PFOA/PFOS Comments.pdf

The Association of State Drinking Water Administrators (ASDWA) comments on the EPA's "Draft Interim Recommendations for Addressing Groundwater Contaminated with PFOA and PFOS". ASDWA suggests EPA work with other federal agencies to assess, address, and remove PFAS from the environment, and recommends expanding investigations to include additional PFAS chemicals, providing state review of related EPA guidance, and developing guidance to address PFOA and PFOS in surface water. ASDWA also comments on screening levels and preliminary remediation goals, suggesting language be added to consider combined concentration screening levels and more stringent state levels. Additionally, ASDWA recommends requiring sampling for PFOA and PFOS at Superfund sites, ensuring adequate capacity to reopen Records of Decisions, and re-assessing closed Superfund sites near drinking water sources.