HomeMy WebLinkAbout05.a. Receive update on Per- and Polyfluoroalkyl Substances (PFAS) Page 1 of 9
Item 5.a.
CENTRAL SAN
June 1, 2020
TO: REAL ESTATE, ENVIRONMENTAL AND PLANNING COMMITTEE
FROM: MELODY LABELLA, RESOURCE RECOVERY PROGRAM MANAGER
REVIEWED BY: JEAN-MARC PETIT, DIRECTOR OF ENGINEERING AND TECHNICAL
SERVICES
ROGER S. BAILEY, GENERAL MANAGER
SUBJECT: RECEIVE UPDATE ON PER-AND POLYFLUOROALKYL SUBSTANCES
(PFAS)
Staff will review the attached presentation on PFAS at the June 1, 2020, Real Estate, Environmental &
Planning (REEP) Committee meeting.
ATTACHMENTS:
1. Presentation
June 1, 2020 REEP Committee Meeting Agenda Packet- Page 20 of 30
Page 2 of 9
UPDATE ON
PER- AND POLYFLUOROALKYL
- SUBSTANCES (PFAS)
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Melody LaBella, P.E.
Resource Recovery Program Manager
REEP Committee Meeting
June 1 , 2020
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PRESENTATION OVERVIEW
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What are PFAS?
Sources to the Water Environment
State Board's Phased Investigation Plan
Drinking Water Notification and Response Levels
Legislation Updates — Federal and State
Treatment Technologies
Upstream Regulation Opportunities
Next Steps for Central San
Questions
CFNTPAISAN
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June 1, 2020 REEP Committee Meeting Agenda Packet- Page 21 of 30 1
Page 3 of 9
WHAT ARE PFAS?
PFAS are a broad class of fluorine-rich,
specialty chemicals that have been
manufactured and used in a variety of
industries around the globe, including in the
United States, since the 1940s.
Some possess thermal stability, non-reactivity, and
surfactant properties.
The carbon-fluorine bonds are some of the strongest
known to science, which means PFAS show extremely
high persistence.
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SOURCES OF PFAS TO THE WATER ENVIRONMENT
Military bases and airports
Due to aqueous film-forming
foams used for fire fighting
PFAS production facilities
Air deposition
Landfills
Chrome plating
Fume suppressant
• Treated wastewater effluent
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CFNTPAI SAN
June 1, 2020 REEP Committee Meeting Agenda Packet- Page 22 of 30 2
Page 4 of 9
rHE CHALLENGE OF PFAS
Lack of information
No standard analytical methods
Very limited human studies
Human targets have been translated from animal studies
Found in a vast array of consumer products
CFNTRAISAN
STATE BOARD'S PHASED INVESTIGATION PLAN
Phase I — issued in March 2019
Covered airports and landfills
Phase II — issued in October 2019
Covered chrome platers
Phase I II — will cover wastewater treatment plants
Delayed due to COVID-19
California Association of Sanitation Agencies (CASA) working
with State Board to refine order requirements
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CFNTPAI SAN
June 1, 2020 REEP Committee Meeting Agenda Packet- Page 23 of 30 3
Page 5 of 9
PHASE III SCOPE FOR WASTEWATER
Release of General Order planned for the coming months
Quarterly sampling for 23-39 analytes on influent, effluent, and
solids/biosolids for publicly-owned treatment works (POTW) > 1
million gallons per day (MGD)
Samples analyzed by one of ten labs certified by California's
Environmental Laboratory Accreditation Program, in spite of no
approved method
Costs: $600/sample for wastewater, $700/sample for solids
Potentially $20,000 annually per treatment plant
CALIFORNIA DRINKING WATER
NOTIFICATION AND RESPONSE LEVELS
In August 2019, the Office of Environmental Health Hazard
Assessment (OEHHA) recommended the notification level (NL) for
perfluorooctanoic acid (PFOA) and perfluorooctanoic sulfonate
(PFOS) be set at the lowest reliable detection limit in drinking
water to protect against cancer and non-cancer effects.
The State Water Resources Control Board (State Board) Division
of Drinking Water (DDW) matched OEHHA's recommendations.
NLs of 5.1 parts per trillion (ppt) for PFOA and 6.5 ppt for PFOS
Response level (RL) at 70 ppt (discontinue source or provide treatment)
In February 2020, the DDW lowered the RL from a combined
(PFOA + PFOS) of 70 ppt to 10 ppt for PFOA and 40 ppt for PFOS.
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June 1, 2020 REEP Committee Meeting Agenda Packet- Page 24 of 30 4
Page 6 of 9
LEGISLATION UPDATES — FEDERAL
Federal Aviation Administration (FAA) Reauthorization
Bill of 2018 was signed into law in October 2018
Included a provision requiring the FAA to update its
specification for firefighting foam to eliminate PFAS by 2021
FAA is now testing new PFAS-free foams
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LEGISLATION UPDATES — FEDERAL
National Defense Authorization Act (NDAA)
S. 1790 (Inhofe): passed Senate in June 2019
HR. 2500 (Smith): passed House of Representatives (House) in
July 2019
The House version had two troublesome amendments:
Add all PFAS to the Clean Water Act toxic pollutants list and
require the Environmental Protection Agency to develop effluent
limits and pretreatment standards for PFAS by January 1 , 2022
Designate all PFAS as hazardous substances, which would trigger
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) liability (for effluent and biosolids disposal)
NDAA did not advance ANIL,
June 1, 2020 REEP Committee Meeting Agenda Packet- Page 25 of 30 5
Page 7 of 9
LEGISLATION UPDATES — FEDERAL
Slowed due to COVID-19
HR. 535 — PFAS Action Act of 2019
Passed the House in January 2020
Proposing the similar troublesome requirements for creation
of effluent limitations, pretreatment standards, and the
CERCLA hazardous waste designation
No Senate action
LEGISLATION UPDATES — STATE
Slowed due to COVID-19
SB 1044 — would ban the use of PFAS in firefighting
foam and require disclosure of PFAS in firefighter
turnout gear (uniforms)
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CFNTPAISAN
June 1, 2020 REEP Committee Meeting Agenda Packet- Page 26 of 30 6
Page 8 of 9
TREATMENT TECHNOLOGIES
Revere osmosis (RO) is effective at
removal, but concentrates PFAS in J
the RO membrane reject. . i
Granular activated carbon and ion
exchange are effective, but require
regeneration
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UPSTREAM REGULATION OPPORTUNITIES
• The Safer Consumer Products Program under the ONS MR
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California Department of Toxic Substances Control
(DTSC) can require manufacturers to complete an
alternatives analysis to find safer substitutes for
harmful chemicals in consumer products.
Central San recently sent support letters to DTSC
for proposing the following as Priority Products:
PFAS-containing treatments for converted textiles
PFAS in carpets and rugs
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June 1, 2020 REEP Committee Meeting Agenda Packet- Page 27 of 30
Page 9 of 9
NEXT STEPS FOR CENTRAL SAN
Continue tracking and supporting CASNs efforts to work
with the State Board to shape the Phase III investigation
plan for wastewater treatment plants
Continue supporting opportunities for upstream
regulation of consumer products with PFAS
Continue evaluating participation in and/or support of
various wastewater studies on PFAS
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CFNTPAISAN
QUESTIONS?
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June 1, 2020 REEP Committee Meeting Agenda Packet- Page 28 of 30 8