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PFAS

New drinking water standards for “forever chemicals” or per- and polyfluoroalkyl substances (PFAS) were recently released by the EPA which will take effect in 2029.  PFAS are a group of chemicals manufactured since the 1950’s that are used to make coatings and products that resist water, heat, oil, stains, and grease. They are found in non-stick cookware, firefighting foam, food packaging, clothing, cosmetics, and many other items. PFAS do not break down in the environment, ultimately finding their way into drinking water sources such as lakes and rivers. Santee Cooper, Summerville CPW’s water provider, has been monitoring levels of PFAS chemicals in Lake Moultrie for several years and found PFAS in levels slightly higher than the new EPA standards. In anticipation of the new standards, Santee Cooper began evaluating new treatment options, assessing each option for effectiveness in removing contaminants and cost. Santee Cooper will be prepared to treat the source water for PFAS when the new standards take effect.  In the meantime, consumers wanting to decrease their exposure may consider home or table-top water filters.

PFAS Information

Additional PFAS Information

The EPA adopted drinking water Maximum Contaminant Levels (MCLs) for six PFAS chemicals on April 26, 2024.  Water systems nationwide believe that EPA’s MCLs are not based upon good science, were determined based upon a clearly erroneous cost-benefit analysis, and the implementation period is too short and does not prioritize systems with the highest PFAS levels.  As a result, the American Water Works Association has filed a rare challenge by the drinking water industry to an EPA MCL.

Drinking water is only one of many pathways by which people can be exposed to PFAS.  EPA estimates Americans get 80% of their PFAS intake from other sources besides drinking water – dietary contributions being by far the greatest.  Significant human exposures of short-chain PFAS come from contaminated indoor air and dust in homes and businesses.

Water systems do not manufacture or use PFAS.  The systems are passive receivers of PFAS from source waters that have been contaminated by PFAS manufacturers and/or dischargers.  Bills and policies need to be developed to clarify liability of PFAS in water systems and associated waste discharges to prevent water systems from being potentially subject to future, avoidable legal risks particularly as EPA considers parameters for designating PFAS compounds as “hazardous substances” under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

3M, DuPont, and other manufacturers voluntarily started pulling PFOA, PFOS, and other long-chain compounds off the market in the 2000s. By 2018, according to the CDC’s most recent data, blood levels of PFOA and PFOS in the U.S. population had plummeted by 70 and 85 percent, respectively.  This trend is expected to continue in that direction as those compounds are no longer being introduced into the environment.  Many systems that are being required to invest millions of capital dollars in treatment facilities due to slight exceedances of the MCLs for those two PFAS compounds may not need it in a few years.

Many stakeholders have criticized EPA for its approach to the science underpinning the MCLs because EPA elected to ignore significant health-related data from populations exposed to PFAS “hot spots” around the country in favor of lab studies on mice and other animals which they then extrapolated to humans.  Much of the human data available was a result of USDA studying PFAS blood levels of 10,000 Americans annually since 1999, Chemours-related medical studies of residents of Vienna and Parkersburg, WV, and health data from Wilmington, NC residents.

EPA’s cost-benefit estimate badly missed the mark, as it estimated $1.5 billion in annual water treatment costs as compared to $1.5 billion in annual health benefits.  In actuality, AWWA estimated that annual operation and maintenance costs alone will be in the $3.8 billion range with another $40 billion in capital costs to install PFAS removal technology to meet the 4 ppt (PFOA/PFOS) MCL.  On the benefits side, EPA fails to identify any health-related clusters in the “hot-spot” areas around the country to support their benefits assessment.  The costs may imperil the financial sustainability and affordability of some water systems an direct resources away from other water system priorities.  EPA’s cost benefit estimates assumed all water utilities requiring treatment to reduce PFAS to meet the new MCL would do so by implementing GAC.  EPA added the potential, ancillary reduction of disinfection by-products into their equation when calculating the health benefits/savings. 

The five-year compliance schedule is woefully short and misguided.  EPA requires compliance with its MCLs by April 26, 2029,  knowing that five-years is nowhere near enough time for the thousands of affected water systems to immediately scramble to (1) hire a PFAS consultant, (2) identify the right PFAS technology, (3) plan its installation, (4) design the installation, (5) identify related water facility changes that the PFAS technology will necessitate, (6) identify and obtain funding (massive rate increases are the most likely result), (7) obtain state (and/or federal) permitting, (8) bid the project, (9) construct the project, and (10) verify that the project is successful.   Five-years is essentially a construction schedule for this type of sophisticated projects.  That means the 3,000-5,000 water systems needed to start earlier this year to meet the deadline.  With the compressed schedule all systems are limited to selecting current treatment technologies in lieu of considering potential emerging technologies.  This limits the availability of engineers, contractors permitting agency resources, funding and construction and operating materials.

EPA’s MCLs are significantly more stringent than other prominent health organizations such as the World Health Organization.  In September, 2022, WHO set provisional guidance values of 100 for PFOA/PFOS.  EPA does not address WHO’s decision to establish 100 ppt thresholds as opposed to its 4 ppt threshold.  If EPA adopted 100 ppt (or even 25 ppt) for PFOA or PFOS, likely 80-90 percent of affected water systems would no longer need to install PFAS removal technology.  EPA should clearly and compellingly explain the differences between WHO’s science and the science EPA relied on for its 4 ppt MCLs for PFOA and PFOS.