AMWA submitted comments to EPA’s Office of Pollution Prevention and Toxics June 14 on the agency’s Initiation of Prioritization Under the Toxic Substances Control Act (TSCA). This notice, published in the Federal Register March 21, outlines EPA’s risk-based process for designating 20 high priority chemicals and 20 low priority chemicals for risk evaluation under TSCA. This is EPA’s first set of candidate chemical substances to be reviewed after taking comment on potential approaches for the process in January 2018.
AMWA’s comments focused on the need to define the phrase “near significant sources of drinking water” when discussing the relevant information interested persons may voluntarily submit to the agency for review. The association brought particular attention to the necessity of defining “near” and “significant”. AMWA recognized that the request was not an easy task but stressed that “it is necessary to do so in order for EPA, industry, and the public to best provide information, data, and feedback.”
AMWA suggested that EPA use its own Drinking Water Mapping Application to Protect Source Waters (DWMAPS) tool to assist in this effort. The Office of Groundwater and Drinking Water created the tool to take advantage of GIS layers and data to help users find information critical to protecting drinking water sources. In particular, AMWA encouraged using the data available on sole source aquifers and areas with high concentrations of drinking water intakes and wells to inform EPA’s prioritization process.
AMWA encouraged EPA to continue to provide transparent and detailed frameworks for the types and quality of data the agency will require to help prioritize chemicals throughout the TSCA process. The association also reiterated the importance of EPA’s TSCA group continuing to work with the agency’s Office of Water “in order to effectively prioritize chemicals which have the potential of impacting drinking water sources, both ground water and surface water.”