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ASDWA Comments on EPA Draft Recommended PFAS Aquatic Life Water Quality Criteria

ASDWA submitted comments this week on EPA’s Draft Recommended Aquatic Life Water Quality Criteria for PFOA and PFOS under the Clean Water Act (CWA). ASDWA’s comments support the development of these draft recommendations and broadly address the use of the CWA ambient water quality criteria (AWQC), as part of a holistic and coordinated lifecycle approach to assess, address, and remove PFAS or prevent PFAS from entering the environment (and drinking water sources). ASDWA’s comments recommend that EPA:

  • Consider additional PFAS beyond PFOA and PFOS;
  • Move forward with timely and additional CWA actions to develop human health criteria recommendations for water bodies used as drinking water sources; and
  • Develop associated guidance for addressing PFAS in National Pollutant Discharge Elimination System (NPDES) permits.

In addition, state efforts from Michigan and Colorado are provided as examples for the Agency to consider as it develops human health AWQC for PFAS based on the assumption that that drinking water utilities should only need to use standard treatment protocols to protect human health from contaminants in drinking water sources.

Read ASDWA’s comments here. For more information about the AWQC, visit the EPA website, view the regulations.gov docket, and read the EPA Fact Sheet.