To:	The Record

	Perchlorate Supplemental Request for Comments

From: 	Simma Kupchan

	Office of General Counsel

	Environmental Protection Agency

Date:	September 2, 2009

Re:	Meeting with Representatives from the Association of Metropolitan
Water Agencies 	(AMWA)

	Representatives from AMWA came to EPA today to discuss issues related
to drinking water regulation, including the content of EPA’s
Perchlorate Supplemental Request for Comments related to EPA’s
perchlorate regulatory determination.  74 Fed. Reg. 41,883.  EPA
representatives at the meeting included: Peter Silva and Michael Shapiro
of the Office of Water (OW); Cynthia Dougherty and Eric Burneson of
OW’s Office of Ground Water and Drinking Water; and Simma Kupchan from
the Office of General Counsel.  Representatives from AMWA included Diane
VanDe Hei and Erica Brown.

	AMWA reiterated their past position that EPA should make a
determination to regulate perchlorate.  The chief issue the AMWA
representatives raised related to perchlorate was their recommendation
that EPA ask the National Academy of Sciences (NAS) to review the
Agency’s re-evaluation of perchlorate science, particularly the
derivation of alternative health reference levels using life stage
specific exposure factors for infants and children.

 

	EPA reiterated its statement in the Supplemental Request for Comments
that it does not plan to request further NAS review of issues related to
perchlorate.  EPA also responded that if the Agency determines to
regulate perchlorate, it would consult with the Science Advisory Board
before promulgating a maximum contaminant level goal and national
primary drinking water rule, as the Safe Drinking Water Act requires.

