EPA Regulations on PFAS

The number of U.S. communities confirmed to be contaminated with the highly toxic fluorinated compounds known as PFAS continues to grow at an alarming rate. As of August 2023, the latest data shows 4,621 locations in 50 states, the District of Columbia and two territories are known to be contaminated.[1] Additionally, PFAS have been detected in the blood of 98% of Americans, according to a 2019 report using data from the National Health and Nutrition Examination Survey.[2] And, at least 45% of tap water in the U.S. is known to have PFAS in it, according to the U.S. Geological Survey.

Given these concerning statistics, in March 2023, the Environmental Protection Agency (EPA) released their proposed National Primary Drinking Water Regulation Standards (NPDWR) for PFAS and is on track to finalize the regulations in early 2024.* The EPA’s proposal includes maximum contamination levels (MCLs) for six PFAS in drinking water. The EPA anticipates that if this new regulation is fully implemented the rule will prevent tens of thousands of serious PFAS-attributable illnesses or deaths. If finalized, the rule would establish the first national standard for PFAS in public water supplies, bringing uniformity to a jumble of state regulations. Solving this forever-chemicals crisis requires cooperation between many forward-thinking institutions and organizations.

Breakthrough detection and results

Academic scientists, as well as private companies in collaboration with federal agencies are addressing the PFAS challenge. In a study featured in the Journal of Hazardous Materials, researchers from the New Jersey Institute of Technology have demonstrated a new lab-based method to detect traces of PFAS in water and soil samples in just three minutes or less.

This detection method – involving an ionization technique for analyzing the molecular composition of sample materials called paper spray mass spectrometry (PS-MS) – significantly speeds up efforts to study and tackle the issue, which would greatly affect communities and utilities. For example, researchers in this lab were able to couple this analytical method to a novel degradation catalyst, which degrades 98.7% of PFAS in drinking water samples within three hours.

While this work is currently focused on New Jersey because 10% of the 9.2 million people in the state have high levels of PFAS in their drinking water compared to the national average of 1.9%, this methodology certainly could be replicated nationally.

Another example of innovative work to detect and combat PFAS is from researchers at the U.S. Department of Energy’s Fermi National Accelerator Laboratory in association with 3M – a world expert in PFAS. This team has successfully demonstrated that an electron beam can destroy the two most common types of PFAS in water—PFOA and PFOS.

“‘The electron beam is a promising technology to break down PFAS in large volumes of water that contain high concentrations of PFAS,’ said Fermilab principal investigator Charlie Cooper.”[3]

According to Cooper, conventional water treatment methods, such as reverse osmosis, granular activated carbon or ion exchange resin, do not destroy PFAS; they simply concentrate PFAS in a form that subsequently requires treatment or disposal. In some cases, conventional water treatment techniques can even make the environmental contamination worse. In contrast, the electron beam actively destroys the forever chemicals quickly, enabling a larger volume of water to be treated in the same amount of time as some other methods. Electron beams could also be used in pump-and-treat methods, a common groundwater treatment approach.

Additional research showing much promise is from Selma Thagard, a chemical engineer at Clarkson University, in Potsdam, New York. Thagard was developing a plasma reactor for water treatment in 2016 when an environmental-engineer colleague suggested she add PFAS to the water she was testing. This addition was suggested to create a useful reference sample since the PFAS wouldn’t ostensibly be destroyed by Thagard’s plasma reactor. However, in just a few minutes, the chemicals were gone.

“When plasma degraded PFAS so rapidly, within minutes, ‘That’s not right. Nothing can degrade PFAS,’ Thagard said. She ran the test seven or eight more times, and each time the chemicals disappeared.”[4]

Thagard is also chief executive of DMAX Plasma, a start-up firm she founded in Potsdam to commercialize the technology. The start-up has sold small systems to military and industrial customers, but with some engineering work, this could be scaled up to meet the needs of water-treatment plants.

In addition to these examples, there are many other scientists, institutions and organizations throughout the country developing methods to break down PFAS into fluoride and carbon dioxide, which are not dangerous in the small amounts produced. The challenging questions are where in the water cycle to deploy them and which methods are cost effective.

Exceeding thresholds and real-time information

Monitoring is a core component of a NPDWR and assures that water systems are providing necessary public health protections. Given the extremely low concentrations deemed acceptable, there are not yet any real-time analytical methods for PFAS. “Currently, approved EPA methods of measurements involve the use of solid-phase extraction (SPE) to concentrate the sample followed by LC-MS/MS analysis. This method provides information regarding compound occurrence and concentrations based on multiple lines of evidence,”[5] and samples are shipped off to a laboratory for analysis.

However, there are real-time values that measure the efficiency of the processes that actively remove PFAS. For those plants operating in environments at risk for exceeding the limits, monitoring of such processes becomes more important. New investments in assets like GAC (granular activated carbon) filters, ion exchange, and reverse osmosis will require ongoing maintenance and monitoring, which is where real-time monitoring and remote notification can be helpful.

Multiple instrument-based methods exist for sensitive and selective detection of PFAS in a variety of matrices, but these methods suffer from expensive costs and the need for a laboratory and highly trained personnel. There is a big need for fast, inexpensive, robust, and portable methods to detect PFAS in the field. This would allow environmental laboratories and other agencies to perform more frequent testing to comply with regulations.[6]

Again, while there currently isn’t a way to utilize real-time monitoring to check if utilities are exceeding threshold levels, if they know the reverse osmosis system isn’t operating efficiently, for example, and that system is what reduces PFAS to acceptable levels, then this equipment needs to be checked and more closely monitored. Since the monitoring frequency for any PWS depends on previous monitoring results, analyzing historical data allows operations management to identify patterns, trends, and anomalies that may otherwise go unnoticed.

Reporting

Reporting software enables organizations to turn raw process data into actionable information, thereby increasing efficiency and reducing costs. Furthermore, automated reporting solutions streamline regulatory compliance by collecting data from various sources like SCADA, LIMS, and manual entry. As the data is collected it is summarized as key metrics – flow totals or turbidity threshold analysis. These advanced reporting solutions offer templates for compliance, making it easy to populate and publish in the format required by regulatory authorities like the EPA.

Big challenge, big impact

While promising methods to eradicate PFAS are emerging, there is still much work to be done to find solutions that can be replicated from labs and small-scale programs to full treatment plants and do so cost effectively.

A study released by the American Water Works Association found that the estimated national cost for water systems to install current-market treatment systems to remove PFOA and PFOS to levels required by the EPA proposal would exceed $3.8 billion annually. While there are many funding options available, including $4 billion through the Drinking Water State Revolving Fund (DWSRF), $5 billion through EPA’s Emerging Contaminants in Small or Disadvantaged Communities Grant Program, and an additional $12 billion in BIL DWSRF funds for safer drinking water, industry groups representing water utilities have expressed concerns that the proposed standards would exceed the additional funding provided by the agency.

*As of the article deadline, the regulations were not finalized.