Following through on promises made via its PFAS Action Plan, the U.S. Environmental Protection Agency (EPA) has officially issued preliminary determinations to regulate PFOA and PFOS, two of the most common members of the PFAS family tied to potential health hazards. EPA called the move a “key milestone” in its efforts to help address PFAS nationwide.
The announcement marks a significant shift in public policy, from a wait-and-see posture toward action-oriented treatment strategies. But this is not the first move to tip the scales. PFAS policies have steadily gained momentum at the state level, as well. Massachusetts and New Jersey have already issued MCLs below the federal advisory level, and other states are on their way to similar announcements. Most recently, California state regulators issued dramatically lower response levels. According to the State Water Resources Control Board, water systems must shut down service, provide treatment or notify their customers—depending on various factors—if levels exceed 10 parts per trillion (ppt) for PFOA and 40 ppt for PFOS. The new California response levels represent an 85% drop for PFOA and a 43% drop for PFOS compared to previous levels.
While state and federal MCLs are critical pieces of the regulation puzzle, the response to PFAS contamination is far more complex than numerical thresholds. Using the EPA Action Plan as a framework, let’s take a look at how we’re moving from positions of investigation toward practical treatment.
For the first time in Agency history, we utilized all of our program offices to construct an all-encompassing plan to help states and local communities address PFAS.
The preliminary regulatory determination is one component of a larger strategy around drinking water that also includes new toxicity assessments and ongoing monitoring of the compounds. In December, the agency released a new validated testing method to help public and private laboratories measure more PFAS compounds in drinking water.
CDM Smith is working with the Water Research Foundation on bench-scale leaching tests of biosolids to assess PFAS release. The research project is considered the first to study the impacts of biosolids processing and aging, key areas of concern related to the study of PFAS-laden waste.
Research and Development
EPA Administrator Andrew Wheeler has stated that the agency’s action plan represents the “first time we have used all of our program offices to deal with an emerging chemical of concern.” The science behind public health and environmental safeguards overlaps many disciplines and business sectors. Taking that into account, EPA has kickstarted an extensive research campaign:
- Early in 2019, the agency advised the Office of Research and Development to find practical solutions to manage PFAS chemical issues that impact agricultural economies.
- With hundreds of PFAS variants in existence, government scientists face an uphill battle to find a comprehensive way to analyze them. In addition to recently released drinking water test methods, EPA is researching new methods for groundwater, surface water and wastewater. These studies include efforts to develop high-resolution mass spectrometry techniques that will allow for a more comprehensive analysis.
CDM Smith has been working closely with the federal government on global sampling and analysis, especially in aqueous film-forming foam (AFFF) concentrates and solutions. As part of a recent study for the U.S. Department of Defense (DoD), our researchers have collected and analyzed data from hundreds of mobile and fixed fire suppression systems. We are also collaborating with DoD on increasing our understanding of PFAS mass discharges, transformation and fate and transport in unsaturated soil and in groundwater.
EPA’s Action Plan includes oversight and support of response actions. In an update to the plan, the agency offers Ayer, Massachusetts as an example. At this project site, the U.S. Army is providing a treatment system for well water threatened by a PFAS plume, and EPA helped fast-track the remediation by assigning a "time-critical removal action" as outlined under the Comprehensive Environmental Response, Compensation and Liability Act, or Superfund. Given the green light, the town of Ayer teamed with CDM Smith to identify an efficient treatment option.
While a multitude of possible treatment solutions currently exist, no single technology has been proven across all sites and conditions. In the case of Ayer, an existing treatment plant and the presence of constituents like iron, manganese and arsenic have significantly impacted response efforts. To satisfy expectations for all stakeholders, CDM Smith conducted sampling and bench-scale tests that helped the project team select anion ion exchange resin (AIX). Construction of the new AIX-equipped treatment plant is currently underway.
A short drive away in the city of Westfield, Massachusetts, bench-scale testing proved that granular activated carbon (GAC) would suffice as an efficient treatment approach. And in North Carolina, Brunswick County officials and CDM Smith scientists selected low-pressure reverse osmosis to remove PFAS and another emerging contaminant known as GenX. The CDM Smith Bellevue Research and Testing Laboratory conducts regular treatability studies and has also validated approaches like electrochemical and UV reductive treatment under certain conditions.
EPA calls risk communication a “critical” component of community support across the country. But, emerging contaminants, like PFAS, introduce uncertainties in traditional risk management strategies. These uncertainties include still-evolving regulatory standards and criteria, the effectiveness of existing treatment technologies, the ongoing development of sampling methodologies and analytical procedures and a complicated mix of sources and market sectors (e.g., wastewater, industrial, agricultural). As a member of the Interstate Technology and Regulatory Council’s PFAS team, experts like our own Melissa Harclerode are contributing to risk communication tools that will equip practitioners with science-backed stakeholder engagement strategies.
EPA’s preliminary determination represents one link in the chain of regulatory development. With its publication in the Federal Register, the agency will open the process for public comment, and evaluate whether it will proceed to the final step of formal regulation. Stay tuned to Breaking Down PFAS for the latest updates to this process.
Every site is comprised of different contaminants. We’re in a unique position to make sure a combination of technologies will fit exact site specifications.