PFAS Safe Drinking Water Act: National Association of Clean Water Agencies Comments on U.S. Environmental Protection Agency Proposed Primary Drinking Water Standards | JD Supra

The National Association of Clean Water Agencies (NACWA) Comments on Proposed Safe Drinking Water Act (SDWA) National Primary Drinking Water Standards for PFAS

The National Association of Clean Water Agencies (NACWA) has submitted comments on the proposed Safe Drinking Water Act (SDWA) National Primary Drinking Water Standards for six PFAS (Per- and Polyfluoroalkyl Substances). The six PFAS included in the proposal are:

• Perfluorooctanoic acid (PFOA)
• Perfluorooctane sulfonic acid (PFOS)
• Perfluorononanoic acid (PFNA)
• Hexafluoropropylene oxide dimer acid (HFOP-DA)
• Perfluorohexane sulfonic acid (PFHxS)
• Perfluorobutane sulfonic acid (PFBS)

The proposal by the United States Environmental Protection Agency (EPA) was published on March 14th. The docket ID number for the proposal is EPA-HQ-0W-2022-0114.

PFAS are a group of man-made chemicals known for their resistance to heat, water, and oil. They are persistent in the environment and do not easily degrade. Potential human exposure to PFAS can occur through drinking water, air, or food.

The Safe Drinking Water Act and EPA’s Role

The Safe Drinking Water Act is a federal law that protects drinking water supplies. Under this law, the EPA is required to identify drinking water contaminants and develop rules to either set maximum permissible levels for the contaminants or establish treatment protocols to minimize their levels. Public water systems are required to comply with the primary (health-related) standards set by the EPA.

States can be delegated the authority to enforce their own requirements under the Safe Drinking Water Act. In Arkansas, the Arkansas Department of Health implements and operates the program.

NACWA’s Perspective

NACWA represents the interests of over 350 municipal clean water utilities, including dual systems that provide safe drinking water supplies and treat wastewater to high quality standards before discharging into surface waters. NACWA highlights that the proposed National Primary Drinking Water Regulation (NPDWR) will have an impact on wastewater and water recycling utilities regulated under the Clean Water Act. This includes utilities that discharge to surface waters designated as drinking water supplies or overlie groundwater used for drinking water. It also affects those involved in innovative water recycling and reuse projects that may need to comply with the SDWA’s Maximum Contaminant Levels.

NACWA’s comments request that the EPA consider the potential interactions between the NPDWR and Clean Water Act regulations, particularly regarding the increased PFAS monitoring requirements for clean water utilities while simultaneously imposing new PFAS monitoring requirements on public water systems.

Issues and Concerns Addressed by NACWA

• EPA’s development of ambient human health water quality standards based on doses for which no existing or affordable PFAS treatment techniques are available.
• Underestimation of cost impacts on public water systems.
• Failure to consider laboratory capacity, resulting in a backlog for monitoring and compliance by tens of thousands of public water systems and clean water utilities.
• Potential shortages of treatment equipment and carbon supply.
• Potential impacts on greenhouse gas emissions due to energy consumption at public water systems and clean water utilities.
• Impact on clean water utilities engaged in water reuse.
• Lack of readily available PFAS destruction technology and EPA’s reliance on treatment techniques without considering indirect impacts.

To read the full comments submitted by NACWA, click here.

SDGs, Targets, and Indicators in the Article

1. Which SDGs are addressed or connected to the issues highlighted in the article?

• SDG 6: Clean Water and Sanitation
• SDG 13: Climate Action
• SDG 15: Life on Land

2. What specific targets under those SDGs can be identified based on the article’s content?

• SDG 6.3: By 2030, improve water quality by reducing pollution, eliminating dumping and minimizing release of hazardous chemicals and materials.
• SDG 13.3: Improve education, awareness-raising, and human and institutional capacity on climate change mitigation, adaptation, impact reduction, and early warning.
• SDG 15.1: By 2020, ensure the conservation, restoration, and sustainable use of terrestrial and inland freshwater ecosystems and their services.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

Yes, the following indicators can be used to measure progress towards the identified targets:

• Indicator 6.3.2: Proportion of bodies of water with good ambient water quality.
• Indicator 13.3.1: Number of countries that have integrated mitigation, adaptation, impact reduction, and early warning measures into relevant policies, strategies, or planning.
• Indicator 15.1.1: Forest area as a proportion of total land area.

Table: SDGs, Targets, and Indicators

Behold! This splendid article springs forth from the wellspring of knowledge, shaped by a wondrous proprietary AI technology that delved into a vast ocean of data, illuminating the path towards the Sustainable Development Goals. Remember that all rights are reserved by SDG Investors LLC, empowering us to champion progress together.

Source: jdsupra.com

Join us, as fellow seekers of change, on a transformative journey at https://sdgtalks.ai/welcome, where you can become a member and actively contribute to shaping a brighter future.