![]() There has been much debate about whether the new criteria are attainable, with the adjustment of the excess cancer risk being driven by the concerns of industrial and municipal dischargers. Finally, when this adjustment to the excess cancer risk results in an increase to an individual numeric criterion as compared to the old NTR criterion, Governor Inslee is proposing to retain the older, lower, numeric criterion. ![]() Had the Governor gone beyond the one in one hundred thousand risk level, EPA policies may have required more robust consideration of the public interest (although it appears the Governor has deeply considered many aspects of the public interest) and EPA policies also require more robust quantification of the actual risk level because of the decreasing amount of conservatism built into higher risk levels. The native tribes in Washington are not enthusiastic about this change, nor is EPA Regional Administrator Dennis McLerran, although the adjustment in excess cancer risk is consistent with EPA’s Clean Water Act regulations and guidance. This is a concept that has emerged over the past year as a work-around to the exceedingly low (and often unattainable) numeric criteria that result from the ~30 fold increase in fish consumption rate. Governor Inslee is proposing to adjust the acceptable excess cancer risk level from one in a million to one in one hundred thousand, with the potential to offset the impact that the much higher fish consumption rate has on numeric criteria for toxics. The most controversial part of his plan has to do with the acceptable cancer risk used in calculating the new criteria. What is also not surprising is the proposal to use the federal drinking water standard for arsenic instead of the current standard, which is below background because of high levels of naturally occurring arsenic in Washington’s waters. This adjustment has been coming for some time, so the new 175 gram per day number isn’t surprising. ![]() Governor Inslee proposes to adjust the fish consumption rate (used to calculate water quality criteria for toxics) from 6.5 grams a day (the default in the National Toxics Rule, the current applicable water quality standards for toxics in Washington) to 175 grams per day. The Governor’s proposed approach is consistent with what we’ve been hearing from Ecology and other sources over the past few months. The video of the press conference is here, my summary and thoughts follow: This has been a long time coming, and is a significant development on what is arguably the most important environmental rulemaking effort Washington has seen in years. Governor Inslee held a press conference yesterday morning, where he presented his policy brief on Washington’s ongoing efforts to update its water quality standards to account for higher fish consumption rates.
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