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Please submit the following comment to the U.S. Environmental Protection Agency (EPA) and sign the petition below.
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This is Clean Air Council's suggested comment:
I strongly support the proposed National Primary Drinking Water Regulation (NPDWR) to reduce polyfluoroalkyl substances (PFAS) and their mixtures: Perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), 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). The adverse health effects of per- and polyfluoroalkyl substances (PFAS), ranging from birth defects to cancer, have been clearly established in numerous studies. Unfortunately, these “forever” chemicals do not break down and are widely found in our environment, including in our drinking water.
I thank the U.S. Environmental Protection Agency (EPA) for its sound research and effort that generated the proposed NPDWR and for the opportunity to comment. The adverse health effects of these chemicals are well-documented, as discussed in the proposed NPDWR. These chemicals are frequently found in drinking water: For example, in Pennsylvania, a survey of drinking water systems conducted by the Department of Environmental Protection found PFAS in more than ¼ of the samples. Regulating them is essential for protecting public health.
For PFOA and PFOS, whose carcinogenic nature requires setting their Maximum Contaminant Level Goal at 0.0 parts per thousand (PPT), the proposed Maximum Contaminant Level (MCL) allowed in drinking water of 4 PPT is adequate to protect public health, reasonable, and feasible for both testing and treatment. PFHxS, HFPO-DA, PFNA, and PFBS have not been classified as carcinogens, but have been shown to affect health in a cumulative, additive manner. They often exist as mixtures in water, as found in the Pennsylvania drinking water sampling study where, for example, approximately 70% of samples containing PFNA also contained at least one other PFAS species that is not PFOA or PFOS. EPA effectively addresses this issue of “dose additivity” by setting a Health Based Water Concentration (HBWC) value for the level of each chemical, and a Hazard Index (HI) for the mix. The proposed values are adequate to protect health, reasonable, and achievable.
To maintain the efficacy of the proposed rule, I ask that EPA continue reviewing data regarding the health effects of these compounds, adjusting the MCLs and HBWC values and adding more chemicals to the regulations as new data becomes available.
Treatment of contaminated drinking water to achieve the proposed MCLs and HI is technically feasible for national implementation of the proposed PFAS regulations. However, the treatment processes produce waste that needs to be disposed of safely. This issue will become acute once the NPDWR is enacted due to the large quantities that will be produced.
I understand that developing safe disposal methods for the PFAS-infused waste produced by water treatment under the proposed rule is outside the scope of the NPDWR. However, while the proposed NPDWR is a crucial step to protecting human health and the environment from the significant harms caused by PFAS, to be ultimately effective, prevent the re-introduction of PFAS to groundwater and soil, and stop the release of toxic fluorinated emissions to air, EPA should expeditiously address the next step: Facilitating effective and safe disposal methods of the waste material from PFAS removal.
In sum, I firmly support the proposed NPDWR and look forward to seeing it implemented as a vital part of an overall strategy to protect public health from PFAS.
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