Episode 68 – PFAS: Update from the EPA

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 episode of the 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 the issue are US Environmental Protection representatives Brian Damico and Matt Claussen. Claussen gives us an overview of the EPA’s PFAS strategic roadmap, highlighting the agency’s approach to the issue, while Damico discusses effluent limitation guidelines and several ongoing studies to note.

 

We’re excited to share some of the work that we are doing on PFAS and this class of chemicals. What I wanted to kind of do to begin today is to give you all a sort of high level overview of the work that we are doing on per and polyfluoroalkyl substances or or PFAS here at the Environmental Protection Agency. And my role is to kind of give you the landscape of the work that we are doing and within the context of EPA’s PFAS strategic road map, which I’ll cover in greater detail in just a moment. And then I’ll turn it over to Brian to share some more specific work that we’re doing under our Clean Water Act authorities here at EPA that we think will be most relevant, to you all and the work that, that you do in the context of of Clean Water Act, effluent guidelines, methods, and, and some work on NPDES or Clean Water Act permitting, that I will share. So the goal here is to give you an an overview of the work that we’re doing to touch on the overall landscape of the work, that we’re doing at EPA.

 

One of the best and the worst parts about summarizing the the work that EPA is doing on PFAS is the incredible scope of work that we have underway across the agency, and and the challenge in describing all of that work and being able to be fully sophisticated about about all the actions we’re taking and their potential implications for you all. So I’ll do my best to share an overview of the work that we’re doing, as will Brian. So first of all, understanding that you all may be in different places on your understanding of this class of chemicals, whether that’s the class as a whole or specific chemicals. We wanted to spend a few minutes just on the background, of these chemicals and why EPA is concerned. We wanted to talk a little bit about our PFAS strategic roadmap, and where that came from.

 

We wanted to spend, the majority of the time on some of the actions and progress we’ve made under that road map, including the more specific Clean Water Act pieces that Brian will share, and then, to to to both touch on those water actions, and signal some of the work that we have, coming up in in the years ahead. The framework of the work that we are doing on PFAS, as I mentioned, is known as our PFAS strategic road map. Our administrator, Michael Regan, announced this road map in October of 2021, which is a product of a group called EPA’s PFAS Council, which I manage here at EPA. That’s a group that our administrator created in April of 2021 to help develop the agency’s plan to address PFAS, and since then, to oversee the implementation of the actions, that it includes. One of the key attributes of this plan is it’s a a what we call a whole of agency approach.

 

So not only using our authorities in the water space under the Clean Water Act, the Safe Drinking Water Act, and other laws, but pulling in other offices like those that oversee the Toxic Substances Control Act, CERCLA or Superfund, the Resource Conservation and Recovery Act, the Clean Air Act, and several other laws. And to do this in a holistic and cross agency way using the authorities, that EPA has. And the road map, does a few particular things. It includes specific timelines for actions between 2021 and 2024. We think the road map helps both fill a gap in federal leadership that has existed on PFAS, in recent years, while also continuing to support, the powerful and ongoing efforts by states here in the United States, by tribes, and other stakeholders.

 

And the road map is founded on a base of scientific integrity and making sure that that sound science, informs, and guides the work, that we are doing. And, I’m gonna return in just a moment to some of the more specific commitments in the PFAS road map, but I wanted to start here with the overall framing of the work that we do. Before I share a bit more about our PFAS road map, I wanted to just step back for a second to share a little bit about, what these chemicals are, how we talk about them at EPA, and why we’re concerned. PFAS stands for Per and Polyfluoroalkyl Substances, as I shared earlier. And this is a group of synthetic chemicals.

 

They’re human made They consist of chains of carbon atoms bonded to fluorine atoms in a number of different chemical structures. And there are thousands of different chemicals in the PFAS family. Some are much better known than others. 2 of the best known are PFOA and PFOS. Now these chemicals as a whole, PFAS, have been used in homes and businesses and industry since at least the 19 forties.

 

And they’re found in lots of consumer products, including likely a number of the products that you all use, as well as, other products that you may find in your household or for particular applications, such as their use in, firefighting foam used to extinguish fuel fires. And due to the widespread use and ubiquity of these chemicals in society, and in the economy, They’ve also been found in soil, in water, in fish, in drinking water, both around the country and around the world. And centers for, the surveys by the Centers For Disease Control and Prevention have also found these chemicals, in human blood, particularly PFOA and PFOS. And most exposures to these chemicals are relatively low, but some exposures can be high, particularly if people are exposed to a concentrated source over a long period of time, whether that’s a contaminated site, whether that’s by drinking contaminated drinking water, or potentially other mechanisms. And we’re concerned about these chemicals, at EPA, particularly those, about which we know the most due to either their known or their suspected toxicity.

 

And we’re continuing to gather the scientific information we need to better evaluate the human health and environmental impacts of these chemicals. But we know that they are are are toxic to to many organ systems. The 2 best known chemicals are also likely carcinogens. NEP is working very hard, to use the authorities that we have to protect, human health and the environment and help reduce the risks of these chemicals. It’s also important to mention that these chemicals, due to their ubiquity and due to their chemical structure, are very slow to break down in the environment.

 

Part of the reason they’re called forever chemicals. And this can also translate into heightened risk, and and impacts to human health, because they do not decompose, in human bodies or the environment, and they can stick around for very long periods of time. A bit more on the background and the life cycle of these chemicals, some of the pathways by which PFAS can enter the environment, flow through the environment, and potentially impact, human health. These include discharges from PFAS manufacturing facilities, discharges of PFAS firefighting foam, the PFAS entering a wastewater treatment facility, as well as, PFAS potentially applied to agricultural fields, in the context of biosolids. Some of these exposure pathways are unique to PFAS, but some of them are similar to other environmental contaminants.

 

The uniqueness comes in in many ways, for example, due to their persistence and presence in biosolids, or the ways in which they flow through the environment, and are very difficult, to remove, as they flow through the environment, that that they may be admitted to air from manufacturing facilities, and may end up, in soil, groundwater, or other elements of the environment. And as EPA considered ways to address these chemicals, we identified a series of principles to guide the work that we do and the more specific actions that I’ll describe in a moment. First of all, we have a very strong focus in our work at, considering this life cycle of PFAS and identifying the most effective opportunities to use our tools at the Environmental Protection Agency to help reduce risks, to to improve our understanding of these chemicals, and identify the most effective option. Also relevant to this diagram, we’re working very hard, as Brian will share under the Clean Water Act, as what we call getting upstream of the problem, to take steps to prevent PFAS discharges in the first place, rather than solely focusing on cleaning up the contamination where it already exists. We have a strong focus in the roadmap on holding polluters accountable, on identifying the manufacturers of these chemicals, and those who have significantly contributed to their presence in the environment and focusing our efforts, on those entities.

 

We have a strong focus, as I shared before, on science based decision making, and in investing in the science, needed to better understand this class of chemicals. And 5th, we have a strong focus on protecting, and prioritizing disadvantaged communities, recognizing that the impacts of PFAS, like many other environmental contaminants, may disproportionately affect particular communities and working hard to make sure that all communities have equitable access to solutions. Before I get to some, very specific actions we’re taking across the agency, I wanted to just spend a moment on the three overall goals under our PFAS strategic roadmap to give you a sense of the scope of the actions that we’re undertaking. And we like to think of these goals as the 3 r’s, which are restrict, remediate, and research. And I wanted to walk through each of those, individually, which you’ll also see on some subsequent slides in describing the work that we do as we consider the life cycle of PFAS and identify actions we can take in each of these three areas.

 

Restricting PFAS is about proactively preventing the contamination in the 1st place. It’s about getting upstream of the problem, both because it’s much more cost effective, but also because, it can help prevent impacts to human health and the environment before they occur. Remediate is about using our cleanup authorities, to broaden and accelerate the PFAS of contamination to protect both human health and the environment in a number of ways that I’ll describe in a moment. And 3rd, continuing to ground the work that we do in science and research. We’re investing in the research and development and innovation in many different aspects of PFAS, but focusing on 3 main areas, methods for measuring PFAS in the environment, which Brian will share a bit more on a little bit later, assessing the human health and environmental risks of these chemicals through toxicology studies, evaluating the scientific literature, and other mechanisms.

 

And finally and critically, evaluating and developing technologies for reducing PFAS in the environment for destroying and disposing of these chemicals, and to hopefully preventing the forever nature of these chemicals, through the deployment and development of new technologies. I wanted to cover in, in greater detail some of the recent accomplishments across the agency on PFAS before turning to Brian, for some more specifics. I wanted to spend, the rest of my time, on the accomplishments that we’ve made in our work across our PFAS strategic road map to highlight one specific Clean Water Act area and then turn to Brian, for the specifics from there. As I mentioned earlier, there’s an enormous amount of work happening across the Environmental Protection Agency. I can only give you a as you’re likely aware, in April, EPA finalized the first ever safe drinking water act standards, to address 6 PFAS in drinking water.

 

This is a step EPA has been working on for a number of years. We proposed a regulation in March of 2023, and we are excited to finalize that regulation, in April of 2024. The final rule will reduce exposure to PFAS for approximately a 100,000,000 people. It will prevent thousands of deaths and reduce tens of thousands of serious illnesses over the duration of the regulation. And importantly, the the limits in the rule, which apply specifically to public water systems as defined under the Safe Drinking Water Act are achievable during using a range of available technologies and approaches, and we’ll be working very closely with states who are in the lead role in implementing regulations under the Safe Drinking Water Act to support water systems, local governments, and others in implementing this regulation.

 

The second of the rule is a final regulation, that we announced in April and formally published in the Federal Register, in May under the Comprehensive Environmental Response Compensation and Liability Act, known as Superfund, to designate 2 PFAS, the 2 shown on the previous slide, PFOA and PFOS, as hazardous substances under the Superfund Law. In the short term, that will improve, transparency and accountability, to clean up PFAS contamination in communities, including release reporting, for releases of these chemicals. And, also, it enables us to use one of our strongest enforcement tools, to compel polluters to pay for or conduct investigations and cleanup rather than taxpayers. The other announcement concurrent with the release of that final regulation was an enforcement discretion policy from EPA’s Office of Enforcement and Compliance Assurance, highlighting that EPA will be focusing its enforcement work on parties who significantly contributed to the release of PFAS chemicals, into the environment. This is an important point I wanted to hit, with this audience, that EPA is being very mindful of its authorities, and has heard a lot from, different industries and stakeholders since EPA proposed the rule, in better, evaluating the use of EPA’s enforcement authorities, and being transparent, about the ways we intend to use those authorities in the future, through a policy also released alongside the rule.

 

EPA also, had a very busy early 2024, including some proposed rules earlier this year under the Resource Conservation and Recovery Act, as well as, in April as well, EPA releasing updated guidance on PFAS destruction and disposal. As I mentioned earlier with respect to our research work, one of the areas that we’re working, to much better understand are the availability and, development and deployment of technologies both to filter out PFAS contamination, from sources such as wastewater, which, of course, is of great interest to you all, but also similar questions with respect to drinking water, with respect to incineration or landfills or underground injection control. And so in April, we were excited to reach a milestone of updating the interim destruction and disposal guidance that we had released in 2020 with new research results, in response to some public comments we received on the earlier version of the document, and to really update what we know and what we don’t know about different technologies and how they may, be successful or may still have some information gaps with respect to PFAS and PFAS containing materials. We also, as I mentioned, know that, there are a lot of emerging technologies, and we provided a framework for, helping to consider and evaluate those technologies, to better clarify how EPA would think about new technologies, and their effectiveness for PFAS destruction and disposal.

 

And we also highlighted, many of the information gaps that we currently have, particularly with respect to incineration or thermal treatment with recommendations, for how to design and carry out studies, to better help us speak to the effectiveness of those technologies in the future. And so I wanted to quickly highlight some of the actions we included in our annual PFAS road map progress report last December. In the roadmap in October 2021, we committed to doing annual progress reports on our work each year, and we’ve since published 2 reports, the first of those in November of 2022 and our latest last December of 2023, to highlight the PFAS work that we’ve done. So far, I’ve only been focusing on the actions we’ve taken since our latest progress report in December. But I wanted to spend a moment, to catch you all up on the work that we described in that report, in December to highlight, the scope and the breadth of some of the other work that we’ve done.

 

One of the important, considerations, I think, for your industry and for your work, is is the question of of PFAS in products and PFAS, in in efforts to better understand PFAS in the economy and in particular products, and take steps to reduce the concentrations of PFAS in those products in order to prevent, PFAS contamination in the future. And our colleagues in the Office of Chemical Safety at EPA are taking a number of steps under our authorities, to better understand the presence of PFAS, and also be able to, to take action where our legal authorities allow us to do so. We’ve been doing that under the Toxic Substances Control Act, including tightening up the review considerations and processes we’re using to evaluate new PFAS. And we’re also continuing to improve the release reporting on PFAS under EPA’s Toxics Release Inventory Program, including continuing to add PFAS to the TRI list, as well as removing some exemptions that previously existed to limit the reporting of certain PFAS under TRI. We’re also taking a lot of steps through EPA’s voluntary, approaches such as our, environmental certifications and eco labels and standards to better, provide information on the presence of PFAS and products to evaluate standards and ecolabels, with respect to whether they address PFAS or not, and providing web resources, to better, point people in the direction of those certifications, so that they can make choices to help reduce the presence of PFAS in products.

 

At the same time, we’ve also been working with our federal agency partners, like the General Services Administration and the Council on Environmental Quality to take steps to reduce the presence of PFAS, for example, in, GSA custodial contracts, for cleaning services in federal buildings, to help, make choices, that reduce or eliminate the presence of PFAS in particular products. We know this work is a critical step toward, preventing PFAS contamination in the first place, And we know it also, relates to a lot of work at the state level, to help better evaluate the presence of PFAS and products, in some cases, to require reporting of PFAS concentrations, in particular products or industries, and longer term steps being taken at the state level to phase out PFAS, in particular types of products. The second focus is on holding polluters accountable. Wanted to just touch on this for a moment both to reiterate, the Circular Hazardous Substance Designation, but also the associated enforcement discretion policy, but also to note that our progress report highlights a number of site specific enforcement actions EPA has taken, to prevent endangerment of human health and the environment, from industries or military bases, or other sources, taken since November 2022.

 

As I mentioned earlier, we highlighted the work that we’re doing to develop nationwide drinking water standards, which, as I mentioned, we finalized this past April, as well as some significant drinking water monitoring that’s happening across the country through what’s known as our unregulated contaminant monitoring rule under the Safe Drinking Water Act. Another key point I wanted to highlight is, the unprecedented resources we have available at EPA and that we’re providing to states in order to provide assistance, for drinking water and wastewater projects, through drinking water grants, through the Drinking Water State Revolving Fund, and through the Clean Water State Revolving Fund. Of particular interest likely to you all is $1,000,000,000 under the Bipartisan Infrastructure Law to address PFAS and other emerging contaminants through the Clean Water State Revolving Fund, which has fairly broad eligibilities to conduct studies, and and to do various actions to reduce PFAS levels. And, our Office of Wastewater Management has published a number of resources and fact sheets and had a webinar fairly recently describing the eligibility to set this program with respect to PFAS, and the steps that can be taken, including for pretreatment, including at industrial sources, and even to use those, those funds to better investigate the sources of contamination and potentially involve, install treatment.

 

I won’t touch on this, to a meaningful extent, but we also highlighted the work that Brian and team are doing to turn off the tap for industrial polluters under the Clean Water Act and the authorities that we’re taking through effluent guidelines and others. We highlighted the work that we’re doing to to advance the science on toxicity, on exposures, and on methods, which Brian will cover in greater detail in just a moment. We’ve continued to have a strong focus, as I shared earlier, on equity and environmental justice, and especially on gathering and releasing the information we have about PFAS contamination in communities, including, what’s known as our PFAS analytic tools, which we released in early 2023, that provides significant information to the public about what we know about PFAS contamination from wastewater discharges, to drinking water monitoring results, to potentially PFAS contaminated sites, to other environmental and human health data, that we have collected, that states collected, or that federal partners have collected along the way. And finally, we also highlighted in that report, a series of listening sessions we did in 2023 to listen from and learn from communities to inform the work that we do.

 

We held a series of listening sessions, 10 sessions for each of our regional offices, as well as a specific session for tribes, in which we shared the work that we’re doing under the PFAS strategic roadmap and solicited feedback, on how to improve and and, adapt the work that we do, to be more responsive, and to be more effective for communities. So we highlighted that work in our report last December. I wanted to cover some work that we’ve done under the Clean Water Act before I turn to Brian, to round us out with some more, specific work under the Clean Water Act, that we think will especially resonate, with you all, and and help inform, and and, and educate you all on on what we’ve been up to and where we plan to go from here. One of the key authorities, that we’re working on, of course, is the Clean Water Act. And the one area I wanted to highlight, here is both the breadth of the work under the Clean Water Act, and this is the overall scope of the work that we do, but also to highlight the work that we’re doing under the Clean Water Act’s National Pollutant Discharge Elimination System Program, n p d e s, and a memo that we released, in December of 2022 with recommendations on how to use that program to better understand PFAS contamination, and potentially take steps, to to include limits, even at this time, or at that time as we were working on, analytical methods, as Brian and team were working on effluent guidelines, and as we were taking broader steps under the PFAS strategic roadmap.

 

But before I get to that specific slide, I wanted to just pause here for a second, to give you this overall scope of the work, that we’re doing under the Safe Drinking Water Act and the Clean Water Act, and protect and to protect our waterways, to protect our drinking water, under the whole of agency approach. I mentioned a moment ago that, I was gonna highlight a memo that EPA put out in December 2022, which is available on our website. I encourage you to to, to take a look at this memo. It’s, reasonably short. It’s only a few pages long, and this is a key commitment in our PFAS road map, to to better, provide guidance, first to EPA regions in early 2022, and then, both to our regions and to NPDS authorized states, to identify approaches and make recommendations for how to use NPDS permitting to both reduce discharges to waterways and also just obtain additional information about the sources or potential sources, of PFAS and the quantities that are discharged from those sources, to help inform the work that we do and to inform the public.

 

And in this memo from December 2022, we recommended that permitting authorities use the most current sampling and analysis methods to identify known or suspected sources of PFAS. As Brian will describe in a moment, we’re now at a position where we have final Clean Water Act methods, for PFAS, although we’ll be continuing the process to promulgate those methods. But what we recommended in December 2022 is the use of those methods, at the permitting authority’s discretion to provide additional information now, on potential sources of PFAS, in order to provide us with additional information and enable steps to be taken as quickly as possible to help reduce the PFAS in those discharges where that’s appropriate. We also encourage in that memo, for permitting authorities, even in in the case where we are now of effluent guidelines not addressing PFAS, and a limited information, and only proposed water quality criteria for PFOA and PFOS to take, the available authorities they have using pretreatment and permitting authorities, to, for example, impose technology based limitations where appropriate on sources of PFAS discharges and provided some recommendations in that memo about how to do so. We also highlighted best management practices that have been, employed, to better understand PFAS in particular discharges and take steps to control them.

 

For example, with respect to firefighting foam discharges in airports, we encouraged a number of steps for pollution prevention and minimization in that memo. And we’re hopeful that states will continue to use the recommendations provided in that memo along with the finalized analytical methods that Brian will talk about in just a moment, to continue to, to use the NPDS program as a way to better understand PFAS and discharges, and help reduce those discharges in the future. We’re continuing to track the extent to which, particular, permits include monitoring requirements or or limits in permits for PFAS. Right now, I think across the country based on information from our Office of Waste Water Management, there are a few 100 permits, that include either a a monitoring provision or a limit. And while that is a very small number compared to the total number of permits around the country, It is a significant increase, in the last couple years, in the information we have available and the information coming to states, to EPA and communities about the presence in those discharges.

 

And so we’re we’re very excited about gathering that additional information, in order to better ex understand the extent of the problem, and as I mentioned earlier, to use that as a mechanism to, to get upstream of the problem and prevent discharges in the 1st place. So with that, I wanted to, to turn it to Brian, and and thank you all for the, chance to cover this, significant overview of the work that we do, and I’ll turn to Brian, to cover a couple additional pieces. Now for a brief message from TRSA. Laundries are certified hygienically cleaned through third party inspection and quarterly testing that quantifies an established threshold of pathogens on textiles to levels that pose no threat of illness. Inspectors also verify employee training, safety standard compliance, and operational efficiencies.

 

Certified laundries must maintain a quality assurance or QA manual that indicates their management, housekeeping, and training practices comply with the hygienically clean standard. Now back to the episode. Thanks, Matt. So let me give you a little bit of background real quick on the Effluent, Limitation Guidelines Program and then I’ll walk through some of the, the actions that we’re currently undertaking to address PFAS and the environment. The Clean Water Act directs EPA to promulgate effluent limitation guidelines and standards, or ELGs for short, for a not for for industrial categories.

 

And and, essentially, what that is is it’s a technology based numeric limit based solely on the performance of the best available technology that has been demonstrated to be economically achievable. And what that essentially means is is we will identify we’ll identify an industrial category, and we’ll identify the pollutants associated with that industrial category, and we will find the technology that works best to remove those pollutants, And we will, look at available data to show that that technology is compatible with the wastewaters for that specific industry and that that specific industry can afford to implement that technology on a nationwide basis. These tech based limits do not take water quality concerns into account. They are they are meant to set a level playing field for an entire industrial category, and water quality based limits can come in on a site specific basis and tighten up as necessary based on local water quality concerns. Additionally, the Clean Water Act requires that we review every ELG we’ve we’ve written annually and publish a plan every 2 years with the results of those reviews.

 

And to date, we’ve written 59 ELGs. And we have a pretty routine 2 year cycle right now, where in year 1, we will, publish the preliminary ELG plan. And we’ll request comment on its contents. Year 2, we will publish the final plan. In addition to the results of those annual reviews, we’ll also use that plan as an opportunity to share with the public any, new or revised guidelines or studies that we’ve initiated, status updates on ongoing activities, and announcing any new work.

 

Our last ELG plan, which was ELG Plan 15, was published in January 2023. We are currently working on preliminary ELG program plan 16 and our hope is to publish that later this year. And now I’ll just give a a quick overview of some of the activities we have going on to address PFAS from industrial sources. So for ongoing rulemakings, we, the first one we announced was the PFAS manufacturers, ELG. We announced that in September 2021 as part of preliminary plan 15.

 

And the purpose of this rulemaking is to limit PFAS discharges from facilities that manufacture PFAS. Fairly straightforward. We’ve been working on this for a number of years. Our hope now is that we will be publishing the proposal on this rulemaking later this year. Next, we have metal finishing and electroplating.

 

That was also announced in preliminary plan 15. And a little background is metal finishers use PFAS as a fume suppressant, to limit exposure to hexavalent chromium. That’s that’s typically used in chrome plating operations. We are working towards, developing numeric limits to to to limit PFAS discharges stemming from those operations. We’re currently working on that proposal right now.

 

We’re likely gonna publish something in the next 2 years or so. So that’s that’s a bit of a a longer timeline than the PFAS manufacturers. Up next, landfills. That was announced in program plan 15 just last year. Landfills are full of consumer goods that all contain PFAS.

 

We’ve looked at leachate data from a number of landfills and found PFAS and close to all of them. The goal here again is setting numerical limits to limit the the discharge of PFAS from these facilities into, surface waters, and POTWs. We’re very early in the rulemaking process, and I would say that, we will be publishing updates and preliminary plan 16 later this year, to discuss timing and activities a little bit further. Moving on to some studies, the one ongoing study that that may be of interest to you all, we were looking at textile manufacturing. That was announced also as part of ELG program plan 15 in January of 2023.

 

Textile and carpet manufacturers use PFAS as part of their process. We’ve looked at some limited data on wastewater discharges from these facilities and it shows that in those limited instances, PFAS is being discharged. And we are we are in the process of trying to better understand the, the potential for discharge from these facilities. How much, how widespread is it? And as part of that, we’re in the process of developing a mandatory questionnaire and seeking approval from, the the White House to distribute it nationally in order to to gather, you know, firsthand data to understand the the the use and discharge of these chemicals.

 

And then finally, the the POTW influence study. So everything what I just discussed was was based on essentially the data that was available to us. That being said, there there’s not a lot of available discharge data. This is something that, you know, is, is reasonably new. The the, the ability to measure this in wastewater has been evolving over the years.

 

And we’re looking to do a strategic, data gathering to to really understand the source of PFAS in the environment. So we are looking to work. We’re partnering with POTWs across the country to collect samples from, wastewater treatment plant influent, effluent, biosolids, as well as having the the POTWs go up stream and sample their industrial customers. All of this data will be packaged and made available to the public at the conclusion of the study. Our hope is is this will be the largest and most comprehensive dataset on sources of PFAS in the environment, and and this is something that we’ll be using for years to help EPA priorities on future studies and rulemakings.

 

So we talked about all these studies and rules and and, you know, how do you comply with the rule? And that’s by using appropriate wastewater or an appropriate analytical method. And that’s, that’s something we’ve been working on for several years now. We’ve developed 2 methods for measuring PFAS in wastewater. The first is method 1633.

 

That measures up to 40 specific PFAS compounds across 8 environmental matrices, wastewater, surface water, groundwater, and a host of others. We we developed this method in conjunction with DOD. This was this is probably the most validated, most, well researched method that we’ve put out in the Clean Water Act Methods Program. And so this is this is available on the website right now. Additionally, EPA method 1621.

 

This does not measure any specific PFAS compound, but it does measure adsorbable organic fluorine. Essentially measures the carbon fluorine bond. And this is a good surrogate for for analyzing PFAS, and and you need to know about what you’re sampling when you use this method. You know, I I would not recommend taking a sample of unknown water and running method 16/21. That won’t tell you very much.

 

But if you know where the wastewater is coming from and you know the processes they’re using and if it’s a facility using or generating PFAS and you’re measuring for AOF and you’re getting detections of AOF in that sample, you can be pretty confident that AOF is coming from the PFAS they’re using. So these two methods, both very high quality methods, both found on the website process of, incorporating these methods into the CFR through a notice and comment rulemaking. And that that has just gone underway, and I would expect we’ll have more, information on the timing of that coming up. If you’d like to view a slide deck from the EPA that gives an overview of their latest efforts regarding PFAS, send an email to podcasts attrsa.org. That’s podcasts attrsa.org.

 

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