NGWA’s Government Affairs submitted comments on October 23 to the U.S. Environmental Protection Agency on its Proposed High-Priority Substance Designations under the Toxic Substances Control Act (TSCA).
Three chemicals in this proposed action have the most direct relation to groundwater in their product use:
- Poly Acrylonitrile (PAN) is used in the manufacture of fibers for ultra filtration membranes and hollow fibers for reverse osmosis (RO) applications. RO is used for water treatment in both remediation and water supply to remove contaminants from water.
- Vinyl Chloride is used as a principal ingredient in the manufacture of polyvinyl chloride (PVC) pipe. PVC pipe is used extensively in groundwater production as well casing and screen and delivery of groundwater through water pipe lines.
- 4,4-methylene bis(2-chloroaniline) is used as a curing agent for polyurethane that has been used for environmentally friendly grouts used to contain groundwater contamination or preferentially control groundwater migration in sensitive areas.
NGWA asked that these uses be considered in the EPA’s risk assessment. Click here to read NGWA’s comments.