NRWA is gathering information across the country to see how many water systems have been affected or have growing concerns about perand polyfluoroalkyl substances (PFAS).
What is PFAS?
PFAS are a group of manmade chemicals that includes PFOA, PFOS, GenX and many other chemicals. PFAS have been manufactured and used in a variety of industries around the globe, including in the United States since the 1940s. PFOA and PFOS have been the most extensively produced and studied of these chemicals. Both chemicals are very persistent in the environment and in the human body—meaning they don’t break down and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects.
What are the possible health effects?
Studies have shown an association between increased PFOA and PFOS blood levels and an increased risk for several health effects, including effects on the liver and the immune system, high cholesterol, high blood pressure, thyroid disorders, pregnancy-induced hypertension and preeclampsia and cancer (testicular and kidney).
Where can PFAS be found?
PFAS may be in drinking water, food, indoor dust, some consumer products and workplaces. Blood serum concentrations of PFASs are higher in workers and individuals living near facilities that use or produce PFASs than for the general population. Pathways of exposure include ingestion of food and water, use of consumer products or inhalation of PFAS-containing particulate matter (e.g., soils and dust) or vapor phase precursors.
What is being done?
On October 10, 2008, the U.S. Environmental Protection Agency (USEPA) announced a negative regulatory determination for perchlorate in accordance with the SDWA, "The Agency determined that a national primary drinking water regulation (NPDWR) for perchlorate would not present a meaningful opportunity for health risk reduction for persons served by public water systems."
USEPA revised this determination on February 2011 with an affirmative conclusion. "EPA has determined that perchlorate meets SDWA’s criteria for regulating a contaminant—that is, perchlorate may have an adverse effect on the health of persons; perchlorate is known to occur or there is a substantial likelihood that perchlorate will occur in public water systems with a frequency and at levels of public health concern; and in the sole judgment of the Administrator, regulation of perchlorate in drinking water systems presents a meaningful opportunity for health risk reduction for persons served by public water systems. Therefore, EPA will initiate the process of proposing a national primary drinking water regulation (NPDWR) for perchlorate."
Eight years later, USEPA announced a PFAS Action Plan to respond to the public interest and utilized information received. This represents the first time EPA has built a multimedia, multi-program, national communication and research plan to address an emerging environmental challenge like PFAS.
EPA’s Action Plan identifies both short-term solutions for addressing these chemicals and long-term strategies that will help provide the tools and technologies that states, tribes and local communities need to provide clean and safe drinking water to their residents and to address PFAS at the source—including before it gets into the drinking water.
The USEPA Action Plan includes:
1 PFASs are persistent in the environment, meaning they are resistant to typical environmental degradation. Water providers suffer significant operation and maintenance costs because these chemicals never degrade, making it harder to get them out of water systems.
2 Blood serum concentrations of PFASs are higher in workers and individuals living near facilities that use or produce PFASs than for the general population. Pathways of exposure include ingestion of food and water, use of consumer products or inhalation of PFAS-containing particulate matter (e.g., soils and dust) or vapor phase precursors.
3 Studies have shown an association between increased PFOA and PFOS blood levels and an increased risk for several health effects, including effects on the liver and the immune system, high cholesterol, high blood pressure, thyroid disorders, pregnancy-induced hypertension and preeclampsia and cancer (testicular and kidney).
4 During manufacturing processes, PFASs are released to the air, water and soil in and around manufacturing facilities. Recently, PFOS and PFOA contamination has also been observed in facilities using PFAS products to manufacture other products (secondary manufacturing facilities).
5 PFAS has been detected in surface water and sediment downstream of production facilities and in wastewater treatment plant effluent and sewage sludge.
Together, these efforts will help EPA and its partners identify and better understand PFAS contaminants generally, clean up current PFAS contamination, prevent future contamination and effectively communicate risk with the public. To implement the Action Plan, EPA will continue to work in close coordination with multiple entities, including other federal agencies, states, tribes, local governments, water utilities, industry and the public.
In April 2019, a key component of the Action Plan, a draft interim guidance for addressing groundwater contaminated with perfluorooctanoic acid (PFOA) and/or perfluorooctane sulfonate (PFOS), was released for public review and comment.
A month later, USEPA released the pre-publication version of the proposed perchlorate drinking water regulation. USEPA asked for comments on a proposed Maximum Contaminant Level (MCL) and Maximum Contaminant Level Goal (MCLG) of 56 micrograms per liter. In addition, the Agency is seeking comment on three alternative regulatory options: an MCL and MCLG for perchlorate set at 18 micrograms per liter, an MCL and MCLG for perchlorate set at 90 micrograms per liter and withdrawal of the Agency’s determination to regulate perchlorate.
The rule denies any opportunity for a small community "variance," which is a compliance option authorized in the Safe Drinking Water Act that allows a small community that exceeds the MCL at a level that presents no harm to the public to have access to an affordable compliance option.
NRWA had asked EPA to clarify the "intelligible principle" used by the Agency in implementing the decision to select perchlorate as a regulation. The proposal does not include any articulated "intelligible principle" for how EPA decided to select perchlorate for regulation. The proposed rule does not explain what principle EPA relied on to determine how to select perchlorate for a SDWA regulation.
What you can do now?
NRWA is bringing together utility systems from across the country that have concerns or have been affected by PFAS contamination. NRWA has set up a page on its website, NRWA.org/initiatives/PFAS, for systems to enter their information. This information will allow NRWA to arrange a free evaluation of the system and provide more details about efforts to recover costs for remediation and treatment from PFAS contamination.
Visit nrwa.org/initiatives/pfas to learn more and be a part of future efforts to recoup costs from PFAS contamination.