Rather than attempting to find sources of PFAS (polluters) via large sampling programs of stormwater effluent, some states are requesting, requiring, or ordering local wastewater treatment plants to provide PFAS concentration data.
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In these cases, the states are putting the onus on the wastewater treatment plants (WWTPs) to find the source if PFAS is found in their effluent. When PFAS is detected in wastewater streams, it doesn't take long to track it back to the influent source and report them to state agencies.
- Michigan has required WWTPs to report PFAS data via law designating it cannot exceed 11 ppb.
- Wisconsin has requested WWTP sampling to monitor PFAS and should have a regulatory driver for this in summer 2022.
- California simply ordered WWTPs to sample for PFAS as part of the permit process.
In the case of California, operators could have a huge PFAS problem on their hands overnight if forced to sample. There was no law in effect, it was by simple decree. This could be the train operators don't see coming and are not scientifically equipped to handle the necessary remediation newly required. Additionally, if the company's solvency is not accounted for, or without help from state agencies that are requiring these actions, PFAS could become a problem for every taxpayer, not just operators.
Here in New Mexico, Governor Lujan-Grisham has called out the use of PFAS-containing firefighting foam used by the Department of Defense that contaminated groundwater at Cannon and Holloman Air Force bases. However, in most cases operators are unaware that there is PFAS on (or under) their property and are unlikely to have a plan in place to sample and treat PFAS.
If you are an operator who would like help navigating this issue, please reach out to me using the contact form at www.mielsolutions.com.