Out of the Lab and into the Field

Following through on promises made via its PFAS Action Plan, the U.S. Envi­ron­men­tal Protection Agency (EPA) has officially issued preliminary deter­mi­na­tions to regulate PFOA and PFOS, two of the most common members of the PFAS family tied to potential health hazards. EPA called the move a “key milestone” in its efforts to help address PFAS nationwide. 

The announce­ment marks a significant shift in public policy, from a wait-and-see posture toward action-oriented treatment strategies. But this is not the first move to tip the scales. PFAS policies have steadily gained momentum at the state level, as well. Mass­a­chu­setts and New Jersey have already issued MCLs below the federal advisory level, and other states are on their way to similar announce­ments. Most recently, California state regulators issued dramat­i­cally lower response levels. According to the State Water Resources Control Board, water systems must shut down service, provide treatment or notify their customers—depending on various factors—if levels exceed 10 parts per trillion (ppt) for PFOA and 40 ppt for PFOS. The new California response levels represent an 85% drop for PFOA and a 43% drop for PFOS compared to previous levels. 

While state and federal MCLs are critical pieces of the regulation puzzle, the response to PFAS cont­a­m­i­na­tion is far more complex than numerical thresholds. Using the EPA Action Plan as a framework, let’s take a look at how we’re moving from positions of inves­ti­ga­tion toward practical treatment. 

Drinking Water 

The preliminary regulatory deter­mi­na­tion is one component of a larger strategy around drinking water that also includes new toxicity assessments and ongoing monitoring of the compounds. In December, the agency released a new validated testing method to help public and private labo­ra­to­ries measure more PFAS compounds in drinking water.  

CDM Smith is working with the Water Research Foundation on bench-scale leaching tests of biosolids to assess PFAS release. The research project is considered the first to study the impacts of biosolids processing and aging, key areas of concern related to the study of PFAS-laden waste. 

Research and Development

EPA Admin­is­tra­tor Andrew Wheeler has stated that the agency’s action plan represents the “first time we have used all of our program offices to deal with an emerging chemical of concern.” The science behind public health and envi­ron­men­tal safeguards overlaps many disciplines and business sectors. Taking that into account, EPA has kickstarted an extensive research campaign: 

• Early in 2019, the agency advised the Office of Research and Development to find practical solutions to manage PFAS chemical issues that impact agri­cul­tural economies. 
• With hundreds of PFAS variants in existence, government scientists face an uphill battle to find a compre­hen­sive way to analyze them. In addition to recently released drinking water test methods, EPA is researching new methods for groundwater, surface water and wastewater. These studies include efforts to develop high-resolution mass spec­trom­e­try techniques that will allow for a more compre­hen­sive analysis. 

CDM Smith has been working closely with the federal government on global sampling and analysis, especially in aqueous film-forming foam (AFFF) concen­trates and solutions. As part of a recent study for the U.S. Department of Defense (DoD), our researchers have collected and analyzed data from hundreds of mobile and fixed fire suppression systems. We are also collab­o­rat­ing with DoD on increasing our under­stand­ing of PFAS mass discharges, trans­for­ma­tion and fate and transport in unsaturated soil and in groundwater. 

Treatment Methods

EPA’s Action Plan includes oversight and support of response actions. In an update to the plan, the agency offers Ayer, Mass­a­chu­setts as an example. At this project site, the U.S. Army is providing a treatment system for well water threatened by a PFAS plume, and EPA helped fast-track the remediation by assigning a "time-critical removal action" as outlined under the Compre­hen­sive Envi­ron­men­tal Response, Compen­sa­tion and Liability Act, or Superfund. Given the green light, the town of Ayer teamed with CDM Smith to identify an efficient treatment option. 

While a multitude of possible treatment solutions currently exist, no single technology has been proven across all sites and conditions. In the case of Ayer, an existing treatment plant and the presence of constituents like iron, manganese and arsenic have signif­i­cantly impacted response efforts. To satisfy expec­ta­tions for all stake­hold­ers, CDM Smith conducted sampling and bench-scale tests that helped the project team select anion ion exchange resin (AIX).  Construc­tion of the new AIX-equipped treatment plant is currently underway. 

A short drive away in the city of Westfield, Mass­a­chu­setts, bench-scale testing proved that granular activated carbon (GAC) would suffice as an efficient treatment approach. And in North Carolina, Brunswick County officials and CDM Smith scientists selected low-pressure reverse osmosis to remove PFAS and another emerging contaminant known as GenX. The CDM Smith Bellevue Research and Testing Laboratory conducts regular treata­bil­ity studies and has also validated approaches like elec­tro­chem­i­cal and UV reductive treatment under certain conditions. 

Risk Commu­ni­ca­tion

EPA calls risk commu­ni­ca­tion a “critical” component of community support across the country. But, emerging cont­a­m­i­nants, like PFAS, introduce uncer­tain­ties in traditional risk management strategies. These uncer­tain­ties include still-evolving regulatory standards and criteria, the effec­tive­ness of existing treatment tech­nolo­gies, the ongoing development of sampling method­olo­gies and analytical procedures and a complicated mix of sources and market sectors (e.g., wastewater, industrial, agri­cul­tural). As a member of the Interstate Technology and Regulatory Council’s PFAS team, experts like our own Melissa Harclerode are contribut­ing to risk commu­ni­ca­tion tools that will equip prac­ti­tion­ers with science-backed stakeholder engagement strategies.

EPA’s preliminary deter­mi­na­tion represents one link in the chain of regulatory development. With its publication in the Federal Register, the agency will open the process for public comment, and evaluate whether it will proceed to the final step of formal regulation. Stay tuned to Breaking Down PFAS for the latest updates to this process.