system chose to participate in a MMM program and thus comply
with the 4,000 pCi/L AMCL, it could be perceived as violating the seemingly
safer MCL.

To eliminate this risk, AMWA offers an alternative framework in which the MCL
would be 4,000 pCi/L, and 300 pCi/L (or the number EPA chooses in the final
rule) would be called an Action Level. Systems choosing to participate in a
MMM program would comply with the MCL of 4,000 pCi/L. Systems that choose to
control radon through water treatment alone would be subject to the Action Level.

With this approach, the perception that a water system is choosing to avoid
compliance with the MCL disappears.

Simplify MMM Program Concept AMWA suggests that EPA review the proposed rule
for opportunities to simplify the current MMM program concept to find ways to
encourage state-sponsored MMM programs.

This would eliminate the need for water systems to develop such programs on
their own.

EPA Guidance and Technical Assistance for Final Rule AMWA stresses the need
for EPA guidance and technical assistance materials to support the implementation
of the final rule.

The association suggests that EPA provide sufficient resources and public review
for the development of all guidance and technical assistance materials.

For more information, contact AMWA at 1717 K Street NW, Suite 801, Washington,
DC 20036, phone 202-331-2820; fax 202-785-1845, or visit their website at amwa-water.org.

Edited by Tracy Fabre from information provided by AMWA.


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