DEQ-CFW_00004180

Mr. Jeff Brand
Henderson, N.C. 27536
Dear Mr. Brand,
Thank you for your letter expressing your concerns about the recommendations for statewide
groundwater quality standards for perOuorooctanoicacid in North Carolina. The governor's staff has
asked that | reply onher behalf.
North Carolina state agencies began evaluating the need for groundwater water quality standards for
ammonium perfluorooctanoate (APFO), commonly called perfluorooctanoic acid, PFOA or C-8 when
DuPont De Nemours-Fayetteville facility began manufacturing the compound in 2002. In accordance
with an agreement with the US Environmental Protection Agency, DuPont installed and sampled 39
temporary and permanent monitoring wells with initial samples collected in 2002.
At this time, and in light of the growing public concern over perfluorinated compounds, state Division of
Water Quality staff, began consultation with the Division of Waste Management and the state
Department of Health and Human Services to develop a statewide groundwater standard. In 2006, a
statewide health based level for groundwater of 2 micrograms per liter (2 parts per billion) for PFOA was
developed using applicable state regulations and the published peer -reviewed toxicological data that
was available prior to December 2006. North Carolina is the first state to develop statewide standard
for PFOA.
As the current standard was being developed, the then -director for the Division of Water Quality
requested that the North Carolina Science Advisory Board assist DVVQin assessing the health risks
associated with PFOA. In May of this year, the N[ 5AB released a draft PFOA risk assessment for public
comment. This draft recommendation was a maximum allowable concentration for PFOA in
groundwater to be established in the range ofO.O'1.6 micrograms per liter as based on the available
published peer -reviewed data available prior to May 2010. In July, the NC SAB discussed a number of
new, yet unpublished, PFOAtoxicity studies that could impact their risk assessment results and
maximum allowable concentration recommendation.
When a final recommendation is made by the NC SAB or when USEPA releases toxicity information,
DVVQwill reevaluate PFOAand take into consideration the recommendation and any other peer -
reviewed toxicityinformabon available.
While there are site -specific conditionsxvhereheahhimpactshavevvanantedhea|dh|imhsforPF0Athat
are more stringent than North Carolina's current statewide standards or those drafted by the N[SAB, |
assure you that the process used by DVVQis consistent with state regulations. The process for
establishing standards is iterated in the North Carolina Administrative Code at 15A NCAC 2L .0202. For
OEQ-CFVV_00004180

more information on groundwater standards and our process to develop them, please visit the DVVQ
w/ebsiteat: http://portal.ncdenr.org/web/wq/ps/csu/gwstandards .Tu learn more about PFOA, please
visit the USEPAPFOAweb page at: http://xvvvxv.epa.8ov/oppdnt[/pfoa/.
I also invite you to add your name to our e-mail listserve for those who are interested in water quality
standards issues and rulemaking so that you will be notified of actions taken in those areas. To sign up,
please *end a blank e-mail to: DENR.DVVCLDVVO/u|es-join@|ists.ncmaiinet.
And lastly, thank you for your interest in preserving North Carolina's environment. | commend you for
your vigilance and appreciate your involvement in the process. I hope you will continue to offer your
input asvvework together toprotect our state'swater resources.
Susan Massengale
OEQ-CFVV_00004181