Joint Response to Comments Related to 1,2,3-TCP MCL

  • Jul 14, 2017
  • Comment Letters

Agency:  State Water Resources Control Board

Subject: 1,2,3-Trichloropropane Maximum Contaminant Level (SBDDW-17-001) – Response to Comments

Letter excerpt:

The Association of California Water Agencies (“ACWA”) and the California-Nevada Section of the American Water Works Association (“CA-NV AWWA”) are concerned with a number of the responses issued by the State Water Resources Control Board (“Water Board”) in the DRAFT – Initial Response to Comments for Proposed 1,2,3-Trichloropropane (1,2,3-TCP) Maximum Contaminant Level (MCL) Regulations (“Response to Comments”). As stated in our April 19, 2017 joint comment letter, ACWA and CA-NV AWWA, with our respective member agencies and utilities, support the adoption of the proposed MCL for 1,2,3-TCP without further delay. The MCL will set a clear target for water agencies and utilities that will allow them to take the necessary steps towards meeting the MCL and continuing to protect public health. However, our associations remain extremely concerned that the regulations fail to include a sufficient time period for public water systems to implement measures to comply with the new MCL without being deemed in violation.

ACWA and CA-NV AWWA are concerned that the Response to Comments fails to acknowledge the processes that water agencies and utilities must use to comply with the proposed MCL and the impacts that will occur as a result of non-compliance. These impacts include increased costs to ratepayers without any improvement to public health and therefore are not in the public interest. We would like to address the following assertions from the Response to Comments in order to clarify the impacts that can be avoided simply by including a reasonable compliance period in the proposed regulation.

Download joint response letter

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3 RESOURCES
Joint Comments on Perchlorate Reporting

Submitted to the State Water Resources Control Board on June 29, 2017.

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