On November 30, 2020, the Environmental Protection Agency announced it is aggressively addressing per- and polyfluoroalkyl substances (PFAS) in the environment. The agency announced two steps that it states would help ensure that federally enforceable wastewater monitoring for PFAS can begin as soon as validated analytical methods are finalized.
First, EPA issued a memorandum detailing an interim National Pollutant Discharge Elimination System (NPDES) permitting strategy for addressing PFAS in EPA-issued wastewater permits.
EPA’s interim NPDES permitting strategy for PFAS advises EPA permit writers to consider including PFAS monitoring at facilities where these chemicals are expected to be present in wastewater discharges, including from municipal separate storm sewer systems and industrial stormwater permits. The PFAS that could be considered for monitoring will have validated EPA analytical methods for wastewater testing. The agency anticipates being available on a phased-in schedule as multi-lab validated wastewater analytical methods are finalized. The agency’s interim strategy encourages the use of best management practices where appropriate to control or abate the discharge of PFAS and includes recommendations to facilitate information sharing to foster adoption of best practices across states and localities.
Second, EPA released information on progress in developing new analytical methods to test for PFAS compounds in wastewater and other environmental media.
In coordination with the interim NPDES permitting strategy, EPA is developing analytical methods in collaboration with the U.S. Department of Defense to test for PFAS in wastewater and other environmental media, such as soils. The agency is releasing a list of 40 PFAS chemicals that are the subject of analytical method development. This method would be in addition to Method 533 and Method 537.1 that are already approved and can measure 29 PFAS chemicals in drinking water. EPA anticipates that multi-lab validated testing for PFAS will be finalized in 2021. For more information on testing method validation, see https://www.epa.gov/cwa-methods.
EPA continues to expand its PFAS Action Plan to protect the environment and human health. To date, it has assisted more than 30 states in helping address PFAS, and the agency is continuing to build on this support. Across the nation, the EPA has addressed PFAS using a variety of enforcement tools under SDWA, TSCA, RCRA, and CERCLA (where appropriate), and will continue to protect public health and the environment.
The agency is also validating analytical methods for surface water, groundwater, wastewater, soils, sediments, and biosolids; developing new methods to test for PFAS in air and emissions; and improving laboratory methods to discover unknown PFAS. EPA is developing exposure models to understand how PFAS moves through the environment to impact people and ecosystems.
This blog references information issued from the US EPA, Office of Public Engagement.
In this Waste Today article, Sam Cooke discusses the factors, treatment options, analytical methods, and identifying PFAS sources to most effectively reduce the concentrations of ammonia and PFAS in landfill leachate.
Reducing these concentrations help meet discharge permit requirements for direct discharge of treated leachate to surface waters and to meet publicly owned treatment works (POTW) discharge permit standards.
Sam points out that accomplishing ammonia and PFAS reduction with established wastewater treatment technologies works, but the right treatment depends on each site’s specific parameters. He suggests conducting bench-scale and pilot-scale testing for any feasible nitrogen removal or treatment system. Testing the wastewater helps to identify any changes in the concentration of nitrogen compounds. Thus, necessary changes to the treatment processes, such as additional aeration or chemical additions are easier to identify and less costly to implement.
About the Author: Mr. Cooke, PE, CEM, MBA, is a Vice President and our expert on Industrial Waste Pretreatment. He has nearly three decades of professional and project management experience in engineering with a concentration in environmental and energy engineering. Mr. Cooke works within SCS’s Liquids Management initiative to provide services to our clients nationwide.
Reprint of Press Release: EPA and Partners Announce Collaborative Implementation of the National Water Reuse Action Plan
WASHINGTON Feb. 27, 2020 — Today, at an event at the U.S. Environmental Protection Agency (EPA) headquarters in Washington, D.C., EPA Administrator Andrew Wheeler, U.S. Department of the Interior Secretary David Bernhardt, and U.S. Department of Agriculture Secretary Sonny Perdue, and White House Council on Environmental Quality Chairman Mary B. Neumayr joined federal, state, tribal, local and water sector partners to announce the National Water Reuse Action Plan: Collaborative Implementation (Version 1). The actions that EPA and its partners commit to in the Action Plan will help strengthen the sustainability, security and resilience of our nation’s water resources by creating new partnerships, providing accountability and promoting communication and transparency with a new online platform.
“A reliable water reuse program provides great opportunity for alternatives to existing water supplies across the nation to enhance water security, sustainability, and resilience for communities, rural and urban alike, across the country,” said EPA Administrator Andrew Wheeler. “By launching this phase of the National Water Reuse Action Plan, federal agencies are driving progress on this national priority and delivering on President Trump’s commitment to ensuring a reliable supply of water for our nation.”
“Under President Trump’s leadership, we are pursuing an aggressive approach to ensuring reliable and secure water delivery—driven by modern technology and the best possible science. As our water users are preparing for the future—by strengthening their own water systems and integrating new technologies—collaboration across federal partners is critical to supporting rural and urban water users alike. The National Water Reuse Action Plan will guide the Administration’s efforts to provide safe, affordable, and reliable water to the American people,” said U.S. Secretary of the Interior David Bernhardt.
“President Trump and his Administration are committed to making it easier for farmers to succeed and to ensure they are the most innovative in the world. Administrator Wheeler’s action plan on water reuse will help inspire creative, problem-solving that boosts production on farms, ranches, and private forests – ultimately improving water quality, soil health, and wildlife habitat,” said U.S. Secretary of Agriculture Sonny Perdue.
“As we pursue practical approaches to address our nation’s most pressing environmental challenges, including water scarcity, this Administration strongly supports developing modern, resilient infrastructure to effectively manage our nation’s water resources,” said White House Council on Environmental Quality Chairman Mary B. Neumayr. “One way to support our nation’s communities, economy and environment is by continuing to develop additional opportunities for water reuse to promote safe and reliable water supplies for our homes, businesses, agricultural communities, recreation, and healthy ecosystems. The National Water Reuse Action Plan is a practical example of agencies coming together to improve use of technology to increase water reliability and better manage our nation’s water resources.”
“The Department of Energy is delighted to support EPA’s efforts on the National Water Reuse Action Plan through our Water Security Grand Challenge,” said U.S. Department of Energy Assistant Secretary for Energy Efficiency and Renewable Energy Daniel R. Simmons. “Water is a critical resource for human health, economic growth, and agricultural productivity. We are calling on the power of competition and drawing on the strengths of our partners and stakeholders to advance transformational technology and innovation to meet the global need for safe, secure, and affordable water.”
“Our nation is blessed with abundant access to safe and reliable water sources throughout our country. However, as our country and economy continues to expand, we must ensure that this reliability continues for future generations. I am pleased the administration has taken a forward-looking approach to include federal, state and tribal agencies, along with a multitude of diverse stakeholders, to put out the WRAP. It is an example of the good that comes when government and the private sector work together to lay out practical suggestions to steward our natural resources well,” said Congressman Bruce Westerman (AR-04).
“Finding new ways to preserve and protect water in Oklahoma is one of our top priorities as a state. Today’s release of the “Water Reuse Action Plan” shows that the federal government is serious about leading in their mission to assist all 50 states as well as sovereign tribal nations in developing valuable resources out of previously worthless water. These goals cannot happen without the full partnership of states, tribes, local governments and our federal partners across all agencies working together. Kudos to the Trump Administration and Administrator Wheeler for their leadership in this important endeavor,” said Oklahoma Secretary of Energy & Environment Ken Wagner.
“The U.S. Department of State is excited to use the WRAP as a tool to raise awareness about water reuse around the world. By encouraging partner governments to adopt water re-use policies, management approaches, and new technologies – many of which were made here in America – the State Department is helping to implement the President’s Global Water Strategy. And, through our outreach efforts, all of the people and agencies who contributed to the WRAP are also helping to make other nations more water-secure,” said Principal Deputy Assistant Secretary of State for Oceans and International Environmental and Scientific Affairs Marcia Bernicat.
“The U.S. Army Corps of Engineers continues to work with its federal partners and local sponsors to identify opportunities and include water reuse features in congressionally authorized Civil Works projects,” said Principal Deputy Assistant Secretary of the Army for Civil Works Ryan Fisher.
Over the next decade, 40 states anticipate some freshwater shortages within their borders. The Action Plan supports the President’s memorandum on Promoting a Reliable Supply and Delivery of Water in the West and will help advance water reuse technology that has the potential to ensure the viability of our water economy for generations to come. The Action Plan is a collaborative effort that represents the first initiative of its magnitude to be coordinated across the water sector and builds on more than four decades of water reuse experience and practice. It frames the business case that water reuse is a viable and growing means of supporting our economy and improving the availability of freshwater for farmers, industry, communities, and ecosystems. The Action Plan identifies 37 specific actions across 11 strategic themes to be led by a spectrum of federal, state, local and private sector interests. The Action Plan reflects new partnerships, generates action through more than 200 initial implementation milestones and provides accountability through transparency and routine progress updates.
For more information, including opportunities to engage with EPA on this effort and to find implementation progress updates, visit: https://www.epa.gov/waterreuse/water-reuse-action-plan
Produced water and flowback water are generated from the CBM, shale gas, and shale oil wells. Produced water is water that is withdrawn from the coal seam and shale through the vertical wells drilled into the coal seam and shale in order to release the hydrostatic pressure to enable gas/oil collection at the surface.
Flowback water is used to fracture coal seam cleats and shale in order to open the fissures that enable the release of the gas from the formation if the natural fissures are not fully developed. This water is pumped into the formation and then eventually collected at the surface in a manner similar to the collection of the produced water.
SCS Engineers employs several technologies to reuse, or at the end of the reuse cycle, dispose of production and flowback water.
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.