The EMC is moving to set permanent groundwater standards for 3 PFAS compounds. This process is separate from the Interim Maximum Allowable Concentrations (IMACs) set by the Department of Water Resources, which will be temporary. The commission is moving forward with only 3 PFAS, which is indicative of their lack of commitment to set meaningful protections for PFAS in surface water as well. We suspect that only these 3 PFAS (PFOA, PFOS, and GenX) are slated for groundwater regulation because they will also be less controversial for industrial interests when the time comes to set regulations on surface water. These compounds are mostly phased out and replaced with substitutes (PFOA and PFOS) or is a proprietary compound for Chemours (GenX). While we do want these 3 compounds to move forward, the EMC must continue to regulate the rest of the 8 PFAS compounds regulated by the EPA. See our full talking points below:
Please use the following talking points to help inform your comments; however, you do not need to be an expert to weigh in! What’s most important is that the EMC hears from community members that want the strongest protections from forever chemicals possible.
Comments should be brief; each speaker will most likely have 3-5 minutes. Personalized comments will have the biggest impact on the EMC.
Please issue permanent groundwater standards for PFOA, PFOS, and GenX.
- As written, the new PFAS regulations from the EPA do not protect private well water users from contamination in their groundwater, which is why we must have groundwater limits for our state.
- Once adopted, the groundwater standards will serve as default, health-based cleanup targets when PFAS contamination is found in groundwater.
- While we support the 3 groundwater standards, the EMC should be moving forward to set health protective standards for additional PFAS. The EMC must set standards for all 8 of the PFAS included in the EPA’s new drinking water standards, and those limits should apply to both groundwater and surface water.
- To protect North Carolina community members from PFAS exposure, the EMC should finalize the proposal at hand, but also move forward with a “class-based” approach to regulate all PFAS with cumulative toxic impacts.
- Beyond groundwater, and outside the scope of this particular rulemaking, the EMC needs to stop delaying and move forward with standards that limit discharges of PFAS to surface water.
We will see you in Raleigh!