PFAS Insights - November 2019

Our understanding of the presence, toxicity, and potential impacts of emerging contaminants continues to advance. One class of emerging contaminants attracting attention is per- and polyfluoroalkyl substances (PFAS), a class of synthetic compounds used in a wide variety of consumer products due to their water and stain repellent properties and thermal resistance.

The risk they pose to human health and the environment is not yet fully understood – there is concern that these compounds may have an impact, but how and under what circumstances is not yet definitive. Although many emerging contaminants have been used for decades, only recent advances in technology have been able to reliably quantify their presence and potential effects.

GHD and PFAS

Our experienced global team is working together to provide comprehensive, practical, risk-based solutions to our clients including site investigations and development of conceptual site models, risk assessments, and innovative remedial technologies.  GHD tracks the fast changing regulatory and technical aspects of PFAS at both the state and federal levels, and is committed to sharing all the latest insights.

In recent news, EPA opens another protocol for public comment, Connecticut releases action plan, plasma technology is tested for destructive capabilities, the Australian government faces class action lawsuit, Lowe’s phases out the sale of all residential carpets and rugs containing PFAS, and GHD’s Environmental and Digital Groups develop digital fingerprints profiles for PFAS sources.

EPA releases next part of its PFAS Action Plan

On November 7^th, EPA announced its Systematic Review Protocol for five PFAS toxicity assessments, which will be open for public comment for 45 days, ending December 23. The protocol details the methods for conducting systematic reviews for perfluorodecanoic acid (PFDA), perfluoronoanoic acid (PFNA), perfluorohexanoic acid (PFHxA), perfluorohexanesulfonate (PFHxS), and perfluorobutanoic acid (PFBA). Assessments described in the protocol will identify the potential human health effects from exposure to each PFAS, and develop toxicity values for each PFAS.

EPA states it is “gathering and evaluating information to determine if regulation is appropriate for other chemicals in the PFAS family.” The release also details other parts of the action plan it intends to develop, including PFAS regulations to promote surface water protection, enforcement, and research. The EPA also intends to issue its proposed regulatory determination for PFOA and PFAS, which is the next step in the process to set drinking water standards under the Safe Drinking Water Act (SDWA).

On November 25^th, EPA requested public input on potentially adding certain PFAS to the list of chemicals companies are required to report to the agency as part of the Toxics Release Inventory (TRI). The agency will use public comments and information in response to the Advance Notice of Proposed Rulemaking (ANPRM) to help the agency determine whether data and information are available to fulfill the TRI chemical listing criteria and to help evaluate the extent and usefulness of the data that would be gathered under TRI. If the EPA decides to move forward with adding PFAS to the TRI, the agency will publish a proposed rule and seek public comment on the proposal.

Connecticut PFAS Action Plan finalized

On November 4, 2019, the finalized PFAS Action Plan, compiled by the Connecticut Interagency PFAS Task Force, was officially released by CT Governor Lamont. The plan details several recommended actions and the strategy focuses on minimization of exposure to PFAS through drinking water testing, assessment of food-related PFAS exposure pathways, and reduction or prevention of future releases of PFAS-containing foams. More information regarding the plan and GHD’s participation can be found in the October PFAS Insights.

Clarkson University researchers testing the effectiveness of plasma technology at destroying PFAS in groundwater

At Wright-Patterson Air Force Base in Ohio, researchers conducted a field demonstration of a plasma reactor to study its effectiveness at treating water containing PFOS and PFOA. The Enhanced Contact Plasma Reactor is a closed system which uses water, electricity, and argon gas to reduce the PFAS chains to smaller compounds. According to the principal investigator at Clarkson, Dr. Selma Mededovic, “The argon gas concentrates PFAS at the gas-liquid interface and plasma is generated at that interface, which then destroys PFAS.” Studies for the project have tested water drawn from monitoring wells at fire training areas, and from various other Air Force bases. One of the two-week studies treated hundreds of gallons of contaminated groundwater. The next phase for the research will be an analysis of the treated water, and further scaling-up of the reactor design, with the ultimate goal of transitioning laboratory technology to the field. The testing was conducted under an Air Force Civil Engineering Center contracted with Clarkson University and teaming partner GSI Environmental. GHD is evaluating preliminary data and will be potentially conduct a pilot study using this technology.

Australian government faces class action lawsuit regarding PFAS contamination

Eight communities near military bases throughout Australia have filed a lawsuit against the Australian government to request compensation for PFAS contamination of their drinking water. Around 40,000 people affected by the alleged contamination are involved in the lawsuit, making it the largest class action lawsuit in Australian history. Shine Lawyers, the firm representing the defendants, enlisted American activist Erin Brockovich to gain global attention for the case.

Lowe’s home improvement bans PFAS in its residential carpet and rug products

On October 31, Lowe’s announced it will phase out the sale of all residential carpets and rugs containing PFAS. The company also stated it plans to release new restrictions on other toxic chemicals involved in carpet, paint, and fiberglass insulation. This ban on PFAS in carpet sales follows The Home Depot’s announcement of a similar goal to phase out sales of carpet and rugs containing PFAS in September. A report by the Ecology Center released in 2018 found PFAS in half of all carpet samples tested. The research was conducted on samples from carpets produced by the U.S.’s six largest carpet manufacturers. In a public statement, Lowe’s stated, “all indoor residential carpet and rugs purchased by Lowe’s will be free of PFAS chemicals by January 2020.”

Developing a digital evaluation for environmental source determination

Using new digital tools, GHD’s Environmental and Digital Groups have been able to develop reasonably accurate digital fingerprints profiles for PFAS sources, which are unique and very challenging to profile in comparison to conventional releases. Continuing to advance our methodologies to determine our understanding of source markers of environmental impacts is critical to assessing the sources of impacts, completing comprehensive investigations, developing accurate conceptual site models, and determining appropriate remedial actions.

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