Advanced GeoServices, a Montrose Environmental company, attended USEPA's (EPA) Per- and Polyfluoroalkyl Substances (PFAS) Community Engagement event in Horsham, PA on July 25th. The all-day event featured panels consisting of Federal, State, local government, community and then a listening session from the public. Common themes from the communities were that PFAS standards are greatly needed and without enforceable standards:
- The public cannot be protected, and
- The regulatory communities cannot mandate cleanups.
The communities with impacted water supplies from the military bases were unanimous in that the Federal Government who contaminated the water supplies should pay for the remediation and any required water treatment, not the residences.
It was apparent from the event, and Advanced GeoServices’ own experience, that there are major differences in the assistance the public and municipalities were receiving from State and Federal agencies - depending upon what State and EPA Region you were located. States, such as PA, have taken a low profile in developing PFAS standards and seem to have gotten fewer assistance with medical monitoring, remediation costs and other environmental studies than other states and regions.
EPA stated there will be a push to have PFAS listed as a hazardous substance under CERCLA. This will then provide the enforcement teeth for Superfund to require investigations and cleanups and go after reimbursement from the polluters. EPA also stated they believe air emissions are a major migration pathway of PFAS and they are working on procedures for air sampling and analytical standards.
The major water providers, like Aqua PA, are using EPA's Health Advisory Level (HLA) of 70 ppt for PFOA/PFOS. Tainted water supplies below these limits are not being treated, even though recent toxicological data for PFOA and PFOS suggest these limits (maybe 7 to 10 times higher than they should be) to be considered safe for human consumption. There are between 2,500 to 3.500 individual PFAS, and only a handful have been studied for toxicological affects. The ones that have (e.g., PFNA, PFHxS, PFBS, and GenX) all suggest that standards should be closer to 10 ppt. Probably the most alarming news was how much PFAS contamination is continuing to be discharged through stormwater runoff from these federal military bases and airports into the waterways because of lack of enforceable standards and regulations.
The science and engineering for understanding and addressing PFAS contamination is still evolving. Advanced GeoServices and it's sister Montrose companies are actively working on multiple PFAS-related projects. Montrose senior technical personnel will be attending the next USEPA sessions in Colorado and the following session in North Carolina to stay abreast of this national issue.
If you have any questions regarding the Horsham event or other #PFAS questions, please contact:
Senior Project Consultant