U.S. EPA looks back at third year of PFAS Roadmap implementation

In 2021, the Environmental Protection Agency (EPA) put together their PFAS Roadmap. This roadmap delineated many of the tasks they have taken on in the last three years, although work on PFAS had been going on in the agency already before that. Several EPA staff were present at the Great Lakes PFAS Summit this year to talk about the work that has been done in the last three years with that roadmap as a guidance document. 

Their third annual progress report was recently published, according to Zach Schaefer of the EPA, and he and several other staff members came to the PFAS Summit to talk about that progress report and the work that has been done to research, restrict and remediate PFAS.

In 2024, the EPA set Maximum Contamination Levels (MCLs) for six different PFAS under the Safe Drinking Water Act. They also designated PFOS and PFOA as hazardous substances under the Comprehensive Environmental Response and Compensation Liability Act (CERCLA).

“This will reduce PFAS for more than 100 million people in America and avoid thousands of deaths and tens of thousands of avoidable illnesses over the life cycle of this rule,” Schaefer said of the established MCLs. The designation of hazardous substances, he said, will help states as well as the EPA to hold polluters accountable for their actions and to get those entities to think twice about releasing those PFAS into the environment as well as to help communities recover the costs associated with cleaning up those contaminants. The agency also issued an enforcement discretion policy to help to provide some relief for passive users such as fire departments, airports and farmers who have had to handle of use PFAS through no fault of their own. Schafer said those were the two most high profile actions taken by EPA this year, but there were many other undertaking in the area of PFAS as well. 

Work has been going on in the chemical safety office also, he said. The EPA has been working to close loopholes using the Toxic Substances Control Act and their Toxic Release Inventory, EPA has been able to close loopholes on PFAS that may no longer need to be used as well as to establish review of PFAS before they are used in commerce to ensure the safety of those compounds to the public and the environment. All of these action, Schafer said, helped the agency to achieve one of the goals of the roadmap: getting upstream of the problem to prevent dangerous PFAS before it is used.

The agency has also put a great deal of time and money into addressing PFAS in drinking water and wastewater nationwide. In order to do this, they utilized $10 billion that was dedicated in a bipartisan infrastructure law to addressing emerging contaminants, which included PFAS. This funding, Schaefer said, has gone out to states and communities nationwide. States also have the ability to use a portion of that funding to address PFAS in private drinking water wells, a subject about which most Northwoods residents are quite aware.

Further steps have also been taken in the area of enforcement. The enforcement and compliance office has established PFAS as one of their national enforcement compliance initiative priorities, according to Schafer, for 2024 to 2027.

Brian Demico of the EPA spoke about two new analytical methods to measure PFAS compounds that had been developed in the last year. The first, EPA Method 1633, can measure  up to 40 specific PFAS compounds in wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate and fish tissue.

The second method was called EPA Model 1621. This measures adsorbable organic fluorine, which while not a PFAS itself, can be used to screen for PFAS in certain waste waters where PFAS is suspected to be occurring, he said. 

Demico also spoke about some studies on which the EPA had been working in the last two years. These were the POTW (publicly owned treatment works) Influent study as well as the Textile Mills Study. In the first study, EPA looked to work with POTWs to leverage their resources to collect industrial discharges with a goal of collecting a nationwide data set on PFAS in industrial waste water. At the end of this study, he said, the data will then be made available for public use. Sampling activity should start to take place in 2025. 

The goal of the second study was to collect data on PFAS discharges from manufacturing of textiles. The goal would be to distribute a questionnaire that would allow the agency to learn more about processes occurring at those facilities and their use of PFAS and any potential discharges of PFAS.

Effluent limitation guidelines are another deliverable from the EPA’s PFAS roadmap, Demico said. Those guidelines have been introduces for PFAS manufacturers, metal finishing an electroplating and landfills. The agency, he said, would be looking to set technology-based discharge limits on waste water generated from those facilities that produce PFAS.

In the area of electroplating, the agency is currently in the data gathering process, so it is not as far along as the limitations set for PFAS manufacturers. Landfill limitation guidelines were just announced recently, he said, and work has begun on that regulation front as well. 

Colleen Flaherty then spoke about the drinking water regulation end of things where PFAS was concerned. She said her team was able to finalize enforceable standards for PFAS in water, as well as to publish final human health toxicity assessments for PFOA and PFOS. Those assessments, she said, would then be used to assess the risk in other media of those two chemicals. 

Flaherty’s team also finalized a framework to estimate health risks associated with PFAS mixtures. Information about all of these things, she said, is available on EPA’s rule making website.

Another area in which Flaherty has been working is in disseminating information to states and tribes to help them to better protect their water bodies. For some PFAS, where data is limited, Flaherty said, it can be difficult to determine toxicity to aquatic life and to human health as well. These are, of course, simply recommendations given to states and tribes, but those entities are free to create their own standards.

In October, EPA released its final aquatic life criteria for PFOA and PFOS and eight benchmarks protection of aquatic life for certain data-limited PFAS. Flaherty expected human health criteria for several PFAS to be released soon after the summit.

Biosolids risk assessment for PFOA and PFOS has been another area garnering attention and time from EPA staff, she said. The agency was required to assess potential environmental and human health impacts of contaminants found in sewage sludge under the Clean Water Act. They have been looking into those two compounds and associated risks with land application of biosolids contaminated with PFAS. Those efforts are focused on farming communities and areas nearby areas where those biosolids are land-applied. That draft risk assessment should also be available for public comment soon, she said. Where human exposure is concerned, researchers are most interested in pathways in both drinking water and diet. 

Susan Burden from EPA’s Office of Research and Development spoke about some of the human health assessment products that had been coming out of that office. That office has a large resource portfolio available, she said. 

“Anything you can think about related to PFAS science, we probably are doing some work within the Office of Research and Development,” Burden said. One of the highlights she touched on was human health assessments for PFAS. This is being done through EPA’s Integrated Risk Information System (IRIS). Several assessments have been finalized and two more have been released in draft form for public comment. She expected those to be finalized this year. In one of the products, the EPS transcriptomic assessment product, the agency is actually doing the toxicity testing, as there is no data available for human toxicity levels for some of these compounds. The first of these is now available on the EPA website, she said. 

Burden also spoke about research grants. This past fall, she said, the agency awarded over $15 million in research grants focused on getting a better understanding of uptake and bioaccumulation of PFAS in plants and animals. Both Michigan and Illinois have received research funds through this program. 

Another guidance that has been finalized was guidance for destruction and disposal of PFAS. That is required to be updated every three years, Burden said, with the second version of this guidance being released in 2024. There is also a great deal of research going on surrounding these topics as well. To learn more about PFAS and the research and deliverables of the EPA where PFAS is concerned, see their website at epa.gov.

Beckie Gaskill may be reached via email at [email protected].