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.
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.