June 15, 2022 By Seth D. Jaffe
Categories: CERCLA , Superfund , EPA , Regulation , Toxic Torts , Water
Just when we environmental old-timers were just getting used to talk about PFAS concentrations in the low parts per trillion range, EPA has moved us squarely into uncharted territory. EPA has released new, interim, lifetime drinking water health advisories of 4 parts per quadrillion for PFOA and 20 parts per quadrillion for PFOS. I'll just note a couple of points:
Whatever the regulatory status of health advisories, it would be wise to assume, absent a successful legal challenge, that parts per quadrillion concentrations for at least these two PFAS are going to work their way into regulations under both the Safe Drinking Water Act and CERCLA.
That's when the real fun will begin.