ASDWA Submits Comments on EPA’s Draft Recommendations for Addressing PFOA and PFOS in Groundwater

On June 10, ASDWA submitted comments on EPA’s Draft Interim Recommendations for Addressing Groundwater Contaminated with Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonate (PFOS). The comments make note of ASDWA’s previous comments to EPA on multiple PFAS topics and provide new suggestions for EPA that are both directly related to the recommendations in the document and also in the broader context of cleanup program efforts and in related guidance to:

  • Expand recommendations to include additional PFAS chemicals beyond PFOA and PFOS.
  • Provide the opportunity for state review of related EPA guidance.
  • Cite existing guidance or develop guidance for emergency orders issued under the Safe Drinking Water Act.
  • Develop guidance and undertake actions to address PFOA and PFOS in surface water.
  • Use combined concentration screening levels for PFOA or PFOS.
  • More directly reference that more stringent state levels should be followed where applicable.
  • Require sampling as soon as possible, especially near sources of drinking water.
  • Ensure that EPA has adequate capacity to reopen previous Records of Decisions.
  • Ensure existing remedies are appropriate and are not inadvertently redistributing contamination.
  • Re-assess the status of any closed Superfund sites near sources of drinking water.
  • Enable responsible parties and public water systems to be innovative in responding to PFAS contamination.

For more information, view the EPA Docket at For questions, contact Deirdre Mason of ASDWA at