PFAS - CBIA

PFAS

WHAT ARE THEY | KNOWN SOURCES AND OTHER STATES |CONNECTICUT AND PFAS | RISK MANAGEMENT

CURRENT SITUATION & A PRACTICAL APPROACH

PFASWhat Are They

What Are PFAS?

PFAS Background• ITRC PFAS technical and regulatory guidance document = https://pfas-

1.itrcweb.org/• 1940s – U.S. manufacturing began

o Aqueous film forming foams (AFFF)o Chemically complex – mixture of hundreds or thousands of PFAS

• Productso Teflon™ and Scotchgard™o Electronicso Surfactant/additiveo Metal plating and coating mist controlo Textiles, paper and surface treatment

• Manufacturing• Landfills• Wastewater treatment plant

biproducts/sludges

Summary of PFAS Regulations• Early 2000s, production of PFOA and PFOS significantly reduced via TSCA regulations

• May 2016 the EPA set Health Advisory (HA) for PFOA and PFOSo 0.07 µg/L (70 parts per trillion) for PFOA and PFOS combined

• 14 States have established drinking water standards as low as 0.008 ug/L.o Significant for impacted water wells and remediation projects w/ usable aquifers.

• 21 States have established groundwater standards

• Four states have established surface water standards

• 18 States have established soil standards

• Three states have established air standards (NH for ambient air)

Federal Regulatory Actions to Watch• Section 7321 of the 2020 NDAA added 172 PFAS to the TRI

list. Affects 2021 reports.

• February 2020 - EPA made preliminary determinations to regulate PFOS and PFOA in drinking water.

• Multiple attempts to list all or certain PFAS as hazardous substances.

• All PFAS• Class-Based Approaches (i.e. – all perfluoroalkyl acids)• Certain PFAS

PFAS Form Long Plumes• Generally low but also variable (depending on

the PFAS chain length and class) adsorption affinity

• High solubility

• High recalcitrance (terminal PFAS are not biodegradable)

• Surfactant behavior (attracted toair-water interface)

• Susceptibility to electrostatic forces (due to ionic form in solution)

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Multiple Sources – Adjacent and In-Plume

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Major Sources of PFAS- Fire Training Areas

(see Fire Training Areas CSM)- Industrial/Air Emissions(see Industrial Sites CSM)- Landfills/WWTP

IntermediateTransformationProducts with

Varying Stability

• Evolving PFAS Regulations• Is looking at PFOA and PFOS enough?• Changing standards• Expanding lists of regulated PFAS

• Growing Toxicological Dataset Will Inform New Regulation

• Stakeholder Concerns• Ample media coverage• Community sensitivity• Litigious subject

Regulatory Complexities / Stakeholder Sensitivity

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SERDP Project ER19-1205 Results

Alix E. Rodowa, et al.Environmental Science & Technology Letters 2020 7 (3), 156-163DOI: 10.1021/acs.estlett.0c00036

PFASKnown Sources and

State Regulatory Actions

1. Abbreviated from: Glüge, Juliane & Scheringer, Martin & Cousins, Ian & DeWitt, Jamie & Goldenman, Gretta & Herzke, Dorte & Lohmann, Rainer & Ng, Carla & Trier, Xenia & Wang, Zhanyun. (July, 2020). Journal of Engineering, An overview of the uses of per- and polyfluoroalkyl substances (PFAS).

AlphabeticalAerospace Medical utensilsApparel Metal Products ManufactureAutomotive MiningBiotechnology Oil and gas industryBuilding and Construction Paper and packagingCarpets Personal care productsChemical Industry Pharmaceutical industryCleaning compositions Photographic industryCoatings, paints and varnishes Production of plastic and rubberElectronic Industry ResinsElectroplating Sealants and it easesFirefighting foam Semiconductor industryFloor polish Sport articlesFood production Textile and upholsteryLeather Water and effluent treatment

Wire and cable

Known PFAS Use by Industry Category1 Top US PFAS Use Categories (TSCA 2016)1

Sorted by Use in TonsElectrical equipment, plants, and component manufacturing-functional fluidMachinery manufacturing-functional fluidChemical manufacturing-refrigerant (heat transfer fluid)Firefighting foam agentsIndustrial gas manufacturing-air conditioner/refrigerationPlating agent and surface treatingComputer and electronic product manufacturing-solvent for cleaning and degreasing

Scandinavian PFAS Use Categories (2000 to 2017)1

Sorted by Use in TonsProduction of plastic and rubberElectronic industryCoatings and paintsLubricants and greasesBuilding and constructionChemical industryManufacturing of metal productsAutomotiveFlame retardant's and extinguishing agentsPrinting inksMachinery and equipmentSurface treatmentsOil and gas industryTextile including textile production

State Regulatory Approaches• California – 2019

• Phase I• Airports• Landfills• Drinking water wells

• Phase II• Refineries• Bulk terminals• Non-airport fire training areas

• Phase III• Secondary Manufacturers• Wastewater treatment plants• Domestic wells

State Regulatory Approaches

Colorado - 2019• Fire department survey

• Statewide inventory - recently sent industrial discharger questionnaire

• New standards for water

Michigan – 2017• Surface Water Lakes and Streams• Sediment• Foam occurrences• Drinking Water• Wastewater effluent, sludge, and

permits• Wildlife – aquatic and terrestrial

Category Site Count % of Sites Cumulative % of SitesLandfill 49 33% 33%

AFFFAFFF Military (12)AFFF Fire Department (4)AFFF Airport (3)AFFF Training Site (1)

Plating 18 12% 59%

Automotive Plant 14 9% 68%

Manufacturing Plant 9 6% 74%

Chemical Plant 8 5% 80%

Unknown 7 5% 84%

Disposal Site 5 3% 88%

Wastewater Treatment Plant 5 3% 91%

Paper Mill 4 3% 94%

Petroleum Refinery 3 2% 96%

Dry Cleaner 2 1% 97%

Leather Tanning 2 1% 99%

Historic Use 1 1% 99%

Incinerator Ash Lagoon 1 1% 100%

Michigan Groundwater Impact Sites

20 14% 47%

Who is Feeling the Effects?

Where are We Seeing Activity?

• Landfills

• Plating

• Manufacturing Plants

• AFFF Users

• Chemical Plants

What is Driving the Response?

• Affected Drinking Water Resources

• State Regulation

• Litigation

• Construction Projects

• Risk Reduction

PFAS in ConnecticutFarmington River, June 2019 Rainbow Brook, October 2019

• Issued November 1, 2019• Connecticut Interagency PFAS Task Force• Led by DPH and DEEP• Many other Agencies, Entities, &

Individuals/Public-Private• Draft Plan (10-01-2019)

• Over 400 comments submitted• 4 Strategic Focus Areas

PFAS ACTION PLAN

www.ct.gov/CTPFASTaskForce

Action Plan Strategic Focus Areas

Education, outreach, & communication

HUMAN HEALTH

Minimize human health risk for Connecticut

residents

POLLUTION PREVENTIONMinimize future

releases of PFAS to the environment

REMEDIATIONIdentify, assess,

and clean up historical releases

of PFAS to the environment

• Test Drinking Water for PFAS – public water, private wells, bottled water, educate, monitor

• Establish a Safe Drinking Water Advisory Council – MCLs• Financial Assistance (public water systems) for

infrastructure improvement• Identify other potential sources of PFAS exposure• Procure Laboratory Instruments (CT Dept of Public Health

Laboratory)

Action Plan Highlights:Human Health

• Minimize AFFF releases – Take-Back Program, find alternative F-free foams, legislation

• Identify other potential sources of PFAS pollution –operations, processes, consumer products

• Test wastewater treatment plants, biosolids, and compost• Establish discharge limits for PFAS in air and water

Action Plan Highlights:Pollution Prevention

• Map potential PFAS sites to ID areas of greatest concern• Large-scale environmental testing – ambient and impacted

source areas• AFFF sites, landfills

• Establish PFAS cleanup standards for soil, groundwater, surface water, and aquatic biota

Action Plan Highlights:Remediation

Additional Polluting Substance (APS) PFAS Remediation Criteria

Soil• RES DEC 1.35 mg/kg• I/C DEC 41 mg/kg• GA PMC 0.0014 mg/kg• GB PMC 0.014 mg/kg

Groundwater• GWPC* 0.07 ug/L

Notes: PFAS = Sum of PFOA, PFOS, PFNA, PFHxS, and PFHpA*GWPC is consistent with DPH’s Drinking Water Action Level established Nov. 2016.

• AFFF Take-Back Program • Planning to remove ALL AFFF stock from state and municipal fire

services• Lab testing of alternative F-free foams

• RFP for PFAS Sampling in drinking water and other media• GIS project/vulnerability study to guide future statewide

sampling• Near future – POTW influent/effluent testing at 1/3 of

facilities

CT DEEP – PFAS Activities Underway

• Future testing of surface water and fish tissue• Development of Ambient & Surface Water Protection Criteria• Supplemental laboratory bid for PFAS analysis (additional

matrices)• Development of sampling guidance to support regulatory

programs (sampling and analytical methods, analytes)

• Regulatory challenges – analytical methods, disposal options

CT DEEP – PFAS Anticipated Next Steps

Risk Management

Risk Management –Considerations and Questions• Manufacturers and other users of PFAS• Buyers and Due Diligence Concerns• Owners of facilities with known past uses• Owners of facilities with potential past uses

Manufacturers and Other Users of PFAS

STOP!!!Look for alternatives or process changes

that would eliminate PFAS

Buyers and Due Diligence• Phase I Site Assessment

• Site History –• Which operations could be a source of PFAS? • Which compounds are used in such operations?• Any history of fires at the site?

• Are there RECs associated with the possible use of PFAS?• Is site groundwater a (potential) drinking water

source? • Are there other potential sources upgradient?

Facilities with Known Past Uses of PFAS• What is the history of use of PFAS on-site

• Which compounds were used on-site?• How were those materials handled or disposed of?

• Is there a known release? • Is it on the property or downgradient? • What are the impacts? Drinking water? Surface water?

• Are there other potential sources upgradient? • How can you distinguish your site?

Facilities with Identified PFAS Impacts• What is the history of use of PFAS on-site

• Were PFAS compounds used on-site? Any evidence of use? • How were possible sources handled or disposed of? Septic

systems? Air emissions? • What are the impacts?

• On-site or off-site? • Surface Water? Drinking Water?

• Are there other potential sources upgradient? • How can you distinguish your site?

Brian Hoye [email protected] Fieber [email protected] Frigon [email protected]

Shannon Pociu [email protected] Elkow [email protected]

Thank You!

Questions?