- EPA’s preliminary determination is based on an HRL (Health Reference Level) of 70 ppt total combined concentration of PFOA and PFOS. This is the same as EPA’s current lifetime Health Advisory, which is non-enforceable. This suggests that the current 70 ppt Health Advisory level would be the most likely basis for an MCLG and NPDWR if EPA makes a positive determination.
- EPA relied on occurrence data primarily sourced from UCMR 3 sampling between 2013 and 2015. The median summed PFOA/PFOS concentration was 50 ppt. 1.37% of samples had detections of either or both compounds, and the summed concentrations exceeded the 70 ppt level at a minimum of 1.3% of public water systems (63 public water systems serving 5.6 million people, located in 25 states, tribal areas or territories). EPA also supplemented its UCMR data with data from states that have sampled for PFAS, including New Hampshire, Colorado, Michigan, and New Jersey. EPA noted that it is aware that additional states have conducted monitoring and specifically stated that it will consider any additional data submitted in response to its proposal to inform its regulatory decision. It also intends to include nationwide drinking water monitoring for PFAS in UCMR 5 (to be conducted in 2023-25).
- EPA signaled that it is seeking comment on treatment technologies for PFOA/PFOS, including cost analysis and effectiveness.
- EPA is developing a risk assessment for potential public health and ecological risks associated with PFOA and PFOS in land-applied biosolids;
- EPA is conducting a multi-industry study to determine which industries are most likely to discharge PFAS into the environment, including information about PFAS in discharges to surface waters from industrial sources that may be subject to future regulation, and included analyses of industrial sources and discharges of PFAS in its Preliminary Effluent Guidelines Plan 14;
- EPA is considering the development of water quality criteria for PFAS, by considering whether it has enough data to support the development of water quality criteria and scoping the development of draft human health and aquatic life criteria for PFOA and PFOS.
Ed Roggenkamp is a seasoned litigator focused on resolving complex environmental matters. Ed uses his skills as a former professional actor and teacher to help his clients win environmental cases, by explaining complex technical ...
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Willis Hon focuses on serving water industry clients across California on a broad range of administrative and regulatory matters. He has extensive experience before the California Public Utilities Commission where he has ...
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