May 26, 2020

AWWA Comments on EPA Regulatory Determinations for PFAS

The AWWA provided comments on the U.S. EPA’s “Preliminary Regulatory Determinations for Contaminants on the Fourth Drinking Water Contaminant Candidate List."

drinking water

The American Water Works Association (AWWA) recently provided comments on the U.S. EPA’s “Preliminary Regulatory Determinations for Contaminants on the Fourth Drinking Water Contaminant Candidate List."

According to a press release released by AWWA, the association supports the eight preliminary regulatory determinations included in EPA’s proposal. 

According to the EPA, the objective is to finalize these preliminary determinations in less than eight months. 

AWWA offered specific recommendations relating to per- and polyfluoroalkyl substances (PFAS), according to the press release, including: 

  1. EPA should move forward to develop primary standards for perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS).
  2. EPA has a responsibility to evaluate PFAS other than PFOA and PFOS in a timely manner. 
  3. EPA should supplement monitoring data from the Third Unregulated Contaminant Monitoring Rule (UCMR 3) with high quality occurrence data and per EPA policies control for any biases in the datasets when conducting its meta-analysis. 
  4. The absence of timely health risk assessments prevents EPA from preparing analyses to support regulatory determinations and drinking water standards for PFAS, for which EPA already has occurrence data. 
  5. The EPA must address outstanding data and knowledge gaps regarding PFAS before determining a regulatory grouping approach.
  6. If EPA develops standards for PFOA and PFOS, EPA should adapt the Standardized Monitoring Framework for synthetic organic chemicals to PFAS. This can be done by using one-half the MCL as the trigger level for quarterly monitoring. 
  7. EPA should engage an expert panel to develop a science-based evaluation of the state of available PFAS health risk data. 
  8. The proposed negative regulatory determinations for 1,1-dichloroethane, Acetochlor, Metolachlor, methyl bromide, nitrobenzene, Royal Demolition Explosive are appropriate. 
  9. Continuing to collect data to support a regulatory determination for 1,4-dioxane, 1,2,3- Trichloropropane and strontium is appropriate.
  10. Finally, the EPA should collaborate with AWWA, the water system community and states to manage manganese occurrence. 

Any other questions regarding this correspondence or if AWWA can be of assistance in some other way should be directed towards Chris Moody at 202.326.6127 or [email protected], concludes the press release.

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