Professional Documents
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PERSPECTIVE:
Seven views of
challenges and opportunities
1. PFAS &
INDUSTRY
Per- and polyfluoroalkyl substances (PFAS) are a group of After leading more than 15 years’ worth Take a proactive and
of PFAS-driven environmental projects, pragmatic stance
emerging contaminants with unique chemical features. They our PFAS experts understand the
A pragmatic approach to assessing an
are a broad class of chemicals that, for decades, have been challenges, sensitivities and risks that
industrial site’s PFAS risk is to assess its
industry is dealing with. When the United
utilized in technical and consumer products for their oil, States Environmental Protection Agency’s
vulnerability. Performing a thorough
water and heat resistant properties. (USEPA) promulgation of a health
vulnerability assessment involves
evaluations of:
advisory level for PFAS in drinking water
was released in May 2016, it created a
• The current and future regulatory
In recent years, concerns around the non-government organizations and host of additional risks for companies with
environment
human health impacts of certain PFAS interest groups encouraging agencies to U.S. sites.
have substantially increased the regulate all PFAS. • PFAS presence in products, supply
awareness and scrutiny of this class of Some risks are financial, including triggers chains, and manufacturing processes
chemicals. The rapidly evolving regulations and to set reserves for publicly traded
• The hydrogeology and physical
innovation around measuring and companies or to increase reserves as a
setting of an individual site, including
Regulatory agencies in North America treating PFAS make it difficult to chart result of growing regulatory awareness
other potential PFAS sources
and around the world are setting limits the optimal management strategy for and enforcement. Other risks are related
for select PFAS compounds in drinking these chemicals. By examining our to third-party liabilities, which typically
Digital solutions like Arcadis’ geographic
water, especially perfluorooctane experiences working with PFAS from arise when PFAS travels outside a facility
information system-based PFAS
sulfonate (PFOS) and perfluorooctanoic industrial, federal and public utilities and threaten potential receptors. Finally,
vulnerability tool can provide a head
acid (PFOA). In the U.S., some state perspectives, we hope to increase risks also include brand exposure and
start on assessing and prioritizing actions
agencies are casting wider regulatory organizations’ abilities to manage PFAS public relations concerns.
without sampling or testing. The tool
nets to include more PFAS, and there are impacts proactively.
enables a focused and risk-driven
Companies looking to prepare for these
approach for an individual site or a
risks must adopt proactive and pragmatic
portfolio of sites with mixed risk profiles.
strategies for PFAS, understand and
engage in the regulatory landscape, and
consider alternatives to PFAS.
At a Glance
1. Industry......................................................................................................................................... 3
2. Litigation....................................................................................................................................... 6
3. Treatment Technology.............................................................................................................. 8
4. The Federal PFAS Response: America................................................................................... 10
5. The Federal PFAS Response: Canada.................................................................................... 12
6. Airports.......................................................................................................................................... 14
7. Water Utilities.............................................................................................................................. 16
Keys to Planning for PFAS............................................................................................................ 18
Arcadis’ PFAS site vulnerability tool can provide a head start on assessing and prioritizing actions without
sampling or testing.
It maps USEPA data on PFAS and other Understand the PFAS organizations understand where Consider alternatives that the costs of replacing a fire suppression
chemicals in public water for all major regulatory landscape regulatory risks may be higher for certain lower PFAS risk system might make PFAS-based
water supplies, including permitted PFAS chemistry at individual facility firefighting foam the preferred choice.
The science around most PFAS (e.g.,
industrial discharges in the U.S. It also locations or regions. Often, the PFAS have been used for decades Still, there are opportunities to alter and
PFOA, PFOS, PFNA) that informs many
uses state data to perform another layer regulatory trends around health effects because of their unique and valuable adapt testing and training methods and
regulatory discussions is still developing.
of assessment, identifying smaller public and toxicity observed in the EU and chemical properties, and some facility infrastructure to minimize
The fact that states are proposing or
water supplies as well as locations of
private potable wells, and providing
have enacted enforceable regulatory
standards for additional PFAS (e.g., GenX,
Australia influence U.S. state and federal
regulations. Some fluorine- companies may need to continue to
manufacture or use PFAS in operations.
potential environmental releases.
leading the way The DOD sits at the leading edge of the
while the USEPA does not currently
have any PFAS drinking water or
PFAS response, as demonstrated by its groundwater standards, it announced
proactive assessment of PFAS impacts at that it will develop maximum
DOD installations across all military contaminant levels (MCLs) within the
branches. DOD programs have provided next four years.
millions of dollars to fund research of
PFAS chemistry, treatment, and fate and National Defense Authorization
transport. The DOD is also working to Act (NDAA)
transition away from PFAS-containing Congress drafted language in the Fiscal
foams by funding research on F3 foams Year 2020 NDAA to address PFAS
that can safely meet the firefighting associated with DOD operations. As part
needs of the DOD. of the legislation, the DOD is now
required to ensure proper disposal of
The DOD is doing more than just research PFAS containing materials, and enter
and analysis. For example, it has hired into cooperative agreements with states
Arcadis and is working collaboratively to for testing and remediation of PFAS
perform preliminary assessments and site releases associated with DOD
inspections at 85 U.S. Army installations operations. In addition, this legislation
using a programmatic approach. identified specific PFAS to be added to
Similarly, other branches of the DOD are the USEPA’s list of chemicals included in
systematically reviewing their portfolios, the Toxic Release Inventory (TRI).
Some water utilities are Most larger water supplies have If utilities have the means, more
completed some initial PFAS testing. The expensive treatment options, such as
finding PFAS in their source next step for water utilities with positive nanofiltration and reverse osmosis, are
water supplies, but many detections will be to conduct additional available. However, cost-effective
monitoring to understand how the management of rejectate volumes with
do not have installed occurrence of PFAS in their individual concentrated PFAS remains an obstacle.
treatment that will remove supply wells or intake locations varies Many of the advanced treatments
these compounds. And like throughout the day and year. employed by industry and federal
Understanding the variability of PFAS agencies are not currently feasible for
the DOD, water utilities are occurrence will be useful in designing the water utilities. Besides disposal
struggling with a lack of appropriate management or treatment challenges, volume differences – large
option. utilities might treat 100x more water
federal standards. each day than industrial sites – make
Build a foundation of data some solutions impractical to implement.
In 2016, the USEPA released a Lifetime Any effort will start with data collection.
While the regulatory framework is still Partnerships and innovation
Health Advisory of 70 parts per trillion for
PFOA and PFOS in drinking water. There developing, there are still opportunities will help
are utilities taking action to stay below to conduct due diligence around In the future, industrial dischargers to
this level, but many water purveyors are potential PFAS in water sources. Early public wastewater facilities may be PFAS discharges to limit future liability as predictive analytics could leverage public
hesitant to use tax revenues given the assessments allow for better planning required to pre-treat for PFAS. This is now this issue becomes a public concern. data to map out problem areas and
lack of more formal (state or federal) and efficient use of resources, should required in a few U.S. states, but the potential treatment strategies according
standards, including the absence of any treatment be required. trend is expected to increase. Potable reuse can alleviate strain on to which compounds are present and to
required MCLs. stressed water supplies, but PFAS add what extent. Innovation like this might be
Treatment options are limited Currently, many wastewater utilities are new challenges to implementing many of the difference in overcoming PFAS
Some private water utilities, much like not equipped to treat PFAS. Arcadis the advanced treatment processes challenges.
Today, the most common approach to
companies with sites in multiple states, supports various industrial dischargers by required for reuse, such as oxidation and
achieving drinking water standards is
want to implement uniform responses. helping them lower PFAS in their waste reverse osmosis membranes. Oxidation
through dilution and blending of
While the regulatory framework
Differing state-by-state regulations will streams/conveyance, as well as providing could convert precursors into
different water sources. When treatment
make that a challenge, and the cost-effective end-of-pipe solutions. perfluoroalkyl substances, and while
is required to remove PFAS from drinking
membranes can concentrate PFAS
is still developing, there are still
inconsistency will make it harder to talk water, it is usually done using GAC These efforts can help resolve problems
about PFAS with the public. Despite no before discharges impact drinking water successfully, utilities are not typically
filtration. GAC is effective at removing
clear federal and state standards, an supplies. equipped to handle the resulting
opportunities to conduct due
some PFAS, particularly the longer
increasing public awareness and the concentrations of PFAS residuals.
chained PFOS and PFOA. Plus, GAC and
potential of litigation and/or actual ion exchange are broadly understood Another growing concern is the
lawsuits are driving PFAS cleanup efforts
at municipal water facilities.
treatment technologies that are readily
deployable and will be more easily
management of PFAS-impacted biosolids
from conventional wastewater
As the water sector embraces Intelligent
Water, there might be new strategies for diligence around potential PFAS
in water sources.
accepted as viable treatment options by treatment. More industrial users are PFAS. For example, machine learning and
state regulatory agencies. taking steps to reduce and eliminate
drinking water.
migrating to water supplies is the most prudent
approach to managing these sensitive sites.
It is worth noting that while the majority of regulator and stakeholder concerns are currently focused on the
presence of PFAS in drinking water, Arcadis is also a leader in the assessment and mitigation of PFAS
presence in air, natural waters, sediments, and wastewater.
Contact us to learn more about our specific PFAS services and how we can help your organization carefully
chart a path forward in this evolving landscape.
Jeff Burdick
Global Leader Site Evaluation Rebecca Slabaugh
and Restoration Drinking Water Practice Lead
jeff.burdick@arcadis.com rebecca.slabaugh@arcadis.com
Federal shannon.dunn@arcadis.com
Arcadis.
Improving quality of life.