PFAS Federal Facility Accountability Act of 2018

PFAS Federal Facility Accountability Act of 2018

The Subcommittee on Energy has introduced the PFAS Federal Facility Accountability Act of 2018. This bipartisan legislation requires federal agencies to cooperate with states as per- and polyfluoroalkyl substances (PFAS) contamination is detected in communities near federal facilities, such as active military installations, former military installations, or National Guard facilities.  For affected states, the individual State Agreements must be executed within 1 year of the Bill enactment.  If passed into law, this bill will help speed up coordinating the response between state and federal agencies in handling these contaminants.  

PFAS comprises a group of chemicals used in firefighting, manufacturing, and common household and consumer products and are deemed a threat to human health and the environment.  These chemicals can be found in water, soil, air, and wastewater and were frequently used in firefighting foam commonly used at federal facilities.

Advanced GeoServices and its sister companies have been actively working on PFAS projects and other emerging contaminants and can assist you with your PFAS issues.

For more information on this legislation and PFAS, contact:

Rick Shoyer, LSRP
Senior Project Consultant

USEPA PFAS Horsham, PA Engagement Session

Image courtesy of Carpe Diem! Philadelphia

Image courtesy of Carpe Diem! Philadelphia

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: 

  1. The public cannot be protected, and
  2. 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:

Rick Shoyer
Senior Project Consultant

PADEP Southeast District Update

The Pennsylvania Department of Environmental Protection (PADEP), Southeast District provided a regulatory update on a variety of topics on June 18, 2018:

PADEP Southeast District Update

  • The District is still trying to fill several Section Chief positions and is hopeful they will be filled in the near future.
  • The Land Recycling Program Technical Guidance Manual (TGM) is currently being updated with a goal of it being finalized later this year. Several plan changes include:
    • Combining the vapor intrusion guidance into the TGM, and
    • Separating the toxicological tables out of the TGM, which will allow the PADEP to more readily make changes in the future.
  • The Per- and Polyfluoroalkyl Substances (PFAS) investigations of the Department of Defense (DoD) bases in Warminster and Horsham, as well as, the Easton Road PFC and Ridge Run PFC HSCA sites. To date, the sources of the Hazardous Sites Cleanup Act (HSCA) sites have not been identified. The District has reported that the PADEP is requiring some industrial National Pollutant Discharge Elimination System (NPDES) permit renewal applicants to provide data on PFAS; however, the PADEP does not have any current plans to follow in the footsteps of New York State or New Jersey and develop state Maximum Contaminant Levels (MCL’s) or initiate/mandate PFAS investigations at potential source sites.

Thanks to the Society of Women Environmental Professionals, Philadelphia Chapter for arranging the PADEP update.

For more information on this topic, contact:

Steve Kirschner, P.E.
Senior Project Professional