(September 18, 2019) - NACWA has provided feedback to EPA on the shortcomings and inherent complications of the draft technical support document for the Agency’s December 2018 aquatic life water quality criteria for aluminum in freshwater. The draft technical support document was published to help regulators with the implementation process for the new criteria.
NACWA’s comments outline particular concern that the modeling approach EPA recommends assumes the worst-case scenario and results in very conservative conclusions which are not likely to be representative of true site-specific water quality characteristics, bioavailability of aluminum, or the toxicity to aquatic life.
Further, EPA’s recommended sampling approach assumes that all dischargers have issues with aluminum in receiving waters. The requirement that POTWs sample for 24 months is overly stringent, especially if the facility does not have aluminum water quality challenges. Lastly, NACWA notes that there are alternative extraction methods EPA could have considered within the scientific peer-reviewed community, notably a recent publication in the journal Environmental Toxicology and Chemistry.
NACWA will continue to engage with EPA on the draft technical support document and will keep members advised of any new developments. If members have questions, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.