Risks of PFAS in Wastewater and Initial Steps for Detection

12.18.23

As drinking water providers nationwide devise plans to mitigate and treat PFAS substances in order to meet new federal drinking water regulations, a corresponding set of regulations could potentially be on the way. Citing a need for a comprehensive PFAS contamination solution in its PFAS Roadmap, the EPA has encouraged wastewater treatment facilities to begin testing their effluent for these forever chemicals to understand how they are impacting local water supplies.

PFAS are found to reduce vaccine effectiveness, cause cancer, and inhibit fetal and infant growth, among many other health impacts. Upcoming EPA drinking water MCLs (maximum contaminant levels) will reduce household PFAS exposure for millions of Americans and safeguard drinking water quality. However, as wastewater containing PFAS impacts water sources, the remediation efforts by water utilities and municipalities may be consistently hindered by this continuous contamination.

As communities with shared water sources devise plans to comprehensively handle this widespread contamination, wastewater sampling and analysis will play a key role in closing the contamination loop. However, this requires wastewater utilities to be aware of how to detect PFAS contamination in wastewater and respond to the results.

What Are PFAS and Why Are They a Concern?

PFAS are a group of synthetic chemicals that have been used in consumer products worldwide since the 1950s. Primarily known for their anti-stick properties, PFAS are challenging to break down and persist for long periods in the environment after leaching from these consumer products and the facilities that make them.

Water is the universal solvent. And unfortunately, PFAS have infiltrated the Earth’s water cycle, placing them in almost every water source in the United States. Their bio-persistent and difficult-to-destroy characteristics, coupled with this relationship to water, has made them one of the most widespread water contaminants globally.

Once PFAS find their way into a municipal water source, they often pass through the water treatment process, as conventional water treatment methods are not designed to consistently remove these chemicals. After infiltrating public water systems, if not treated, PFAS are consumed by humans via tap water, presenting public health hazards. Populations near a facility that discharged the chemical into the local water supply are particularly vulnerable.

PFAS exposure via water, food, and the air can cause kidney cancer, weaken immunities, and much more in humans and wildlife, negatively affecting biodiversity and the overall health of our environment. This is evidenced from ecological indicators, such as amphibians exposed to PFAS, that show malformations, cancers, and reproductive difficulties, which has stressed ecosystems globally.

Impact of PFAS Contamination on Water Quality Testing

PFAS and wastewater discharge have a long, intricate relationship. Beginning at large companies like 3M and DuPont producing PFAS-latent consumer and industrial products, contaminated wastewater has been collected and discharged to the surface and groundwater supplies that municipal water providers have relied on for decades. As PFAS became more ubiquitous in the ecosystem and more consumer products have continued to be discarded over time, municipal wastewater plants have become passive recipients and as a result, PFAS dischargers.

Mitigation of Contamination Ramifications

Upon discovering PFAS in your wastewater, the implications on budget and public perception are stark. PFAS contamination has the potential to upend capital expense plans, trigger costly construction projects, and permanently increase labor costs as high-tech equipment reclassifies treatment facilities and requires additional training for operations staff.

The EPA's pivotal proposal to classify PFOA and PFOS as hazardous substances is expected to result in a CERCLA designation by early 2024. So, while the introduction of federal regulation for PFAS in wastewater remains uncertain, conversations on how to comprehensively remove PFAS from the environment are taking place in state and federal regulatory circles. And the actions that stem from these discussions have the potential to hold a hefty price tag.

Ahead of federal guidelines, several states have approved or are considering laws pertaining to testing PFAS concentrations in biosolids, which has already disrupted ongoing land application and landfill practices. In Maine, for example, biosolids must be tested for PFAS before being land-applied, with certain concentrations disqualifying previously acceptable biosolids standards. This rule has shifted the state’s biosolids disposal practices as wastewater utilities are relegated to more costly disposal options. And as regulatory bodies investigate the role of landfills in PFAS contamination, even disposal may come under scrutiny.

As drinking water providers begin to receive PFAS settlements from big-name PFAS manufacturers such as 3M and DuPont, some proactive wastewater utilities are beginning to align themselves with the ongoing legal actions with the objective to cover the contamination mitigation costs.

Initial Steps for Detection and Response

Water utilities depend on wastewater treatment plants to treat their effluent to the highest standards in order to preserve water source quality. Many downstream water providers already maintain lines of communication with upstream wastewater plants to discuss nitrate, ammonia, and phosphorus levels seen at their water plant’s intake, since water quality has a direct effect on water treatment operations and costs. As PFAS MCLs go into effect in the next few years, PFAS concentrations may become a part of this ongoing conversation.

To protect their community’s water source, as well as the ones downstream, wastewater plants can be assets to neighboring drinking water providers by considering the following steps for PFAS detection in wastewater and response.

Establish a Cross-functional Team

Detecting and communicating PFAS concentrations requires a cross-functional team to collaborate within a utility. Ideally, this team includes representation from laboratory staff, utility communications staff, plant operations, and leadership to routinely test water quality, manage lab results, and communicate these results to those who share water bodies with the wastewater plant. Together, this intra-utility PFAS team can decide what information is essential and how to convey it to neighboring utilities and ratepayers.

Assess Water Sources

After assembling the cross-functional PFAS task force, the next step is to identify nearby water sources that local municipalities depend on. This is to gain a sense of which water supplies could be contaminated by PFAS wastewater. These sources include groundwater, surface water, as well as drinking water treatment and distribution systems.

Assess Contamination Sources

Once local water sources are identified, locating potential PFAS contamination sources becomes more manageable. Municipal wastewater effluent is a known contributor. However, industrial sites and landfills in the watershed may be contributing to PFAS through discharge and leaching.

Prioritize Sampling Sites

With water and contamination sources in mind, the wastewater team can begin prioritizing water sampling sites and testing frequency. For wastewater utilities, this is primarily a question of where their effluent enters water supplies and potentially contaminates ground and surface water resources.

Implement Testing and Evaluate Results

Water and wastewater utilities can work together to test prioritized sampling sites to track and monitor PFAS entering the water supply. Using EPA Methods 1633 and 8327, private and in-house labs across the country now have the means to determine PFAS concentrations in wastewater, biosolids, and soil to determine PFAS concentrations and the risk they pose to local water sources.

Develop Mitigation Plan

Upon determining PFAS concentrations and their sources, wastewater utilities can put themselves in front of potential clean water regulations by creating PFAS mitigation plans to counter its public health impacts. In addition to considering mitigation and treatment options, multi-utility teams can communicate PFAS’ presence in local drinking water supplies and what’s being done together, presenting a united front against this pervasive contaminant. Mitigation plans can even include dual funding strategies to ease treatment cost burdens and meet current and future compliance standards for both clean and drinking water.

Proactive Approach to Contamination Mitigation

Water and wastewater utilities do not always consider litigation to fund treatment technology. But courtroom successes on the water side of the industry show it is a proven method of financing the technologies needed to remove PFAS while not penalizing ratepayers. Plus, it ensures that the polluters are held accountable.

SL Environmental Law Group has over 20 years of experience helping municipalities, water systems, and states hold polluters accountable and is currently focused on helping public entities recover the costs of PFAS contamination. SL already represents more than 100 water providers in the current Aqueous Fire Fighting Foam multidistrict litigation and over the past decades has helped over 150 clients, resulting in over $1.2 billion recovered in settlements and trials, to pay for the cost of contamination clean-up.

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