Following the release of the U.S. Environmental Protection Agency’s PFAS Action Plan, many states have begun to draft plans and take action to address per- and polyfluoroalkyl substances (PFAS).
PFAS have been used in the production of a wide range of industrial and household products, including fire suppressant foam (Aqueous Film-Forming Foams or AFFF) stored and used at airports and aviation facilities for example. Peripatetic in water, PFAS are in the environment and detected in humans.
Nationwide PFAS Sampling and Analyses Plans
States and the federal government are launching programs to sample stormwater, groundwater, and wastewater for the more common PFAS substances at aviation facilities, firefighter training facilities, military bases and training centers, petroleum refineries and terminals, and petrochemical production facilities.
Other secondary sources, such as landfills, wastewater treatment plants, and where biosolids are used in agricultural applications, are preparing for more aggressive water and environmental testing to help the states determine the potential exposure through drinking water due to the tendency of the substances to accumulate in groundwater.
Many states, such as California are focusing on PFAS analytes including PFOA and PFOS. Massachusetts, for example, is focusing on a subset of PFAS compounds – PFOA, PFOS, PFHxS, PFHpA, and PFNA, because these compounds are considered a threat to human health at high levels. According to the Center for Disease Control (CDC), blood levels of both PFOS and PFOA have steadily decreased in U.S. residents since 1999-2000, but only water and soil-sampling plans can help narrow down potential sources and those facilities that may have accumulated PFAS historically. Although not an exhaustive list, they are a sound and reasonable start, which accredited laboratories are capable of detecting, analyzing, and can be treated with available technology.
Focus on California’s Phased Plan – Phase I for Airports, Aviation Facilities, Landfills
In our blog, we’ll focus on California and the State Water Resources Control Board’s (SWRCB) PFAS Phased Investigation Approach published on March 6, 2019. On March 20, 2019, the SWRCB initiated Phase I of its investigative plan by issuing orders to 31 airports, over 250 landfills, and over 900 drinking water wells to obtain PFAS data across the state. The order issued to airports entitled “Water Code Section 13267 Order for the Determination of the Presence of Per- and Polyfluoroalkyl Substances – Order WQ 2019-0005-DWQ,” requires source investigation and sampling at airports. We’ve linked to the PDF for airports here. Phase II will cover refineries, bulk terminals, non-airport fire training areas, and 2017-2018 urban wildfire areas. Phase III will cover secondary manufacturers, wastewater treatment plants and pre-treatment plants, and domestic wells.
The Order requires the facilities to submit a Technical Report to the Regional Water Board upon notification. For example at aviation facilities, an “Airport Operator Questionnaire” is due to the Regional Water Board within 30 days and other requirements including a Work Plan for a one-time preliminary site investigation within 60 days of receiving order notification. Submission of the final sampling and analysis report for each facility is due 90 days following the State or Regional Water Board acceptance of the facility’s Work Plan.
Hire a State-licensed Professional Geologist or Professional Engineer
While the schedule is aggressive, professional engineers familiar with these investigations and reporting requirements can meet the timetable. What should facility owners and managers expect from their professional geologist or engineer? A complaint investigation of possible PFAS releases at your site will include all of the following:
Preparation of the state required documents including a work plan for the preliminary site investigation.
A site map with sample locations, PFAS material storage and use areas, probable release areas including firefighting training areas, crash sites, and spills from handling.
The report needs to identify sensitive receptors such as municipal supply wells, domestic wells, and surface water bodies within a one-mile radius of a suspected source area.
Proposed surface and subsurface soil sampling locations to delineate the surficial and vertical extent of impacts where PFAS were applied to land.
Proposed representative groundwater sample locations in proximity to a suspected source area.
Existing monitoring wells for your facility may be used if located in proximity to PFAS source(s), and groundwater samples would be representative of groundwater conditions. If the groundwater gradient is unknown, at a minimum, three groundwater samples will be collected around the source area.
The sampling and analysis plan for compounds and parameters specified by the state that includes quality assurance and quality control procedures necessary to ensure valid and representative data is obtained and reported. Your engineer or geologist will determine the appropriate sampling procedures, including sampling equipment, sampling containers, the quality of water used for Blank preparation and equipment decontamination, sample holding times, and quantities for sampling PFAS compounds.
Best practices will minimize contamination, so all sampling materials, equipment, blanks, containers, and equipment decontamination reagents used in sampling must be PFAS free, to the maximum extent practicable.
Include all reporting limits for PFAS.
The signature, stamp, and contact information of the California-licensed Professional Geologist or Professional Engineer responsible for the content of the Work Plan.
The Final Report should include the final sampling and analysis report, submitted no later than 90 days following the State or Regional Water Board acceptance of the Work Plan. This report should include a description of the sampling activities; a summary table of analytical results; the Chain of Custody; the field sampling log; and boring logs and any temporary/permanent monitoring well construction details.
The report will also contain the site map showing the sampling/monitoring locations, and a copy of the laboratory analytical results of the monitored media.
The Questionnaire is to be completed and submitted within 30 days if your facility has not discharged, disposed of, spilled, or released in any way, AFFF or other PFAS containing materials to the land at your facility, or if you have already conducted sampling for these constituents in compliance with the minimum work plan requirements.
The Questionnaire, the Work Plan, and all other reports and analytics are submitted in a searchable electronic format, with transmittal letter, text, tables, figures, laboratory analytical data, and appendices in Portable Document Format (PDF) format and in electronic data deliverable (EDD) format to state’s GeoTracker website via the Electronic Submittal of Information (ESI) Portal.
SCS Engineers’ professional engineers, geologists, and hydrogeologist are available to answer questions. SCS samples, oversees analyses, writes environmental reports, and designs-builds treatment for landfill, industrial, and aero facilities nationwide. Visit our website or contact SCS at-1-800-767-4727 or . SCS will match your industry need with a local professional to assist you.
For more information use the links in the blog, or visit the USEPA PFAS website.
About the Authors:
Chris Crosby is a Project Manager at SCS Engineers and has over thirteen years of professional experience in the environmental consulting field. He successfully manages complex environmental site assessments, subsurface investigations, and remediation projects to help navigate regulatory requirements and meet client objectives. He routinely investigates a variety of constituents of concern at properties with soil, groundwater, and vapor intrusion impacts due to releases from historical site use and implements appropriate remediation technologies to restore properties to be protective of human health and the environment.
Diane Samuels is the Corporate Communications Director at SCS. She writes blogs and articles about environmental challenges and the technologies available to design solutions for waste management and other industries responsible for safeguarding the environment.
As a national environmental consulting and contracting firm specializing in managing hazardous substances, SCS Engineers is helping our clients now. Start by reading The Environmental Dangers of PFAS and Technologies for Removing Them, published in WasteAdvantage magazine for use in the solid waste industry and other industrial applications in support of EPA’s Action Plan.
On February 14, 2019, the U.S. Environmental Protection Agency (EPA) Acting Administrator Andrew Wheeler announced EPA’s Per- and Polyfluoroalkyl Substances (PFAS) Action Plan. The PFAS Action Plan is in response to public interest and input the EPA has received over the past year. EPA’s Action Plan identifies both short-term solutions for addressing these chemicals and long-term strategies for states, tribes, and local communities need to provide clean and safe drinking water to their residents and to address PFAS at the source. These actions include:
Contact a local SCS professional at or visit our website.
We will continue to see changes on the federal, state and local regulatory front that together will help us manage storm water in a smart, cost-effective manner preserving our water resources. Betsy Powers of SCS Engineers provides an update in her most recent article.
Until a new WOTUS definition is finalized, the U.S. EPA and the U.S. Department of the Army have indicated their intent to re-codify the pre-Obama regulations. The revised WOTUS rule is expected to include looser regulatory requirements, meaning fewer waters will qualify, and therefore, fewer permits will be required.
To speed up approvals of permits for highways, bridges, pipelines and other major infrastructure, an Obama-era executive order aimed at reducing exposure to flooding, sea level rise and other consequences of climate change were rolled back reducing the environmental reviews and restrictions on government-funded building projects in flood-prone areas.
Removing phosphorus from storm water runoff is a hot topic, with partners exploring alternative opportunities to reduce the introduction of phosphorus in runoff, remove it or manage it in watersheds.
More proprietary filters are being used for pretreatment before underground infiltration for redevelopment sites for total suspended solids (TSS) control and where land is limited. The performance of proprietary devices continues to be studied and improved to meet regulatory requirements. Increasing general attention is being paid to emerging contaminants that are problematic in storm water runoff. Among the emerging contaminants of concern are pharmaceutical and personal care products, pesticides, hydrocarbons, and hormones. Many of which are now included within the Endocrine Disrupting Chemicals group.
Betsy Powers is a civil and environmental engineer with SCS Engineers.
Of interest to industries concerned with wastewater ammonia treatment or landfill leachate ammonia treatment.
SCS Engineers publishes a new SCS Technical Bulletin entitled “Treatment of Ammonia in Wastewater and Leachate – Considerations and Technologies.”
Reducing the amount of ammonia in landfill leachate and other industrial wastewaters are often necessary to meet discharge standards. Proven wastewater treatment technologies can effectively reduce ammonia concentrations, but selecting the right technology requires careful consideration. This SCS Technical Bulletin provides background on ammonia in wastewater, and reviews factors to consider in selecting a treatment technology. The Bulletin includes a review of eight of the most common and effective treatment and disposal methods for wastewater with elevated ammonia or nitrogen.
Read or share the SCS Technical Bulletin here.
Explore SCS’s Liquids Management resources here.
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