By Guest Blogger Van Burbach, PhD, PG
Did you miss Dr. Burbach's Post: PFAS- What's all the fuss about?
PFAS has been in the news a lot recently, so here is an update on recent actions and plans from both the US EPA and the North Caroline DEQ. PFAS (per- and poly fluoroalkyl substances), are often referred to as “forever chemicals” because they do not readily degrade in the environment or in our bodies, and therefore tend to build up over time. PFAS refers to a large class of chemicals which includes more than 5000 specific compounds. The most common and most studied of these compounds include perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA), both of which can no longer be manufactured in the USA. A subset of PFAS that have been especially impactful in North Carolina are the GenX compounds, which were released to both surface water and the atmosphere from the Chemours facility in Fayetteville and have been the subject of intense investigations and legal actions against Chemours by the North Carolina Department of Environmental Quality (NCDEQ) in recent years.
What sets PFAS apart is that they have multiple carbon-fluorine bonds, which are one of the strongest chemical bonds in nature. This is why they do not degrade and are hard to destroy. All PFAS are man-made and can be found in many common consumer products, including food packaging, water-resistant or stain-resistant clothing, non-stick cookware, and fire-fighting foam. Nearly all Americans have been exposed to PFAS and studies show that more than 98% of Americans have detectable levels of PFAS in their blood.
According to the United States Environmental Protection Agency (EPA)1, current peer-reviewed scientific studies have shown that exposure to certain levels of PFAS may lead to:
Reproductive effects such as decreased fertility or increased high blood pressure in pregnant women;
Developmental effects or delays in children, including low birth weight, accelerated puberty, bone variations, or behavioral changes;
Increased risk of some cancers, including prostate, kidney, and testicular cancers;
Reduced ability of the body’s immune system to fight infections, including reduced vaccine response;
Interference with the body’s natural hormones; and
Increased cholesterol levels and/or risk of obesity.
In October 2021, the EPA release its PFAS Strategic Roadmap: EPA's Commitments to Action 2021-20242. The EPA’s Roadmap presented an integrated approach to PFAS focused on three central directives:
Research. Invest in research, development, and innovation to increase understanding of PFAS exposures and toxicities, human health and ecological effects, and effective interventions that incorporate the best available science.
Restrict. Pursue a comprehensive approach to proactively prevent PFAS from entering air, land, and water at levels that can adversely impact human health and the environment.
Remediate. Broaden and accelerate the cleanup of PFAS contamination to protect human health and ecological systems.
On June 15, 2022, the EPA issued new health advisories for four specific PFAS3, as follows:
Interim Health Advisory for PFOA = 4 parts per quadrillion (ppq);
Interim Health Advisory for PFOS = 20 ppq;
Final Health Advisory for GenX chemicals = 10 parts per trillion (ppt); and
Final Health Advisory for PFBS = 2000 ppt.
The new advisory levels for PFOS and PFOA are incredibly low. To put this into perspective, one ppq is equivalent to approximately one gallon of water in all of Lake Michigan. These levels are below the technical ability of most laboratories to detect in any but the most pristine samples and analytical conditions. The previous EPA Health advisory for PFOS and PFOA combined (issued in 2016) was 70 ppt. Note that these are Health Advisory Levels, NOT regulatory standards. Health Advisories are issued for informational purposes and are not legally enforceable. There is still no enforceable federal standard for any PFAS.
To bring this down to our local level - the most recent sample results (dated May 10, 2022) released by the City of Greensboro, NC Water Resources Department found PFOS at 24 ppt and PFOA at 3.7 ppt in Greensboro’s drinking water. These results are approximately 1000 times the new Health Advisory levels. Again, these are not enforceable drinking water standards, so when the city says that our drinking water meets all federal and state standards, that is technically correct.
Another new development in the PFAS arena came on June 7, 2022, when the NCDEQ issued its Action Strategy for PFAS4. The NCDEQ strategy prioritizes three key action areas: Protecting Communities; Protecting Drinking Water; and Cleaning Up Existing Contamination. The strategy presents NCDEQ’s plan to propose state regulatory standards for PFOA, PFOS, Gen-X, PFBS, and PFBA to the North Carolina Environmental Management Commission (EMC). NCDEQ anticipates proposing groundwater standards by summer/fall 2022, surface water standards by fall/winter 2022/2023, and drinking water standards by fall/winter 2022/2023. Proposing standards to the EMC is the first step in the regulatory process to make these standards state law. The EMC will then review the proposed standards and make recommendations to the NC legislature, which in turn will need to pass legislation to promulgate the standards into law. This process could take years.
On a positive note, both the EPA and the NCDEQ have made PFAS a significant priority. Not only does this bode well for eventually getting enforceable state or federal standards for at least the most common PFAS, it also means that more resources will be available for state and local agencies to address PFAS contamination. In their June 15, 2022, announcement, the EPA issued an invitation to states and territories to apply for $1 billion (the first of $5 billion in the Bipartisan Infrastructure Law grant funding) to address PFAS and other emerging contaminants in drinking water, especially for small and/or disadvantaged communities.
USEPA, 2022. Our Current Understanding of the Human Health and Environmental Risks of PFAS. https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas. Updated March 16, 2022.
USEPA, 2021. PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024. EPA-100-K-21-002. October 2021.
City of Greensboro Water Resources Department, 2022. https://www.greensboro-nc.gov/departments/water-resources/water-system/pfos-pfoa-updates/pfos-pfoa-sample-results. Accessed 7/20/2022.
NCDEQ, 2022. Action Strategy for PFAS. June 7, 2022.
Dr. Burbach brings a broad background in geology and geophysics to the table. He worked for over six years in the oil industry and for over 20 years in environmental project management. He has also served as a visiting research professor at North Carolina A&T State University. He has extensive experience in the development, planning and implementation of environmental assessment and remediation projects and hydrogeological and geophysical investigations.
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