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ASDWA Submits Comments on EPA’s Preliminary Fourth Regulatory Determinations

On Friday (4/17), ASDWA submitted comments on EPA’s Preliminary Fourth Regulatory Determinations. ASDWA supported EPA’s positive preliminary regulatory determinations for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). ASDWA also recommended that when finalizing this regulatory determination, EPA also include positive determinations for four additional long-chain PFAS compounds with PFOA and PFOS: Perfluoroonanoic acid (PFNA), Perfluorohexanesulfonic acid (PFHxS), Perfluoroheptanoic acid (PFHpA), and Perfluorodecanoic acid (PFDA).

ASDWA also recommended that EPA thoroughly consider state standards and guidelines with significantly lower PFAS levels than EPA’s Health Advisory Level (HAL) of 70 parts per trillion (ppt) for combined concentrations of PFOA and PFOS. At least eight states are moving forward with their own state standards or guidelines using significantly lower PFAS levels than EPA’s HAL, which will be in place well before EPA develops a final NPDWR.

ASDWA also supported EPA’s negative regulatory determinations for 1,1-Dichloroethane, Acetochlor, Methyl Bromide (Bromomethane), Metolachlor, Nitrobenzene, and RDX. ASDWA supported EPA’s conclusions that each of these contaminants does not present a meaningful opportunity for health risk reduction through a National Primary Drinking Water Regulation (NPDWR). ASDWA also provided two recommendations for EPA to consider for the final Fourth Regulatory Determination and for the Draft Fifth Contaminant Candidate List (CCL5). ASDWA’s detailed comments can be found below.

Final ASDWA RegDet4 Comments w Appendices 04172020