Comments on Advance Notice on the Regulation of Perfluoroalkyl, Polyfluoroalkyl Substances (PFAS) as a Class

Comments
November 16, 2020

Joint NRDC comments with Conservation Law Foundation, Vermont Natural Resources Council, and others that outlines the scientific and technical information to support regulation of the PFAS class in drinking water and groundwater. To protect Vermont communities, the Agency should promulgate new rules for the PFAS class and establish a (1) maximum contaminant level goal (MCLG) of zero for the PFAS class; (2) combined maximum contaminant level (MCL) at the lowest, most health protective level technically achievable for the maximum number of quantifiable PFAS; and (3) treatment technique standard for the PFAS class based on total organic fluorine (TOF) as soon as an analytical method is validated by an international, federal, or state agency. With respect to the combined MCL, the Agency should require a pre-oxidation step in which perfluoroalkyl acids (PFAA) precursors are oxidized to terminal PFAAs before measuring individual PFAS to capture a more accurate accounting of PFAS in the public water supply.

Joint comments accompanied and supported by: Technical Comments of Anna Reade, PhD, Natural Resources Defense Council, and Katherine Pelch, PhD, University of North Texas Health Science Center to the Vermont Agency of Natural Resources Re the Advance Notice on the Regulation of Perfluoroalkyl, Polyfluoroalkyl Substances (PFAS) as a Class, November 2020