Summary of EPA’s 03/29/2023 Presentation: Drinking Water Professional Community Webinar on the Proposed PFAS (Perfluoralkyl Substances) National Primary Drinking Water Regulation (NPDWR)
EPA provided an overview of the proposed PFAS NPDWR as well as a description of the analysis leading to the proposal and anticipated compliance costs. The proposed rule was officially published in the Federal Register March 29, 2023, thereby initiating the required 60 day comment period on the proposal. The comment period closes on May 30, 2023. Supporting docs, as well as a recording of the webinar are available on EPAs website.
The proposed regulation focuses on two PFAS (PFOA and PFOS) that will be monitored individually, and a group of four additional PFAS that will be monitored and controlled as a group. These four compounds include PFBS, PFHxS, PFNA, and HFPO (aka Gen X).
If finalized in the current form, the proposed regulation will require public water utilities to:
Monitor water supplies for specific PFAS
Notify the public within 30 days if the proposed standard is exceeded
Reduce the levels of PFAS in the public water supply if tnecessary
Citing peer-reviewed toxicology, clinical and epidemiological data, the EPA noted that “the science is clear” on the “significant health effects” associated with PFAS compounds as the motivation for the proposed limits. EPA specifically called out PFAS-related health risks including issues related to pregnancy (both to the pregnant person and to the fetus), weakening of the immune system, increased risk of cancer (e.g. kidney, liver, pancreatic) and increased cholesterol levels leading to increased risk of heart attacks and strokes.
In recognizing PFOA and PFOS as likely carcinogens, EPA suggests a Maximum Contaminant Level Goal of 0. However, citing technological limits in monitoring, the Maximum Contaminant Level for PFOA and PFOS in drinking water is proposed at 4 parts per trillion. The additional four PFAS included in the rule will be measured individually, and adjusted for their relative toxicity before being added together as a “Health Index”. Drinking water samples must have a Health Index of less than 1 with respect to the sum of the 4 PFAS to be considered safe. It is not necessary for all four of the PFAS to be present to exceed the Health Index; the HI may be exceeded when drinking water has one, two, three or all four compounds present.
The EPA reminded viewers that PFAS-contaminated drinking water is not the fault of communities or local water authorities, but rather it is the fault of “upstream” industrial polluters. Additional components of the PFAS Drinking Water road map are designed to specifically address and mitigate the damage caused by the industrial polluters.
EPA also reiterated that $9 Billion dollars is available via the Bipartisan Infrastructure Law to help communities address costs associated with monitoring and treating PFAS-contaminated water. The four water treatment technologies EPA used in their analysis include granular activated carbon (GAC), Anion Exchange, Nanofiltration, and Reverse Osmosis. All technologies are >99% effective at removing PFAS compounds targeted by this proposal; all have on-going maintenance costs. In the cost/benefit analysis, EPA modeled costs associated with installing and maintaining each of these systems. EPA estimates that 3,400-6,300 water treatment facilities in the US will fail the PFAS specification as currently proposed and thus require additional investment in treatment.
EPA will host a public hearing on the proposed rule on May 4th, 2023 and expects to finalize a PFAS proposal by the end of 2023. Details about the proposed rule, including how it was developed and what research was evaluated is available on EPA’s website: https://www.epa.gov/pfas
