PFAS (explained below) is the emerging contaminant that is already here. In fact, it's just about everywhere in our environment. Typical PFAS sources include airports, landfills, chemical manufacturing plants, metal plating and semiconductor manufacturing, oil and gas refineries, pulp and paper, artificial soccer turf, and textile facilities.
EPA's 2021 Multi-Sector General Permit (MSGP) went into effect March 1, 2021 for stormwater effluent related to industrial activity. Within that document, operators are required to create and make publicly available their Stormwater Pollution Prevention Plan (SWPPP).
"PFAS" is an umbrella term and in the case of the 2021 MSGP applicable to industrial activity includes 18 different perflouroalkyl and polyflouroalkyl substances. These are all summed to determine the screening level, or Maximum Contaminant Limits (MCLs) in drinking water.
For non-potable, stormwater runoff testing for industrial activity, here are the 18 PFAS chemicals detected by EPA Method 537.1*:
Hexafluoropropylene oxide dimer acid
N-ethyl perfluorooctanesulfonamidoacetic acid
N-methyl perfluorooctanesulfonamidoacetic acid
*There are 11 more that are only tested for drinking water, using EPA Method 533.
Now you can understand why the industry uses the shorthand "PFAS" to discuss these chemicals.
For drinking water, the MCL is almost within the error range of the detection limit. This means that if you have a detection of PFAS, you almost certainly have met the MCL and need to remediate. It is not encouraging that PFAS is almost everywhere in our environment.
There is currently no standard for MCL's in non-potable/industrial water, and the EPA is currently in "data-collection mode" on the issue. There are reporting requirements detailed in the 2021 MSGP, but the corrective actions are not punitive even though operators are required to take action (monitoring and reporting each quarter).
What we know is that PFOS and PFOA have toxic bioaccumulative properties and persist in the environment, traveling through oil and water equally, until they are identified and remediated. Labs around the country are innovating to reach even lower detection levels and standards are still being set by EPA for industrial monitoring, reporting, and remediation. This is an evolving story and one that I'll be following closely in the years to come.
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