Are You PFAS’d Out?
Just when you thought everyone was fatigued by PFAS constantly being in the limelight, the US EPA released its Interim Strategy Memo for National Pollutant Discharge Elimination System (NPDES) announced in a press release dated November 30, 2020. PFAS has been the hot topic monopolizing environmental news and conferences for quite some time now. Most environmental conferences are filled with 2-3 days of PFAS topics across matrix lines. PFAS analysis is still in its infancy with more laboratories offering PFAS analytical services and just the current US EPA-approved drinking water methods. Methods are still not settled.
The press release discussed two issues. First, in its memorandum, US EPA detailed an interim NPDES permitting strategy for addressing PFAS in US EPA-issued wastewater permits. Second, the press release addressed the US EPA-released information on progress in developing new analytical methods to test for PFAS compounds in wastewater and other environmental media. “Better understanding and addressing PFAS is a top priority for EPA, and the agency is continuing to develop needed research and policies,” said US EPA Administrator Andrew Wheeler. “For the first time in EPA’s history, we are utilizing all of our program offices to address a singular, cross-cutting contaminant and the agency’s efforts are critical to supporting our state and local partners.”
With the PFAS guidelines and available information almost constantly evolving, how does one protect themselves from future liabilities? How does one go about analyzing samples for PFAS compounds? To answer these questions, one needs to seek help in securing the most comprehensive set of data with the best available technology. Analysis of wastewater samples by US EPA Methods 533 and 537, or 537.1 (modified) for drinking water will not suffice. How can the US EPA consider interim strategies that consider wastewater monitoring without first developing robust analytical methods to detect PFAS in wastewater? Determining the PFAS compounds in your matrices requires the knowledge base of existing technologies and current trends. Literature states that the number of PFAS compounds is between 3000 to 6000.
Due to the finite number of standards available for target compound analysis and lack of methods and regulations, one would potentially need to consider total organic fluorine (TOF) analysis, analysis of PFAS by US EPA Method 537 (modified), total oxidizable precursor (TOP) assays and non-targeted analysis (NTA). Some state agencies have set regulations and aggressive limits for their programs, but the comprehensive analytical requirements are non-existent. To sum it all up, one needs to seek help from experts in the field to come up with a strategy.