AWWA Letter to Radhika Fox: Comment on EPA's Drinking Water Contaminant Candidate List 5-Draft

Thanks to G. Tracy Mehan III, executive director for government affairs at the American Water Works Association, for sending me this letter he sent to Ms. Radhika Fox, EPA Assistant Administrator, Office of Water. The topic:

Comments on EPA Drinking Water Contaminant Candidate List 5-Draft Docket ID: EPA-HQ-OW-2018-0594

The cover letter is pasted below, and here is the PDF, which contains 11 pages of comments:

Download AWWA Comments on EPA Drinking Water Contaminant Candidate List 5 Draft

The cover letter:

From the comments here is the conclusion:

Enjoy!

"Education is a progressive discovery of our own ignorance." - Will Durant

Comments

[Joseph A. Cotruvo]

Re CCLs. They have historically been useless and a waste of paper. The last 2 had more than 112 listed chemicals and microbes. The vast majority had no potential for being drinking water regulations based upon toxicology and occurrence in drinking water--based upon EPA's own data which they apparently do not read. The most recent draft finally eliminate more than 60 of them---which means they should not have been on in the place. The only possible value of the CCLs is to highlight a short list of contaminants that have a reasonable reasonable potential to become regulated and guide researchers to produce additional data.
Joe Cotruvo (was director of EPA DW Standards division many many years ago.

[EJ Hanford, PhD.]

"The Draft CCL 5 includes 81 contaminants or groups (Exhibits 2a, 2b, and 2c). The list is comprised of 69 chemicals or chemical groups and 12 microbes. The 69 chemicals or chemical groups include 66 chemicals recommended for listing following an improved process to evaluate the PCCL, one group of cyanotoxins, one group of disinfection byproducts (DBPs), and one group of PFAS chemicals. The 12 microbes include 8 bacteria, 3 viruses, and 1 protozoa recommended for listing based on the scores for waterborne disease outbreaks, occurrence, health effects, and recommendations from various experts."

This list is indeed focused on three groups of chemical contaminants, along with a select number of microbes, that pose significant health risks amongst the multitude of drinking water contaminants that need to be addressed to ensure the safety of public water supplies.

The letter implies that the list is "not yet sufficiently focused" but does not begin to suggest how the current list could be more focused or prioritized.