Per- and Polyfluoroalkyl Substances (PFAS), also referred to as Perfluorinated Compounds (PFCs), are an emerging hot topic in the environmental consulting industry and public concern is increasing. Environmental regulators at both the state and federal level are discussing the concern as the science struggles to keep up with the speed of public interest and the pressure to “do something”.
From the 1950s until recent, PFAS were widely used in industry and consumer products. These synthetic compounds are unique in chemical structure due to their defining fluorine carbon bond, considered the strongest chemical bond in nature with distinctive strength, durability, heat-resistance, and stability properties. This unique characteristic made PFAS an attractive chemical to make products resistant to grease, stains, and water. PFAS has been widely-used and can be found in varied products including non-stick cookware, stain-resistant textiles, waterproof clothing, and food packaging. Additionally, manufacturers used PFAS in aqueous film forming foams (AFFF) as a surfactant, useful to fight fires that have a flammable liquid component (e.g. jet fuel). This made PFAS-containing firefighting foams popular with fire stations, refineries, defense sites, large rail yards, and airports. PFAS also reduce friction and so were found in aerospace, automotive, building & construction, and electronics applications.
The health effects of PFAS are not currently well understood. Studies show ingestion of PFAS may lead to adverse effects in laboratory animals and humans. Some studies link certain types of PFAS to cancer and other maladies. The fact that PFAS bioaccumulate in animal and human tissue is of upmost concern and has led to fish consumption advisories.
Regulators and investigators are finding that PFAS contamination appears to be wide-spread, environmentally persistent, and difficult to remediate, leading stakeholders to ask “what do we do once we find it”?
State and federal agencies are working together to establish criteria for PFAS and to identify facilities associated with PFAS use. Regulators indicate that environmental professionals should consider whether these compounds are constituents of concern and test for them where appropriate, indicating that “doing so will help avoid uncertainty, audits, and further work in the future”.
The EPA announced their plan to develop formal limits on PFAS chemical contamination at a PFAS summit in Washington on May 22nd, attended by environmental regulators and officials from over 30 states and tribes. A meeting in Exeter, New Hampshire, scheduled for June 25th and 26th will be the first stop on a national listening tour to further educate, update, and ease the minds of communities effected by or concerned with PFAS contamination while incorporating suggestions into EPA’s plans. Although there are no current EPA-approved methods for PFAS analysis of wastewater or biosolids, the EPA is diligently proceeding with external validation of ASTM D7979. In the meantime, EPA Method 537 (Modified) is commonly used and acceptable for analysis until ASTM D7979 is approved. Furthermore, a modification of the EPA Method 537 may also be approved for wastewater and biosolids at some point.
In the interim, regulators at the state level are taking the initiative with state specific requirements and guidelines. The new Connecticut General Permit for the Discharge of Groundwater Remediation Wastewater, re-issued by the Connecticut Department of Energy and Environmental Protection (CTDEEP) in February of this year, has a requirement to screen wastewater for emerging contaminants including PFAS, if applying to discharge groundwater remediation wastewater to surface water, groundwater, or to a POTW. This will lead to a requirement for those operating groundwater remediation systems to sample for PFAS where its presence is known or suspected. As of February, the Michigan Department of Environmental Quality (DEQ) requires Wastewater Treatment Plants (WWTPs) with Industrial Pretreatment Programs (IPPs) to evaluate potential sources of PFAS, investigate probable sources, reduce/eliminate the sources found, and take other actions to protect surface water quality. Many other states including all of New England are evaluating different PFAS sampling requirements.
Loureiro foresees some significant challenges as scientists and regulators attempt to develop a comprehensive approach to PFAS.
- Due to their wide-spread uses, identifying the source associated with the presence of PFAS in, say, an influent stream, may be challenging.
- Potential cross-contamination and false positives during sampling due to its presence in certain types of sunscreens, cosmetics, bug repellants, waterproof applications, fast-food containers and wrappers, fabric softeners, etc. Proper training of field samplers will be a major factor in avoiding inadvertent contamination of samples by the sampler.
- Analytical methods which are not fully validated and approved could lead to false positive results in addition to the inherent challenges associated with the rollout of any new analytical method.
- If the current understanding of the health effects is presumed accurate, PFAS will be regulated in parts per trillion. As we start to sample more locations at lower concentrations we will likely find PFAS is more ubiquitous than we previously thought. Removing PFAS from waste or water to parts per trillion concentrations will pose another challenge.
Caution should be taken by regulators to avoid being reactionary in the face of public concern. Transparency is needed from all parties involved to develop sound scientific evidence that can be relied upon by the appropriate agencies to develop specific requirements and regulations regarding PFAS.
Loureiro is tracking the understanding of PFAS toxicity and health effects as the studies continue as well as the development of laboratory methods, regulations, and remediation technologies. Currently our advice to clients is very case-specific.
Luke P. Chmielecki
Loureiro Engineering Associates, Inc.