ASDWA Comments On EPA's Significant New Use Rules For Chemical Substances (PFAS).pdf

The Association of State Drinking Water Administrators (ASDWA) comments on the EPA's Significant New Use Rules for certain chemical substances. ASDWA emphasizes a holistic approach to managing per- and polyfluoroalkyl substances (PFAS), advocating for coordination across all EPA programs and federal agencies under TSCA. This includes considering drinking water treatment, disposal in wastewater, sludge, biosolids, landfills, leachate, and air emissions from incineration.

ASDWA urges the EPA to use its TSCA authority to restrict chemicals that could harm drinking water sources and public health throughout their lifecycle. They recommend closer coordination between the Office of Pollution Prevention and Toxics (OPPT) and the Office of Ground Water and Drinking Water (OGWDW) for better data on chemical risks.

ASDWA appreciates EPA's risk assessments but calls for more studies to characterize potential human and environmental health risks. Concerns are raised about chemicals in SNURs that may impact drinking water, recommending a deliberative process using sound science and stakeholder engagement to assess and restrict these substances' release into surface waters.

Specific concerns include:

1. PMN Number: P–18–151: Formaldehyde reaction products with 1,3-benzenedimethanamine and p-tert-butylphenol (CAS number: 158800-93-2). EPA's assessment indicates high drinking water Acute Dose Rate (ADR) and lifetime average daily dose (LADD), concerns for various toxicities, moderate migration to groundwater, partial removal by wastewater treatment, environmental persistence, low bioaccumulation potential, and high environmental hazard.

2. PMN Number: P-19-88: Ethanamine, N-ethyl-, 2-hydroxy-1,2,3-propanetricarboxylate (1:?). EPA estimates acute oral toxicity with a lethal dose (LD50) of 540 mg/kg-bw and requires further review for surface water concentrations exceeding 46 ppb.

3. PMN Number: P-19-109: Copper compounds (chemical A and B). Exposure assessed via groundwater impacted by landfill leaching, not drinking water or fish ingestion due to no expected releases to surface water. Further EPA review is required for surface water concentrations exceeding 3 ppb, with identified oral lowest-observed-adverse-effect level (LOAEL) of 50 mg/kg/day based on developmental toxicity.