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ASDWA Submits CCL 5 Comments

Today, ASDWA submitted its comments on the draft fifth Contaminant Candidate List (CCL 5). ASDWA included the following in its comments:

The CCL Process

  • ASDWA emphasizes its support of the regulatory development process outlined in the 1996 Safe Drinking Water Act (SDWA) amendments, including the CCL, the Unregulated Contaminant Monitoring Rule (UCMR), Regulatory Determination, and Six Year Review, which is vastly preferable to regulating based on arbitrary target numbers or focusing on contaminants with high media profiles.
  • ASDWA expresses concern with the Agency’s approach for UCMR 5, specifically that the final UCMR 5 did not include many contaminants identified in CCL 4 where national occurrence data is needed.
  • ASDWA recommends that EPA provide further details on why contaminants from CCL 4 were not also listed on CCL 5 when no regulatory determination was made.

Moving Forward with Regulatory Determinations

  • ASDWA encourages EPA to make a regulatory determination for any CCL contaminants with adequate data, specifically the 23 on CCL 5 that have nationally representative finished water occurrence data and qualifying health assessments.
  • ASDWA emphasizes that the CCL is not intended to be a permanent home for contaminants.

Contaminant Groups

  • ASDWA supports contaminant grouping but requests clarity on how groups of contaminants will be treated for Regulatory Determinations and UCMR selection as well as how contaminants within the groups will be prioritized for research.
  • ASDWA recommends that EPA reevaluate the definition of PFAS used in CCL 5 to be more inclusive of structurally different PFAS.

ASDWA also included comments on contaminants listed on the Draft CCL 5 that are a particular concern for state drinking water programs. These contaminants included: manganese, 1,4-dioxane, PFAS, DBPs, Legionella, and cyanotoxins. To view ASDWA’s full comments, click here.