Per- and Polyfluoroalkyl Substances (PFAS)
State Drinking Water Program Challenges
NEW! ASDWA PFAS – Source Water Protection Guide and Toolkit
ASDWA developed this guide and toolkit with support from a Project Advisory Council (PAC) with representatives from nine states (Colorado, Kansas, Minnesota, New Hampshire, North Carolina, Pennsylvania, Vermont, Virginia, and Wisconsin), and the Cadmus Group. The purpose of the guide is to demonstrate and share effective strategies for addressing PFAS contamination risk in source waters that will help inform policy decisions, assist state drinking water programs in protecting public health, and encourage collaboration and communication among states and water utilities. The tool includes three main components and a factsheet.
- The ASDWA PFAS SWP – Decision Support Tool is downloadable in Excel and provides examples of state actions to address PFAS contamination. It includes an update form for states and other organizations to submit updates or new entries for the Tool.
- The factsheet for Communicating with Industry on PFAS Contamination includes best practices and questions with fillable fields to support state planning efforts.
- The Technical Appendix includes an overview of PFAS, chemicals of concern, PFAS in the U.S., and state PFAS profiles.
- The Mapping Guide aids identifying and mapping source waters that are vulnerable to PFAS contamination.
REGISTER HERE for the June 18th webinar (from 1:00 – 2:30 pm eastern time) to learn more about the guide and toolkit!
PFAS Background: The understanding of potential drinking water impacts from PFAS has significantly increased over the past decade. This class of chemicals started to get publicity in 2001 & 2002 due to water contamination from the Washington Works Plant located outside of Parkersburg, West Virginia, on the West Virginia/Ohio border. The class-action lawsuit against DuPont due to water contamination at Little Hocking Water District and Lubeck Public Service District generated additional publicity. In 2006, DuPont and other manufacturers such as 3M, agreed to principally phase out the production of PFOA and PFOS. Third Unregulated Contaminant Monitoring Rule (UCMR3): Due to escalating concerns, six PFAS compounds were included in EPA’s final UCMR3. UCMR3 monitoring occurred between January 2013 and December 2015 and included two to four quarterly samples at mostly large water systems throughout the country using EPA Method 537. As typical for the UCMRs, EPA regularly released the UCMR3 monitoring data, starting in late 2013. EPA’s 2009 Provisional and 2016 Revised Health Advisories (HAs): In 2009, EPA established provisional health advisories (HAs) for PFOA at 400 parts per trillion (ppt) and for PFOS at 200 ppt; those two numbers were the benchmark at that time, even though an EPA health effects review was underway. Based on the provisional health advisories, national occurrence in UCMR3 for PFOA and PFOS, at the time, appeared to be relatively low. In May 2016, EPA released revised HAs for the sum of PFOA and PFOS at 70 ppt. This numerical reduction significantly increased the number of water systems impacted. 2019 EPA PFAS Action Plan: Commitments by EPA in the action plan included: HAs Versus Regulatory Standards Create Challenges: Use of HAs as guidance, versus a Safe Drinking Water Act (SDWA) regulation with an established Maximum Contaminant Level (MCL) creates challenges for state drinking water programs and public water systems. The HAs for PFOA and PFOS do not provide clarity on necessary actions for water systems to address the compounds, and how to communicate their actions and the associated health risks to the public. State Regulatory and Oversight Challenges: States are having to make tough decisions about whether or how to implement HAs and address PFAS in drinking water in the absence of federal standards. The table below shows the states that have proposed or established PFAS standards or guidelines that are lower or different than EPA’s HAs. These numbers demonstrate the variation in health risk goals and risk reductions among states in the absence of federal standards and are creating public confusion about what levels of PFAS are safe in drinking water. PFOS PFOA PFOS 40 5.1 6.5 PFOS PFNA PFHxS PFBS PFHxA GenX 16 6 51 420 400,000 370 Surrogate of PFOS HBV PFOS PFHxS 15 47 PFOS PFHxS PFNA 15 18 11 PFOA PFOS 14 13 PFOS 10 Click to expand the section below to see more examples of state efforts: More PFAS Contamination Sites are Being Found: The number of PFAS contaminated sites continues to grow. Over the past decade, PFAS contamination was found in many more locations beyond where the UCMR3 required water systems to conduct monitoring. Initially, contamination was thought to be somewhat limited to the chemical manufacturing facilities but has now expanded to include military bases, fire-fighting foam application, storage, and disposal sites, manufacturing sites of fire-retardant materials, landfills, and many other locations, including some that appear to be caused by air deposition. The Number of PFAS Being Manufactured Continues to Grow: The number of PFAS compounds that might be a cause of concern is thought to be in the hundreds and continues to grow. Since the phase-out of PFOA and PFOS, companies have shifted to “short-chain” PFAS such as GenX, which is now a significant concern in the Cape Fear Watershed downstream of a Chemours manufacturing plant in North Carolina. The increasing number of PFAS of concern is creating a host of data collection and analysis issues, as regulators and researchers are struggling to get enough robust health effects, analytical methods, and treatment data to make smart decisions. For more information on how states are addressing PFAS, contact Deirdre White of ASDWA at dwhite@asdwa.org
UCMR3
Compound Name
2009 EPA HAs
2016 Revised HAs
PFOA
Perfluorooctanoic acid
400 ppt
70 ppt (individual and combined sum with PFOS)
PFOS
Perfluorooctanesulfonic acid
200 ppt
70 ppt (individual and combined sum with PFOA)
PFNA
Perfluoroonanoic acid
No HAs
No HAs
PFHxS
Perfluorohexanesulfonic acid
PFHpA
Perfluoroheptanoic acid
PFBS
Perfluorobutanesulfonic acid
State
Drinking Water Action
Compound
Level (ppt)
California
Response Levels
PFOA
10
Connecticut
Action Level
Sum of PFOA, PFOS, PFNA, PFHxS, PFHpA
70
Massachusetts
Proposed Groundwater Clean-up Standard
Sum of PFOA, PFOS, PFNA, PFHxS, PFHpA, PFDA
20
Michigan
Proposed Drinking Water MCLs
PFOA
8
Minnesota
Health Based Guidance for Water
PFOA
35
New Hampshire
Adopted Regulation 10/1/19
PFOA
12
New Jersey
Adopted Regulation
PFNA
13
New York
Rulemaking Initiated 7/8/19
PFOA
10
North Carolina
Health Advisory
GenX
140
Vermont
Drinking Water Health Advisory
Sum of PFOA, PFOS, PFNA, PFHxS, PFHpA
20
ASDWA PFAS Recommendations to EPA and CDC
ASDWA’s State Drinking Water Program Recommendations to EPA and CDC on PFAS (1/12/18) includes the following recommendations: