Colorados approach to addressing PFAS contamination January 14, - - PDF document

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Colorado’s approach to addressing PFAS contamination

January 14, 2020 David Dani

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Overview

• PFAS background.
• Where have they been detected?
• Regulatory challenges with contaminants of emerging concern.
• Steps EPA and Colorado are taking to reduce risk.
• Family of thousands of human-made substances.
• Carbon fluorine bond - strongest in nature, no natural degradation.
• Used in products that resist heat, oil, stains, grease and water.

○ Class B fire-fighting foams. ○ Raincoats, shoes, popcorn bags, pizza boxes, Teflon pans.

• Found in 99% of people’s blood.
• Primary concern is drinking water. People drinking contaminated

water tend to have high PFAS blood levels.

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Per- and polyfluoroalkyl substances (PFAS)

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PFAS and health

• High cholesterol.
• Liver damage.
• Decrease vaccine effectiveness.
• Asthma.
• Thyroid disease.
• Decrease fertility.
• Pre-eclampsia.
• Lower birth weight.
• Possible kidney & testicular cancer.

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EPA PFAS drinking water health advisory (non-regulatory) 2016: PFOS + PFOA < 70 ng/L

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EPA’s process to establish drinking water standards

EPA.gov

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PFAS contamination impacting water supplies

Hu, et al. 2016. ES&T Letters: 3(10), pp 344–350.

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State response

Establish collaboration Reduce risk Develop solutions

Agencies - EPA, local health, water systems, potential responsible Resources – staff, funding, hyrology and sample data Communication - potentially affected Decrease water levels - system operation, alternate sources Treatment - design and install Pursue regulatory authority - further reduce pollution and exposure risk Pipeline install GAC Ion exchange

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Whose authority? Health advisory challenges

• Health advisory ≠ Maximum Contminant Level (MCL)

○ Not regulated under Safe Drinking Water Act ○ No clarity on water system actions or communicating risk

• Health advisory ≠ clean-up level

○ Not regulated under CERCLA/Superfund

• Fire fighting foam used as intended ≠ solid waste

○ Not regulated RCRA

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2019 EPA PFAS Action Plan

• Proposed regulatory determination for PFOA and PFOS in 2019.
• Determining if PFOA and PFOS are CERCLA hazardous substances.
• Determining if regulation is appropriate for broader class of PFAS.
• Developing toxicity assessments for PFBS, PFBA, PFHxA, PFHxS,

PFNA, PFDA, and GenX.

• Including a larger group of PFAS in UCMR 5 for systems serving

3,300 and above.

• Developing guidance/toolkits for communications, cleanup, etc.

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PFAS in National Defense Authorization Act

• Doesn’t designate PFAS as CERCLA hazardous substances or require

PFAS drinking water MCL.

• Drinking water monitoring in UCMR 5 (2023-2025).
• PFAS releases will be reported to EPA’s Toxics Release Inventory.
• $100M per year in public water system grants.
• EPA to publish guidance on disposal/destruction of PFAS materials.
• Research health/environmental effects, monitoring, remediation.
• USGS to develop detection standards and sample nationwide.
• DOD to phase out PFAS foams by Oct 2024.

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State actions to address PFAS in absence of federal standards CDPHE PFAS Action Plan

• Break chain of exposure.
• Statewide monitoring to identify impacted drinking water.
• Develop inventory of contaminated sites with EPA.
• Regulatory authority.

12 Journal of Exposure Science & Environmental Epidemiology volume 29, pages131–147 (2019)

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PFAS drinking water sampling project

• Free PFAS testing for drinking water using emergency

supplemental funds approved by Joint Budget Committee.

• All community and non-transient, non-community public water

systems can apply for these funds.

• We’ll share results with systems and publish them on our website.
• If results are above level of concern, we’ll coordinate with water

system to notify public and identify options to reduce exposure.

13 CDC website

PFAS Narrative Policy Workgroup Objectives

• Narrative provisions in Regulations 31 and 41 to limit PFAS

contamination entering surface water and groundwater.

• Implementation in Colorado Discharge Permit System
• Initial monitoring: based on survey results, 28 PFAS species.
• Continued monitoring and source investigation.
• Effluent limits.
• CDPHE will propose policy to WQCC in May 2020.
• For more information: colorado.gov/cdphe/PFCS

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PFAS Narrative Policy Translation Levels

• Division should consider permit effluent limits if exceeded.
• Grouped based on health effects.
• Levels based on relative toxicity.

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Developmental Endocrine Renal

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Fire Fighting Foams Control Act (HB 19-1279)

• Prohibits use of PFAS foam for training or testing.
• Prohibits sale of PFAS foam by August 2021.
• Requires CDPHE to survey fire departments every 3 years on

amount of PFAS foam held, used, and disposed of.

• Results were due October 31 and report due January 1.
• 89 of 331 fire departments, airports, and industries responded.

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Thank you! What are your questions?

David Dani david.dani@state.co.us 303-692-3605

More information available at colorado.gov/cdphe/PFCS

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