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�_tablishniert of Pt1CL5 at the Npect I�� �Is trat have Deen ShOti'✓n to <br /> ia:i5e no ao'der_, impact on human health) and nropo«o a primary MCL also at <br /> 5 aci/If' <br /> The EPA criteria document for chloroform mentions the amendment, at trat <br /> time proposed, to the National Interim Primary Drinking ';later P,eoulations <br /> which established the MCL for TTHiIS of 100pg/l. The criteria document <br /> states that 1t)his limit was set largely on the basis of technologic and <br /> economic feasibility." <br /> When ambient water containing natural organic matter, such as humic acids, is <br /> chlorinated for disinfection, trihalomethanes (THMs) are produced. There are <br /> other methods of disinfection for drinking water, such as ozonation and <br /> radiation, that do not produce THMs. However, the capital cost of converting <br /> the majority of the nation's water supply systems to these other methods is <br /> currently prohibitive. If the EPA was to establish an MCL for chloroform at <br /> the cancer risk level, the agency would, in essence, be mandating the <br /> conversion of disinfection systems at the local level. Under federal law, the <br /> federal government would have to provide a significant portion of the funding <br /> for this federally mandated local program. The same analysis applies to state <br /> standard setting for drinking water. Therefore, EPA and DHS are unable to <br /> promulgate a chloroform MCL that is not readily attainable with our current <br /> drinking water disinfection technology. <br /> The disinfection technology which causes the unintentional formation of <br /> by-products, that is, chloroform and other THMs, in finished drinking water <br /> serves a valid purpose— the reduction or elimination of the risk of infection <br /> from pathogens contained in raw water supplies. A treatment process is <br /> implemented to mitigate a potentially harmful condition. The MCL for TTHMs <br /> was derived by balancing the benefit of the elimination of pathogens in water <br /> against the potential harm caused by the resulting THM contaminants. In this <br /> balancing, EPA (and later DHS) made the determination that the risk of adverse <br /> health effects from THMs at 100 pg/l is more acceptable that the risk posed <br /> by pathogenic organisms. Thus, a concentration of THMs at the tap of up to <br /> 100 ug/1 will not result in an enforcement action by EPA or DHS against the <br /> water supplier. <br /> The same balancing of potential harm with benefit cannot be applied to a <br /> situation in which improper waste discharge practices of an individual permit <br /> chloroform, or any other contaminant, to enter ambient water. In this case, a <br /> potentially harmful condition is being caused by the inappropriate action of an <br />