As we’ve discussed in prior posts, per- and polyfluoroalkyl substances (PFAS) have historically been an important component of aqueous film forming foam (AFFF) products that are used for training and fire suppression. As awareness of PFAS in AFFF has grown over the last several years, governments at the federal, state, and municipal level, as well as industry, have sought to … Continue Reading
Costs and Benefits of Regulating to PPT Not Yet Understood
The economic impact — both costs and benefits — of the issuance of low parts per trillion standards for nearly ubiquitous PFAS compounds is something that will become clearer as businesses, municipalities, water suppliers and communities act to comply with regulatory standards that require they test for and remove these substances down to trace levels in drinking water and environmental … Continue Reading
The Challenge of Regulating to (and Achieving) Parts Per Trillion
U. S. EPA has established a Health Advisory Level for PFOA and PFOS in drinking water of 70 parts per trillion (“ppt”). Several states are regulating PFAS at the low parts per trillion level. For example, on June 1, 2020, the New Jersey Department of Environmental Protection adopted maximum contaminant levels (“MCLs”) in drinking water for PFOA and PFOS of … Continue Reading
Lack of Approved Analytical Methodologies a Challenge to Site Characterization
One of the potential challenges with starting and completing site characterizations for PFAS compounds (in addition to the lack of approved cleanup standards for many of the environmental media) is the lack of approved and/or certified laboratory analytical methodologies, both at the federal and state levels (in many states), for media other than drinking water and groundwater.
As noted by … Continue Reading
SCREENING LEVELS VS. HEALTH ADVISORY LEVELS
On December 20, 2019, the United States Environmental Protection Agency (EPA) issued its Interim Recommendations for Addressing Groundwater Contaminated with Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonate (PFOS) under federal cleanup programs, such the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Resource Conservation and Recovery Act (RCRA). EPA’s guidance recommends the use of a “screening level” of 40 … Continue Reading
Illinois Initiates PFAS Sampling Process and Releases Draft Amendments to Groundwater Standards for PFAS
In 2019, the Attorney General of Illinois joined in a letter with 22 other states in urging Congress to address the public health threat associated with per- and polyfluoroalkyl substances (PFAS). This approach was no surprise, as the Illinois Environmental Protection Agency (IEPA) had, since 2018, determined that it was time to start assessing PFAS in the environment. See Annual … Continue Reading
ITRC Issues its PFAS Technical Guidance Document
On April 17, 2020, ITRC published its PFAS technical guidance that is the culmination of the efforts of a 400-person team over a three-year period that included public and private sector representatives. The guidance can be found here. According to ITRC, the Technical Guidance Document provides a summary of the current understanding of all aspects of PFAS from a … Continue Reading
PA Department of Environment Protection Issues COVID-19 Guidance
In response to the COVID-19 emergency, and consistent with Gov. Tom Wolf’s Proclamation of Disaster Emergency of March 6, 2020, the Pennsylvania Department of Environmental Protection (PADEP) has developed guidance for those permit holders and operators who have questions about their obligations during this time.
Key Points:
PADEP COVID-19 Emergency Request to Temporarily Suspend Regulatory Requirements and/or Permit Conditions. … Continue Reading
About PFAS and Emerging Contaminants
Regulatory attention is focused on the presence of certain man-made substances in the environment at trace levels (parts per trillion or ppt). The science regarding whether these trace levels cause harm is not well developed. However, there is growing awareness that some of these substances are detectable in nearly all U.S. blood samples, and they are commonly present in drinking … Continue Reading
Map of States with PFAS Regulations
PFAS State Survey: Standards and Guidance Values for PFAS in Groundwater, Drinking Water and Surface Water
Source: Interstate Technology Regulatory Council (“ITRC”) PFAS Fact Sheets updated as of August 31, 2020.
To see the specific state standards or guidance for groundwater, drinking water and surface water refer to PFAS Fact Sheets, PFAS Water and Soil Values Table on the ITRC … Continue Reading