The U.S. EPA’s per- and polyflouroalkyl substances (PFAS) health advisory level announcement June 15 highlights the criticality of stakeholder engagement and communications, according to industry experts.
The EPA released drinking water health advisories for PFOA, PFOS, GenX and PFBS last week at levels the agency noted it cannot yet detect. Previously, the combined health advisory level was 70 parts per trillion (ppt) for PFOA and PFOS. The draft screening level is still 4 ng/L.
Industry associations released statements highlighting the levels for PFOA (0.004 ppt) and PFOS (0.02 ppt) and the impact that would have on utilities and their communities. Engineering firms shared similar sentiments but also noted the importance of properly communicating this announcement to not only the industry but also to the general public.
What is a Health Advisory Level?
A health advisory level is a non-regulatory and non-enforceable level determined by EPA using the latest available science. It indicates a level at which a contaminant is understood to have health impacts on humans. These levels are set by the U.S. EPA prior to and as part of the process for regulating contaminants, particularly for maximum contaminant levels or maximum contaminant level goals. Health advisories, by their definition, do not consider the feasibility of detection and treatment, nor do they consider the cost of detection and treatment.
In a panel webinar hosted by Water Environment Federation (WEF) Friday, June 17, U.S. EPA Director of the Office of Science & Technology Deborah Nagle said the announced PFAS health advisories only apply to drinking water applications. She also said EPA is not encouraging utilities to test for nor to treat to this health advisory level. That statement echoed the words of U.S. EPA Assistant Administrator for Water Radhika Fox during a press conference June 16.
“Drinking water health advisories are not enforceable standards. They’re really a synthesis of the best available science both on health effects as well as on monitoring and methods,” Fox said. “When we’re advising a drinking water system that might be concerned about PFAS in their supply, we really recommend testing using the available methods, which is — for PFOS, PFOA — at 4 ppt.”
If a utility tests for and sees levels below the 4 ppt threshold, Fox said it is an opportunity to start a conversation with constituents and the public about their water supply.
Impact on Utilities
In an article posted to the CDM Smith website following the announcement, CDM Smith Vice President and Remediation Practice Leader Tamzen Macbeth said the announcement’s impact will be felt far and wide.
"By setting HALs below the detection limits of current analytical methods, EPA is declaring that there is potential health risk of any detection of these chemicals in drinking water; likely affecting hundreds, if not thousands, of drinking water systems nationwide,” Macbeth said. “In addition, the PFOA HAL of 0.004 ppt implies that 2.2 gallons of PFOA are capable of contaminating one quadrillion gallons of water, or roughly the volume of Lake Michigan. This means that even small and non-point sources of PFAS could potentially threaten drinking water supplies.”
Many utilities throughout the country were already working toward PFAS mitigation strategies, particularly in a handful of states where local PFAS limits were established and enforced.
While not enforceable, Holly Churman, water treatment and desalination service line leader for GHD, said the low HALs will give utilities pause as they work to address PFAS in their drinking water system, especially if the figures graduate to enforceable levels. Some drinking water facilities, she said, may even reconsider their treatment options.
“Concentrations greater than these Interim updated health advisories have been detected in rainwater and in areas with no apparent sources of PFAS,” Churman said, “and thus, many facilities that had not previously considered PFAS to be chemicals of concern to their operations may now need to assess and manage these chemicals.”
The HALs are currently below levels of detection. In fact, the PFOA and PFOS health advisory levels announced by EPA are not achievable by current drinking water analytical methods 537.1 and 533.
Frank J. Johns, chief engineer for Stanley Consultants, said with the health advisories being so low utilities will look for multi-pass systems for additional treatment to reach the detection levels.
“Many cities may consider expanding their existing PFAS treatment systems to include additional or multi-pass processes to meet more stringent PFAS criteria or add these additional treatment steps or technologies to any of their PFAS projects in design,” he said.
Communications are Vital
While the levels announced cannot be enforced, utility and engineering experts note the public will not see it the same way. Because the health advisory levels are below the 4 ppt detection limit, this means every utility is likely to test for and find PFAS at levels the EPA has now deemed will impact human health, according to the new HALs.
In the WEF panel discussion June 17, Barns & Thornburg Partner Jeff Longsworth said this creates confusion. How, he asked, can utilities instill confidence in their customers that their water is safe when they report below EPA’s recommended 4 ppt detection level but above the new 0.004 ppt health advisory level? This was also noted by Churman.
“As these very low values are less than most laboratory detection limits, it is not yet immediately clear as to how site owners or operators will even be able to determine whether or not there are issues that require management,” Churman said.
Tamara House-Knight, emerging contaminants technical team leader for GHD, said communication and education are vital as utilities field questions about their water systems considering these HALs.
“What will be important in the short-term, is effective stakeholder engagement and communication of the actual risks, to members of the public or community who may now be alarmed by the Interim updated Health Advisories,” House-Knight said.
Mike McGill, president of WaterPIO a communications consulting company for water utilities, said he is advising his clients to be “active and forceful.”
“Active, in that they take the initiative and go first with information that provides perspective for the press, elected officials, community leaders and the public and respects the concerns these goals may raise as protectors of public health,” McGill said. “Forceful, in that we must talk about the goals and their many flaws.”
One crucial talking point, he said, is highlighting how EPA notes that 80% of the public’s exposure to PFAS is through sources other than drinking water. This includes consumer products, clothes, cookware, carpets and other items. This means members of the public can mitigate exposure through more than just drinking water treatment.
Most of all, utilities need to be open, honest and frank with their communications, regardless of the contaminant of concern or the crisis at hand.
“If they hear from you first, they trust you first. If they hear from you last, they trust you last,” he said. “The best way a utility can instill confidence in its drinking water is to tell the press, the public, elected officials, and community leaders what it knows about PFAS, discuss what its own testing reveals, and detail what the utility is doing, if anything, about the findings. And the information must be front and center across its information streams and adequately cover customers of all ages.”
Treat & Destroy
While the announcement is specific to drinking water systems, the CDM Smith article also notes the importance of destruction of these chemicals for long-term remediation.
The EPA press release indicated that granular activated carbon, anion exchange and high-pressure membranes are important treatment technologies for removing PFAS from drinking water systems.
Once removed, however, disposal and destruction become another question to answer. The U.S. Department of Defense recently halted incineration of PFAS as it awaits more science on effective destruction methods. And while the HALs announced are specific to drinking water, questions have arisen regarding wastewater, biosolids incineration and biosolids land application as it relates to PFAS. EPA indicated the science regarding wastewater is on track to be communicated by the end of 2022.