Across the industry, stakeholders agree the next few years will be critical in shaping how landfills deal with PFAS and how the public perceives it. Waste trade associations, scientists, and a host of organizations are in the midst of conducting a number of studies looking closely at the issue, PFAS treatment options, the positive impact of recycling, and regulatory policies.
While there are sites noted in the article, there’s no practical way for most companies and landfills to respond at this time responsibly. Additionally, landfills are unique; no two are alike. Most human exposure to PFAS occurs through contaminated food. The majority of landfill leachate is pre-treated at the landfill before going to a wastewater treatment plant, where additional treatment occurs before discharge.
According to EREF President Dr. Bryan Staley, in the article, “The relative impact of leachate as a human exposure pathway needs further evaluation to understand its relative degree of importance as it relates to health implications.”
Dr. Gomathy Radhakrishna Iyer, landfill leachate and design expert for SCS Engineers, said some operators are waiting to see what regulations may come even as they work on accounting for potential compliance issues and seeking solutions. “When the clients are thinking of upgrading their treatment plans, some are definitely taking into consideration PFAS treatment,” Radhakrishna Iyer said.
“You’re spending millions of dollars, you need to do your due diligence, right? At this point, consideration should be given to PFAS treatment during the feasibility stages,” she said.
Complementing the Interstate Technology and Regulatory Council’s – ITRC, PFAS Technical and Regulatory Guidance, the website now has ITRC Per- and Polyfluoroalkyl Substances – PFAS, and Risk Communication Fact Sheets available. The site and updated content replace older fact sheets with more detailed information and useful for those who wish to understand the discovery and manufacturing of PFAS, information about emerging health and environmental concerns, and PFAS releases to the environment with naming conventions and federal and state regulatory programs.
SCS Engineers’ professionals recommend further reading to understand specific chemicals or subgroups of chemicals under study to comprehend PFAA behavior in the environment. There are appropriate tools to develop a site-specific sampling and analysis program and considerations for site characterizations following a PFAS release.
We combine ITRC resources and our own to compile an updated library that we hope you find helpful. You can always contact one of our local Liquids Management or Landfill professionals too.
PFAS Behavior in the Environment
PFAS Concerns
PFAS Evaluations
PFAS Remediation
The Interstate Technology and Regulatory Council (ITRC) is a state-led coalition working to reduce barriers to the use of innovative air, water, waste, and remediation environmental technologies and processes. ITRC documents and training can support quality regulatory decision making while protecting human health and the environment. ITRC has public and private sector members from all 50 states and the District of Columbia and is a program of the Environmental Research Institute of the States (ERIS), a 501(c)(3) organization incorporated in the District of Columbia and managed by the Environmental Council of the States (ECOS).
ITRC Goals
SCS Engineers
Perfluoroalkyl and polyfluroalkyl substances (PFAS) and other emerging contaminants are becoming increasingly important for real estate transactions. Several states have adopted or proposed health guidelines or Maximum Contaminant Levels (MCLs) for PFAS in their state. States with adopted limits include CA, CT, CO, MN, NC, NH, NJ, and VT; and states with proposed limits include IL, MA, MI, and NY. You can track bills by state here.
The Wisconsin Department of Natural Resources (WDNR) and the Environmental Protection Agency (EPA) are focusing their attention on these contaminants. The WDNR recently issued letters to more than 3,000 responsible parties listed with open cases on the DNR’s Bureau for Remediation and Redevelopment Tracking System (BRRTS) requesting they review PFAS use at open sites. Read a sample of the DNR letter.
With WDNR’s increasing focus on PFAS, a lack of sufficient due diligence, which includes evaluations for PFAS, could lead to significant additional liability for property purchasers, developers, and lenders. In addition, a lack of sufficient assessment could lead to a delay in case closure even after responsible parties have addressed all other contaminants and potential exposure pathways at a site. A sufficient assessment for PFAS will depend on site-specific factors and should carefully consider the associated risks and liabilities.
For real estate buyers, owners, developers, lenders, brokers, and contractors the potential presence of PFAS at a property presents significant liabilities that need to be incorporated into due diligence procedures and safe work plans. The investigation and remediation of sites with PFAS contamination can be expensive, and the WDNR is working to define enforceable cleanup goals for soil and groundwater.
Resources:
About PFAS
PFAS are often referred to as “forever chemicals” due to their inability to be broken down in the environment. Due to the very high toxicity of PFAS, the proposed groundwater standard is extremely low – in the parts per trillion, which is more than 100 times lower than the groundwater standards for other well-known toxic contaminants such as benzene from gasoline or tetrachloroethylene commonly used at dry cleaners and industrial facilities.
PFAS are found in a wide variety of products, including nonstick coatings (e.g., Teflon), water-repellent coatings used on clothing and food packaging, fume suppressants, and firefighting foams. Potential sources of PFAS include many types of manufacturing and processing facilities, locations where firefighting foams have been used, metal plating facilities, wastewater treatment plants, and many more.
PFAS systems can treat and clean sources and remediation solutions by environmental engineers can bring properties back to life; safe to build and live on.
Chemical companies are phasing out certain PFAS commonly used in fast food wrappers – read the full story and report at C&EN.
Chemical manufacturers are planning to gradually ramp down sales of certain short-chain per- and polyfluoroalkyl substances (PFAS) used as grease-proofing agents on fast food wrappers, take-out containers, and other paper-based food packaging, the US Food and Drug Administration announced July 31.
AGC Chemicals Americas, Archroma Management, and Daikin America will phase out sales of substances that contain 6:2 fluorotelomer alcohol (6:2 FTOH) for use in paper and cardboard food packaging beginning in January 2021. The process is expected to take 3 years, with up to an additional 18 months to use up existing stocks. A fourth company, Chemours, told the FDA last year that it has already stopped selling the substances in the US market.
PFAS that contain 6:2 FTOH replaced long-chain PFAS in food packaging nearly a decade ago because of concerns about the safety of long-chain PFAS, which are linked to cancer and immune disorders. FDA scientists, however, are now questioning the safety of those replacements. Data from rodent studies suggest that 6:2 FTOH accumulates in the body, the FDA reported in January (Toxicol. Appl. Pharmacol. 2020, DOI: 10.1016/j.taap.2020.114878).
“The data suggest the potential of 6:2 FTOH to also persist in humans from chronic dietary exposure,” the FDA says in a statement. “Further scientific studies are needed to better understand the potential human health risks from dietary exposure to food-contact substances that contain 6:2 FTOH.”
Rather than conduct those tests, the three manufacturers of the substances in question agreed to phase out sales in the US. – read the full story and report at C&EN.
Find more information on PFAS removal and treatment systems.
SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. We also publish these on our website at https://www.scsengineers.com/publications/technical-bulletins/.
Our most recent Bulletin summarizes the 2020 USEPA Adds 172 PFAS Chemicals to EPCRA TRI Reporting Program. The new PFAS rule went into effect on June 22, 2020. However, the rule requires PFAS to be included in TRI reports submitted for all 2020 calendar year activity (i.e., January 1 through December 31). The deadline for submitting the 2020 TRI reports is July 1, 2021.
TRI-Covered Industries include:
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and webinars for our clients.
Contact https://www.scsengineers.com for an Environmental Engineer near you.
When a release of PFAS occurs at a metal finishing facility, it is often due to the integrity of the wastewater system. Due to the persistence of PFAS and very low concentrations considered to be toxic, even water containing a small amount of PFAS can result in a large impact on the environment. If water can migrate into the subsurface, so can PFAS. Once in the soil, any water introduced into the soil can transport the PFAS into the groundwater.
The Californian chrome plating facilities are being required to test for PFAS even if there is no evidence of historical contamination at the property from any chemicals. Current testing is requiring the analysis of 25 different kinds of PFAS, including PFOS and 6:2 FTS.
Because such low concentrations of PFAS are considered to be toxic and their prevalence in common consumer products and tools, false-positive detections are common during the investigations for PFAS. False positives detections can lead to unnecessary expense and additional investigations. Therefore, selecting a knowledgeable, skilled, and experienced environmental consulting firm, is paramount to keeping the investigation as low cost as possible.
The author is Lynleigh Love a Senior Professional Geologist at SCS Engineers specializing in emerging contaminants.
To purchase, read, or cite this article: https://doi.org/10.1080/00202967.2020.1696597
(2020) Upcoming mandatory testing requirements for chromium plating facilities, Transactions of the IMF, 98:1, 6-7, DOI: 10.1080/00202967.2020.1696597.
PFAS are also key components in aqueous film-forming foam (AFFF), which is used to fight petroleum-based fires at aviation and manufacturing facilities. For decades, AFFF containing PFAS has been used extensively at airports throughout the world to protect the safety of passengers, crew, and others. The FAA requires that commercial airports train with, calibrate equipment with, and use the best performing AFFF fire suppression systems. AFFF is required to be used at airports and must be certified to meet strict performance specifications, including those mandated by the U.S. Department of Defense Military Specifications.
Lynleigh Love and Chris Crosby of SCS Engineers discuss the risks and issues with PFAS-based firefighting foam used at airports. The authors cover the regulatory climate, contamination investigations, operational and environmental management and litigation, along with alternatives to using traditional AFFF. There are some possible alternatives that can mitigate health risks in your community.
Read this article to help inform your mitigation plan and strategies to minimize risk.
REPRINT OF USEPA PRESS RELEASE
EPA Moves Forward on Key Drinking Water Priority Under PFAS Action Plan
WASHINGTON (Dec. 4, 2019) — Yesterday, the U.S. Environmental Protection Agency (EPA) sent the proposed regulatory determination for perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) in drinking water to the Office of Management and Budget for interagency review. This step is an important part of EPA’s extensive efforts under the PFAS Action Plan to help communities address per- and polyfluoroalkyl substances (PFAS) nationwide.
“Under President Trump, EPA is continuing to aggressively implement our PFAS Action Plan – the most comprehensive cross-agency plan ever to address an emerging chemical,” said EPA Administrator Andrew Wheeler. “With today’s action, EPA is following through on its commitment in the Action Plan to evaluate PFOA and PFOS under the Safe Drinking Water Act.”
The action will provide proposed determinations for at least five contaminants listed on the fourth Contaminant Candidate List (CCL4), including PFOA and PFOS, in compliance with Safe Drinking Water Act requirements.
Background
The Safe Drinking Water Act establishes robust scientific and public participation processes that guide EPA’s development of regulations for unregulated contaminants that may present a risk to public health. Every five years, EPA must publish a list of contaminants, known as the Contaminant Candidate List or CCL, that are known or anticipated to occur in public water systems and are not currently subject to EPA drinking water regulations. EPA publishes draft CCLs for public comment and considers those prior to issuing final lists.
After issuing the final CCL, EPA determines whether or not to regulate five or more contaminants on the CCL through a process known as a Regulatory Determination. EPA publishes preliminary regulatory determinations for public comment and considers those comments prior to making final regulatory determinations. If EPA makes a positive regulatory determination for any contaminant, it will begin the process to establish a national primary drinking water regulation for that contaminant.
For more information: www.epa.gov/ccl
Background on the PFAS Action Plan
PFAS are a large group of man-made chemicals used in consumer products and industrial processes. In use since the 1940s, PFAS are resistant to heat, oils, stains, grease, and water—properties which contribute to their persistence in the environment.
The agency’s PFAS Action Plan is the first multi-media, multi-program, national research, management and risk communication plan to address a challenge like PFAS. The plan responds to the extensive public input the agency received during the PFAS National Leadership Summit, multiple community engagements, and through the public docket. The PFAS Action Plan outlines the tools EPA is developing to assist states, tribes, and communities in addressing PFAS.
EPA is taking the following highlighted actions:
Highlighted Action: Drinking Water
Highlighted Action: Cleanup
Highlighted Action: Monitoring
Highlighted Action: Toxics
Highlighted Action: Surface Water Protection
Highlighted Action: Biosolids
Highlighted Action: Research
The agency is also validating analytical methods for surface water, ground water, wastewater, soils, sediments and biosolids; developing new methods to test for PFAS in air and emissions; and improving laboratory methods to discover unknown PFAS.
Highlighted Action: Enforcement
Highlighted Action: Risk Communications
For more information, article, and treatment options visit SCS Engineers.
Per- and poly-fluoroalkyl substances (PFAS) are receiving increasing attention from regulators and the media. Within this large group of compounds, much of the focus has been on two long-chain compounds that are non-biodegradable in the environment: PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid).
Long detected in most people’s bodies, research now shows how “forever chemicals” like PFAS accumulate and can take years to leave. Scientists have even tracked them in biosolids and leafy greens like kale. Recent studies have linked widely used PFAS, including the varieties called PFOA and PFOS, to reduced immune response and cancer. PFAS have been used in coatings for textiles, paper products, cookware, to create some firefighting foams and in many other applications.
Testing of large public water systems across the country in 2013 through 2015 found PFAS detected in approximately 4 percent of the water systems, with concentrations above the USEPA drinking water health advisory level (70 parts per trillion) in approximately 1 percent (from ITRC Fact Sheet). Sources of higher concentrations have included industrial sites and locations were aqueous film-forming foam (AFFF) containing PFAS has been repeatedly used for fire fighting or training. Source identification is more difficult for more widespread low-level PFAS levels.
With the EPA positioned to take serious action on PFAS in 2020 and beyond, regulators in many states have already started to implement their own measures, while state and federal courts are beginning to address legal issues surrounding this emerging contaminant. State actions have resulted in a variety of state groundwater standards for specific PFAS compounds, including some that are significantly lower than the USEPA advisory levels. These changes mean new potential liabilities and consequences for organizations that manufacture, use, or sell PFAS or PFAS-containing products, and also for the current owners of properties affected by historic PFAS use. If you operate a landfill or own a site with PFAS history this may be something you need to discuss and plan now.
Questions for property owners, property purchasers, and manufacturers include:
If PFAS treatment or remediation is required, a number of established options to remove PFAS from contaminated soil and groundwater are available, including activated carbon, ion exchange or high-pressure membrane systems. On-site treatment options, including in-situ or ex-situ alternatives, the management of reject streams with concentrated PFAS waste where applicable, are also available.
Do You Need Help?
Need assistance with PFAS or have an idea that you would like to discuss? Contact , or find the SCS Engineers location nearest you.
This week, 271 chrome plating facilities in California received an order from the California State Water Resources Control Board (SWRCB) mandating the investigation of Per- and poly-fluoroalkyl substances (PFAS) at their facilities. Up until 2016, fume suppressants used by these facilities often contained perfluorooctanesulfonate (PFOS), a variety of PFAS.
PFAS consists of thousands of entirely man-made chemicals characterized by a strong bond between fluorine and carbon that have many manufacturing and industrial applications. They are also found in consumer products such as carpeting, apparel, personal care items, and fast food paper wrappings. PFAS is used in firefighting foam, wire and cable coatings, and in the manufacturing of semiconductors. Health studies have linked small doses of PFAS, including PFOS, to reduced immune response, raised cholesterol, and cancer.
PFAS has been widely used within the chrome plating industry as a chemical fume suppressant. According to the National Association for Surface Finishing, it’s estimated that 30 – 40% of surface finishing facilities have chromium electroplating processes. The beginning of its use in the industry goes back to the 1950s and most recently has been required by many states to reduce harmful hexavalent chrome air emissions. Because the chrome plating industry is so highly regulated and monitored, the required use of PFAS in the plating process is well known and therefore has been “on the radar” of state and federal enforcement agencies as potential sources for PFAS pollution.
For more information or assistance with PFAS in the chrome plating industry in California, contact Senior Geologist Lyn Love at 562-426-9544 or .
For help assessing and managing PFAS nationwide please contact for assistance.
