Environmental Protection Agency (EPA) has released new drinking water health advisories (HA) for four per- and polyfluoroalkyl substances, known as PFAS. The move is meant to reduce exposure to these compounds, which have been used in a multitude of applications prior to the discovery of their negative health impacts.
The latest PFAS HAs have stirred great interest, as they could impact operations, treatment and monitoring efforts across a wide range of industries. It is vital to take proactive steps to better understand PFAS challenges and anticipate potential solutions.
The HA levels for PFBS, PFOA, PFOS and GenX chemicals were issued as 2,000 parts per trillion (ppt), 4 parts per quadrillion (ppq), 20 ppq, and 10 ppt respectively. These levels for PFOA and PFOS are far lower than the 70 ppt EPA established in 2016. The lower threshold reflects EPA’s latest review of the studies performed on the health effects of PFAS compounds. The lower levels are challenging in laboratory analysis, as EPA’s laboratory methods cannot quantify PFAS at the ppq level. As a result, we cannot effectively evaluate whether PFAS are present at these concentrations.
Health advisories are science-based guidance limits and predicated on how the chemicals could affect a person’s health over the course of a 70-year lifetime, accounting for exposure from a wide variety of sources. However, in the rule-making process required under the Safe Water Drinking Act, economic factors and the technical feasibility of meeting proposed standards must also be taken into consideration.
HA values are used by the Science Advisory Board to inform the development of actual enforceable water quality limits which will be established as a maximum contaminant level (MCL). EPA has committed to establishing enforceable MCLs for PFOA and PFOS in 2023. The proposed rule is expected to emerge near the end of this year and may expand beyond the compounds identified in the recent HAs.
The MCLs will not only establish enforceable drinking water standards but will represent cleanup goals for many remediation sites where drinking water resources are compromised. Given that, the HAs do not account for economics or the technical feasibility of meeting these limits. It is anticipated that — and EPA has indicated that — the MCLs will be well above the 4 ppq and 20 ppq limits and below the 70 ppt established in 2016, perhaps falling within the single digit parts per trillion range.
For municipalities and water utilities, these can be uncertain times, with potentially large changes to treatment and monitoring efforts on the horizon. However, we advocate a restrained approach until the rule-developing process proceeds further, or until your local authority requires specific action. The following measures can assist you in becoming better prepared for the future:
Funding to address emerging contaminants in drinking water is available through the Infrastructure Investment and Jobs Act. An initial $1 billion will be allocated in 2022 and another $4 billion will be distributed through 2026. These federal funds are distributed though state clean water agencies.
From varied industries to municipalities and water utilities, navigating environmental regulations can be tricky. As emerging contaminant standards change, a trusted partner can help develop a comprehensive plan that addresses your unique needs.