In comments submitted July 13, NACWA asked EPA to more carefully consider how its proposed rule to ban chrysotile asbestos will affect the chlorine supplies used by drinking water and wastewater utilities.  EPA’s proposed rule would ban the use of the asbestos membranes that are used to produce 30 percent of the nation’s chlorine supply.  The ban would take effect two years after the final rule is promulgated.

The estimated cost to replace the asbestos membranes is $1.8 billion.  The short timeframe proposed by EPA for converting these facilities to new technologies will almost certainly result in shortages and price increases for chlorine and other disinfection and treatment chemicals used by the water sector.  This is especially problematic right now given the increased costs utilities are already facing due to current inflationary and supply chain pressures. Although NACWA appreciates the significant health and environmental concerns presented by asbestos products, a shortage of chlorine will also cause public health and environmental problems.

NACWA recommended that EPA use its authority under the Toxic Substances Control Act (TSCA) to provide an exemption for asbestos membranes used to manufacture chlorine for the water sector. NACWA also asked the EPA to expand its timeframe to the maximum allowed under TSCA if an exemption is not possible to allow a stable chlorine supply for water utilities.

NACWA will continue to work with EPA and other water sector associations to ensure that chlorine supplies are protected.  NACWA members with questions about this issue should contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.