Per- and polyfluoroalkyl (PFAS) substances are a large family of thousands of chemicals consisting of varying degrees of chemical properties and potential risks to human health. PFAS’s persistence in the environment is due to widespread use in industrial processes, firefighting foams, and consumer products. Toxicological studies within the last decade have raised concerns regarding PFAS bioaccumulative properties that may have implications with respect to human health risks and their associated exposure.
PFAS regulations are evolving
As PFAS regulations continue to quickly evolve, jurisdictions will need to adopt regulatory criteria as they are released. In general, while states are driving regulations in the United States, many states have yet to adopt any standards; but that may soon change. In the western region, California, Nevada, and Oregon have established criteria while some states have pending criteria that may eventually result in some form of regulatory guidance or default to the United States Environmental Protection Agency (US EPA) Lifetime Health Advisory (HAL). In this blog, I will inform the reader of upcoming PFAS regulatory guidance of which stakeholders should be aware.
Some states have established drinking water criteria for PFAS
Nineteen states have established drinking water criteria for PFAS. Six of those states have drinking water limits lower than US EPA health advisories, while another six states have criteria for other types of PFAS constituents. Among all the states that have established criteria, California has the lowest perflurooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) notification levels of 5.1 and 6.4 parts per trillion (ppt), respectively.
US EPA’s PFAS Action Plan
Stakeholders will be required to develop a framework for following existing regulations. In 2019, the US EPA PFAS Action Plan outlined new analytical methods for detecting PFAS in drinking water for “short chain” compounds (i.e., those with carbon chain lengths between 4 and 12), along with existing methods. This 2019 Action Plan provides valuable insight with respect to regulatory expectations on the federal level.
For example, according to the US EPA PFAS Action Plan; groundwater guidance for federal clean-up programs includes using a screening level of 40 parts per trillion (ppt) to determine if PFOA and/or PFOS is present at sites that may warrant further action. However, the US EPA’s PFOA and PFOS Lifetime Drinking Water Health Advisory Level has targeted a concentration of 70 ppt as a preliminary remediation goal (PRG) for contaminated groundwater that is a current or potential source of drinking water. This PRG is a general initial cleanup target level but could be adjusted on a site-specific basis.
Federal MCL for PFAS expected by 2022
With time, additional state and federal drinking water limits are expected to develop. Under the Safe Drinking Water Act (SDWA), the US EPA is expected to set an enforceable maximum contaminant level (MCL) for PFAS sometime before the end of 2022. Limit guidance on surface water, wastewater discharge, and alternate shorter chain PFAS compounds are also expected to develop within a similar time frame.
In general, the regulatory pace in each region is often guided by the magnitude of PFAS contamination. Future federal MCLs are expected to warrant intense action toward implementing treatment solutions to meet these standards. An increased attention toward alternative short chain PFAS compounds continue to be on the horizon.
Are you dealing with PFAS contamination?
If you are faced with meeting PFAS standards today or preparing for future regulations, the consultants at Hargis can help. Our engineers and hydrogeologists understand the complexity of groundwater and drinking standards and have experience with PFAS projects. Reach out to us today https://www.hargis.com/contact/.
ABOUT THE AUTHOR
Christian has been an engineer-in-training since 2017 and has provided environmental consulting services for groundwater remediation projects regulated by Department of Toxic Substances Control (DTSC) and California State Water Resources Control Board (SWRCB). Current responsibilities include implementing field investigations from soil vapor and groundwater monitoring programs, data evaluation and result interpretations from field investigations, technical report preparation, optimizing treatment system operations, maintenance and improvements of existing remediation system assets, and project task management.
Christian is no longer with Hargis + Associates, Inc. For questions regarding this blog, please email firstname.lastname@example.org.