Comment Letter: ACWA Comments on Notification Levels for PFOA, PFOS

  • Jul 15, 2019
  • Comment Letters

Agency: State Water Resources Control Board, Division of Drinking Water

Subject: Notification Levels and Response Levels for PFOA and PFOS

Letter excerpt: 

Dear Mr. Polhemus:

The Association of California Water Agencies (ACWA) has been alerted that the State Water
Resources Control Board’s (State Water Board) Division of Drinking Water (DDW) plans to lower the Notification Levels and Response Levels for perfluorooctanoic acid (PFOA) and
perfluorooctanesulfonic acid (PFOS) as early as July 8. As you are aware, PFOA and PFOS are two contaminants in the per- and poly-fluoroalkyl substances (PFAS) family of synthetic chemicals that have recently received substantial and prominent public attention due to their potential impacts to public health through exposure in drinking water.

ACWA is concerned about the unintended consequences resulting from lowering the
Notification Levels and Response Levels and ensuring the public’s confidence in the safety and quality of our state’s drinking water sources. Many sites that currently test below the existing levels would test above the new levels. Although Response Levels are not regulatory per se, the public will expect water agencies to provide drinking water only below DDW’s established Response Levels since DDW recommends that water systems remove sources from service if contaminants are detected at concentrations above those levels. Providing drinking water above those levels would undermine the public’s confidence in the overall safety and quality of their drinking water supplies. Water systems would therefore be compelled to remove numerous wells – at least 30% or more for many impacted water systems – that, notwithstanding PFOA and PFOS, are in compliance of existing drinking water regulations.

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