…An Overview of PFAS

May 2019

5/28/2019

2

We were cleaning everything up to non-

detectable levels

Then came risk-based corrective action; the

fundamental premise being that

concentrations don’t matter so long as there

is no exposure

5/28/2019

3

We’ve found ourselves chasing vapors in both

a subsurface & ambient environment, where

the leading edge of a plume may far exceed

the extent of soil or groundwater impact we

had previously delineated

5/28/2019

4

We’re on to per- & polyfluoroalkyl

substances or PFAS

5/28/2019

5

A group of emerging & potentially harmful

contaminants used in thousands of

applications globally, from fire-fighting

foams, stain repellants, nonstick cookware,

waterproof clothing, food wrappers & even

cosmetics

5/28/2019

6

Developed as early as the 1930’s with the accidental discovery of Teflon.

Usage in the 1950’s began in consumer and industrial products.

Aqueous Film Forming Foam (AFFF) developed in 1960’s. (Still being used; 34,142 gallons in MI fire departments.)

Usage in different industries significantly expanded in 1970’s.

5/28/2019

7

They don’t break down readily in the

environment, can bioaccumulate over time

(in plants & animals) & move easily into

water

Exposure to PFAS has been linked in human

studies to certain cancers, kidney disease,

thyroid conditions & auto-immune disorders

5/28/2019

8

2002-2008: 3M voluntarily phased out production

2010-2015: 8 other manufacturers eliminated production

Production shifted to Asia & Eastern Europe

Exemptions: EPA allows continued, low-volume use in specific applications (semiconductor, etching, metal plating, aviation & photographic/imaging)

PFAS now largely phased out of food packaging (e.g., popcorn bags, fast food containers, etc.)

2018 study of food-contact papers from five of the nation’s largest grocery chains

5/28/2019

9

In January 2018, the Michigan Department of Environmental Quality (MDEQ) set a legally enforceable cleanup standard of 70 parts per trillion for certain PFAS compounds, such as perfluorooctanoic acid (PFOA) & perfluorooctanesulfonic acid (PFOS), something only a handful of states have done thus far.

5/28/2019

10

The criterion is set at the lifetime (unenforceable) health advisory level (HAL) published by EPA in 2016, under which compliance requires comparing the sum of the PFOA & PFOS concentrations to the drinking water criterion of 0.07ug/L.

(HALs don’t establish a regulatory limit or “maximum contaminant level” [MCL]. They provide guidance to state & local officials in evaluating drinking water quality based on levels below which adverse health effects are not anticipated to occur over a lifetime of exposure.)

With this criterion, MDEQ can now issue violation notices & act against any responsible party who doesn’t comply with the state’s cleanup rules.

A part per trillion is one droplet of water in 20 Olympic-sized swimming pools. (BTW - an Olympic pool holds about 660,000 gallons of water!)

1.5 drops out of the average consumption of water in a lifetime

about thirty seconds out of every million years

7 cents out of $1 billion

Less than 1 person out of the world’s population

5/28/2019

11

In fact, it is. The amount -- even at

microscopic levels -- can still matter because

of the way cells interact with molecules. Our

cells respond to those levels, even at a part-

per-trillion concentration.

5/28/2019

12

PFAS contamination has been found in more

than 30 locations in 15 different communities

across the state, including several military

facilities, like Wurtsmouth Air Force base.

To underscore its significance, in late 2017

former Governor Snyder created the Michigan

PFAS Action Response Team (MPART) to

address this emerging issue & help raise

awareness among the public.

5/28/2019

13

MPART recently completed a $23 million

state-funded effort to locate PFAS

contamination, identify sources & oversee

remediation activities aimed at protecting

the state’s water resources & mitigating risks

to the public.

5/28/2019

14

In May 2018, MDEQ began sending letters to Michigan’s 1,380 public water systems, outlining its plans to conduct a state-wide PFAS study of public water supplies.

In addition, 461 schools that operate their own wells were considered priority testing sites under the initiative.

Did not test approximately 1m private wells.

5/28/2019

15

A state of emergency has been issued for Kalamazoo County because of the ongoing health & safety concerns due to PFAS contamination in the drinking water for Parchment & Cooper Township.

PFAS has been found in fish, foam & water samples near the Camp Grayling Army Airfield & Lake Margrethe area in Crawford County.

PFAS has been found in foam & water samples near House Street in Belmont from a Wolverine Worldwide, Inc., disposal site in Kent County.

PFAS has been found in fish & groundwater samples near the Former Wurtsmouth Air Force Base in Iosco County.

PFAS has been found in groundwater samples near the Alpena Combat Readiness Center in Alpena County.

5/28/2019

16

5/28/2019

17

MPART’s efforts have led to the development of

several methods to measure & track

contamination in groundwater.

Sampling protocols are stringent & arduous – no

waterproof note pads or clothing, no Teflon

tubing or connectors, no plastic clipboards, no

Scotch Guard or Gortex & no cosmetics.

The applicability of many cleanup technologies is

limited because remediating PFAS contamination

has only recently been contemplated.

We lack federal EPA standards.

5/28/2019

18

We lack sufficient knowledge required to

understand the toxicity of all PFAS

chemicals.

Federal Agencies can not assure newer

shorter chain PFAS chemical are safer.

5/28/2019

19

Excavation & offsite disposal

Pump & treat

5/28/2019

20

Adsorption

Bioremediation

Chemical oxidation

Chemical reduction

Electrochemical oxidation

Incineration & thermal treatment

Membrane filtration

Solidification/stabilization

Sonochemical treatment

5/28/2019

21

In May 2018, EPA announced it planned to

visit several communities impacted by

PFAS to understand & support work being

done at the state, local & tribal levels.

EPA also announced it planned to develop

a PFAS management plan to be released in

late 2018.

5/28/2019

22

EPA has started the process of designating PFOA & PFOS as “hazardous substances” through available statutory mechanisms, including potentially CERCLA section 102.

EPA is developing groundwater cleanup recommendations for PFOA & PFOS at contaminated sites (was to have been completed by fall 2018).

In February 2019, EPA released the PFAS Action Plan which outlines the steps it is taking to address PFAS and to protect public health. (The Plan describes the EPA’s approach to identifying and understanding PFAS, approaches to addressing current PFAS contamination, preventing future contamination, and effectively communicating with the public about PFAS.)

EPA is collaborating with federal & state partners to develop toxicity values for GenX & perfluorobutane sulfonate by this summer.

5/28/2019

23

PFOA & PFOS are made up of “chains” of eight carbon atoms attached to fluorine & other atoms.

Replacement chemicals, like GenX, tend to have fewer carbon atoms in the chain, but have many similar physical & chemical properties as their predecessors (e.g. they both repel oil & water).

U.S. industries have phased out production of PFOA & PFOS because of concerns about health risks to humans & have been using replacement PFAS, such as GenX.

There is a substantial body of knowledge for managing risk from PFOS & PFOA, but much less knowledge about the replacement PFAS.

5/28/2019

24

Acceptable PFAS exposure levels continue to be debated nationally. (Many researchers argue the 70 ppt safety threshold should be lower!)

A June 2018 report by the Agency for Toxic Substances & Disease Registry found the current health advisory could be 7-10 times too high.

EPA is initiating steps to evaluate the need for a maximum contaminant level (MCL) for PFOA & PFOS.

On March 28th, Michigan approved a request for rule-making to establish enforceable drinking water standards for PFAS found in public drinking water supplies, and is considering whether it should lower its current 70 ppt health advisory and cleanup standard.

Michigan’s GOP-led Legislature currently stalling a Democratic-sponsored bill calling for 5 ppt ceiling.

5/28/2019

25

In July 2018, ABC News reported all 28 groundwater wells tested at Patrick Air Force Base, near Satellite Beach, Florida showed potentially harmful levels of PFOS & PFOA, ranging from 71 parts per trillion -- just slightly over the EPA’s acceptable limit –- to as high as 4.3 million parts per trillion.

In 2017, the DOD reported 2 of 4 on-site monitoring wells at Millington Naval base in Tennessee tested positive for PFOS/PFOA at levels of 70-1,238 ppt.

5/28/2019

26

Approximately 250 public drinking water systems (PWSs) statewide were sampled between 2013 & 2015.

PFAS compounds were reportedly detected in 12 PWSs, but only 3 were reported at levels exceeding EPA’s established HALs.

Further evaluation and/or corrective actions have been taken or are ongoing. Examples:

In Stuart, the water, which is pumped to 19,000 customers, tested positive for PFOS & PFOA in 2014 & 2015, the first years EPA tested for them. In 2016, when EPA recognized the dangers, the city closed & later replaced the wells contaminating the water supply. Stuart's highest level was 180 in 2014. It reportedly averaged 43 in May 2017.

On August 2, 2016, Zephyrhills reported results of 20 parts per trillion for PFOA & 120 parts per trillion for PFOS; a combined value of 140 parts per trillion. The affected well was removed from service.

FDEP & DOH have partnered to sample approximately 100 private drinking water wells. This sampling began in fall 2016 & is ongoing. Results of this sampling are being used by DEP & DOH to determine if any further testing is needed.

In June 2018 & at the request of FDEP, the UF Center for Environment & Human Toxicology calculated irrigation water screening levels (IWSLs) for PFOA and PFOS it believes are protective of human health under an irrigation scenario.

5/28/2019

27

In 2015 and 2016, drinking water from 136

community drinking water systems in

Tennessee was sampled six PFAS compounds.

More than 500 samples were collected and

only 2 had detectable concentrations of PFAS

(Murfreesboro & Georgetown); each of which

were well below the EPA’s 70 ppt HAL.

TDEC is currently identifying activities within

the state which may result in the presence of

PFAS (either through use or as a waste) and

plans to conduct additional sampling.

5/28/2019

28

The department has formed an interdisciplinary working group to identify potential activities likely to contribute to PFAS contamination, identify potential sites with PFAS contamination and determine the agency’s best course of action for protecting Tennesseans from adverse health effects resulting from PFAS contamination.

TDEC is also actively coordinating with the Tennessee Department of Health to determine opportunities to take proactive steps to address PFAS in Tennessee. This includes supporting each organization’s work through regular communication and updates as well as Department of Health staff participating in TDEC’s working group.

5/28/2019

29

Experts are becoming increasingly concerned by the potential effects of high concentrations of PFAS on human health. (An understatement.)

Although there is more to learn about PFAS & human health, states are beginning to take this issue very seriously.

The MPART discoveries & issues like those at Satellite Beach, Murfreesboro, Georgetown and Millington suggest a growing interest in establishing limits on PFAS in drinking water.

5/28/2019

30

… we were cleaning everything up to non-

detectable levels. With PFAS cleanup levels in

the parts per trillion … (don’t blink).

5/28/2019

31

5/28/2019

32

Marc D. Florian, CPG, RG, CUSTP

Vice President | Site Assessment & Remediation Group

269-927-3366 (Office) | 268-927-3684 (Fax)

mflorian@ectinc.com | www.ectinc.com