PFAS FAQs: Updated for 2022
Released in Q4 2021, the U.S. EPA’s 2021-2024 PFAS Strategic Roadmap set a number of actions in motion. This has led to new questions from municipal water and wastewater quality managers. We’ve combed through the questions we’re getting from Pace® clients to create this updated compendium of frequently asked questions and answers for 2022.
Download the 2022 Municipality’s Guide to PFAS Testing and Contamination.
WILL THE EPA’S PROPOSED MAXIMUM CONTAMINANT LEVELS FOR PFOA AND PFOS BE THE SAME AS THE CURRENT HEALTH ADVISORY?
The U.S. EPA plans to propose a national drinking water standard for PFOA and PFOS in late 2022, with a final ruling expected in late 2023. The current health advisory level (HAL) is 70 ppt combined or individually for PFOA and PFOS; however, many expect they will go lower when the EPA proposes legally enforceable standards. The EPA may also choose to update its HALs for PFOA and PFOS even while the proposed drinking water standard is still working its way through the rulemaking process.
HOW WILL THE EPA’S RECENT ACTIONS IMPACT STATE REGULATORY ACTIVITY?
We expect PFAS regulatory action in the states to heat up based on both the growing public and political awareness of PFAS and actions the EPA has taken or plans to take in the near future. For example, many states have legally enforceable MCLs and various other limits for PFOA and PFOS based on the EPA’s health advisory. If the EPA lowers their health advisory for these two compounds, we could see states lower their legal limits even before the national drinking water standards are finalized in 2023.
In 2021, the EPA updated its toxicity assessment for PFBS and published the assessment for GenX. The agency also plans to publish toxicity assessments for PFBA, PFHxA, PFHxS, PFNA, and PFDA over the next couple of years. Toxicity assessments can be a precursor to health advisories, and the EPA has announced that they anticipate issuing advisories for GenX and PFBS in the spring of 2022. As noted, state legislators and regulatory bodies may use these published toxicity assessments and proposed/published health advisories to inform state-level regulatory action.
Finally, UCMR 5 could also have a significant impact once sampling begins in 2023. If municipalities start detecting high levels of the 29 PFAS included in the rule, pressure on state legislatures to pass PFAS laws will likely increase.
WHAT’S THE STATUS OF THE NEW PFAS TEST METHODS UNDER DEVELOPMENT BY THE EPA FOR NON-POTABLE WATERS AND SOLIDS?
EPA Method 8327 was finalized for EPA’s RCRA program but has limitations that restrict its applicability. EPA Draft Method 1633 was published in August of 2021 and enables analysis for 40 unique PFAS compounds in non-potable water and solid matrices. As written, the method closely resembles PFAS by Isotope Dilution, a method developed by Pace® for non-potable water and solids. Once finalized, Draft Method 1633 and its SW-846 counterpart method are expected to be the required methods for most regulatory programs moving forward, including wastewater and stormwater discharge monitoring, RCRA, and CERCLA. We predict that it will replace lab and state-specific SOPs as well as become the method of choice for DOD projects.
ARE WE REQUIRED TO USE FIELD REAGENT BLANKS OR FIELD BLANKS?
Field Reagent Blanks (FRBs) are used when testing drinking water to verify that PFAS were not introduced into a sample by cross-contamination during sampling. When testing environmental samples, e.g., soil and non-potable water, they are typically referred to as Field Blanks (FBs).
Any sampling program that requires a test method that mandates the use of FRBs (e.g., EPA Methods 533 and 537.1) will automatically require FRBs. For example, UCMR 5 requires both Methods EPA 533 and 537.1 to test for the 29 PFAS on the unregulated contaminants list. One FRB is required per test method per sampling point under the program.
Due to the potential for cross-contamination during sampling for PFAS, the inclusion of FRBs/FBs and other field QC samples are written into every available PFAS sampling SOP issued by various states and other organizations, such as the ITRC.
SHOULD WE TEST OUR FIREFIGHTING FOAMS FOR PFAS?
Many municipalities and businesses are switching to fluorine-free firefighting foams (FFF). However, while the FAA allows FFF to be used for training purposes, it has not yet been approved for actual aviation emergencies. Aqueous film-forming foam (AFFF) also has a long shelf life, and the ingredients are not always clearly marked. Furthermore, tests performed on some fluorine-free foams have shown that, although the foams do not contain PFOA or PFOS, they may not be completely fluorine-free. Pace® offers testing services for FFF that can determine which PFAS compounds are present, and if so, at what level. We also offer testing services for legacy AFFF. This data can be used to inform your disposal strategies.
SHOULD WE TEST BOTH UNTREATED AND TREATED WASTEWATER?
This is a common question we get from industrial and municipal wastewater professionals. Testing treated wastewater is clearly vital if it is being directly released into the environment and impacting drinking water sources. However, if treated wastewater levels are elevated, testing untreated wastewater can provide a clearer picture as to the source of the PFAS. For example, TOP Assay can detect PFAS precursors that may degrade into terminal PFAS during treatment.
WHY SHOULD WE CONSIDER TESTING FOR TOTAL ORGANOFLUORINE?
There are ongoing discussions in the scientific and regulatory communities about regulating PFAS as a class of chemicals. Testing for total organofluorine (TOF) can give you a clearer picture of total PFAS contamination as it enables detection of the total of all PFAS present as a single number versus the total level of individual PFAS compounds. For businesses concerned about future legal liabilities, testing for TOF can also inform your risk mitigation strategies.
SHOULD PFAS TESTING BE INCLUDED IN OUR SITE ASSESSMENT BEFORE WE ACQUIRE A BUSINESS OR PROPERTY?
WHAT OTHER EPA ACTIONS MIGHT INCREASE MY POTENTIAL LIABILITY?
The EPA has also proposed designating PFOA, PFOS, PFBS, and the GenX Chemicals as hazardous substances under the Resource Conservation and Recovery Act (RCRA). The EPA further intends to clarify under this new ruling that it has the authority to require the investigation and cleanup of contaminated sites under RCRA’s corrective action program. To help assess liability issues, businesses that have manufactured or handled PFAS on-site, whether they still do today or not, should also consider testing potentially impacted matrices such as soil and groundwater.
For a more complete assessment of EPA actions impacting your industry or organization, reach out to our emerging contaminants team for a Technical & Regulatory Briefing.