G. Tracy Mehan III, executive director for government affairs at the American Water Works Association,just sent me a copy of a 23-page letter that AWWA sent to EPA's Office of Ground Water and Drinking Water. I've posted the entire letter below but will just list AWWA's 10 recommendations regarding PFAS below the PDF.
Download 05 21 2020 AWWA Comments on Regulatory Determinations for Contaminants on the 4th DW CCL
EPA’s objective is to finalize these preliminary determinations in less than eight months. With that short administrative timeline in mind AWWA offers the following specific recommendations relating to PFAS:
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EPA should move forward to develop primary standards for perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) expeditiously but not without undertaking the analyses required to ensure that the resulting regulations are sound.
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EPA has a responsibility to evaluate PFAS other than PFOA and PFOS efficiently and in a timely manner. Doing so will require applying the adequate resources to collect the necessary data and undertake the requisite analyses to prepare a sound regulation.
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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.
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Currently the absence of timely health risk assessments prevents EPA from preparing the necessary analyses to support sound regulatory determinations and drinking water standards for PFAS for which EPA already has occurrence data.
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The Agency must address outstanding data and knowledge gaps regarding PFAS of concern prior to determining a regulatory grouping approach for PFAS.
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If EPA develops standards for PFOA and PFOS, EPA should adapt the Standardized Monitoring Framework for synthetic organic chemicals to PFAS by using one-half the MCL as the trigger level for quarterly monitoring
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7. EPA should go beyond typical practice to engage an expert panel to develop a sciencebased evaluation of the state of available PFAS health risk data.
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EPA’s proposed negative regulatory determinations for 1,1-dichloroethane, Acetochlor, Metolachlor, methyl bromide, nitrobenzene, Royal Demolition Explosive are appropriate.
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Continuing to collect data to support a regulatory determination for 1,4-dioxane, 1,2,3- trichloropropane, and strontium is appropriate at this time.
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EPA should collaborate with AWWA, the water system community and states to utilize available tools to manage manganese occurrence.
Enjoy!
“For decision making, data are always preferable to model output.” – Huggett’s Rule
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