DEQ-CFW_00010110

From: Moore, Sandra [/O=NCMAIL/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDI BOHF23SPDLT)/CN=RECI P1 ENTS/CN=SAN DRA. MOORE]
Sent: 5/2/2012 7:15:23 PM
To: Moore, Sandra [/o=NCMAIL/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=sandra.moore]
Subject: FW: PFOA Interim Maximum Allowable Concentration
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,,goar
[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: Moore, Sandra
Sent: Tuesday, 3anuary 18, 20113:28 PM
To: Reid, Dianne
Cc: Moore, Sandra; Brower, Connie
Subject: PFOA Interim Maximum Allowable Concentration
Dianne,
Here's a draft email. We should get Connie's input on the recommendations before we send something up to
Coleen. I have requested input from the DPH and DWM but have not heard anything as yet.
Coleen,
As you recall, the NC Science Advisory Board on Air Toxics (NCSAB) recommended in a letter to you that
DWQ take action to reduce the current PFOA IMAC from 2 ug/l to I ug/L. The NCSAB recommendation is
based on information from their May 2010 draft PFCA, risk assessment. Note that a copy of this risk
assessment was not submitted with their December 10, 2010 recommendation and it is not available on their
web site.
The NCSAB 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 to you in the
Spring, 2011.
In regard to the current PFOA [MAC, the CSU recommends one of the following approaches:
Leave the current PFOA [MAC in place until the NCSAB releases their final recommendation in the Spring. We
don't see a need to change the standard from 2 ppb to I ppb if a recommendation based on new science is coming out
in the near future.
2. Change the current PFOA IMAC to the EPA Drinking Water Provisional Health Advisory concentration of 0.4 ug/L.
While it is a provisional concentration, it is currently used by EPA and other states as a health -based drinking water
remediation goal. In addition, the EPA DW Health Advisories are one of the resources used when establishing
groundwater standards (2L .0202 (e)(2)). Also, Dr. Ken Rudo, a State Toxicologist with the Division of Public
Health, has stated that the PFOA IMAC should be 0.4 ug/L or lower.
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Please let us know what action you would like for us to take in regard to the PFOA IMAC and we will begin the
process as soon as possible.
Below is the basis of the EPA Drinking Water Provisional Health Advisory along with PFOA target
concentrations used by other states.
EPA Drinking Water Provisional Health Advisory is 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.
htt.1)://wat.er.epa.gov/action/advisories/diinking/tiploa.d/2009 01 15 criteria. drinking Pha-PFOA PFOS.pdf
Minnesota has a chronic non -cancer health risk limit of 0.3 ug/L.
http://www.health.state.mn.iis/d.ivs/eh/risk/ guidance/ gw/pf6a.pdf
In 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
State Water Quality Standards Co -coordinator
Division of Water Quality
NC Department of Environment and Natural Resources
1617 Mail Service Center ,, Raleigh, NC27699-1617
IU11110101" 1 4
Note: E-mail correspondence to and frorn this oddress fnay be subject to the North Carolino Public Records Low and may be disclosed
to third parties.
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