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HomeMy WebLinkAbout04.b. Receive update on per-polyfluoroalkyl substances (PFAS)Page 1 of 13 Item 4.b. F__1_448�411C_S0 November 15, 2021 TO: REAL ESTATE, ENVIRONMENTAL AND PLANNING COMMITTEE FROM: MELODY LABELLA, RESOURCE RECOVERY PROGRAM MANAGER BLAKE BROWN, SUPERVISING CHEMIST REVIEWED BY: LORI SCHECTEL, ENVIRONMENTALAND REGULATORY COMPLIANCE DIVISION MANAGER JEAN-MARC PETIT, DIRECTOR OF ENGINEERINGAND TECHNICAL SERVICES ROGER S. BAILEY, GENERAL MANAGER SUBJECT: RECEIVE UPDATE ON PER -AND POLYFLUOROALKYL SUBSTANCES (PFAS) PFAS are a class of highly -stable, man-made chemicals that have been in use since the 1940s. PFAS are so widely used in consumer products, they are considered ubiquitous. Many PFAS persist in the environment and the human body and there is evidence that PFAS exposure can lead to adverse human health impacts. In 2019, due to a high level of interest in PFAS in the media and, subsequently, the Federal legislative session, which resulted in the introduction of dozens of PFAS-related bills, Central San's staff started to closely monitor PFAS developments, formed an internal PFAS Task Force, and began providing regular PFAS updates to the Real Estate, Environmental and Planning Committee. Staff has prepared the attached presentation to provide background and a periodic update on PFAS and looks forward to reviewing it at this meeting. Strategic Plan re -In GOAL TWO: Environmental Stewardship Strategy 2 — Anticipate and prepare for potential regulatory changes, Strategy 3 — Support regional development of local water supply ATTACHMENTS: 1. Presentation November 15, 2021 Special REEP Committee Meeting Agenda Packet - Page 9 of 23 Item 4.b. (updated presentation) UPDATE ON PER- AND POLYFLUOROALKYL SUBSTANCES (PFAS) Melody LaBella, P.E. Resource Recovery Program Manager Blake Brown, Supervising Chemist Real Estate, Environmental & Planning Committee Meeting November 15, 2021 WHAT ARE PFAS? PFAS are a broad class of fluorine -rich, a specialty chemicals that have been manufactured and used in a variety of industries around the globe, including in the United States (US), 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 ("forever chemicals"). WHY THE CONCERN? PFAS have been linked to increased cancer risk, liver damage, thyroid disease, elevated cholesterol levels, decreased fertility, and reduced response to vaccines. Well -studied perfluorooctanesulfononic acid (PFOS) and perfluorooctanoic acid (PFOA) have been shown to be highly toxic. Other PFAS have received little to no testing, but their structural similarities suggest they are likely to trigger similar concerns for human and ecological health. 31 WHY THE CONCER Nearly 5,000 PFAS are used in a variety of consumer, commercial, and 00 .owrH it 00 a Mk, V industrial applications. Ile As a result, PFAS are ubiquitous. �r••— The ingestion route has been found to _ be most substantial and PFAS are being found in drinking water supplies. AREAS. Safety/Central San Usage IldMeasurement Future Regulations Resource Recovery MEM - CENTRAL SAN STATE BOARD'S PHASED PFAS INVESTIGATION PLAN • Phase I — issued in March 2019 Covered airports and landfills Phase II — issued in October 2019 Covered chrome plating facilities Phase III — issued in July 2020 Covered wastewater treatment plants Phase IV — issued in March 2021 Covered refineries and bulk fuel terminals .DULY 2020 STATEWIDE ORDER VS. REGION 2 STUDY Participants 249 publicly owned treatment works (POTWs) (>1 Million of Gallons Per Day (MGD) Average Dry Weather Design flow) Sampling Frequency Quarterly sampling for one year Sample Locations Influent, Effluent, Biosolids, and Reverse Osmosis Concentrate Analyte List 31 PFAS Sample Types Composites Lab Requirements POTWs can use any lab that is California Environmental Laboratory Accreditation Program (ELAP) accredited for PFAS analysis 15 (of 37) POTWs from Region 2 Two Phases Influent, Effluent, Biosolids, and Reverse Osmosis Concentrate 40 PFAS +Total Oxidizable Precursors (TOP) in Biosolids/Influent Grabs All participating Region 2 POTWs use the same lab (SGS AXYS) TOP ANALYSIS Oxidation of perfluoroalkyl acids (PFAA) precursors v Conversion of building block PFAAs �•� {�y,, :y� (precursors) to 17 terminal target PFAS There are 5000+ PFAS, that can be analyzed Conversion of PFAA but current capabilities precursors to measurable are limited to analysis of perfluoroalkyl carboxylic - -40 individual PFAS acids (PFCAs), like PFOA �. M 120 100 C C 00 4 U 40 0 20 t� REGION 2 PHASE 1 RESULTS Comperi5on of WWTP Influ6nt and ,Effluent ❑PFBA ■PFPeA ■PFHxA ■PFHpA ❑PFCA ❑PFNA ❑PFDA ❑PFBS ■PFPes ■PFHxS ©PFOS ■62 FTS ■5.3 FTCA ❑PFOSA ■N-lVleF0SAAoN-E[F08AA Ei WWFOSE Source: SFEI, Miguel Mendez and Diana Lin, August 10, 2021, BACWA Permits Committee CENTRAL SAWS INFLUENT/EFFLUENT DATA 90 80 J 70 ago 60 0 50 c 40 8 30 u 20 10 I _ILA IN I_ O�YOh� Q�p`� Q��P Q�QP Q�QoP Q��QP Q��+S Q���P Q��P Q�O�P Q�pS Q�OP Q�QeS Q�Qe e. 'e- Analyte ■ Influent (Target) ■ Influent (TOP) ■ Effluent (Target) 10 REGION 2 PHASE 1 BIOSOLIDS (TARGET) No Digestion Mesophillic Anaerobic w/ Mesophilic Anaerobic Thermophilic 350 I storage in lagoon or bed I I Anaerobic 300 I I I r. 250 I Median: 178 ng/g o zoo I I 150 I I I I I d2 100 I ! 50 0 CCCSD BIO PA BIO VFWD ®O DSRSD B10 NSD BIO SJSC BIO FSSD BIO GSM BIO SEP BIO USD BIO OSP BIO EBMUD BIO (Wet Ash) oPFBA ■PFPeA ■PFHxA ■PFHpA oPFOA oPFNA oPFDA ■PFUnA ■PFDa4 ■PFrFDA ❑PFTeDA DPFBS ■PFPeS EMUS aPFHpS ■PFOS ■PENS ■PFDS ■6-2FTS ■8:2 FTS ■53 FTCA ■73 FTGA oPFOSA ■N-MCFOSA oN-EtFOSA oN-McFOSAAON-EtFOSAA oN-Me-FOSS DN-fit-FOSS Source: San Francisco Estuary Institute SFEI / Bay Area Clean Water Agencies (BACWA), Miguel Mendez and Lorien Fono, September 1, 2021, Clean Water Summit Partners PFAS Workshop #4 Segment 2 30 25 20 c ° 15 12 10 c 0 U 5 0 CENTRAL SAN'S SOLIDS DATA QQ�P QQOP QQOoP QQ�QP QQ�+S QQZ QQ�P QQpc�P QQO" QQ�P An a lyte ■ Wet Ash (Target) ■ Wet Ash (TOP) ■ Cake (Target) ■ Scum (Target) QQQeS QQQeP Q�e�P �sOP Q Q 1I go SUMMARY OF RESULTS • PFAS concentrations (conc.): Effluent > Influent (Both studies) Median Influent PFAS conc. -66 ng/L 27ng/L 22 ng/L Median Effluent PFAS conc. -115 ng/L 58 ng/L 44 ng/L Median Influent TOP conc. N/A 231 ng/L 285 ng/L Median Biosolids PFAS conc. N/A 178ng/g ND (Ash), 68ng/g (Cake) Median Biosolids TOP conc. N/A 594ng/g 1.7ng/g (Ash) • Short Chain PFAS more prevalent than long chain • Consistent with phase out of long chain and substitution of short chain PFAS • Long chain PFAS still found even with PFOS production phased out in the US • Possibly due to imported goods • Statewide order, Residential/Commercial (non -industrial) discharges are significant source • 100% Residential/Commercial Influent Background level: ND-385 ng/L • 100% Residential/Commercial Effluent Background level: 21-632 ng/L • POTWs are unable to control Residential sources • Pretreatment programs target industrial sources only ' 13 CENTRAL SAN B A C W A REGION 2 STUDY, PHASE 2 __Vr [CLEAN WATER i� A G E N c I E s • Purpose: • Determination of PFAS `Residential Baseline' • Upstream sewer shed sampling to understand different service population contributions • Further investigation of PFAS precursor's role • Analyze TOP in effluent to complete the mass balance within POTW • Analyze total organic fluorine (TOF) for fluorine terminal product • Examine residential flows compared to commercial and industrial flows • Car washes, Laundries/carpet cleaners, Manufacturing, Hospitals, Prisons, Fire stations, and Food waste/organics • Participants: • Central San, East Bay Municipal Utility District (EBMUD), Dublin San Ramon Services District (DSRSD), San Jose, San Francisco Public Utilities Commission (SFPUC), and San Mateo • Project Timeline: • August —Phase 1 data interpretation SFE1 SCIENCE • September — Develop Phase 2 study objectives, Finalize Sampling Plan •,g•,, CENTER :: CENTER • Early 2022 — Begin Phase 2 Sampling m NPDES PERMIT: Regulatory Guidance: November 2020 — US Environmental Protection Agency (EPA) published: "Interim Strategy for Per- and polyfluoroalkyl substances in Federally Issued National Pollutant Discharge Elimination System (NPDES) Permits" October 2021— EPA announced 'Strategic Roadmap: EPA's Commitments to Action 2021-2024' Analytical Method: September 2021 - Draft Method 1633 for the analysis of 40 PFAS available on EPA's Clean Water Act (CWA) Analytical Methods website (Errata Sheet published October 15, 2021) Single -laboratory validated (Pending multi -laboratory validation, expected completion in Fall 2022) "While EPA has not promulgated the method in Part 136 and it is not nationally required for use in the NPDES program at this time, permit authorities may require the draft method in individual NPDES permits and EPA is encouraging its use for that purpose." THE CHALLENGE OF PFAS IN WASTEWATER TREATMENT • There is negligible removal of PFAS through conventional wastewater treatment. Current treatment technologies achieve separation, not destruction. PFAS thermal destruction range is 600 to 3,600°F. Resource Recovery efforts will be affected. Recycled water Solids handling •ate M. LEGISLATIVE EFFORTS IN 2021 Federal PFAS Action Act of 2021 (HR 2467) passed the US House of Representatives Establishes requirements to limit use of PFAS (hazardous waste designation) Includes $200 Million in grants to water systems for treatment of water contaminated with PFAS California Assembly Bill (AB) 1200 (Ting): bans PFAS in food packaging, requires PFAS disclosure for cookware in California AB 652 (Friedman): bans PFAS in baby products in California SB 170 (Skinner): includes $30 Million in the 2021/2022 state budget for PFAS remediation in drinking water Other States Maine bill requires non -essential uses of PFAS to be phased out by 2030 Vermont bill restricts use, manufacture, and sale of products containing PFAS New Hampshire bill sets nation's toughest drinking water standards for PFAS UPSTREAM PFAS REGULATION 1010-, 4W SAFER The Safer Consumer Products Program under the CONSUMER California Department of Toxic Substances Control PROpUCTS (DTSC) can require manufacturers to complete an alternatives analysis to find safer substitutes for harmful chemicals in consumer products. • DTSC has established the following as Priority Products: • PFAS in carpets and rugs • PFAS-containing treatments for converted textiles • PFAS in food packaging go WATER RESEARCH FOUNDATION PFAS STUDIES PROJECT ADVISORY COMMITTEE PARTICIPATION Investigation of Alternative Management Strategies to Prevent PFAS from Entering Drinking Water Supplies and Wastewater (Project 5082) Studying the Fate of PFAS through Sewage Sludge Incinerators (Project 5111) MISCELLANEOUS Full-scale PFAS drinking water treatment in Orange County Yorba Linda Water Agency Largest in the nation (19 million gallons per day) Eleven Orange County water agencies' lawsuit against PFAS manufacturers 10 QUESTIONS? EVOLUTION OF STATE AND FEDERAL PFAS ACTIONS • California Environmental Protection Agency (CaIEPA) and US EPA coordinated to sample 2,807 public water supply wells in 2012- California for 6 PFAS (US EPA Third Unregulated Contaminant Monitoring Rule (UCMR)). • May 2016 - US EPA set Lifetime Health Advisory (LHA) limit for PFOA and PFOS of 70 parts per trillion (ppt). • November 2017 - PFOA and PFOS added to the California Proposition 65 list. 2016-20 • June 2018 - SWRCB established interim notification levels for PFOA/PFOS. February - US EPA released PFAS Action Plan. Ap April -SWRCB strategy for Statewide PFAS source investigation. Fe July - AB 756 (Garcia): PFAS monitoring for California water systems (enacted). 2019 August - SWRCB lowered notification levels to 5.1 ppt for PFOA and 6.5 ppt for PFOS. December - Department of Defense (DoD) prohibited the use of fluorinated Aqueous film forming foams (AFFF) and recommended screening levels for PFOA and PFOS in groundwater. • January -AB 756: Established drinking water notification levels. • February - SWRCB lowered the response level to 10 ppt for PFOA and 40 ppt for PFOS in drinking water. • July - State Board issued WQ 2020-0015-DWQ Investigative Order to 249 POTWs for the sampling of 31 PFAS compounds (part of April 2019 strategy). • September - SWRCB expanded public water system testing based on 2019 data. • September- SB 1044 (Allen): Bans PFAS in firefighting foam by January 2022 in California (enacted). • September -AB 2762 (Muratsuchi): Bans toxins in cosmetics in California (enacted). • November - US EPA announced interim strateav to address PFAS throuah NPDES hermits. 11 EVOLUTION OF STATE AND FEDERAL PFAS ACTIONS March - US EPA published UCMR 5 compound list. Public Water System data collection is 2023-2025. List includes 29 PFAS compounds. April - US EPA Council on PFAS (exposure point concentration (EPC)) established. 2021 July - PFAS Action Act of 2021 (HR 2467) passed the US House of Representatives. Establishes requirements to limit use of PFAS and includes $200 Million in grants to water systems for treatment of water contaminated with PFAS. Federal September - US EPA released plan to propose PFAS wastewater discharge limits from PFAS manufacturers and chromium electroplating facilities. 2021 State February - Division of Drinking Water (DDW) issued General Order DW-2021-0001-DDW for public water systems to sample and report PFAS within and adjacent to DoD facilities in California that have been identified as having used AFFFs. March - DDW issued Drinking Water (DW) notification level and response level of 0.5 parts per billion (ppb) and 5 ppb perfluorobutane sulfonic acid (PFBS). March - SWRCB issued Investigative Orders to Refineries and Bulk Fuel Terminals (161) for one-time sampling effort. March - Office of Environmental Health Hazard Assessment (OEHHA) recommended pernuorodecanoic acid (PFDA), perfluorohexane sulfonate (PFHxS), perfluorononanoic acid (PFNA), and perfluoroundecanoic acid (PFUnDA) and their salts and PFOS transformation/degradation products to California Proposition 65 List. September - AB 1200 (Ting): Bans PFAS in food packaging, PFAS disclosure requirement for cookware in California (signed October 5, 2021). September - AB 652 (Friedman): Bans PFAS in baby products in California (signed October 5, 2021). 2021-2022 State Budget includes $30 Million for PFAS remediation in drinking water (signed September 23, 2021). �OEHHAp ° w�T� �t3� A NPDES PERMIT EXAMPLES Massachusetts/EPA Region 1: Summer 2020 - Draft NPDES permits containing PFAS monitoring • No Numerical Limits • Quarterly monitoring of Influent, Effluent, and Sludge • Testing to begin within 6 months of EPA's multi -lab validated method for wastewater made available to public on EPA's Clean Water Act Methods program website. • Michigan: NPDES Permitting Strategy Parameter Jnits AeasurernentFrequency ample Type Perflucrahexanesulfanicacid (PFHxS) g/L uarterly' 4-hourNrposite Perfluaraheptanoic acid (PFHpA( g/L Juarterly 4-hour Composite Perfluoranonanoic acid (PFNA) g/L Juarterly 4-hour Composite Perflucraoctanesulfonicacid (PF05i g/L Juarterly 4•hourComposite Perfluaraoctanoicacid (PFOA) gfL uarterly 4•hourComposite 14-hour Perfluoradecanoicacid {PFDAj g/L Puarterly CDrrposite Source: MA0040321, July 14, 2020 (Non-POTW discharge permit) • Permits after 10/1/21 will specify effluent limits & include schedules to meet WQS after IPP PFAS reduction actions • For WWTPs >1MGD (even those where no sources have been found) NPDES Permits will include: • PFOS and PFOA monitoring at least 4x's over a 5 year permit cycle • Upon written notification, WWTP may be subject to increase monitoring frequency and/or undergo steps in IPP PFAS Initiative if at any time effluent exceeds the WQS for PFOS or PFOA�1 24 12 2016 REGIONAL MONITORING PROGRAM STUDY BY SAN FRANCISCO ESTUARY INSTITUTE 50 40 J` O� C c 30 0 m m L m 20 V C v 10 0 <P �0 oe oe }QP 40 Q� Q ■ Palo Alto I] SJ/ Santa Clara M EBMUD qlQ Q4� Q� q Qe ❑ EBDA ■ Central Contra Costa I➢ San Mateo sl 13