There has been much talk in recent years around per- and polyfluoroalkyl substances (PFAS) and their impacts on environmental and human health. It’s estimated that more than 200 million Americans are likely drinking water and eating food contaminated with PFAS. Research has shown that high-level exposure to PFAS could be linked to cancer and other health hazards, including reproductive issues. The conversation surrounding these risks has reached such heights that it became part of discussions during the election cycle.
As an EHS manager or engineering and operations director, you’ve been paying attention to the good, the bad and the evolving information. PFAS presents many challenges including applying correct sampling techniques, predicting emerging guidance levels, understanding fate and transport, evaluating risks and communicating those risks to management, regulatory agencies, stakeholders and the public.
To face these challenges and future-proof your operations, you aspire to eliminate PFAS in wastewater and stormwater discharges. But investing in a new treatment system is expensive and cumbersome.
How do you get stakeholders on board? How do you cope with the PFAS challenge while maintaining operations? How to do you plan for regulations that change constantly?
Ramboll has been at the forefront of risk mitigation pertaining to PFAS for more than 20 years. While each situation is different, and each company’s objectives unique, we have a well-honed starting point when it comes to creating PFAS reduction programs.
A phased approach
The good news is that it is indeed possible to run a PFAS reduction program that is both cost effective and efficient. Rather than reinventing your treatment setup, we suggest a phased process:
Phase 1: Source control
Survey the facility and the manufacturing site to identify aqueous inputs and outputs
The product of this work serves as the basis for development of a sampling plan for source identification. The survey could identify important elements related to the site’s water supply and wastewater sources.
Phase 2: Preliminary site review
Conduct a preliminary site review to identify chemicals that may contain PFAS or PFAS precursor compounds. Identify any known PFAS-containing chemicals in use at the facility such as fire suppression foams as well as PFAS compounds or precursors that might be present in chemicals.
Phase 3: Confirmatory sampling
Conduct confirmatory PFAS sampling of treated effluent: Confirm and quantify PFAS concentrations in the treatment discharges and residuals. Ensure proper training of site personnel according to an approved PFAS Sampling Guidance document to reduce the risk of false positives. As necessary, submit information to authorities outlining the next phases and associated schedules.
Phase 4: Systematic sampling
As necessary, develop and implement a systematic sampling and analytical plan (SAP) to identify potential sources of PFAS entering the WWTP based on streams identified during previous phases.
Phase 5: Source reduction and monitoring plan
Define and implement a source reduction and monitoring plan to reduce and/or eliminate PFAS. Data collected during Phase 4 will be used to develop the source reduction and monitoring plan to comply with the state requirements – and to make sure that any solution is economically sound.
By following this phased approach you will know what type of PFAS is present, can identify ways to either treat or eliminate the sources, and can design and implement a monitoring/reduction plan for the next three to five years.
Evolving regulations
Research suggests that stricter regulations around PFAS are coming in the near future. As mentioned in this article from The PFAS Project Lab, President Biden has already pledged to set enforceable limits for PFAS in drinking water and to designate PFAS as a hazardous substance under the Superfund cleanup law as part of his environmental justice plan. President Biden has also pledged to prioritize PFAS substitutes in the marketplace, which means USEPA and USFDA could be tasked with quickly phasing out non-essential uses of PFAS in food packaging, cosmetics, sunscreens and other everyday products.
The approach laid out above allows you to go back and adjust your monitoring and sampling based on updated regulations. This fore knowledge could even give you the opportunity to discover and develop PFAS substitutes, giving you a competitive advantage as stricter and more consistent regulations are developed.
PFAS challenges won’t disappear on their own. Industries need to be prepared for new regulations and the costs associated with them or face unforeseen consequences. Our approach provides a way to effectively monitor the situation and adjust your plans as regulations solidify and new issues arise.
Ramboll can help. If you are interested in working with us on source reduction and monitoring plan for your site, please reach out to one of our experts.
LEARN MORE ABOUT RAMBOLL'S APPROACH TO INNOVATIVE PFAS MANAGEMENT
Janet Egli has 30 years of experience in water and wastewater management. She has particular expertise in innovative treatment technology evaluations and designs, providing the most cost-effective approach to achieve desired water quality. Janet specializes in integrated water management, complementing production processes while minimizing environmental impacts. She has delivered projects around the world for a variety of industries supporting their goals of reducing emerging constituents of concern with specific focus on PFAS.