Life-cycle PFAS management strategies: what can you do now?
In February, USEPA issued its Per- and Polyfluoroalkyl Substances (PFAS) Action Plan, which includes three key near-term actions that could impact a variety of industries. First, by the end of 2019, USEPA will make a regulatory determination on the need to regulate PFAS in drinking water. Second, USEPA will list perfluorooctance sulfonate (PFOS) and perfluorooctanoic acid (PFOA) as hazardous under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), which will give them the ability to require responsible parties to pay for cleanup of PFAS contamination. Third, they will develop an interim groundwater cleanup standard for PFOS and PFOA.
Because of the widespread use and persistence of PFAS in the environment, these actions have the potential to impact a variety of industries.
What can those who may be impacted do to prepare for these upcoming regulatory actions?
Some products containing PFAS, such as aqueous film-forming foam (AFFF), are required to be used by the Federal Aviation Administration (FAA). In anticipation of a fluorine-free product to be certified for use by 2021, transition strategies to dispose of fluorine-containing AFFF and contaminated equipment should be developed now. If you have used a PFAS-containing chemical in the past and the potential for groundwater contamination exists, you should conduct an investigation to determine your potential liability and the need for a PFAS control or remediation strategy.
If you are a water or wastewater agency, have you done monitoring to determine if PFAS are present and at what levels? Are they of concern from a drinking water perspective? Are updates needed to your industrial pretreatment program (IPP)? Are PFAS accumulating in your biosolids—do you need to consider alternative biosolids management strategies? What about PFAS in reclaimed/recycled water?
From contaminated stormwater to groundwater to water and wastewater treatment, PFAS is a One Water challenge. Developing a PFAS response strategy requires a life-cycle management approach. What is the source of the PFAS, and can it be controlled there? If contamination has occurred, who is impacted and can it be managed on site? If it has migrated off site, how can it be most cost-effectively addressed (water treatment, new supply, etc.)?
Mead & Hunt’s One Water strategy seeks to synchronize and mobilize the talents of all our professionals working in the water cycle to provide innovative, effective solutions to clients. Our long tradition of innovation, change and progress has been an abiding part of company culture for over 100 years. The One Water strategy continues this tradition of innovative growth as we strive to better serve our clients and our communities.
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