Per- and polyfluoroalkyl substances (PFAS), including perfluorooctane sulfonic acid (PFOS) and Perfluoroocanoic Acid (PFOA), is a family of environmentally persistent substances that have been in the headlines lately and subject of a Hollywood movie, Congressional task force, California Legislative and State Water Board regulatory actions and public concern. PFAS were used extensively in the United States and globally since the 1940s with peak production years in the United States between 1970 and 2002 due to their unique ability to reduce the surface tension of liquids. PFAS chemicals are resistant to heat, water, stains, grease and oil and are found in every American household in products as diverse as non-stick cookware, furniture, clothing, dental floss, cosmetics, lubricants, paint, carpets, pizza boxes, popcorn bags, etc. They are extremely mobile in water and can make their way to wastewater treatment plants, although this chemical is ubiquitous due to its widespread use. The State Water Resource Control Board (SWB) is investigating the presence of PFAS in California waters and is implementing a three phased plan which requires monitoring for some PFAS compounds to better understand locations, sources and fate of PFAS to California waters[DW1] .
Some PFASs are no longer manufactured in the United States due to a voluntary phase-out program, although it is still used in some industrial processes such as in semiconductors, printed circuits, aviation equipment, defense, pesticides, and solar panels. Other countries still produce PFOA and PFOS and products that contain them may be imported into the United States. There is some evidence that exposure to PFAS at certain levels can lead to adverse health outcomes in humans, while health outcomes are still largely unknown as well as the most significant pathways.
To address this concern, nationally at USEPA, and in California at departments including the SWB, Office of Environmental Health Hazard Assessment (OEHHA), the Department of Toxic Substance Control (DTSC), and the California Air Resources Board (CARB), regulatory agencies are all taking actions to protect public health. CVCWA is monitoring actions being taken by the SWB which has to date included establishing notification levels for drinking water systems at 6.5 parts per trillion for PFOS and 5.1 parts per trillion for PFOA. The SWB is also working with OEHHA to establish primary drinking water standards for certain PFAS compounds and is implementing its three phase PFAS investigation.
Phase 1 of the SWB’s PFAS Phased Investigative Approach included investigative orders at airports, municipal solid waste landfills and nearby drinking water systems as well as impacted drinking water sources. Phase 2 includes primary manufacturing facilities (likely not present in California), refineries, bulk terminals and non-airport fire training areas, and 2017-18 urban wildfire areas. As the SWB is learning more and as analytical methods are being developed, the SWB is modifying its investigation. Recently a 13267 letter was sent to chrome platers and some drinking water systems. These letters may include a questionnaire, and typically require development and implementation of a monitoring workplan which is typically reviewed and approved by the appropriate Regional Water Board.
Currently wastewater treatment plants are identified in the third phase of the State Water Board’s investigation plan, the third phase being set to begin no earlier than mid-February 2020. CVCWA is working with our other clean water partners (CASA – California Association of Sanitation Agencies, BACWA – Bay Area Clean Water Agencies, and SCAP – Southern California Alliance of POTWs) and SWB Staff concerning the PFAS monitoring scope at wastewater treatment plants (WWTPs). SWB Staff is currently planning to issue 13267 letters for influent, effluent, and biosolids testing at a subset of WWTPs based on factors such as facility size, relative location to known hotspots, and proximity to sensitive watersheds. Collaborative efforts will be considered. If your WWTP has tested for PFAS, CVCWA would like to know as it may help reduce the monitoring levels for the WWTP sector. Please email Debbie Webster at firstname.lastname@example.org if your WWTP has conducted PFAS monitoring. Late this spring, the Delta Regional Monitoring Plan is set to begin monitoring for PFAS as part of its Contaminants of Emerging Concern (CEC) pilot program, which will include some WWTP monitoring as well as stormwater and ambient monitoring.
CVCWA has compiled this list of resources below to help you communicate about PFOS with your customers and stay apprised of these regulatory efforts.
Fact Sheets to help you communicate within your agency and to your customers:
State Water Board Websites for PFAS:
- SWB Primary Webpage (guidance, accredited labs, updates, FAQs, links to the December 2019 PFAS Seminar and more) https://www.waterboards.ca.gov/pfas/
- SWB GAMA Groundwater Information Sheet https://www.waterboards.ca.gov/gama/docs/pfoa.pdf
- SWB Sampling/Investigation results https://geotracker.waterboards.ca.gov/
- SWB Email: PFAS@waterboards.ca.gov
- SWB’s 13267 letter sent to the Chrome Plating Industry https://www.waterboards.ca.gov/pfas/docs/pfas_final_order_chrome_plating.pdf
- USEPA’s Primary PFAS website: www.epa.gov/pfas
- USEPA Human Health Advisory for Drinking Water and Groundwater
- USEPA PFAS Action Plan https://www.epa.gov/pfas/epas-pfas-action-plan