The U.S. Environmental Protection Agency proposed on March 29, 2021 a National Primary Drinking Water Regulation and health-based maximum contaminant level goals (MCLGs) for regulating specific per- and polyfluoroalkyl substances (PFAS): perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as contaminants with MCLs of 4.0 ppt (parts per trillion) and perfluorohexane sulfonic acid (PFHxS); hexafluoropropylene oxide dimer acid (HFPO-DA) and its ammonium salt (also known as GenX chemicals); perfluorononanoic acid (PFNA) and perfluorobutane sulfonic acid (PFBS); and mixtures of these PFAS as contaminants with hazard indicies under the Safe Drinking Water Act. In addition to being standards for drinking water quality, MCLs also are applied in remediating contaminated groundwater.
NGWA’s comments in March stated: “If achievable, the maximum contaminant levels proposed should be very protective of the public. Groundwater-supplied community water systems, typically serving small communities, are most impacted in incidence and in concentration for PFAS found previously.
“There are proven technologies to remove PFAS to below the limits proposed, but designing, procuring, and constructing treatment takes time and money. The EPA should direct research to support technologies that can be applied to small water systems and individual residences in the cases of applying alternative treatment technology. The EPA should provide time in implementation for National Sanitation Foundation (NSF) and American National Standards Institute (ANSI) testing and standards processes to catch up with regulatory health protection requirements. Third-party certified products protect the consumer. NGWA sees this proposed regulation as a significant step in the EPA addressing public health protection from PFAS in water and the environment.”
Additionally, NGWA commented on concerns about sufficient laboratory capacity and correctly accounting for nondetects above the health-based water concentration when reporting averages.
Click here to read NGWA’s comments.
NGWA has long been a leader in PFAS research, publishing one of the first practical PFAS guidance documents and regularly producing resources on the impacts of PFAS in groundwater.