Pressure of PFAS

Aug. 25, 2022

Last month, we published an article about the conversations sparked by the Department of Defense’s memo halting its use of incineration as a PFAS disposal method. And this month, we have even more PFAS news.

Th U.S. EPA announced interim health advisory levels (HAL) for PFOA (0.004 ppt or 4 ppq) an PFOS (0.02 ppt) and final HALs for GenX (2,000 ppt) and PFBS (10 ppt). In our special section this month, you can read about the response from industry associations and engineering firms on what this means for the industry.

It should go without saying that figures this infinitesimal set off alarm bells for industry professionals. Accurate measurement at parts per quadrillion is hard to come by, even with the most modern equipment. To add, CDM Smith VP & Remediation Practice Leader Tamzen Macbeth said the "PFOA HAL of 0.004 ppt implies that 2.2 gallons of PFOA are capable of contaminating one quadrillion gallons of water, or roughly the volume of Lake Michigan."

That's an incredibly small measurement, even when put in those terms to help the visualization. To be clear, EPA mentioned in its press release that these levels are below its current ability to detect. But that will not matter to the public.

Instead, the public sees a number that — while non-regulatory and non-enforceable — ostensibly says their water is contaminated and unsafe. It will and has put pressure on utilities to communicate the levels in their water and what they are going to do about it.

There are a couple things I’ve learned that may be of use here. First, EPA said it does not expect utilities to test for or treat to the HALs it announced, and instead said utilities should follow the current detection and limit guidance for regulations. Second, 80% of a person’s exposure to PFAS comes from sources other than drinking water, such as carpeting, clothing, firefighting foam, non-stick cookware and other products.

There is no silver bullet message here.. When a customer calls to ask “Is my water safe to drink with PFAS below detection limits?” even EPA officials did not provide a direct answer. In other words, we’ve got our work cut out for us.

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