MassDEP Hears Testimony on Regulation of PFAS

In response to a 2018.10.28 CLF MA_PFAS_Petitionby the Conservation Law Foundation and the Toxics Action Center, the Massachusetts Department of Environmental Protection held a January 16, 2019 public hearing to receive testimony from stakeholders and interested parties on moving forward with regulations for per and polyfluoroalkly substances (PFAS). Currently Massachusetts has an Office of Research and Standards Goal level of 70 parts per trillion for 5 PFAS compounds. This includes perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), perfluorononanoic acid (PFNA), perfluorohexanesulfonic acid (PFHxS), and perfluoroheptanoic acid (PFHpA). CLF and Toxics Action Center petitioned MassDEP to adopt a treatment technique drinking water standard for the PFAS class of chemicals in lieu of setting a maximum contaminant level (MCL) for specific PFAS compounds. The Massachusetts Water Works Association has provided testimony in favor of deferring to the robust and transparent EPA process of setting the MCLs for PFAS compounds. Notwithstanding this position, if MassDEP does move forward with promulgation of regulations for PFAS compounds, the MWWA and this association believe that the MCL process is most appropriate. Establishing an MCL for PFAS as a class based on the best available, peer-reviewed science should be achievable. Such science would consider the multiple pathways of exposure, and make a well-founded determination as to the contribution from drinking water. Robust research on human toxicology using the best science is needed. In addition, sampling protocols should be developed to prevent cross-contamination at the extremely small concentrations that are be detected.

As PFAS compounds are numerous and well-established in the environment, source control including groundwater discharge limits equivalent to drinking water limits, and site contamination detection and cleanup will be an important part of the overall solution.

Respectfully,

Thomas C. Sexton, PE
Legislative Chairman, PCWWA

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