In recent years, the EPA’s focus on the understanding, exposure reduction, and mitigation of per- and polyfluoroalkyl substances (PFAS) has increased. PFAS are known as “forever chemicals” because of their resistance to degrading naturally – which is why preventing their release to the environment is so critical in managing the levels of PFAS.
The EPA’s PFAS Strategic Roadmap has three main goals: researching, restricting, and remediation of PFAS. The EPA’s PFAS Roadmap includes developing regulations to protect and preserve drinking water, as well as treating PFAS-contaminated water sources. Within the EPA’s Comprehensive PFAS Action Plan, the EPA is moving to develop maximum contaminant levels (MCLs) for certain PFAS in drinking water.
PFAS chemicals have been detected in surface water, groundwater, drinking water sources, wastewater treatment plant (WWTP) effluent, and landfill leachates due to their widespread use in consumer and industrial products, as well as their longevity in nature. In addition to detections in aqueous samples, PFAS has also been detected in water and wastewater treatment residuals, including biosolids. PFAS can be discharged to WWTPs due to industrial, institutional, and domestic usage of PFAS products. Biosolids produced by WWTPs are often used for land applications, which increases the potential exposure to the environment and human health.
States are collecting information on the presence of PFAS in WWTPs with an interest in limiting and remediating.
EPA has identified certain industrial categories as potential sources of PFAS in wastewater, including: organic chemicals, plastics, and synthetic fibers manufacturing; metal finishing; pulp, paper, and paperboard manufacturing; textile mills; and commercial airports. Companiesin these categories discharging to surface water or to a publicly-owned WWTP may be requiredto sample industrial effluent and report results of PFAS.
Typical treatment methods used by WWTPs have limited ability to remove or treat PFAS. As a result, WWTPs have the potential to release PFAS into the environment. As agencies move towards regulations limiting PFAS, WWTP owners are facing additional regulation, costs, and liabilities if they receive, treat, and discharge wastewater containing PFAS, or distribute biosolids containing PFAS.
Through research, a greater understanding of PFAS exposures, human health and ecological effects, and effective interventions is gained. Controlling and preventing PFAS contamination and minimizing the exposure to PFAS during consumer and industrial uses is a proactive step in reducing the impacts of PFAS on the environment and human health. The goal of restricting PFAS has the objective of preventing or minimizing PFAS discharges and emissions into communities.
In December 2019, the EPA published a new validated method to accurately test for 11 additional PFAS in drinking water. The method, Method 533, complements EPA Method 537.1 and allows the measurement of 29 PFAS chemicals.
As part of the Strategic Roadmap, the EPA is looking to require water systems to conduct sampling for unregulated contaminants under the Safe Drinking Water Act (SDWA). The proposed Fifth Unregulated Contaminant Monitoring Rule (UCMR 5) was proposed in March 2021 with the goal to gather new data to improve the EPA’s understanding of the presence of PFAS in drinking water systems. UCMR 5 requires sampling collection for 30 chemical contaminants (29 PFAS and lithium) between 2023 and 2025.
Public water systems (PWSs) are required once every five years to monitor a list of unregulated contaminants.
Effluent Limitation Guidelines
The EPA is moving to restrict PFAS discharges from industrial sources through the utilization of the Effluent Limitations Guidelines (ELGs) program. Regulatory limits of specific pollutants in wastewater discharged into surface waters and WWTPs would be established by these ELGs. EPA continues to collect data on the present of PFAS, and recently announced it will begin developing ELGs for two categories: the Organic Chemicals, Plastics, and Synthetic Fibers category and the Metal Finishing category. Capaccio will be tracking rulemaking notices regarding any proposed ELGs pertaining to PFAS.
As regulations continue to evolve and industry moves towards reducing potential PFAS discharges, our clients have found success collecting data to better understand their own position. Due to historical uses of PFAS, it is valuable to determine background levels and review processes to reduce the uses of PFAS in facilities and operations. Capaccio has helped our clients conduct sampling, evaluate data, and develop action plans, which emulates our mission to “Help industry and the environment prosper”.