Monday, April 29, 2019

EPA Opens Comment Period on Draft PFAS Cleanup Guidance

The U.S. Environmental Protection Agency (EPA) is seeking public comment on a draft set of interim recommendations for addressing groundwater contaminated with perfluorooctanoic acid (PFOA) andr perfluorooctane sulfonate (PFOS) at sites being evaluated and addressed under federal cleanup programs, including the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) and corrective action under the Resource Conservation and Recovery Act (RCRA). The complete guidance can be read at this link. 

PFOA and PFOS are synthetic fluorinated organic chemicals belonging to a large group commonly referred to as per- and poly-fluoroalkyl substances or PFAS. Manufacturers have produced PFAS for a variety of industries and products, including surface treatments for soil/stain/water resistance; surface treatments of textiles; paper; metals; and for specialized applications, such as fire suppression for hydrocarbon fires, and have been widely used on military bases. PFOA and PFOS are resistant to metabolic and environmental degradation; and therefore, are highly persistent in the environment and can bioaccumulate in humans.

Studies indicate that high concentrations of PFOA and PFOS can cause reproductive and developmental, liver and kidney, and immunological effects in laboratory animals. Both chemicals have caused tumors in animal studies. The most consistent findings from human studies are increased cholesterol levels among exposed populations, with more limited findings related to cancer, thyroid hormone effects, other reproductive and developmental impacts in humans, infant birth weights and adverse effects on the immune system.

Drinking water can be a source of exposure in communities where these chemicals have contaminated water supplies. Such contamination is typically associated with a specific facility, for example: an industrial facility where PFAS were produced or used to manufacture other products, or locations where firefighting foam was used such as oil refineries, airfields or other training facilities for firefighters.

PFAS include a large number of important chemicals that can be used in some food packaging and can make things grease- and stain-resistant. They were used in firefighting foams and in a wide range of manufacturing practices. Unfortunately, some of these substances don’t break down over time. That means they build up in the environment and in our bodies. The result is that according to the CDC more than 95% of the U.S. population has measurable levels of PFOA and PFOS in their blood; and babies are born with PFOA in their blood.

If you recall in February the EPA announced their Per- and Polyfluoroalkyl Substances (PFAS) Action Plan, taking the first steps in the process to create a maximum contaminant level (MCL) for PFOS and PFOA to regulate these chemicals under the Safe Drinking Water Act. The current guidance provides interim recommendations for screening levels, and preliminary remediation goals (PRGs) to inform final cleanup levels for PFOA and/or PFOS contamination of groundwater that is a current or potential source of drinking water.

The interim guidance will be open for public comment for 45-days from 04/25/2019 to 06/10/2019.Submit your comments, identified by Docket ID No. EPA-HQ-OLEM-2019-0229, at https://www.regulations.gov. Follow the online instructions for submitting comments. Once submitted, comments cannot be edited or removed from Regulations.gov.

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