In July 2021, the U.S. Environmental Protection Agency (EPA) validated two methods to test for 24 per- and polyfluoroalkyl substances (PFAS) in wastewater, surface water, and groundwater. This validation marks a substantial step forward in efforts to monitor and treat PFAS, as the compounds have long presented numerous analytical challenges due to their widespread presence in a variety of environmental samples, chemical changes that may occur during preservation and storage of the samples, and the need for very low test limits. This month the EPA also validated a draft single-laboratory method to test for 40 PFAS compounds in wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and fish tissue. Improved testing can lead to more effective remediation and protection from the harmful impacts of PFAS contamination.
What are PFAS?
PFAS compounds are a group of synthetic chemicals that are resistant to heat, water, and oil, and have been used in a wide range of consumer products and industrial applications, including food packaging, clothing, fire-fighting foams, and upholstery. At times referred to as “forever chemicals,” PFAS are resistant to typical degradation processes due to their highly stable chemical structure.
However, exposure to certain PFAS compounds has been linked to a variety of health problems in the liver, kidneys, immune system, and nervous system, and may also cause developmental and reproductive issues, such as low birth weight, accelerated puberty, and skeletal changes. Research has suggested links to cancer, thyroid disease, and endocrine disruption. The persistence of PFAS in the environment and, thus, the water supply presents serious risk to public health.
New Testing Methods
The EPA finalized Methods 3512 and 8327, the PFAS analytical methods for wastewater, in July 2021. These were validated together for 24 PFAS compounds in surface water, groundwater, and wastewater. Final versions of these validated methods were published in the SW-846 Compendium. The EPA will be changing its draft permit template language to include a six-month compliance schedule from the effective date of the permit for PFAS monitoring and will also draft letters to permittees that already had the requirement to start the six-month clock.
In partnership with the Department of Defense (DoD) Strategic Environmental Research and Development Program, the EPA has also developed a single-laboratory draft Method 1633 that detects 40 different PFAS compounds in wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate, and fish tissue. The EPA expects to begin multi-laboratory validation of this testing method to complement the existing validated PFAS testing methods, provide a consistent way to test for PFAS in a wide variety of environmental substances (including potable water and wastewater), and contain all required quality control procedures for a Clean Water Act (CWA) method.
The EPA and DoD will continue their partnership into next year on the multi-laboratory validation study of this new testing method. The EPA will use the results of the multi-laboratory validation study to finalize the method and add formal performance criteria. The method validation process may eliminate some of the parameters listed in Draft Method 1633, and it remains to be seen how the EPA will integrate the finalized method into the permitting process.
Protecting Against PFAS
No federal maximum contaminant level (MCL) has been established for PFAS compounds in drinking water. However, the EPA has established a public health advisory level for certain PFAS compounds (PFOA and PFOS) of 70 parts per trillion in drinking water and recently issued a final regulatory determination for these same compounds which advances the process of developing a National Primary Drinking Water Regulation (NPDWR) for promulgation through the Safe Drinking Water Act (SDWA). Meanwhile, many states have implemented their own approaches to addressing various PFAS compounds in their water supplies. Additionally, the recently drafted Unregulated Contaminant Monitoring Rule (UCMR 5), expected to be finalized and published by the end of this year, would expand required assessment monitoring for most public water systems to 29 PFAS compounds.
Wright-Pierce is currently helping several communities solve their drinking water PFAS issues, including some which are receiving funding through PFAS grant programs. We are also assisting several communities in navigating the newer NPDES permit requirements for their wastewater treatment facilities and the EPA’s initiative to include PFAS testing requirements for influent, effluent, and biosolids. If you have questions about current or proposed guidelines for PFAS or want to learn more about the newly validated testing methods, contact us today.