PFAS (old)

• ASDWA and AMWA Joint Letter of Recommendations to EPA on PFAS Risk Communication – May 15, 2020: This joint letter provides recommendations to EPA for developing risk communication messages for states and water systems to use when communicating with their customers and the public about PFAS.

• ASDWA Joint Letter of Comment with ACWA and ECOS to EPA on Adding PFAS to TRI-EPCRA Reporting – February 3, 2020: Our joint comments support the new National Defense Authorization Act (NDAA) requirements and subsequent EPA action for listing both individual and classes of PFAS, but recommend that the NDAA reporting threshold of 100 lbs is too high and should be determined through consultations with states.

• ASDWA letter of comment on EPA’s Draft Interim Recommendations for Addressing Groundwater Contaminated with PFOA and PFOS – June 10, 2019: ASDWA’s comments make note of ASDWA’s previous comments to EPA on multiple PFAS topics and provide new suggestions for EPA that are both directly related to the recommendations in the document and also in the broader context of cleanup program efforts and in related guidance.
• Joint ASDWA Letter of Comment with ECOS, ACWA, and ASTSWMO on EPA’s PFAS Action Plan – April 4, 2019:. While the letter commends EPA for the development of the Action Plan and acknowledgement of state challenges, it also recommends that the Action Plan needs to:  consider setting limits for other PFAS (beyond PFOA and PFOS) in various media; focus on keeping PFAS out of the environment; provide timelines for actions; and address PFAS as a class.
• ASDWA Letter to EPA on Clarifying Use of the DWSRF for PFAS and Unregulated Compounds – January 23, 2019: ASDWA submitted a letter recommending that EPA publish a memo clarifying that states can use the DWSRF to assess and address PFAS and other unregulated contaminants with adverse human health effects to allow water systems to get priority points on DWSRF loan applications to purchase and install additional treatment technology to remove these compounds.
• ASDWA Letter of Comment on EPA’s Draft Toxicity Assessments for GenX and PFBS – January 22, 2019: ASDWA’s comments on EPA’s Draft Toxicity Assessments summarize state and water system challenges with EPA issuing HAs and toxicity assessments versus a Safe Drinking Water Act (SDWA) regulation with an established Maximum Contaminant Level (MCL).
• ASDWA Letter of Comment to EPA on CCL5 and UCMR5 – December 4, 2018: ASDWA’s comments included recommending that PFAS (as a group) be included in the final Fifth Contaminant Candidate List (CCL5). The letter also included reference to ASDWA provided informal recommendations to EPA on the inclusion of more PFAS compounds in the final UCMR5.
• ASDWA President’s Congressional Testimony on PFAS – September 6, 2018: ASDWA President, Lisa Daniels provided testimony at a PFAS hearing of the Subcommittee of the Environment of the House Energy and Commerce Committee asking Congress to direct federal agencies to develop unified risk messaging; list PFAS as a hazardous substance; provide additional funding to EPA and states; and expand the PFAS focus to encompass all programs and media; and more.
• ASDWA Letter of Comment to EPA PFAS Docket – July 20, 2018: ASDWA submitted its letter of comment to the EPA PFAS National Leadership Summit and Engagement comment docket (EPA-HQ-OW-2018-0270) at regulations.gov. The letter emphasizes the continuing challenges and continuing need to address all ASDWA’s recommendations from the January 12, 2018 letter, and the need to do more to ensure the protection of public health from PFAS compounds through the provision of safe drinking water. In addition, the letter expressed support for EPA’s current commitments and highlighted the need for EPA to take additional actions to: work with CDC ATSDR on health risks and messaging; develop a national plan that includes PFAS actions with a budget and timeline; address multiple PFAS compounds holistically through all EPA programs and media and at the source; include PFAS compounds again in UCMR5; and consider needs and implications for state and EPA funding that is being diverted from essential core drinking water activities to address PFAS contamination.
• ASDWA PFAS Letter of Recommendations to EPA and CDC – January 12, 2018: ASDWA sent a letter to EPA and CDC with detailed recommendations to assist states with the growing problem of PFAS in drinking water by forming a federal-state working committee and developing a unified message, promptly, to the public and state regulators on what to do about PFAS. The letter also provides specific recommendations for multiple categories of topics including:  direct engagement with states on any new PFAS advisories and guidelines; the need for more health effects research for additional PFAS compounds and considerations for analytical methods; as well as guidance for wastewater discharges, underground injection control, soil leaching standards, and air emissions.

• Version 2: ASDWA PFAS Lab Testing Primer for States and Water Systems – February 14, 2019: The primer was developed by the ASDWA PFAS Workgroup to provide guidance and an overview of options and issues for state drinking water programs that are associated with testing for PFAS in water samples collected from public water systems. The document has been updated to include information about EPA’s new Method 537.1 that was published in November 2018. The primer is divided into eight topics on selecting an analytical method; finding a qualified laboratory; specifying a list of compounds and the form that each PFAS needs to be reported in; specifying reporting limits; technical issues that cause variability in testing results; sample collection procedures; interpreting results; and EPA’s ongoing work to develop new analytical methods.
• ASDWA PFAS Water Utility Treatment Case Study – Town of Blades, Delaware – December 14, 2018:  This case study was developed for ASDWA by the Town of Blades, where high levels of PFOA and PFOS were found in their wells. The town worked with the state, EPA, and many partners to undertake subsequent actions to add GAC treatment and investigate the source of contamination. The case study includes information about their efforts; their treatment needs, considerations, and decisions; and the associated costs.
• Download the ASDWA PFAS Fact Sheet – February 2020 that includes the information on this webpage in a 2-page PDF.

California is working with EPA to help ten public water systems (PWSs) who had PFAS sampling results over 70 ppt. One PWS applied for grant funding to add granular activated carbon (GAC) treatment. The other PWSs are blending sources. EPA Region 9 has launched an effort to do investigations at nine superfund sites that have treatment to reduce health risks. The investigations at those sites included sampling, and next steps will be decided after they receive results. The California Water Resource Control Board website includes more information about their efforts.

Massachusetts: The state has proposed a new groundwater clean-up standard (GW-1) level of 20 ppt covering six PFAS. In addition, they have started a stakeholder process to establish a DW MCL. These two efforts will influence each other with a goal of a coordinated value for both. So, 20 ppt for six PFAS (PFOA, PFOS, PFHxS, PFHpA, PFNA and PFDA) is a likely starting point for the MCL discussion. Our Office of Research and Standards is also reviewing our existing 70 ppt guideline that covers 5 PFAS and will be consulting with its external advisory committee on this effort. They are working with the PWSs that currently deliver water with the six PFAS between 20 ppt and 70 ppt to encourage activities such as providing public notice and making operational changes to lower the level of PFAS being delivered to the public.

Michigan: The state has created a PFAS Action Response Team and a group of Michigan members of Congress have signed a letter to EPA asking for help to address PFAS contamination. A growing list of communities in the state have found high levels of PFOA and PFOS in their soil and water, some as high as 37,800 ppt (more than 500 times EPA’s HA level). PFOA and PFOS from Aqueous Film Forming Foam (AFFF) has also been found near military bases and at one base in Oscoda, was found at 100,000 ppt. For more information, see the Michigan PFAS Response website.

Minnesota: The 3M Groundwater court case in Minnesota was settled for $850 million and will result in $720 million in available funds. The state Department of Natural Resources and Pollution Control Agency are the lead on this and the hard part will be to determine how to spend the money. The first priority is drinking water and the second priority is natural resources. It may include funding for new wells, water line extensions, treatment, and regional water services. For more information, see the Minnesota Department of Health web page.

New Hampshire has adopted regulations for four PFAS including PFOA, PFOS, PFHxS, and PFNA (see table above). Wastewater discharges to groundwater have had PFAS levels above 100 ppt at some sites and have impacted one PWS well, other private wells, and smaller public water systems. The state has investigated its most susceptible areas. The state’s “Be Well Informed” initiative has spurred communities to demand lower PFAS level standards, partly because it is hard to explain why different states have different numbers. For more information, see the New Hampshire PFAS Investigation website.

North Carolina: The NC General Assembly established the PFAS Testing Network, a collaborative organization of 7 North Carolina universities, to address PFAS in North Carolina in 2018. A major focus of the organization is a sampling effort that covers every public water supply in the state for over 55 different types of PFAS. As samples are processed, any elevated PFAS levels are reported to the communities that are served by that source. It was this team’s data that was used to notify Maysville, NC’s of elevated PFAS levels initially. In addition, the PFAS Testing Network is focusing research efforts on aerial deposition, well risk modeling, removal methods, and a variety of other applied research opportunities concerning PFAS. More information about the projects can be found at http://ncpfastnetwork.com.

New Jersey started to look for PFOS and PFOA in 2006 at 23 susceptible PWSs. All the samples were below the state specific guidance number of 40 ppt (10 ppt detection limit).  In 2009, 30 water systems were sampled for 10 PFCs (5 ppt detection limit). The state has asked the PWSs that had detections to collect additional samples using 5 ppt detection limits and now has data from approximately 200 PWSs. Several PWSs have installed treatment, have taken contaminated wells offline for PFAS, or are blending their sources to reduce exposure. For more information, see the New Jersey website.

Pennsylvania has a handful of impacted PWSs that are clustered in the southeast area of state, mostly near superfund sites where EPA has taken the lead on an investigation. The state has provisions in its regulations to address unregulated contaminants and HAs. Most of the affected PWSs have taken the impacted sources offline, which is causing the plume to spread (an unforeseen consequence).  Large sectors of the public do not feel that the 70 ppt is protective of public health because different states have different numbers. The Legislature has drafted bills to move forward with an MCL and the Delaware Riverkeeper has a petition against the state to develop a 6 ppt standard though the detection limit is only 5 ppt. PA is having challenges with stormwater runoff that is impacting surface water PWSs. They also have impacted private wells that are having to be taken offline. PA has a vacant toxicologist position right now and would like to hear more about the work of other state toxicologists on PFASs. Lab accreditation is another problem, the turnaround time for samples is three weeks for the few labs accredited to do the analysis.

Rhode Island: From August to October 2017, the Department of Health (RIDOH) Center for Drinking Water Quality partnered with the Brown University Superfund Research Program to collect over 60 samples at almost 40 small public water systems (PWSs) not included in UCMR3, that were within one mile of known facilities that used PFAS. The RIDOH lab analyzed for nine PFAS compounds and found 31 water systems with PFAS detections below the reporting limit (4 ppt for all but one PFAS), seven were detected at less than half the EPA HA, one was over half the HA in its raw water but under half in its treated water, and one was over the health advisory. The state is now investigating the source of contamination in the one well, which has also affected a volunteer fire station well and neighboring private wells.

Vermont did not find any PWSs with contamination problems in the UCMR3 data. The state conducted monitoring and found groundwater contamination in private wells near manufacturing sites in the Bennington area. They looked at other susceptible areas in the state (manufacturing, airports, fire training academy). VT found public water system contamination (contamination is defined as exceeding 20 ng/l) at four locations;  one community system near manufacturing, one business park near an airport, and two schools where the source is unclear. VT has groundwater enforceable standards for PFOA, PFOS, PFHxS, PFHpS, and PFNA. The corrective action for the Bennington area has been to expand the two public water systems in Bennington and North Bennington. PFAS response has not always been consistent with standard regulatory approaches. As an example, the state is expected to issue “do not drink” orders even though these are not acute contaminants. For the one impacted community public water system, capacity issues are considerable.

Washington is is finalizing draft PFAS rule language as they consider setting a standard for PFAS that may include requirements for monitoring, record keeping and reporting, follow-up actions, and other associated requirements. For more information, see the Washington web page.

ASDWA PFAS Water Utility Treatment Case Study – Town of Blades, Delaware – December 14, 2018:  This case study was developed for ASDWA by the Town of Blades, where high levels of PFOA and PFOS were found in their wells. The town worked with the state, EPA, and many partners to undertake subsequent actions to add GAC treatment and investigate the source of contamination. The case study includes information about their efforts; their treatment needs, considerations, and decisions; and the associated costs.

ASDWA Webinar: PFAS Treatment Options and Considerations for Drinking Water Utilities – October 2018: This webinar shared information from four companies that offer PFAS treatment technologies for drinking water utilities.

EPA Website on Drinking Water Treatment Technologies – August 2018: The site includes some general information on reducing PFAS in drinking water using activated carbon, ion exchange, and high-pressure membranes. The site also includes a link to EPA’s Drinking Water Treatability Database with more information.

New Jersey Recommendations for PFAS Drinking Water Treatment Options – June 2015: This document developed by the New Jersey Drinking Water Quality Institute Treatment Subcommittee provides drinking water treatment options for removing PFOA, PFOS, and PFNA, as well as some short case studies with treatment information and costs from a few water utilities. There are two addendums dated August 2016 and November 2017 to the original document that update information about treatment and the case studies.

Cape Fear Public Utilities Desktop Evaluation of Alternatives – GenX and Other PFAS Treatment Options Study – July and September 2017: This document includes two Technical Memorandums (TMs) developed by Black & Veatch. The first TM1 compares treatment methods – Granular Activated Carbon, Ion Exchange, and Reverse Osmosis or Nanofiltration for the water utility, and the second TM2 presents planning level opinions of probable cost for treatment options previously selected in TM1.

State Resources:

• EPA web page with state by state PFAS resources including fact sheets, websites, health advisories, and more.
• Connecticut PFAS in Drinking Water Fact Sheet
• Massachusetts DEP PFAS website and  Interim Guidance on Sampling and Analysis for PFAS at Disposal Sites Regulated under the Massachusetts Contingency Plan
• LinkedIn Article – North Carolina to revoke Chemours’ permit to discharge processed wastewater
• Michigan letter to EPA on PFAS Contamination – December 2017
• New Hampshire Presentation at ASDWA – October 2017 – “PFAS in Drinking Water and Groundwater in New Hampshire” by Brandon Kernen
• New Jersey’s Drinking Water Quality Institute – The website includes PFAS rulemaking information.
• Washington State PFAS Chemical Action Plan (CAP) Focus Sheet – The CAP will comprehensively assess the environmental and health effects of PFAS, and to recommend strategies to reduce or eliminate those impacts.
• New York Drinking Water Quality Council – February 26, 2018 Webcast Meeting on PFOS – This recording of the NYDWQC meeting discusses recommendations for developing regulations on PFOA, PFOS, and 1,4 Dioxane.
• Pennsylvania has been petitioned by the Delaware Riverkeeper – News article about the petition to set a PFOA drinking water standard of 1 to 6 ppt.

EPA Resources:

• Health Advisories for PFOS and PFOA
• PFAS Fact sheet
• EPA updated Method 537.1:  In November 2018 EPA released this updated Method 537.1 that can now test for 18 PFAS in drinking water.
• Cross-Agency effort press release
• PFAS methods and guidance for sampling and analyzing water and other environmental media (Technical Brief)
• Website:  https://www.epa.gov/pfas

CDC:

• Agency for Toxic Substances and Disease Registry (ATSDR) – Health Effects of PFAS

Department of Defense (DoD) Resources:

• DoD PFAS Presentation_March 2018 – This presentation summarizes and details DoD’s ongoing work and provides detailed spreadsheets on the individual sites (by service branch) that have been tested.
• Presentation and Webinar – September 2017 – “Research and Development Needs for Management of DoD’s PFAS Contaminated Sites”
• HR 2810 DOD PFAS Health Study and Exposure Assessment – December 2017 – This legislation appropriates $7 million to DoD to work with CDC’s Agency for Toxic Substances and Disease Registry (ATSDR) on a study to assess human health implications of PFAS contamination in water.

Industry Resources:

• NGWA report on “Groundwater and PFAS – State of Knowledge and Practice.”
• ITRC technical and regulatory guidance documents, and Internet based training course – see the website and fact sheets.

Water Research Foundation (WRF) Resources:

• New PFAS Focus Area – December 2017: The new Focus Area may include: emerging and unidentified PFAS; vulnerability of waters and identification of sources and hotspots; management alternatives; behavior, fate, and transport of PFASs in treatment; and treatment and removal of PFAS.
• Treatment Mitigation Strategies for PFAS (project #4322) and Webcast – June 2016
• Technical Brief – Updated June 2018: Provides a brief overview of information on PFAS sources, health effects and regulations, analytical methods, treatment, and future research.

Risk Communication Resources

• ECOS – June 2018: Case Studies on State-Level Risk Communication of PFAS and HABs
• WRF project #4551 – 2017: Guide, Webcast, and Slides on Terminology Guidance for Water Professionals (or, What You Say Is Not What People Hear…). The guide is formatted with very simple and easy to use tables and focuses on communicating with the public on contaminants of emerging concern. It also provides helpful short descriptions in lay language for talking about 127 specific contaminants, including 1,4‐Dioxane and PFOA and PFOS.
• EPA Risk Communication in Action The Risk Communication Workbook – August 2007: Includes basic concepts of risk, communication, and tools and techniques for their application.