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In the span of just a few years, the ubiquitous group of compounds collectively known as PFAS (i.e., per- and polyfluoroalkyl substances) have progressed from relative anonymity in the drinking water treatment community to a generational contamination challenge. Although many water systems will have previously sampled for six PFAS compounds under the USEPA’s Third Unregulated Contaminant Monitoring Rule (UCMR3) a decade ago, the updated PFAS monitoring program currently being conducted under UCMR5 (2023-2025) encompasses more water systems and 29 PFAS compounds, along with lower detection limits. Thus, it is inevitable that many utilities will be unpleasantly surprised to identify the presence of PFAS contamination in their water supplies.
With some of the USEPA’s recently proposed Maximum Contaminant Levels (MCLs) for PFAS very close to their respective limits of detection, many of the water systems that identify PFAS will be required to remove these contaminants from distributed supplies. However, PFAS also present a challenge for water systems detecting concentrations of PFAS compounds below their respective MCLs or even unregulated PFAS species. With the USEPA issuing highly publicized health advisories at almost infinitesimally small parts-per-quadrillion levels for the two most prevalent PFAS species – PFOA and PFOS – in June 2022, consumers are inclined to consider the presence of any PFAS in their drinking water as an unacceptable health risk. Thus, knowingly allowing any detectable PFAS compounds – regulated or not, at any concentration – in treated drinking water delivered to consumers creates the potential for a significant optics problem. Consequently, it is likely that almost any utility identifying PFAS in its water supplies will be obligated to take at least some action in response.
For water utilities already contending with an array of important issues, including lead and copper regulations, infrastructure management and replacement, water supply resiliency, and workforce sustainability (among others), the unexpected detection of PFAS is certainly an unwelcome challenge; however, it does not have to be a daunting one. The following series of methodical, straightforward steps can serve as the outline for an effective roadmap for successfully navigating a PFAS response.
Quickly developing and implementing a communications plan is an important first step to project the utility’s proactive response. Because UCMR5 results are publicly released by the USEPA and must be published in Consumer Confidence Reports (CCRs), customers will be aware of PFAS detections, prompting concerned inquiries from both consumers and the media. Thus, preparing both a list of frequently asked questions for the utility website and appropriate consumer briefing language for inclusion in the CCR are critical tasks. An internal briefing document for the utility may also be valuable so that staff has a common understanding of the issues associated with PFAS and the organizational response.
2. Investigate Funding
The 2021 Bipartisan Infrastructure Law allocated billions of dollars in funding to address PFAS contamination in water supplies, including $4B available under the Drinking Water State Revolving Fund. In addition, cost recovery for treatment systems may be available via various legal settlements of class action litigation against PFAS producers. However, given the broad extent of PFAS contamination throughout the U.S., it is widely anticipated that these funding sources may not be sufficient to cover the treatment costs for all affected water systems. Thus, it is important for utilities to understand their funding needs and initiate action for cost recovery as soon as possible. Although a utility’s specific costs may not be known until the project is further defined, it is important to investigate options and prepare to apply for funding early in the process of any PFAS response. These proactive steps may also be important to highlight in the PFAS communications campaign to help assuage concerns of rate-conscious customers.
In addition to the required UCMR5 monitoring, which mandates sampling only at distribution system entry points, it may also be important to conduct a strategic investigation to determine the source of PFAS contamination. This information may enable less expensive non-treatment options for eliminating PFAS from drinking water supplies (e.g., blending and/or taking affected sources offline). The identification of contamination point sources may also facilitate non-treatment mitigation or cost recovery from responsible parties.
4. Assess Treatment Feasibility
UCMR5 monitoring results will suggest the need for treatment, as well as help inform the selection of viable options. Best available technologies for municipal PFAS treatment include granular activated carbon, ion exchange, and reverse osmosis, although novel sorbents (i.e., crafted specifically for PFAS removal) and other innovative technologies may also be viable. The selection of an optimum treatment process depends on numerous site- and project-specific factors, many of which can be evaluated via an initial desktop study. However, bench- and/or pilot-scale testing may also be advisable to differentiate viable options and compile design criteria. Such testing, along with the selection of a preferred treatment alternative, can also facilitate a refined cost estimate for the purposes of budgeting and grant funding applications. It is important to include residuals management in any feasibility study, as the potential for the USEPA to designate multiple PFAS species as hazardous under the Comprehensive Environmental Response, Compensation and Liability Act (i.e., CERCLA) and/or the Resource Conservation Recovery Act (i.e., RCRA) could be a significant factor influencing the selection of a treatment option and associated costs.
5. Initiate Treatment Design
Upon selecting the most feasible treatment option (if necessary), progressing quickly to design and construction is important to ensure timely compliance with federal regulations and remove PFAS as expediently as possible. Although the USEPA has proposed a three-year compliance window from the date of final promulgation, the number of systems requiring treatment may create high demand for both equipment and contracting services, potentially resulting in delays that could compromise scheduling. This same competition is also likely to escalate costs. Initiating project delivery early may mitigate some of the anticipated cost and schedule challenges.
Although few anthropogenic drinking water contaminants have been as prevalent and broadly disruptive as PFAS, the framework described above provides utilities with a clear path for addressing the associated challenges. Arcadis has been working with federal, industrial, and municipal clients on a wide variety of PFAS-related issues for more than 20 years, including extensive experience with strategic planning and full-scale deployment of innovative technologies and solutions. Please contact us to discuss your PFAS concerns and how we can help you utilize this framework to achieve timely, affordable, and effective PFAS removal in drinking water supplies.