DEQ-CFW_00058108

Summary of EPA -Convened Conference Call for State and Local Organizations
on Health Advisories for Perflourinated Compounds (PFCs)
May 19, 2016
• Today, EPA is releasing two lifetime Health Advisories (HAs) — one for PFOA and one
for PFOS. They supercede the provisional HAs from 2009.
• HAs are scientific and non -regulatory; over 200 have been issued by EPA over the years.
• EPA's intent, in releasing this information, is to provide the Agency's assessment of the
best available peer reviewed science about these compounds as well as associated
sampling and treatment information.
• The PFCs have historically been used widely in a lot of commercial and industrial
applications as well as in special applications, such as fire -fighting foams. While they've
largely been phased out in recent years, they tend to be persistent in both the environment
and in humans.
• Most people's largest exposure to the PFCs is likely to come through other, non -drinking
water pathways, but, drinking water can nonetheless be an exposure pathway of concern.
• Today's HAs contain a margin of protection and address sensitive life stages.
• Each HA is 0.07 ugll (70 ppt); and, because they have similar end points, they can be
compared individually against the 0.07 uglL levels or, if they co-occur, the can be added
and compared against that value.
• In the materials released today, EPA has provided some recommendations for state and
local officials to consider, in terms of risk management. If sampling shows concentrations
above the HAs, EPA recommends confirmatory sampling. If concentrations in follow up
samples are still above 0.07 uglL, EPA recommends that utilities provide public notice to
their customers and consult with state and local officials about potential next steps.
QUESTIONS & ANSWERS (Questions posed by State and Local Stakeholders and answered
by EPA staff)
Lab Capacity: Where can PWSs get their water tested for the PFCs; are there enough labs out
there that can handle the workload from 45,000 CWSs?
A number of labs can test for method 537 (for PFOA and PFOS) and EPA would be happy to
share the information about those certified labs. About 20 labs were on this list (developed by
EPA through the UCMR process). But, it's important to note that the advisories have the
standing of guidance. EPA is not requiring that all systems test for the PFCs.
Risk Communication in Light of Developmental Impacts: Given the
reproductive/developmental impacts, what are the implications for risk communications? Is
DEQ-CFW 00058108

there any recommended language, in the accompanying materials released today, for risk
communication?
The HA levels are supposed to be protective over a lifetime of exposure; but it's important to
recognize the impacts on the most vulnerable life states pregnant or lactating women. EPA
doesn't want to discourage breast-feeding; rather, they're just providing information to pregnant
and lactating mothers to suggest that they may want to consider alternative sources of water
during these critical time frames. In today's materials, this is no risk communication language,
as such, other than the general recommendations.
How to Deal with Non -Detects: If a sample result is non -detect (ND), how should that be
compared to the HAs (e.g., what happens if you have 69 ppt for one PFC and a non -detect for the
other — does the combined results exceed the 70 ppt limit?).
While states can and should consider their own approaches, EPA has, in the U011R, considered
NIA to be zero. So, in the example given, the aggregate sample result of the two PFCs would still
be 69 ppt.
Confirmatory Sampling: How much confirmation sampling is recommended?
EPA's recommendation wasn't intended to be prescriptive for a particular sampling regime.
States should consider site -specific circumstances when determining how many follow up
samples are appropriate.
Implications for Bottle Feeding: How — exactly — does the bottled feeding advice work in the
materials released today?
The advice is as follows: when a water source is above the HAs, parents who are bottle feeding
may wish to consider another source of water for mixing formula (or, pre -mixed formula). EPA
looked at exposure though both gestation and lactation not just one stage in isolation. But the
overall idea is to reduce the body burden of PFCs.
Application to other Media: Would EPA recommend this same level for soil clean up values?
EPA is not yet addressing that subject.
Public Messaging: States really need assistance from EPA in messaging. Levels above the
HAs will come across (in a messaging context) as both a Tier 1 notice (due to the critical life
stages) and a Tier 2 notice (due to the lifetime expression). EPA is encouraged to work with
ASDWA and states to come up with what a messaging template might look like.
EPA is very willing to do so.
Question about the Reference Dose (RfD): Did the new daily reference dose drop at a rate
proportional to the change from the provisional HAs to the new HAs?
DEQ-CFW 00058109

Underlying today's HAs, EPA developed a new W and used it to come up with the new HAs.
Analytical Method Question: Regarding method detection level (MDL), is there a standard that
all labs should use?
The MDL comes from the method 537 used in EPA's UCMR process. Those levels are 0. 02 for
PFOA and 0. 04. for PFOS.
Transparency in Development of HAs: This process seems to have come together pretty
quickly and relatively non -transparently.
The process followed for the PFC HAs is comparable to the process used to develop other HAs.
The supporting health effects studies were the subject to rigorous peer review, just as in any
other HA development process.
What about the other PFCs? They're not being added into the total HA at this stage. Where
do those analyses stand and what can stakeholders expect in that regard?
EPA doesn't yet have adequate science to support HA development for the other related
compounds at this time; but they hope to make progress in that regard in the months ahead
through their IRIS (Integrated Risk Information System) process.
Caveats in the Treatment information Accompanying the HAs: Regarding treatment
technologies; there's a lot of "ifs"(e.g., removal by carbon can be effective if it's the appropriate
type of carbon). Could EPA please work with ASDWA to develop design information? Will
NSF, etc. be working on protocols for certification of POU devices?
Yes, EPA is willing to do so; but, please recognize that every source water is different, so EPA
can't prescribe a one size fits all treatment approach. But, they certainly can help in working
through the process one needs to consider in making treatment choices. And yes NSF is going
through a PO U certification process.
Monday's Webinar for States: Can the call be postponed, since NJ and NY have a PFC
workshop planned for the same day?
(ASDWA) We'd prefer to stick with the scheduled date and time, dice to the desire to get
information out to states quickly; but ASDWA can record the webinar and make it available
afterwards.
Expression of the HAs: Which is correct 70 ppt or 0.07 ugfL and what are the implications of
the way the HA is expressed?
EPA believes that 0.07 is the most accurate expression in conveying significant digits. Thus the
following rounding should occur for these hypothetical results:
DEQ-CFW 00058110

• A result of 0.069 ug/L (69 ppt) rounds up to 0.07 ug/L (HA not exceeded)
• A result of 0.074 ug/L (74 ppt) rounds down to 0.07 acg/L (HA not exceeded)
• A result of 0.076 ug/L (76 ppt) rounds up to 0.08 ug/L (HA exceeded)
What about MCL Development: is there a timeline for a development of an MCL?
EPA will go through the normal process under the SD WA (e.g., applying the 3-part statutory test
to determine whether or not an MCI, is warranted). If deemed to warrant a rule, there would be
a notice of a positive reg determination. That would be followed by a proposed and then a final
rule. (All in all, a rather long process.)
Occurrence: Does EPA have a sense of the percentage -- nationwide -- of systems with
occurrences of the PFCs that would exceed the combined level?
Its a small percentage (a bit over 1 %); but bear in mind that the data are 2013-1 S and steps
may have been taken, in many cases, to get those levels down.
Implementation Authority: Regarding the authority to take the lead on cases -- if EPA has
Section 1431 authority on a case, presumably they would continue to do so. If a state does move
forward with implementing the HAs at federal facility, would EPA assist in that process?
EPA will, through the Regional offices, be in touch about specific situations, as they arise.
DEQ-CFW 00058111