DEQ-CFW_00013882

From: Brower, Connie [/O=EXCHANGELABS/OU=EXCHANG[ADMINISTRATIVE GROUP
(FYD|BOHF2]SPDLT)/CN=REOP|ENTS/CN=7EE8DB84D95G431C9A1F78IF5597BA62-CUBROVV[R]
Sent: 8/14/I0I75:0I:54PW1
To: 6odeau,Jessica [/b=ExchanXeLabs/ou=ExchangeAdministrative Group
(FYD|8OHFZ33PDO)/cn=Redpient$cn=754d9%66f4]4455I9ef389242Oaa44eI-jcgodreau]
CC: Manning, Jeff [/o=ExchangeLabs/ou=EwchangeAdministrative Group
(FYD|8OHFZ33PDO)/cn=Redpient$cn=df%854abf83Z4d7IQcea45OI7aOIQ1Of-jpmanning]
Subject: RE: state standard setting
Imrn��t����that Iwwmuldsay that 0�Nisonly uhem�hdreview! They have mvery deMmedprocedure tmestablish HBV and HRLs. I must be unclear as to what you are seeking.
Their web page indicates -
Health -Based Values (HBVs) and Health Risk Limits (HRLs)
Health -Based Values (H8Vu) and Health Risk Limits (HRLs)are developed bytoxicologists atyWDHusing the best peer -
reviewed science and public health policies available at the time of their development. An HBV or HRL is the level of a
contaminant that can be present in water and pose |h1|e or no health risk to a person drinking that water. H8Vs and
HRLs are developed to protect sensitive or highly exposed populations. HBVs and HRLs are guidance used bythe public,
risk managers, and other stakeholders to make decisions about managing the health risks of contaminants in
groundwater and drinking water. HRLs are guidance values that have been through the Minnesota rulemaking process,
HBVs and HRLs are based only on potential health impacts and do not consider costand technology ofprevention
and/or treatment and may be set at levels that are costly, challenging, or impossible for a water system to meet.
What is confusing (to me) is exacfly how they use them based upon those "guidance" words,
All guidance values (HRLs, Health -Based Values, and Risk Assessment Advice) are available to state programs. Some state
regulatory programs may be restricted to using HRLs or prefer to use HRLs because the values are promulgated into rule.
MDH guidance is only one of many considerations that risk management programs use to determine appropriate
responses to contamination issues. In particular, site specific situations may raise questions for the risk manager
regarding which value to apply. Knowing the reason why a newer value was developed or knowing the populations at
particular risk and how each value protects those populations may be an important consideration for choosing one value
over another. While the selection and use of values is the responsibility of programs that are applying MDH rules and
guidance, MDH staff are available for consultation concerning the basis and potential use of MDH values.
If you need assistance with writing up other states ground water programs — we may already have it availabie.
From: Godreau, Jessica
Sent: Monday, August 14,Z0171:O3PK4
To: Brower, Connie <conniebroxver@ncdenr.8ov>
Subject: RE: state standard setting
| just finished New Jersey and think | need tolook atCalifornia next. |fMNiuonly ahealth data/process review, |may
just rely onyour thoughts. |amnot familiar with the types ofevaluations you read.
OEQ-CFVV_00013882

Jessica CQmdreau
Chief, Public Water Supply Section
Division ofWater Resources
Department ofEnvironmental Quality
9197079078 office
9197079100 mainnumb*r
1G34Mail Service Center
Raleigh WC27GQQ4G34
512 W Salisbury St, Ra|ok]h. NC278D4
£oa
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Sent: Monday, August 14,2D1712x47PK4
To: Godreau,Jessica
Cc: Manning, Jeff
Subject: RE: state standard setting
Well —the differences that I noted (which are certainly not a full list) would automatically derive different numbers
(some higher and some lower)
o Non -carcinogens:
• Established multiple intake rates and multiple exposure durations using numerous reasons NC
does not currently have those provisions
• wider ability to alter the default parameters and formulas for non -carcinogens
• where evidence of carcinogenicity was uncertain (probable; possible) they add a 10 X UF
o Carcinogens:
� establishes that the department must use EPA published Cancer slope factors (it does not seem
toallow any divergence)
N[has the ability touse other sources
It appears that MN uses a 1 in a 100,000 risk for cancer ( we use 1 in a million risk
for NC)
MN applies an age dependent cancer potency adjustment to linear carcinogens for
three separate age ranges — we have language about sensitive sub -populations but
not specific default ranges.
Bottom line — this piece of work is a great example of a very detailed and transparent derivation of Health
Advisories. It would take me a while to understand the ramifications of the difference*. Each of the differences noted
would/could require rule -making for us to adopt their applications into water quality standards. | note that this
document appears to be a work in progress that also is modified by rule -making in MN. |amless clear (right now) about
how the values are used by the state. Several pages appear to be specific to groundwater and the need to abate
pollution —othersdo refer to drinking water evaluations ? | will continue to read through it—areyou reading through it
to determine the differences in currently established drinking water standards?
INGITAWEI
From: Godreau, Jessica
Sent: Monday, August 14,Z0171J:18PM
To: Brower, Connie
OEQ-CFVV_00013883

Cc: Manning, Jeff
Subject: RE: state standard setting
Linda Csaid that the K8Nmodel was being looked atpossible for N[tofollow. I'm not seeing much | would call amodel,
just that the state setshealth advisory levels.
I am wanting to know if the process they follow would yield the same result that we would get in setting GW
standards. If we already look at health -effects data the same way, and would choose the same health -based level, then
w/eneed toknow. If we don't, we need to understand the differences so we understand what using their model would
mean.
I haven't been given a deadline, but am struggling to put relevant information into the hands of the policy -makers as
soon as I have it so we don't take off somewhere we don't want to be.
Let me know if you need more clarity.
thanks
Jessica CQmdreau
Chief, Public Water Supply Gondon
Division ofWater Resources
Department ofEnvironmental Quality
9197079078 office
9197079100 mainnumb*r
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From: Brower, Connie
Sent: Monday, August 14,Z0171J:O7PM
To: Godreau,Jessica
Cc: Manning, Jeff
Subject: RE: state standard setting
Jessica —
This document isquite lengthy —| will need abit more time.
Is there a particular item or subject we are looking for?
A few quickly observed notes:
* It appears that these values are for groundwater —and not necessarily for finished drinking water.
* Need todetermine what they may use for drinking water?
* It appears to have several commonalities with our GW procedures — including a value that resembles our
0 A few differences:
o Established multiple intake rates and multiple exposure durations using numerous reasons
OEQ-CFVV_00013884

o wider ability to alter the default parameters and formulas for non -carcinogens
o where evidence of carcinogenicity was uncertain (probable; possible) they add a 10 X UF
o establishes that the department must use EPA published Cancer slope factors (it does not seem to allow
any divergence)
o itappears that MINI uses a1ina1OD,OOUrisk for cancer
o MN applies an age dependent cancer potency adjustment to linear carcinogens for three separate age
ranges -
PS — just so we are clear — GW derivation in NC is based upon "pure -health", too. The stakeholders and the EMC
however, may suggest modifications to adjust based on costs or technical issues. OR — in the case of 1,1 DCE — the EPA
has reason tomodify anK8CL—but, has not chosen todoso.
Let me know what to focus my search on —
'Wei Tllm-
Fronm:Gudrea4]essica
Sent: Friday, August 11, 2017355 PM
To: Brower, Connie
Subject: FVV:state standard setting
Importance: High
Can you take a quick look at the process Minnesota Dept of health uses for setting health -risk limits and health based
values? This link may bemore onpoint than the links below.
Is this pretty much what you do in setting a GW standard, and if not, how is it different?
Linda [ mentioned that the administration was considering the K8Nmodel. They use apure health -based level asa
health advisory, not a regulatory level.
Jessica C Gudreau
Chief, Public Water Supply Section
Division ofWater Resources
Department ofEnvironmental Quality
9197079078 nffioa
9197079100 mainnumber
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Fromn:B|in8boe Randy(MDH)
Sent: Monday, August 07, 2017 10:53 AM
OEQ-CFVV_00013885

To: Godrea4Jessica
Subject: RE: state standard setting
Thanks, Jessica. Weare considering how tohandle the economic aspect but have a long way togo, Good|uck—I will be
curious Szsee what you develop.
Randy EUingbme,PE
Manager I Drinking Water Protection
Minnesota Department of Health
Qffice:651'ZD2-4G47 |
From: Godrea4Jessica
Sent: Friday, August4, 20174:56 PM
To: 8|ingboe,Randy (K4DH)
Subject: RE: state standard setting
We have staff in our health department that like to develop purely standards, but it is the technical and economic
review | am looking for atthis point. | will look atwhat you've sent and will circle back if | have questions.
I greatly appreciate your help.
Have a great weekend!
Jessica C Godreau
Chief, Public Water Supply Section
Division ofWater Resources
Department ofEnvironmental Quality
9197079078 office
9197079100 meinnumber
Jessica. God reau (a)
1S34Mail Service Center
Raleigh NCJ7GAQ-1S34
512 N Salisbury St, Re|oiQh, NC27GO4
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Fnmrn:B|in8boe Randy(MDH)
Sent: Wednesday, August D2,2U173:S8PIVI
OEQ-CFVV_00013886

Cc: darrin.polhem [e-mail]; june <swallow@health. ri.gov>; Diane Zalaskus <[e-mail]>;
Bridget O'Grady <bo rad asdwa.or >; Darrell Osterhoudt <dosterhoudt asdwa.or >; Deirdre Mason
<[e-mail]>; Roberson, Alan <[e-mail]>
Subject: RE: state standard setting
Jessica,
Minnesota develops what we call Health Risk Limits and Health Based Values for contaminants in groundwater, that are
often used in a way similar to EPA Health Advisories for drinking water. No economic considerations come into play in
development of these numbers. There is more information on these
at htt : www.health.state.mn.us diva eh risk uidance hrit e.htmi and the table of values is at
htt : www.health.state.mn.us divs eh risk uidance w table.htmi
If you would like to discuss this program, I can direct you to the Section Manager who can provide a good overview of
their program.
Let me know if you have questions. Thanks.
Randy Ellingboe, PE
Manager I Drinking Water Protection
Minnesota Department of Health
Office: 651-201-4647 1
x
XX
From: DePeiza, Yvette (DEP)[mailto:[e-mail]]
Sent: Wednesday, August 2, 2017 1:22 PM
To: Godreau, Jessica <[e-mail]>
Cc: darrin. pol hem us waterboards.ca. ov; june <swallow health. ri. ov>; Diane Zalaskus <diane.zalaskus de .ni. ov>;
Bridget O'Grady <[e-mail]>; Darrell Osterhoudt <[e-mail]>; Deirdre Mason
<[e-mail]>; Ellingboe, Randy (MDH) <[e-mail]>; Roberson, Alan
<aroberson asdwa.or >
Subject: RE: state standard setting
Hi Jessica,
Damon provided the following information on the Mass regulation development:
"Although we modeled our development on EPA"s, we didn't have to comply with anything, besides our normal
regulatory promulgation processes (Chapter 30A -
https://malegislature.gov/Laws/GeneralLaws/Parti/Titielli/Chapter30A). We did an occurrence round of monitoring,
developed a health --based value (working with our scientific advisory committee) then adjusted it upward based on
taking into consideration the risk reduction benefit: provided by disinfection. Some of our information is stall on the web
at _http://www.mass.gov/eea/agencies/massdep/water/drinking/lead-and-other-contaminants-in-drinking-
water.html#14 and htt www.mass. ov eea a encies massde water drinkin erchlorate-information.htmi. This
includes the ORS toxicological profile and communications we sent to labs and PWSs.'"' Please contact: Damon at
[phone]if you have any questions.
Yvette
DEQ-CFW 00013887

From: Roberson, Alan [mailto:[e-mail]]
Sent: Wednesday, August 02, 2017 6:40 AM
To: Godreau, Jessica
Cc: [e-mail]; june; Diane Zalaskus; DePeiza, Yvette (DEP); Bridget O'Grady; Darrell
Osterhoudt; Deirdre Mason; Randy Ellingboe
Subject: Re: state standard setting
Jessica, good luck with the new regulatory effort and let me know if we (ASDWA) can do anything to assist -
it's going to be interesting to observe....
I know Massachusetts has their own standard for perchlorate so I have cc'ed Yvette on this email. I am pretty
sure that New Jersey has some of their own state -level standards so I have also cc'ed Diane on this email. 1 also
cc'ed Randy Ellingboe as I know he has a good toxicologist on staff that worked on their state -level PFOA and
PFOS health advisory numbers and might know something about GenX and the other short -chain PFCs.
California has taken cost into consideration in setting their own standards and I think I have the facts right but I
think a Court remanded their new hexavalent chromium standard as the court felt that the State didn't take those
considerations into account properly (which, of course, is always debatable).
Good luck and keep us posted. Alan
On Tue, Aug 1, 2017 at 6:57 PM, Godreau, Jessica <jessica.godreauLa)ncdenrgov> wrote:
Darrin and June,
Greetings from your counterpart in North Carolina.
North Carolina is considering whether to begin developing a process for setting our own standards ahead of
EPA, triggered particularly by the discovery of an unregulated perfluorinated compound, Gen X, developed as a
replacement for PFOA.
We have no history whatsoever in doing so, therefore, I am reaching out to the only two states I know have set
their own standards to gather what information I can about such a program: the resources needed, the kinds of
staff you need, and how you go about a standard -setting process (i.e., is it a purely health -based standard, or like
EPA to you try to look at a cost -benefit analysis and ability for meaningful risk reduction).
Do you have statutes or rules that lay out your standard development process? Is there staffing and budgetary
information you can share?
Please feel free to direct me to the appropriate staff person as appropriate.
DEQ-CFW-00013888

Thank you very much for timely information. Things are moving quickly....
Alan, are you aware of any other states that set their own standards?
Division of Water Resources
Department of Environmental Quality
4YALOYAPHIIIJEFREM117. ION 0411
Jessica. God reau Qncden r.go
1634 Mail Service Center
621PALN&M. rMImwmM:,M. MI NEWUMOV,
C
DEQ-CFW-00013889

J. Alan Roberson, P.E.
]-�-�Ccnglve Dir"%1,01*
Association of State Drinking Wager Administrators (A.SDWA)
140 1 Wilson Blvd. - Suites 1225
Arlington, VA'22209
Office, [phone]
DEQ-CFW-00013890