DEQ-CFW_00009887

From: Moore, Sandra [SANDRA.MOORE]
Sent: 1/19/20115:11:23 PM
To: Ruclo, Ken [/O=NCMAIL/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDI BO H F23SPDLT)/CN =RECI PI ENTS/CN =KEN. RU DO]
Subject: RE: PFOA recommendation
Ken,
Thanks so much for your recommendation. I'll be in touch.
Sandra
State Water Quality Standards Co -coordinator
Division of Water Quality
NC Department of Environment and Natural Resources
1617 Mail Service Center, Raleigh, NC 27699-1617
Sandra. moore@?ncdenr.gov
[phone]
Note: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Low and may be disclosed
to third parties.
From: Rudo, Ken
Sent: Wednesday, 3anuary 19, 2011 10:57 AM
To: Moore, Sandra
Subject: FW: PFOA recommendation
Sandra I would recommend the EPA level of 0.4 ppb for the PFOA I MAC. The reasons you stated are in line with my
thoughts on this issue. I also believe that the EPA approach on this issue is more public health protective than the at this
time incomplete SAB assessment which has raised concerns in OEEB as well as in other states. Kenny
From: Moore, Sandra
Sent: Tuesday, 3anuary 18, 2011 10:46 AM
L. Rudo, Ken; Assefa, Hanna; Lilley, David; Wilcox, Betty
Cc: Moore, Sandra
Subject: PFOA recommendation
n
I am requesting your input on the PFOA Interim Maximum Allowable Concentration (IMAC). The DWQ received a
letter from the NC Science Advisory Board on Air Toxics (NCSAB) recommending that the DWQ take action to
reduce the PFOA (EVIAC) from 2 ug/L to I ug/L. The NCSAB's recommendation is based on information from
their draft PFOA risk assessment which has been removed from their web site and is no longer in the public
domain. A copy was not submitted along with their December 10, 2010 recommendation.
The SAB's letter also stated that publication of several papers that may be of significant interest in the risk
assessment will be published within the next month and that the NCSAB is committed to completing the PFOA
review as soon as it can after a review of the new publications, and should have a final recommendation in the Spring,
2011.
I am in the process of writing up my recommendation to DWQ management on the appropriate action to take given the
SAB's recommendation and I would like your input. Below are my two cents and I would love to hear what action you
believe would be appropriate at this time.
DEQ-CFW-00009887

1. Leave the current PFOA IMAC in place until SAB releases their final recommendation in the Spring. Why
change the standard from 2 ppb to I ppb if a recommendation based on new science is coming out in the spring?
2. If we decide to change the PFOA IMAC then it is more appropriate to change it to the EPA drinking water
provisional health advisory concentration of 0.4 ug/L. This is a level EPA is currently using to assess drinking
water. I believe that the use of new science to derive a groundwater IMAC would be more in line with this
concentration than the SAB ' ' s recommendation of I ppb.
Below is the basis of the EPA DW provisional health advisory and concentrations used by other states.
EPA Drinking Water Provisional Health Advisory — 0.4 ug/L . This is based on a short term (sub chronic
data) exposure scenario for a 10 kg child drinking I L per day and a RSC of
0.2. littp://www.epa.gov/Nvaterscience/criteiia/drinking/pha-PFOA PFOS.pdf
Minnesota chronic non -cancer health risk limit— 0.3 ug/L
http://www.health.state.mn.iis/d.ivs/eh/risk/ Lniidance/gw/pf6a.pdf
West Virginia, residents must be provided with alternative drinking water when PFOA levels exceed 0.4
parts per billion (ppb, or 0.4 pg/L). htti)://www.el)a.gov/r5water/gwdw/dupont/iiidex.htni
New Jersey has established a health -based drinking water guidance level of 0.04 ug/L intended to protect for
lifetime exposure, normally defined as 70 years. http://Nv-ww.state.ni.u.s/dep/dsr/pfoa doc.pd
Thanks so much for your thoughts and quick turn around on this. Don't hesitate to call with questions or to discuss.
Best regards,
Sandra
State Water Quality Standards Co -coordinator
Division of Water Quality
NC Department of Environment and Natural Resources
1617 Mail Service Center, Raleigh, NC 27699-1617
zT
[phone]
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DEQ-CFW-00009888