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PFAS Consultation

The regulatory landscape concerning PFAS is continuously evolving, with the United States Environmental Protection Agency (USEPA) rolling out two new final rules that could potentially impact your business. One of these regulations, the Final Rule for National Primary Drinking Water Regulation (NPDWR), establishes Maximum Contaminant Levels (MCL) for six PFAS in drinking water, including stringent thresholds such as 4.0 parts per trillion (ppt) for two key contaminants, perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFNA). This measure is crafted to safeguard public health by ensuring the detection and control of PFAS contamination in public water systems nationwide.

Furthermore, the USEPA has implemented another significant final rule designating two PFAS, alongside their salts and structural isomers, as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund. This designation empowers federal and state agencies, as well as third parties, to address contaminated sites and pursue cost recovery from responsible parties for any releases. Additionally, the rule allows the federal government to re-open previously closed contaminated sites for remediation.

You may not have heard of Per- and polyfluoroalkyl substances (PFAS), but chances are you’ve come across them in your daily life. PFAS are man-made chemicals that have been around the United States since the 1940s. From Aqueous Film Forming Foam (AFFF) for firefighting to stain-resistant fabrics, the non-stick cookware introduced by Dupont in the 1950s to water-repellent clothing, PFAS have found their way into numerous items we use regularly. 

However, there’s growing concern about the impact of PFAS on both human health and the environment. Studies have linked them to adverse effects, leading to new federal regulations. As a result, there’s a rising demand for services that investigate, treat, and consult on PFAS-related issues. 

One of the challenging aspects of dealing with PFAS is understanding how they behave in the environment. These chemicals can be found in many places, from military bases and wastewater treatment plants to our drinking water and the air we breathe. Some types of PFAS, like perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS), are known for their persistence and ability to accumulate in living organisms, which raises concerns for both us and nature. 

Ongoing research suggests that exposure to PFAS could have adverse health effects such as elevated cholesterol levels, immune system responses, and low birth weight. There’s also a possibility of a suggestive carcinogenic potential. 

The resilience of PFAS is attributed to their unique chemical structure, often described as having a “two-part” composition. The “tail” is a strong bond between carbon and fluorine, making it one of the most robust bonds found in nature. The “head” includes a functional group, like a carboxylic or sulfonic acid, which gives PFAS their remarkable properties of being both hydrophobic (repelling water) and hydrophilic (attracting water). 

What this means to you 

Keeping pace with the ever-changing landscape of PFAS rules and regulations poses a significant challenge. Dealing with PFAS contamination remains a persistent issue for both industries and local governments, each situation presenting its unique complexities. At UES, our team of seasoned environmental engineers, geologists, scientists, and technicians excels in guiding clients through a customized process from start to finish, addressing their individual requirements.

With extensive expertise in navigating PFAS sampling, monitoring, and public awareness scenarios, UES has collaborated with municipalities and governmental entities on various fronts. This encompasses sampling drinking water, wastewater, discharges, and groundwater, while offering comprehensive remedial solutions. Our objective is to effectively steer you through the PFAS testing and remediation journey in a manner that is both cost-effective and technically feasible.

Our PFAS Consulting Process

Sampling, Testing, and Reporting 

UES’ team of PFAS experts collects various types of media including solid, aqueous, and air samples for PFAS testing from specific sites. 

Because PFAS are analyzed in such small quantities–parts per trillion–even the smallest cross-contamination could contribute to a false positive sample. Our experts are highly trained in sample collection procedures and follow standard best practices for environmental sampling to prevent contamination. We select the proper method for collecting samples based on the type of sample, making sure to follow all regulatory guidelines. After the samples are collected, they are submitted for analysis to a certified laboratory to determine the concentration of PFAS present. 

The data is carefully examined by our PFAS experts to see if the samples exceed the regulatory limit for PFAS. The test results are then reported to the Client, and at the Client’s request to the appropriate regulatory agency. Understanding those results is crucial for identifying any potential risks to human health and/or the environment, and figuring out the extent of any necessary remediation activities. 

Remediation and Design 

If determined necessary, UES evaluates, designs and constructs cleanup systems to address contamination at sites across the country. We are actively involved in emerging remediation efforts. Our team of expert PFAS consulting engineers and geologists employ the latest available techniques for soil and source management, as well as groundwater management. Our primary objective is to effectively limit exposure to PFAS and other types of contamination. 

Monitoring and managing PFAS contamination is a vital part of a successful remediation program. We can offer expert guidance on developing and implementing a monitoring plan for sites affected by PFAS. This includes installing monitoring wells to keep a close eye on things. 

We can also assist in grant writing to obtain federal funding for sampling, remediation and other PFAS related activities. 

Our PFAS Services: 

  • Feasibility studies for PFAS removal in water, wastewater, and leachate 
  • Subsurface investigation and sampling of soil, sediments, and groundwater 
  • Historical research and PFAS source identification 
  • Plume evaluation and contaminant migration 
  • Remedial design and treatment of soil, sediments, and groundwater 
  • Installation of remediation systems 
  • Environmental site assessment 
  • Contaminant hydrogeology 
  • Sampling and Monitoring Assistance 
  • Treatability Studies 

Having a proven history of effectively conducting site investigation and remediation projects across various settings, we have refined our expertise in offering reliable PFAS sampling, investigation, and cleanup methods. 

UES’ PFAS Consultation services are offered nationwide. 

Our PFAS Consulting Process

No matter what your environmental consulting needs are, UES's professionals have an answer for you.

The Fifth Unregulated Contaminant Monitoring Rule (UCMR5)

As you may know, as part of the Safe Drinking Water Act (SWDA), the USEPA implements Section 1445(a)(2), Monitoring Program for Unregulated Contaminants. The rule requires once every five years that USEPA issue a list of priority unregulated contaminants to be monitored by certain public water supply systems across the nation. 

The list of unregulated contaminants includes 29 per- and polyfluoroalkyl substances (PFAS) and lithium. USEPA has required all public water supply system serving between 3,300 and 10,000 people to monitor and ensure that a nationally representative sampling of systems serving fewer than 3,300 people monitor for the contaminants in UCMR 5. 

Samples must be collected between 2023 and 2025, and completion of data reporting in 2026. 

The required schedule set by USEPA in the chart below. 

Sampling for PFAS substances is more complex than regular sampling since it is very easy to cross contaminate the samples due to improper sampling techniques including wearing the wrong clothes, gloves, etc. UES has direct experience with the complex collection of PFAS sampling, monitoring, and subsequent public awareness scenarios. Dave Poague of our staff has over 20 plus years working with municipalities and other governmental entities with sampling drinking water, waste water, discharges, groundwater monitoring and analytical support.    

If you do not have the time, resources, or experience in the proper collection and monitoring of PFAS, let UES partner with you and deliver accurate, reliable, and timely results done in a professional manner. 

PFAS are a set of man-made chemicals that have been used in a wide range of consumer and industrial products since the 1940’s due to their resistance to grease, oil, water, and heat. For example, PFAS are used in stain- and water-resistant fabrics and carpeting, cleaning products, paints, and fire-fighting foams. Certain PFAS are also authorized by the FDA for limited use in cookware, food packaging, and food processing equipment.  Common everyday items such as pizza boxes, fast food wrappers, microwave popcorn bags, baking papers, Teflon® coated cookware, protective clothing, tents, personal care products, adhesives, waxes, and carpets are just a few examples of items that contain PFAS.  There has been a reduction in the manufacturing and use of certain types of PFAS.  For example, some manufacturers such as 3M, the principal worldwide manufacturer and sole U.S. manufacturer of PFOS are phasing out the production of PFAS.   There are a total of eight companies worldwide that produce various types of PFAS.  Some companies are replacing PFAS with alternative substitute chemicals with the same performance effectiveness of their predecessors.  Unfortunately, it is not evident that these replacement chemicals are safe to use.  

PFAS are considered “forever chemicals” because they are environmentally persistent, bioaccumulative, and remain in human bodies for an unknown length of time.  Accumulation of certain PFAS has been demonstrated through blood testing of humans and animals around the world.  In fact, polar bears in the Artic have been found to have low levels of PFAS in their blood.  This widespread exposure is attributed to the ability of these chemicals to bind to blood proteins and long half-lives in humans.  PFAS has been shown to cause cancer and other severe health problems and poses serious threat to drinking water supplies across rural, suburban, and urban communities. 

UES has formed a committee to develop standard operating procedures, guidelines and marketing to assist entities that may be impacted or need additional guidance.  UES staff has experience in sampling and can provide direct support to our current and future clients regarding PFAS issues.  There are many business entities that potentially could have used PFAS in their operations including aerospace, manufacturers of textiles, paper products, and insulation, metal platers, semiconductor industry, wire manufacturing, chemical producers and many others.  At least 2,500 industrial facilities across the nation could be discharging PFAS into the air and water, according to EPA.  The image below (obtained from EWG) shows the locations of facilities documented as using PFAS. 

According to EWG there are 446 public water systems known to be contaminated with PFAS and nearly 700 military installations with known or suspected PFAS contamination. These facilities are not shown on the above image.  PFAS contamination has also been identified at landfills (disposal of wastes containing PFAS), wastewater treatment plants (conventional sewage treatment methods do not efficiently remove PFAS), and biosolids (domestic sewage applied on agricultural land).   

Updated PFAS Information

The PFAS landscape is everchanging as EPA continues to propose new rules and regulations to govern PFAS manufacturing, reporting, handling, and disposal.  To keep our clients up to date on the latest challenges regarding PFAS please see the links below:

New Federal Rules Regarding PFAS

There are several important rules finalized by the United States Environmental Protection Agency (EPA) that have the potential to impact your business and/or operations. UES is a national leader in assisting clients with issues pertaining to PFAS. Read more on UES’ PFAS services. 

Final Rule for National Primary Drinking Water Regulation (NPDWR) for Six PFAS

On April 10, 2024, the EPA finalized a rule that established Maximum Contaminant Levels (MCLs) for six PFAS including:

  • Perfluorooctanoic acid (PFOA)
  • Perfluorooctane sulfonic acid (PFOS)
  • Perfluorohexane sulfonic acid (PFHxS)
  • Perfluorononanoic acid (PFNA)
  • Hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX chemicals)
  • Perfluorobutane sulfonic acid (PFBS)

MCLs are enforceable drinking water standards for public water supply systems.  Individual MCL concentrations were finalized for five PFAS, and a Hazard Index MCL was finalized for an additional four PFAS. Health-based water concentrations, which are used to calculate the Hazard Index, were also established for four PFAS. The new MCLs and health-based water PFAS concentrations are summarized in the table below.

NOTE: All units are in parts per trillion. 

Hazard Index MCL – Health-based concentrations are used to calculate the Hazard Index (HI) and were established for four PFAS. The EPA’s Hazard Index uses the individual measurements of PFNA, PFHxS, PFBS, and HFPO-DA to evaluate their combined risk. Measurements of the four individual PFAS are divided by their respective health-based water concentrations, which are included in the table above. The four values are then summed to calculate the HI, which is compared to the Hazard Index MCL of 1.  A Hazard Index greater than 1 would be considered an MCL exceedance.

Analytical requirements to test the water for PFAS as set forth in the final rule include EPA Method 533 or Method 537.1 for NPDWR monitoring.  UES has national contracts with certified laboratories nationwide that meet the NPDWR requirements.

Additional requirements for municipalities (public water systems) include completing initial monitoring of their systems by 2027 and then begin ongoing compliance monitoring thereafter. Beginning in 2027, public water systems must include PFAS monitoring data in Consumer Confidence Reports. Starting in 2029, if public water systems have PFAS concentrations that exceed the MCLs in drinking water, they must take action to reduce levels of these PFAS to below MCL values and notify their consumers.

A link to the final rule is provided:  PFAS FINAL NPDWR

USEPA Designates PFOA AND PFOS as Hazardous Substances under CERCLA

On April 19, 2024, the United States Environmental Protection Agency (USEPA) announced the designation of two PFAS, PFOA and PFOS, including their salts and structural isomers, as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund.  This designation empowers federal and state government agencies and third parties to address sites impacted by hazardous substances and seek cost recovery from those parties responsible for a release.  These actions could include the entire costs of clean-up and providing alternative drinking water supplies to individuals and/or communities. 

The designation will also allow USEPA enforcement authority, reevaluation of on-going remedies at active CERCLA projects and even the reopening of historically closed CERCLA projects.  USEPA has indicated it will focus on holding entities responsible that “significantly contributed to the release of PFAS into the environment” such as manufactures, industrial dischargers, federal facilities and other industrial parties.

The designation will also impact the Due Diligence (Phase I Environmental Site Assessments) process that complies with the federal All Appropriate Inquiry (AAI) rule in order to qualify for certain CERLCA liability protections.  Since PFOA and PFAS, including their salts and structural isomers have been designated as hazardous substances under CERCLA, they are now considered in-scope and must be considered whey identifying Recognized Environmental Conditions (RECs) as part of the Due Diligence process following the current ASTM Standard E1527-21.

Finally, any releases of PFOA and PFAS, including their salts and structural isomers at 1 pound or greater must be reported to the National Response Center within a 24-hour period following the release.  

A link to the designation is provided:  EPA Website 

UES can provide assistance:

If you have questions or would like to discuss how these regulations might impact your business, please reach out to our team of PFAS experts.  UES can provide technical assistance and oversight with sampling, monitoring, assessment, reporting and cleanup of PFAS-related releases and contamination.