Compounding Compounds:

Complying With New PFAS Regulations

The Clean Water Act of 1972 and the Safe Drinking Water Act of 1996 were created to protect surface and drinking water resources. This is accomplished through the regulation of known contaminants and continued identification of emerging contaminants that have been found to be harmful to human health and the environment.

One of the first steps to identifying these contaminants is to determine their abundance in our water sources. The testing applied by the Unregulated Contaminant Monitoring Rule (UCMR) is one way this is done. Every five years, the UCMR identifies 30 unregulated contaminants to be monitored by public water systems that might pose threats to our drinking water supply and require regulation.

It recently identified select compounds known as per- and polyfluoroalkyl substances, or PFAS, in certain drinking water resources throughout the country. This drew further attention to the presence of these emerging contaminants in water bodies near where PFAS were used and produced.

In 2016, the U.S. Environmental Protection Agency (EPA) established a health advisory for two PFAS, perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA). The EPA’s advisory set a limit of 70 parts per trillion for the combined concentration of these compounds in drinking water to provide Americans, including the most sensitive populations, with a margin of protection from a lifetime of exposure to PFOS and PFOA from drinking water. This has set the stage for new enforceable drinking and groundwater standards to be established at the local, state and federal levels.

New regulations have made the continued use of PFAS compounds an environmental issue. Owners and operators in the manufacturing, aviation, oil and gas, utilities, and water/wastewater treatment industries, as well as municipalities and the Department of Defense, must respond by addressing applicable risks to the manufacturer and consumer.

The chemical characteristics that made these compounds ideal for their intended use create a unique set of challenges for environmental practitioners. For example, these compounds will not naturally degrade in the environment and are resistant to many existing remedial technologies.

As regulatory and public attention to PFAS escalates, project managers and their environmental consultants should engineer a solution that considers all available technologies and approaches to PFAS remediation alongside operational and risk management goals.