Episode 53 – PFAS Update

Welcome to the TRSA podcast. Providing interviews and insights from the linen, uniform, and facility services industry. Most Americans might not realize it, but they benefit at least once per week from the cleanliness and safety of laundered, reusable linens, uniforms, towels, mats, and other products provided by various businesses and organizations. TRSA represents the companies that supply, launder, and maintain linens and uniforms. And in this podcast, we will bring the thought leaders of the industry to you.

 

I’m your host, Jason Risley. Thanks for joining us for another episode of the Linen, Uniform, and Facility Services podcast, interviews and insights by TRSA. On this podcast, we tackle the topic of PFAS and the potential for wastewater discharge limits on linen, uniform, and facility services businesses. Joining us to discuss PFAS is John Shaffer. John is the CEO and principal chemist for EEC Environmental.

 

He has been providing environmental consulting services to the laundry industry for 30 years. John specializes in all things related to industrial wastewater, including permitting, compliance, pretreatment system design, and POTW negotiations. EEC is currently working on multiple PFOS drinking water and waste water projects, and recently conducted an extensive wastewater PFOS sampling study at 3 commercial laundry facilities. Additionally, Shaffer served as an expert on an EPA panel on PFAS drinking water regulations and is presented on PFAS for the National Groundwater Association and multiple wastewater agencies. PFAS, most of you have probably heard that that acronym or the term forever chemicals.

 

And so I’m not going to go into too much of the basics on what’s a bit already been out there in newspapers and so forth. But I I do hope to answer these questions for you. But understand that you’re gonna hear some pretty sobering information in terms of how big of an impact PFAS may have on the laundry industry. There will be some good news at the end. I want you to ask you I wanna ask you, encourage you to hang around till the end for some hopeful messages at the end.

 

So what is PFAS? They’re called forever chemicals because they are manmade and very, very difficult to destroy. They don’t break down, you know, biologically in your body. They don’t break down in nature. And so that’s why they’re called forever chemicals.

 

It’s a it’s a bit of an an exaggeration, but it’s it’s not, the most inaccurate title. There are over 5,000 PFAS compounds that makes it very unique compared to other, contaminants that the laundry industry had to deal with. PFOA and PFAS are the 2 that are most well known. Those are the ones you hear about. And and those are the ones that have been the most studied.

 

And those are the ones that are gonna have limits first. But there are many other PFAS compounds that are now being studied and are being focused on, such as PFBS, PFHXS. You’ll hear more about that. Now PFOA and p f PFAS have been phased out of most US products for years, but not from many imported products. And I’m gonna talk about that because that may have a big impact or already is having a big impact on the laundry industry.

 

And then those 2 compounds along with other PFAS compounds are showing up in wastewater throughout the country in parts per trillion concentrations. And because wastewater is a source to drinking water, a direct source, then it’s very toxic and that it doesn’t break down, there’s 5,000 compounds. The other thing very unique about PFAS compounds is there’s a 0% removal efficiency at the p0 2ws, at the municipal treatment plants. That’s just not true for other constituents. If you’re dealing with copper or mercury or what have you, oil and grease, you’re seeing 80, 90, 99% removal efficiencies.

 

It’s 0%. And in fact, many POTWs are seeing higher PFAS coming out of their treatment plants than they are going into their treatment plants. And I’ll explain why that is. And it’s being found in drinking water wells and surface waters throughout the country. Basically, the more sampling that’s being done throughout the country on drinking water sources, the more PFAS they’re finding.

 

Now I think this is an important, point to make here. Michigan is way out ahead of the rest of the country on PFAS in terms of all the studies they’ve done, all the sampling they’ve done, the regulations they’ve adopted, and they’re sharing everything that they’re doing with the rest of the country. And this is a PFAS water cycle that you have maybe seen before. You’ll see it in other states. It’s very similar.

 

What I wanna focus on here is that the POTW or the wastewater treatment plant is the center of the PFAS universe. That’s where the real focus is around the country on how to control PFAS before it gets into groundwater, before it gets into rivers, and so forth. And then, of course, industries are the most controllable source of PFAS. That’s what’s been discovered through all these sampling studies. It’s not households.

 

It’s gonna be very difficult to control the amount of PFAS that’s coming from households, but it is very controllable, the amount of PFAS that comes from industries. And that’s what that’s that’s where the your permits come in. But if you look at those wastewater treatment plants, they receive your wastewater. They are not removing PFAS. And so it’s going straight through and, in some cases, increasing in concentrations.

 

And then they discharge directly, let’s say, to a river. But also their sludge goes to landfills and then the landfill leachate that drains out from the landfills then goes back into the sewer and it’s like a closed loop type of situation. Landfill leachate is a very high source of PFAS, so it’s being looked at similar to industries. And then the biosolids that are land applied, and that’s become more and more common over the years, that’s a major source of PFAS as well. And so that’s a big issue.

 

So basically, everything coming into a POTW and everything coming out of a POTW is a big, big issue when it comes to PFAS. And this is a really important, table here that that Michigan has shared with the country. And I’m gonna just draw your attention to some of the POTWs that are on the left there that are named in Michigan where they have a lot of data, not only on their influent and effluent of their treatment plants, but also all the industries that discharge and the domestic wastewater that discharges. And then I wanna draw your attention to the final column on the right, where it shows the, what they’ve done here is what they for all the sampling studies they’ve done, and this is good news, some of the good news that you’ll hear more about later, is typically PFAS in terms of the pounds per day is coming from 1 or 2 or 3 or 4 sources of, industrial sources or landfill leachate, rather than, you know, all industries are discharging a significant amount. And so that’s very important.

 

That’s a huge pre, industrial pretreatment success story because they did require these industries, you know, the sources they call them, to put in, let’s say, granular activated carbon systems. Many of them are metal finishers. By just regulating 1 or 2 sources going into the POTW, industrial sources or landfills, they were able to remove the PFAS coming into their POTWs by huge percentages, 99%, 97%, 95%. That’s a huge industrial pretreatment success story. And that’s being taught all over the country.

 

Try to find out who your major sources of PFAS are and then regulate them first and then regulate the others later. Great Lakes Water Authority, you’ll hear more about later. They only had a 23% reduction when they, enforced on 9 of their sources. And why was that? Why weren’t they more successful?

 

And it’s because their domestic wastewater has high PFAS, or in this case, it’s PFOS. This is a particular PFAS compound that Michigan is primarily concerned with right now. So all this data is basically on their PFOS. And I’ll talk more about Great Lakes Water Authority in a minute. And this is very unusual too in the sense that all this industrial sampling, laundries, for example, is being published for the world to see on the on the Michigan’s website.

 

That’s very unusual, to have all this, information from industries to be shared with the world. And these are the sites that they’re finding, PFAS at. And these and this is what they’re focusing on. So landfills, metal finishing sites. And you’ll see commercial industrial laundries, in the kind of the 6th or 7th category.

 

But from an industrial category standpoint, it’s number 4. And so people are hearing about this. This doesn’t mean that laundries are discharging, you know, in the top 10 in terms of pounds per day, but there are so many commercial laundries around the country. When I go to these conferences, with NACA, laundries are often talked about because almost any significant size POTW has at least 1, commercial laundry in their service area. And so everybody’s always wondering, are they a source of this contaminant?

 

Are they a source of that contaminant? And they now know that commercial laundries are a significant source of PFAS. We need to get the word out there that laundries are not in that top tier of PFAS dischargers. There’s just so many laundries out there. I’ll talk more about that later.

 

And then maybe you’re wondering, hey, I have a a laundry or 10 laundries or whatever, and I haven’t really heard much about PFAS other than what’s in the paper and on the news and so forth. You’re gonna be hearing about it soon. If you haven’t been getting questionnaires, if you haven’t been sampled, you may have been your wastewater may have been sampled and you didn’t know it. So, you know, where is this gonna hit the laundry industry first? It’s gonna hit with your wastewater local your wastewater permanent limits.

 

Some people are familiar with the term local limits. It’s something that our company deals with every day because we’re either developing local limits for POTWs or we’re helping industries challenge what are considered non technically based local limits. And I think it’s really important for me to educate the audience here a little bit on how local limits are developed and what kinda drives the limits that end up in your permits. So in most cases, it starts with, the EPA developing drinking water standards, and it starts with drinking water health advisory levels that just came out in mid June. I’ll talk a little bit about more of those in a minute.

 

That kinda starts the process. And then, the EPA or states come out with drinking water MCLs or maximum contaminant levels. And that’s the the ones that, you know, drinking water cannot exceed these levels without treatment or you have to shut down your wells and so forth. And those are coming soon. Their states have already some states have already developed MCLs, but the EPA’s MCLs are coming very soon on PFAS.

 

And then that drives state water quality standards, which is basically like a river discharge standard. What concentration can a POTW discharge to a river or to a lake or to the ocean? Those are the state water quality standards. And because most, surface waters other than the ocean are either directly or indirectly drinking water sources, that’s why the drinking water, standards are what drives state water quality standards. And then, those state water quality standards is what the your POTWs are allowed to discharge.

 

If they’re exceeding those or close to exceeding those, then they have to go back and put regulations on their industries to lower the amount of those contaminants coming into the treatment plant, and that’s where your permit limits come in. The conclusion to all this is, for PFAS, is if drinking water PFAS MCLs are in the part per trillion range, which it definitely looks like they’re headed there, and maybe the low part per trillion range or very low part per trillion range, then laundry wastewater discharge permit limits will be very low as well. And here’s an example where it’s already started. So Michigan, again, like I said, is way ahead of the rest of the country, and they are putting pressure through state regulations, on their POTWs to start developing local limits. And the Great Lakes Water Authority, which is the Detroit area, a very large POTW, was the first one in Michigan to develop a technically based local limit for any PFAS constituent.

 

And EEC was very involved because one of our industrial customers discharges to the Great Lakes Water Authority and they asked us to get very involved. I spoke with the pretreatment coordinator from Great Lakes Water Authority on multiple occasions to try to make sure they were there’s lots of options when you do local limits. You can go a business friendly approach. I’m talking about POTW, or they can go a non business friendly approach. And I won’t go into all those different options, but they did choose a business friendly, nonuniform allocation approach for PFOS.

 

That’s their major focus in Michigan right now is PFOS. The other PFAS compounds will be coming soon. So just to summarize this, they developed a technically based PFOS limit of 65 parts per trillion for all their industrial dischargers. And I can say because I was pretty involved in this, they did a good job. They were concerned about, industries like laundries.

 

You know, if they had developed a limit like 10 or 20 parts per trillion, which they could have done, That would have been a huge problem for the laundries in their service area and other industries that discharge similar concentrations. So that limit is achievable by the laundries that are in the Great Lakes Water Authority service area with some minor changes. So that was really good news, compared to what it could have been. So the good news is Great Lakes Water Authority, the first significant POTW in the country to develop a local limit for any PFAS constituent, did use a business friendly non uniform allocation. That is not a common way of doing local limits, and they’re sharing it with anybody that wants copies of their report.

 

And if you want a copy, I can get make sure you get one. And they did come up with a reasonable limit. The bad news is if things continue the way they’re going right now from the EPA and from where the momentum is, if future state water quality standards because remember, this 65 part per trillion PFAS limit was because the water quality standard is currently 11 parts per trillion in Michigan. But if that water quality standard drops dramatically, as it probably will, to, let’s say, a non detect level, like 2 parts per trillion, that’s the detection limit that laboratories can get for PFOS, then the likely low local limit for PFOS in the future will be non detect rather than 65 parts per trillion. I hope that’s not where it’s going, but there’s a very strong chance that’s where it’s going, particularly in a state like Michigan.

 

Now for a brief message from TRSA. Hey, everybody. Charles Esten here. What an honor it is to be keynoting the TRSA 100 and 9th annual conference right here in Nashville, Tennessee, September 13th to 15th. Can’t tell you how much I’m looking forward to welcoming you all here to Music City.

 

From my very first day showing up here 10 years ago to start playing this guy, Deacon Claiborne, on the hit ABC CMT show Nashville, I’ve been in love with this incredible town. So much so that I actually ended up moving my whole family here. We live here now. That’s how I know that come September in the annual conference, you’re gonna love it too. And I’ll tell you something else.

 

It’s not only going to be fun. It’s gonna be meaningful. After 2 difficult years for this nation and for your hardworking industry, coming back together to connect with your industry peers, well, it’s an important part of rebuilding and of growth. As industry executives, when you gather at TRSA’s annual conference, you will share stories of your challenges and of your successes. As an actor and a singer songwriter, I have many of those stories myself, which I will tell you both through word and through song.

 

They don’t call it music city for nothing. Hope to see y’all in person right here in Nashville this September. Now back to the episode. EPA drinking water health advisory levels, why are they so significant? They came out in mid June.

 

You may have heard about them. They are not enforceable standards yet. It is the first significant step towards MCLs, which are the enforceable drinking water standards. And this just gives you an idea of how shocking these concentrations are, these health advisory levels. Twenty parts per quadrillion for PFOS, 4 per parts per quadrillion per PFOA.

 

We’re not even you know, parts per trillion are scary enough. Now we’re talking about parts per quadrillion. These are orders of magnitude below that 2 part per trillion laboratory detection limit. I won’t get into, you know, how EPA developed those. I do have a pretty good understanding of it, the models that they ran and so forth.

 

They feel pretty pretty confident that those are the kinds of concentrations that should not be exceeded in order for people to be safe from particularly, cancer risks and also vaccine hesitancy for children, like diphtheria vaccines. But just see the difference between those health advisory levels that could become the future MCLs. Or even if they’re two orders of magnitude above that, look how different those are from other MCLs and water quality standards throughout the country that are either currently been adopted or proposed. And you can see, let’s say, Michigan, their MCL, they’ve they’ve developed their own drinking water MCL for PFOS of 16 parts per trillion, 8 parts per trillion of PFOA. And then you see the water quality standard is even lower than the MCL, and that’s not unusual, Wisconsin, what they’re proposing.

 

So it’s not like, okay. The MCL is gonna be this incredibly low number, but does that mean the water quality standard, which is the most important number for laundries, Is that gonna be a low number? Yes. That’s typically how it works because most most places that PoWs are discharging to, unless it’s the ocean, are going to be either directly or indirectly drinking water sources. I’m gonna get a little bit deeper into this local limit scenario because I think it’s important because it’s gonna affect each in laundry around the country differently depending on how the local limits are done in your city.

 

So here’s POTWs a and b. Hypothetical POTWs, both discharging 10,000,000 gallon 1,000,000 gallons per day of wastewater. 10% industrial wastewater flow, that’s not unusual for a ratio. And let’s say all the sampling done on all the industries shows that it averages about 20 parts per trillion for PFOA. I’m gonna use PFOA in this example.

 

And then 90% of the wastewater is from domestic wastewater, from homes and so forth. And let’s say that this is a good situation where the PFOA is less it’s the nondetect. It’s less than 2 parts per trillion. And in the world of local limits, you can’t call that 0. You typically say half the detection limit we’re gonna say is the pounds coming from domestic.

 

Then there’s the total pounds of, PFOA that theoretically that POTW is discharging. That’s where how the state would look at it. That’s how the EPA would look at it. And let’s say that they learned about what Great Lakes Water Authority did. And these both these POTWs are doing their local limit studies, running their spreadsheets, and they wanna use a non uniform business friendly PFOA allocation.

 

They don’t wanna chase all their industries out of town. And they’ve done enough sampling to show that one industry discharges 75% of the industrial PFOA load. That would not be unusual based on what Michigan’s already been showing. Let’s take those same 2 POTWs now and make a change. So POTWA has maybe it wasn’t considered a reasonable water quality standard for anything years ago, but it might be considered a pretty reasonable water quality standard for any PFAS, compound in a couple years.

 

So let’s say 10 parts per trillion, similar to Michigan’s PFOS water quality standard. And then you see the pounds on the right. And because the domestic wastewater, had non detect a PFOA and because the industries weren’t a huge source of PFOA, then it turns out if you run the spreadsheet, if they hired a consultant like us, we would say, you don’t need a PFOA local limit, because of this somewhat reasonable water quality standard and not having a lot of PFO in your domestic wastewater. Or maybe you’re worried about an industry coming in in the future that’s not currently there that might be a major source of PFOA. So you wanna put, let’s say, a limit in the ordinance of 50 parts per trillion for all your industries.

 

And everybody can meet that currently, so it’s really a protection for the future. That might very be well be the kind of recommendation we would make to that POTW. Now let’s take POTW B. Everything else was the same. But this is, let’s say, a couple years down the line, could be in Michigan.

 

And now the PFOA water quality standard, because the EPA has adopted an MCL and everybody in the country has to adopt the same MCL or more stringent, And now the water quality standard for PFOA is non detect. That’s a very real possibility. That’s a huge difference. That affects the local limits dramatically. And so if they hired a consultant like us, they may we may have to do the math and come out with, you know, you’re gonna develop a limit of 5 parts per trillion for all industries.

 

Or what we I hope we would recommend is that the most business friendly thing is you have that one industry discharging 75%. We think if you have a 20 part per trillion limit just on that one industry, that’s a little tricky politically. But that would spare the under other industries from having a 5 part per trillion limit. That’s the huge difference between no PFOA limit at all at all or a fairly generous 50 part per trillion limit versus 5 for all or maybe 20 for the largest. And then let’s do one more tweak.

 

Let’s take POTWB, and this is a very real possibility. This will be true many places in the country. Their domestic wastewater isn’t nondetect. It’s 5 parts per trillion. And the PFOA water quality standard is nondetect.

 

Very real possibility. Without even their industrial wastewater as a source, they’re way above what they can discharge to the river or to the lake or to the ocean. What that means is they have no pounds available to allocate to industries at all. So even a consultant like us, which would try to help them be as business friendly as possible, we would have no choice in order for this to be approved by the state or the EPA. They would have to adopt a PFOA local limit of NODETECT for all their industries.

 

And that’s a very real possibility going forward. Not real happy news, I understand that, but I just wanna make sure to get it out there because I think this is where things are headed. Michigan has collected a tremendous amount of data, 10 PFAS compounds here, the 10 most common that are showing up in laundries, laundry wastewater discharge. You see PFOS and PFOA on the on the left. The detectable concentrations between, let’s say, 5 30.

 

And then you see some outliers on PFOA. You see as high as a 110 parts per trillion, on one sample. That came from a linen plant. This is not just an industrial laundry thing. In fact, it has nothing to do potentially with the oils and greases and things that come into a laundry.

 

It it it it appears that it’s most likely from the textiles, that come in, the the, you know, water resistant, stain resistant, the the the, the coatings that are on textiles, that’s what it appears to be. So it really doesn’t matter what type of laundry it is. It matters what type of textiles the laundry is is washing. The focus is on PFOA and PFAS currently around the country. It’s quickly on all the PFAS compounds, particularly compounds like 62 FT feet feet feet feet feet feet feet feet feet feet feet feet feet S.

 

There is a concern that that’s a major precursor to other PFAS compounds like PFOS and PFOA. That p o two w’s when they biologically, treat the wastewater, they take compounds like 62FDS and they get converted into other PFAS compounds. So 62FDS is getting a lot of attention. There’s a lot of toxicity studies being done on it. Those are the highest concentrations so far in the laundry wastewater samples that Michigan is collecting.

 

Now EEC was hired last year by one of our, industrial laundry clients who wanted to get a jump on this and start to figure out, is this something that’s ubiquitous throughout our laundry, or is it coming, you know, kinda like oil and grease? We all know a majority comes from shop towels or from bar bar towels or what have you. You know, mercury is gonna be coming from hospital accounts. You know, can we limit it and find out where the PFAS is coming from and start to figure out how to limit that before we have to even think about treatment? So that was the and and also is it is it coming from certain textiles?

 

Is it coming from washroom chemicals? Is it coming from the potable water? So this was the the sampling study. It’s a confidential client. There were no sewer discharge samples collected.

 

Therefore, none of these results had to be shared with the POTWs. We used the new EPA method 1633, which is soon to be approved for wastewater, which allowed us to analyze for 40 PFAS compounds. And we were very careful to use laboratory PFAS free water for all decan and blanks so that there was no cross contamination. We were very meticulous, of course, about the way in which we sampled and not wearing the wrong clothes and not using any kind of Teflon materials and the wrong gloves. And we didn’t see any evidence of any cross contamination in the sampling, which was good.

 

There were 66 samples collected altogether, potable water, washer drains, wastewater. I have spent a lot of time in my career with cups on a stick underneath washer drains, collecting samples. This was a lot of that. Again, we analyzed for 40 PFAS compounds. So what are the findings real quickly?

 

Well, potable water was not a significant source of PFAS at all 3 laundries. These were in 3 different places in the country. Washroom chemicals, there were 2, 3 laundries, but 2 major washroom chemical suppliers at these 3 laundries And none of the washroom chemicals, we analyze individual washroom chemicals, the main chemicals, you know, surfactant and alkali and so forth. And none of them were did have detectable PFOS or PFOA, which are really good news. Now there were other PFAS chemicals, compounds in these washroom chemicals, but not PFOS or PFOA.

 

And then the drain samples, a lot of drain samples, you know, what we found, which was not great news, was that almost all soil classifications or textile garment type types contain significant PFAS. The one that didn’t was shop towels. That shouldn’t be surprising in a way if it is coming, primarily from textiles because they need to be very absorbent. And so you’re not gonna have water resistant, coatings, for example, on shop towels. But as a guy that has dealt with shop towels my whole career in treating, industrial laundry wastewater, It’s just kind of ironic that shoptiles, at least in this study, were sources of non detect for all the PFAS compounds.

 

We did a lot samples of early drains and later drains to try to find out if a majority of the PFAS compounds were coming from the first 3 or 4 drains of a formula. Logic would sort of dictate that. And that was true. Early drains can generally contain the higher PFAS, but not in all cases. And then the highest PFAS concentrations were 62 FT feet feet feet feet feet feet feet feet feet feet feet feet feet feet feet S, which you heard me talk about earlier.

 

A couple compounds called mEFOs and EFOS. Those aren’t even being analyzed in most places of the country because, EPA method 1633, picks those up. And then the other method methods that have been used to this point don’t analyze for mephos and efos. So those are 2 compounds that is are in laundry wastewaters in significant concentrations. Are they gonna end up being as toxic as PFRS, PFOS, or PFOA?

 

We don’t know, but I just wanted you to be aware of that. And we also took some influent effluent samples from existing wastewater treatment, and we found that they removed very and this was a DAF and microfiltration. We found they removed very little PFOS and PFOA, but they did remove significant 6 2 FTS, Mifo, SETFOS and PFHXA, which means it’s important in and of itself, but it also means that the sludge and the filter cake from laundries, let’s say from a a DAF or a microfiltration system, would logically contain significant PFAS, at least those constituents. Now, you know, this isn’t a huge study, so, you know, take everything I said here, understanding that there was limited data, but I think these are the conclusions we felt we could pretty safely make from that study. What does all this mean?

 

Well, what it means is if PFAS limits all these compounds that are gonna have limits, not just PFOS and PFOA, if they’re headed towards non detect or near non detect limits, then it’s a game changer for any laundry that discharges PFAS. And in reality, every laundry in the country does discharge PFAS. So Michigan and EEC wastewater data show that multiple laundry PFAS compounds are well above nondetect levels. Textiles and washroom chemicals are sources of PFAS and may always be even with their best efforts. And that’s because we’re talking about, you know, 2 parts per trillion as a detection limit, and we’re talking about 5,000 over 5,000 PFAS compounds.

 

So if your suppliers are telling you we’re PFAS free or whatever else, they may believe they are, and they may be being told by their suppliers that they are. But it it just may not be the case at those kinds of low concentrations. And then current conventional laundry wastewater treatment technology, at least those two technologies, staph and microfiltration, do not remove nearly enough PFAS to get down to these non detect levels or near non detect levels. And those manufacturers are aware of that. That shouldn’t be news to them.

 

So that means advanced wastewater treatment that the laundry industry typically does not have to deal with, ultrafiltration, nanofiltration, granular activated carbon, ion exchange, most likely a combination of those technologies will be needed to comply with these very low PFAS limits that are coming if you end up with those limits. And these are dartboard guesses at your installation costs, 1,000,000 to 5,000,000. And again, this is not just industrial on you. This is not just heavy linen plants. This is any any laundry that may have the types of fabrics that could have PFAS in them.

 

And it’s just so ubiquitous. And, you know, are you gonna have to have a separate building for your treatment system? And so is it gonna end up exceeding $5,000,000? I’m just trying to give you some idea of the ranges. And it could be anywhere from a 100,000 to a half a $1,000,000 in annual operating costs.

 

And it could be worse than that because of the sludge disposal situation, which I’ll talk about briefly. Again, I wish I was giving you better news. I’ll have some better news at the end. What does this mean to add PFAS treatment to your existing, wastewater treatment? You may just have lint removal, or you may have a dissolved air flotation system or microfiltration, maybe recycling a lot of your water and and doing treatment for recycling purposes rather than compliance purposes.

 

Well, for a metal finisher, because, you you know, that’s what people are hearing around the country. Hey. Look what Michigan did. They enforced on just a handful of industries, made them put in granular activated carbon, and they didn’t go out of business and look at these incredible success stories. And that’s great because metal finishers, when they come out of their existing metals treatment system, they have very low suspended salts and very low total organic carbon.

 

That’s a phrase you’re gonna hear more about when you start dealing with treatment for PFAS is what is your TOC or total organic carbon? But metal finishing wastewater has pretty darn clean wastewater that comes out of their treatment systems. Pretty clear water, maybe a little color. So when they add granular activated carbon, for example, or ion exchange onto the end of their existing treatment system, it’s not it’s not a game changer. It’s expensive, it’s annoying, but it doesn’t break the piggy bank.

 

And then the exchanges, the the the carbon exchange and the ion exchange frequencies are reasonable. Laundries are completely the opposite. Whatever existing solids and organics treatment the laundries currently have, you see the wastewater that you have discharged, it meets the sewer discharge standards, cloudy wastewater, it’s fairly high in suspended solids, It’s very high in total organic carbon, and that’s because it it doesn’t need to be low in organic carbon. It’s gonna get treated by the POTW. What that means is in order to get down to parts per trillion PFAS levels, there’s gonna need to be a lot of significant solids and organics treatment in addition to what you currently have, let’s say, ultrafiltration or nano filtration, before the water even goes through the polishing treatment of granular activated carbon or ion exchange.

 

And then you’re gonna have very frequent change outs of those vessels for carbon or ion exchange. Real quickly, just snapshot. This may be a laundry, your laundry, a light industrial linen plant with reasonable sewer discharge standards, and you don’t have anything beyond, lint shaker screens, heat exchanger, and so forth. You don’t have this separate wastewater area in your plant for a dissolved air flotation system or a microfiltration system and all the tanks associated. So that would be an example of of a lot of laundries around the country currently.

 

Then a second laundry would be a conventional wastewater treatment system. In this case, we show a dissolved air flotation system. You may have a completely separate room, for this indoors or outdoors, all the tanks associated, your filter press. And this is already a very expensive venture for a lot of laundries obviously. Well, this is what it may look like if you have to put in PFAS treatment.

 

This would be laundry number 2, and now you’re gonna have to add extensive additional treatment, tanks, filtration that may go all the way to ultrafiltration or nanofiltration, then carbon or ion exchange, you’re gonna have to worry about TOC, manganese, iron, TDS, all these constituents you normally don’t have to worry about. And then you’re gonna have the change outs of the vessels. It’s a whole another room. You probably do not have room in your current wastewater treatment area if you do have wastewater treatment or your boiler room. It’s a whole another footprint.

 

This is something we’re helping a laundry with right now that is anticipating in Michigan that they’re gonna have to put in PFAS treatment in the future. And so it’s a brand new laundry, so we’re just making sure there’s enough space, for future treatment. Hopefully, there won’t need need to be a future PFAS treatment system, but the odds are there will be. And we’re just making sure that there’s space for that. There’s a real effort around the country, EPA in particular, and the states that are leading on PFAS, like Michigan, like California, that there’s a concern, hey.

 

We’re only looking at 18 to 40 PFAS compounds and doing toxicity studies on maybe 10 of them so far. What about all these other PFAS compounds? So what about all these people that have stopped using PFOS or PFOA, they’ve substituted other PFAS compounds? How do we know they’re not more toxic or as toxic as PFOS and PFOA? And so what this is leading towards is people saying, we need to start analyzing for total PFAS.

 

And there’s a couple different approaches to that. 1 is called a total organofluorine analysis or TOF analysis. That’s becoming very, common around the country. EPA has fallen in love with it. It’s a very expensive analysis.

 

It’s difficult to do. The one that I think is gonna gain more popularity is the total oxidizable precursor or top assay analysis. This not only analyzes for PFAS but also the precursors to PFAS. And this is a big thing in California. In fact, there’s a study going on right now in the California Bay Area that’s involving, 5 laundries that are being sampled.

 

I’ve touched base with 3 of the laundries who are clients of ours. They were not aware that they were being sampled for PFAS. This, study is gonna be published in early fall 2022, and I think it’s gonna have some very important results for the lawn. They’re sampling other industries as well. But for whatever reason, laundries are sort of near the top of the list along with metal finishers.

 

That concerns me. And they’re looking not just for PFOS and PFOA and PFBS and so forth. They’re looking for precursors because what California is seeing more than anybody else in the country is much higher PFAS concentrations coming out of their Po2Ws than going into their p0 2ws. And they believe this is the reason why is that there are lots of precursors that are not being currently analyzed by current EPA methods, the, let’s say, the 18 to 40. And they believe this is what’s going on, that the biological degradation is taking things like 62 FT feet feet feet feet feet feet feet feet feet feet feet feet S and converting them into PFAS compounds.

 

And so this is a whole another direction that’s being looked at. Again, I know this is not good news. Hang in there. And then more bad news, unfortunately. Solid waste is a big issue for PFAS.

 

So solid face disposal is going to be a big issue most likely for all laundries eventually that it’s non hazardous landfills. Once they find out that somebody has PFAS in their waste, in other words, once that waste is sampled for PFAS compounds, they are rejecting those PFAS bearing waste because they don’t wanna become hazardous landfills. There’s an expectation that PFAS will be classified as a hazardous waste under CERCLA soon, which is the Superfund Act. People are anticipating that, that congress will adopt that soon. And then, unfortunately, current incineration options, there’s a lot of laundry waste, you know, whether it’s lint waste, DAF waste, is going to incinerators.

 

And incinerators, most incinerators in the country don’t burn at nearly a high enough temperature to destroy PFAS. And in fact, it’s spreading PFAS through the air. And so incineration sites are no longer being looked at as being able to take PFAS waste. So that’s a big bummer. More to come later on that, I would say.

 

And then indoor air, EPA and health departments are concerned about people breathing PFAS, of course. And so any industry that’s looked at as a source of PFAS, either to wastewater or soil or groundwater, There’s gonna be concern about the, the breathing airspace for workers, and then stormwater regulations are coming as well. Again, I wish I could give you good news on that. That’s all bad news, bad news so far. How about some good news?

 

Alright. How about some good news? So EPA and states are recognizing that most controllable wastewater, PFAS, comes from 4 to 5 industries and landfills. The data from multiple states is showing that over and over again. Laundries are not in that top tier.

 

They are in the next tier, but we wanna keep them out of that top tier. And POHWs are starting to recognize that business friendly local limits development will be needed to assist industries like laundries. And these business friendly local limits development approaches are not common, but I think they will start to become more common because of PFAS. Laundry suppliers can continue to limit PFAS in their products. I mean, a lot of textile manufacturers are removing at least PFOS and PFOA or other ones that are being studied that are considered more more toxic and putting in either non PFAS compound coatings or PFAS compounds that are not as toxic.

 

And that’s gonna continue over the next few years. And that’s really, really good because if that is the major source of PFAS compounds in the laundries, then that’s the place to really focus on first. And then many laundries will avoid installing PFAS treatment through diligent pollution prevent prevention practices, not on keeping necessarily soil, the wrong kinds of soils out of the laundry, but making sure that the textiles and the washroom chemicals, coagulants, and flocculants are very low in PFAS. And that may be enough to avoid having to put in PFAS treatment. What are some potential next steps?

 

Well, we need to defend the industry and your laundries against unreasonable regulations and local limits. Laundries are PFAS receivers, not manufacturers. Laundries are not a top tier PFAS Discharger. That needs to be said over and over again. The data needs to back that up.

 

Suppliers need to continue to work to minimize the PFAS received by laundries. In in some cases, this may be enough to address the problem. And then I’m recommending to all our laundry clients that they start conducting sampling studies to determine your PFAS sources like the one that we started and and determine if segregating waste streams is an option for less treatment similar to water reuse type strategies. And I do believe the laundries need to begin planning for PFAS treatment, particularly if you’re talking about building a new plant or build or expanding on a plant and making sure you have room for future PFAS treatment. And if you’re going to do PFAS treatment, I didn’t say this earlier, you’re talking about, drinking type drinking water quality that’s gonna come out the back end of your carbon, your ion exchange, and now you have an opportunity to recycle a lot more water.

 

I wish that was better news because it’s a heck of a treatment cost to deal with recycling that, you know, some amount of water. But it is a positive. If you have to put in if you have to put in PFAS treatment, you are gonna develop drinking water quality. Water, you might as well recycle a lot more of it than you’re currently doing. John Shaffer will speak about the impact of PFOS on the linen, uniform, and facility services industry at TRSA’s upcoming annual conference scheduled for September 13th through 15th in Nashville, Tennessee.

 

He will speak at both the Supplier Partner Council meeting on the opening day of the event, as well as during lunch at the conference on September 14th. For more information on TRSA’s 109th Annual Conference, visit www.trsa.org /annualconference. Please subscribe, rate, and review our show on Apple Itunes, Google Podcasts, and Stitcher. For the latest news and information from the linen uniform and facility services industry, subscribe to our newsletter, Textile Services Weekly, and our monthly print publication, Textile Services Magazine. Additionally, don’t forget to follow TRSA on Facebook,