Mid-Atlantic sampling for PFAS in a military base’s water supply

PFAS

How We Can Help

Mid-Atlantic Associates, Inc. has grown into one of the region’s most respected and experienced engineering and environmental consulting firms serving private, commercial, industrial, educational and municipal sectors throughout the Southeast. PFAS can be a confusing and challenging issue to navigate, and clients can spend thousands of unnecessary dollars to address an issue simply because they did not know a better solution was available.

We listen and tailor our approach around our customer’s needs while using available regulatory resources. Oftentimes this means putting our client’s interests before our own as a company, and Mid-Atlantic has a proven track record of saving our clients thousands of dollars from smart consultation and minimizing assessment costs while still meeting our client’s goals. Our high percentage of repeat clients is a testament to our ability to provide high-quality, customer-focused services.

Here are the many environmental services that Mid-Atlantic offers that can help you address PFAS:

What Are PFAS?

Per-and poly-fluoroalkyl substances, otherwise known as PFAS, refers to a group of chemicals that have been synthesized and used across a wide range of industries and products since the 1940’s. PFAS have been subject to increasing regulatory scrutiny due to their known mobility and persistence in the environment and impacts to human and ecological health.

  • Multiple PFAS definitions have been developed with the EPA estimating over 14,000 different chemicals. As noted on EPA’s now retired “PFAS Master List of PFAS Substances”:
    • “There is no precisely clear definition of what constitutes a PFAS substance given the inclusion of partially fluorinated substances, polymers, and ill-defined reaction products on these various lists.”
  • The Interstate Technology and Regulatory Council (ITRC) states:
    • “There is no universally accepted definition of PFAS. However, in general, PFAS are compounds characterized as having carbon atoms linked to each other and bonded to fluorine atoms at most or all of the available carbon bonding sites.”

The bonds between carbon and fluorine atoms characteristic of PFAS compounds are so strong and stable that PFAS are commonly referred to as “forever chemicals”.

PFAS substances have frequently been described as a “chain” of these C-F bonds and have been broadly categorized into many groups/subgroups, with much of the regulatory attention directed towards non-polymer PFAS, which have been most commonly found in the environment. In particular, two perfluoroalkyl acids (PFAAs) called PFOA and PFOS have received a great deal of attention in research and from regulatory bodies.

The chemical structure of perfluorooctanoic acid (PFOA; from Wikipedia)

The Widespread Adoption of PFAS and Subsequent Public Exposure

The hydrophobic and lipophobic nature of PFAS has made them desirable in many products such as textile stain/soil repellants, food-contact paper, flame-retardant fluoropolymers, electroplating, coatings, lubricants and greases, plastic and rubber products, and aqueous film-forming foam for firefighting applications, among many other uses.

For example, PFOA exposure has been linked to microwave popcorn bags

Based on the widespread production and use of PFAS in many consumer products, there are many sources and subsequent exposure pathways that have been identified. For instance, EPA’s Final Rule designating two PFAS compounds, Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS), as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Hazardous Substances (published in the Federal Register on May 8, 2024) lists 88 types of entities among 35 different industry groups that include PFOA/PFOS manufacturers, PFOA/PFOS processors, manufacturers of products containing PFOA/PFOS, users of PFOA/PFOS, users of PFOA/PFOS products, waste management facilities, and wastewater treatment facilities. The historical use of PFAS has been so widespread, that the NCDEQ Inactive Hazardous Site Branch (IHSB) currently estimates that 90% of the sites in their inventory fall within industries linked to PFAS production, use, and/or handling.

Public exposure to PFAS can come through a variety of pathways including consumption of PFAS-impacted drinking water, bioaccumulation of PFAS and subsequent consumption of fish/animal products, and exposure via PFAS-containing consumer products/packaging. PFAS exposure through vapor intrusion is a less understood pathway; however, certain PFAS compounds meet the criteria to be considered vapor-forming chemicals.

The numerous uses and exposure pathways to PFAS has resulted in widespread exposure to these compounds despite the mounting toxicological data. PFOA/PFOS and other PFAS compounds are estimated to be in the bloodstream of most Americans, with one report issued by the Center for Disease Control and Prevention (CDC) finding PFAS in the bloodstream of 97% of the studied population.

So What?

PFAS exposure has been associated with developmental impacts, decreased bone mineral density, tissue damage, delayed puberty, and a host of other health impacts. The EPA currently categorizes PFOA and PFOS as “Likely to be Carcinogenic to Humans”.

Based on the known toxicological profile of multiple PFAS compounds, the EPA introduced a National Primary Drinking Water Regulation that established Maximum Contaminant Levels (MCLs) for six PFAS compounds in April 2024 that range from four to ten parts per trillion (note: MCLs for other contaminants are typically in the part per billion or part per million range). Shortly after, in May 2024, the EPA issued a Final Rule designating PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), which is anticipated to become active in early July 2024.

The Final Rule was issued in an environment of growing public concern and awareness based on the prevalence of PFAS in public drinking water supplies and high-profile releases in North Carolina, which have included former manufacturing facilities, municipal landfills, and fire-training facilities. The introduction of EPA’s Final Rule and our evolving understanding of PFAS is rapidly changing the regulatory landscape and many industries will be impacted in one way or another:

  • As noted under ASTM E1527-21 concerning emerging contaminants (which include PFAS at the time of writing), “If and when such emerging contaminants are defined to be a hazardous substance under CERCLA, as interpreted by EPA regulations and the courts, such substances shall be evaluated within the scope of this practice”. What this means is that when the Final Rule goes into effect, evaluating PFAS will be included as part of Phase I Environmental Site Assessments. Real or perceived environmental impacts related to PFAS can have a material impact on property transactions and present a hinderance to your project that makes the cost of moving forward insurmountable.
  • Properties/facilities known or suspected to have handled PFAS will face increasing scrutiny from regulatory bodies, and in fact already have. For example, the IHSB’s September 2023 “Guidelines for Assessment and Cleanup of Contaminated Sites”, issued prior to EPA’s Final Rule, requires PFAS assessment at sites with known or suspected PFAS releases.
  • As noted previously, the NCDEQ IHSB estimates that 90% of the sites in their inventory fall within industries linked to PFAS production, use, and/or handling. Environmentally-impacted sites that were once thought to be characterized and well understood may now have data gaps that warrant additional assessment.
  • Properties once thought to be environmentally “clean” may be environmentally impacted due to onsite or offsite activities related to PFAS compounds that were unaccounted for in previous assessments.

Useful PFAS Resources

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