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Home My WebLink About06.b.PFASPage 1 of 12 Item 6.b. F--1-448�411C-S0 November 16, 2022 TO: REAL ESTATE, ENVIRONMENTAL AND PLANNING COMMITTEE FROM: MELODY LABELLA, RESOURCE RECOVERY PROGRAM MANAGER REVIEWED BY: LORI SCHECTEL, ENVIRONMENTALAND REGULATORY COMPLIANCE DIVISION MANAGER ROGER S. BAILEY, GENERAL MANAGER SUBJECT: RECEIVE A PERIODIC UPDATE ON PER -AND POLYFLUOROALKYL SUBSTANCES (PFAS) Due to the potentially significant impacts that PFAS pose to the water and wastewater industry, the Real Estate, Environmental & Planning Committee requested periodic updates on the subject. Many Central San staff members have been engaged in working on this rapidly -evolving topic. Resource Recovery Program and Environmental and Regulatory Compliance Division staff look forward to providing the Committee with a variety of updates on PFAS at this meeting via the attached presentation. Strategic Plan Tie -In GOAL TWO: Environmental Stewardship Strategy 1 - Achieve compliance in all regulations ATTACHMENTS: 1. Presentation November 16, 2022 REEP Committee Meeting Agenda Packet - Page 21 of 35 Page 2 of 12 November 16, 2022 Update on Per- and Polyfluoroalkyl Substances (PFAS) Real Estate, Environmental & Planning Committee Meeting Melody LaBella, P.E. Rita Cheng, P.E. Resource Recovery Senior Engineer Program Manager Blake Brown Khang Nguyen, P.E. Supervising Chemist Assistant Engineer 1 What are PFAS? PFAS are a broad class of fluorine -rich, specialty chemicals that have been manufactured and use variety of industries around the globe 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"). s 2 November 16, 2022 REEP Committee Meeting Agenda Packet - Page 22 of 35 Page 3 of 12 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. 3 Why the concern? Nearly 5,000 PFAS are used in a variety of consumer, commercial, and industrial applications. As a result, PFAS are ubiquitous. • The ingestion route has been found to be most substantial and PFAS are being found in drinking water supplies. 4 4 O O � Fra fg�tlng p O ®®p Pasuca a5 foa F.S, food ®� o and he .cldas paa,aging O min.ng Arid o,l wall Pa,^,3o l ) s rtaClan75 Car. P0,1u0" /1� Non.sllck tx,k— Pants Floor FhotograpYdc polanas processes A-1— Stan res,s� n1 hydraulic Mist products fluids 5uppre5aenf -.1 pl..� d ttry November 16, 2022 REEP Committee Meeting Agenda Packet - Page 23 of 35 Page 4 of 12 Federal Actions E Bipartisan Infrastructure Law (Nov. 2021), $10B to fund PFAS remediation ($113 for wastewater) EPA PFAS Strategic Roadmap (Oct. 2021) 'Addressing 4/28/22 EPA issued memo PFAS Discharges in EPA- '�, issued NPDES Permits and expectations where EPA is the Pretreatment Control Authority' OWN 4/28/22 EPA issued draft Freshwater Aquatic Life Water Quality Objectives for PFOA and PFOS 4/28/22 EPA published new draft method EPA 1621 to measure ' Adsorbable Organic Fluorine 8/26/22 EPA proposed to designate PFOA & PFOS as CERCLA Hazardous substances 5 State Actions AB 2771 (Ban on PFAS in cosmetics) — signed by the Governor on 8/30/22 AB 1817 (Ban on PFAS in textiles) — signed by the Governor on 9/29/22 AB 2247 (PFAS disclosure bill) — vetoed by the Governor on 9/29/22 SB 170 State budget appropriated $30M to address 71 r PFAS in drinking water i Budget addendum added $50M to FY 2022/23 and $20M FY23/24——�—�—� R November 16, 2022 REEP Committee Meeting Agenda Packet - Page 24 of 35 Page 5 of 12 Miscellaneous PFAS Updates Water Research Foundation Studies Advances in treatment technologies • New ion exchange resins • Foam fractionation EPA proposing to remove 12 PFAS chemicals from their current list of 'inert' ingredients approved for use in pesticide products Public agency lawsuits continue to grow 11 Orange County water agencies' lawsuit against PFAS manufacturers continues More than a dozen states have filed suits 7 November 16, 2022 A , Proposed PFAS CERCLA Designation Real Estate, Environmental & Planning Committee Meeting Ak Rita Cheng, P.E. Senior Engineer 0 November 16, 2022 REEP Committee Meeting Agenda Packet - Page 25 of 35 Page 6 of 12 What is CERCLA? Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (also known as CERCLA or Superfund) Federal statute designed to facilitate cleanups of hazardous substances CERCLA allows EPA to: Designate hazardous substances that may present "substantial danger" to public health and the environment; Designate "Superfund" sites listed on the National Priorities List (NPL), assess site contamination, propose remedial methods, and recover costs from responsible parties Proposed CERCLA Designation August 2022 — EPA proposed to designate PFOA and PFOS as hazardous substances under CERCLA Prompted by EPA's PFAS Strategic Roadmap and federal efforts under the Biden-Harris Administration to combat PFAS pollution September 2022 — EPA published the Notice of THE WHITE HOUSE Proposed Rulemaking in the Federal Register Winter 2022 to Early 2023 — EPA anticipates to issue an Advance Notice of Proposed Rulemaking to seek public comment on designating other PFAS chemicals as CERCLA hazardous substances Tentative August 2023 - final rule adoption 10 ZEPA PFASSU.[e . A..d..p: FPA's CmmmlVneMs to An. 2021-? 4 FACT SHEET. Biden-Harris Administration Launches Plan to Combat PFAS Pollution E1Fhf Ab m'ircAmm�Flepn in=!�'�q Ner £AA vrA«Ad.•a..;.q�vrmAo-, iw.,_e.d r..d November 16, 2022 REEP Committee Meeting Agenda Packet - Page 26 of 35 Page 7 of 12 Potential Impacts Triggers reporting requirements if 1 or more pound of PFOA or PFOS is released in a 24-hour period (Reportable Quantity, RQ) "Releases" could potentially include wastewater discharges and land application, landfilling, and incineration of biosolids POTWs unlikely to exceed the proposed RQ threshold EPA can potentially revise the 1 pound per 24-hour period RQ threshold Longer -Term and Indirect Impacts May lead to EPA including new contaminated sites and re-evaluate existing sites on the NPL to evaluate PFOA/PFOS contamination, which could lead to remedial action and POTWs becoming Potentially Responsible Parties (PRP) and liable for cleanup cost Land application, landfilling, and incineration can all lead to CERCLA liability, but utilities need all three options for biosolids management May trigger certain state CERCLA-equivalent requirements 11 Recent Actions and Next Steps NACWA submitted comments to EPA and requested: A clear CERCLA statutory exclusion for POTWs National pretreatment actions Federal investment in scientific research and development for PFAS control and destruction technologies Coordination between EPA offices to form holistic, science - based PFAS regulations Staff will continue to monitor the development of the proposed CERCLA designation 12 November 16, 2022 REEP Committee Meeting Agenda Packet - Page 27 of 35 Page 8 of 12 13 eAcwA BAY UREA BACWA Region 2 Study: MEMO AiGENCIrES Phase I 'Where are we now?' Sampled November 2020 Results June 2021 Observed PFAS conc. in Effluent>Influent Observed no correlation between industry and PFAS concentration Learned composites or grabs could be used Learned Total Oxidizable Precursors (TOP) were reason for Effluent > Influent Data Gaps No TOP data for Effluent, Scum, Cake For Central San, no incinerator data or Dry Ash Phase II Sampled April 2022 Results expected March 2023 Explore unanswered questions Targeted Residential & Industrial Contributions Effluent Total Oxidizable Precursors (TOP) Analysis Adsorbable Organic Fluorine (AOF) Analysis 14 Jim Wan Sampling at Scrubber/Centrate Line" November 16, 2022 REEP Committee Meeting Agenda Packet - Page 28 of 35 Page 9 of 12 15 Phase II Sampling Sampling in April 2022 Plant sampling at Influent and Effluent 3 Residential Sites: Ruth Drive, Pleasant Hill (-240 single-family homes) Rosincrest Drive, San Ramon (-252 single-family homes) Creekside Drive, Walnut Creek (-9 apartment complexes & Elks Lodge) 3 Industrial Discharger Sites: — San Ramon Regional Medical Center Nu West Textile Group John Muir Medical Center, WC 7771A '' Ernesto Rodriguez & Jeremy Talarico Residential Sampling Internal Plant Sampling _ Q15 sample locations (4 locations not pictured) 4 Days of sampling , - Correspond with Incinerator Emissions Sampling 4 staff members ° L (by Montrose) Composite -grabs collected 3x/day Wet Weather 1,ll Wet Weather Pumps Storage Return to Plant - 0 {� �• Pdma 3/4" Bar Screens Irdluent Aerated Pumps GdtTanks Prim ry Clarifiers Effluent Anaerobic Aeration Seco Pumps Selector Tanks clan6ers dory UV Disinfection 0 0 `* PAS 0 Suisun Z Screenings Grit Bay `r Treatment Plant Process Schematic 16 16 D-9 Media Filters WAS To Disinfection 0 and Off -Site scrubber Water Reuse B..k— h Stud Sto Lime♦ 0 9Bm rage 2 Scum DAFT. 1 °� Add".'. :"� Ash Sludge Centdluges Blending IF. Tank Justine Gleason & Jim Wan Sampling at Foam Suppression Tank November 16, 2022 REEP Committee Meeting Agenda Packet - Page 29 of 35 Page 10 of 12 Sneak Peek of Effluent TOP data e0 Total Oxidizable Precursors,TOP (Influent vs Effluent) 70 eo ■ Influent, TOP ° 50 40 ■ Effluent, TOP _ ` If 30 y� u 210 0 I I I I■ I� ■ ■■ �� "C' Q��p "D' Q�J�p �Qop tap ��p Q�pS Q�QeS � S ��QS Q�aS Analyze Preliminary Findings: Total Oxidizable Precursors (TOP) wet Dry Influent>Effluent Season (Nov2020) (May2022) s TOP PFOA & PFOS are 2x's Target Influent PFAS Conc. (ng/L) 22 37 r concentration Effluent PFAS Conc. (ng/L) 44 57 Reductions: —63% reduction (with non -detects as zero) Influent TOP Conc. (ng/L) 285 255 Justine G —37% reduction (with non -detects as % MDQ Effluent TOP Conc. (ng/L) Not analyzed 95 Sampling 17 Furnace PFAS Emissions Internal Testing Real Estate, Environmental & Planning Committee Meeting Khang Nguyen, P.E. Assistant Engineer 18 71W 73�_ November 16, 2022 REEP Committee Meeting Agenda Packet - Page 30 of 35 Page 11 of 12 19 Testing Background Informational purposes only, not currently anticipating PFAS emission limits or monitoring requirements May 3-5, 2022 Furnace No. 2; three runs per fuel (natural gas and landfill gas) Montrose Air Quality Services, LLC collected samples EPA Other Test Method (OTM) 45 To promote development of PFAS measurement methodologies Emissions Testing Results MHF No. 2 PFAS Emissions 0.0028 0.0026 0.0024 MOM0.0020 0.0018 0.0016 40.0014 0.0012 0.0010 0.0008 0.0006 0.00 0.0.002 II ' I 0.0000 d . . _ 1 _ 1 ■ ■ . ■ - G � Q4 P Q QFpP QF�P � akOP Q�p'� QkQy'. QkOS 'L4.�S O`'pq pQ,�,P Q�Q CFI Cake ��'�QP ��+5 Cake @ yQ [� A,1 Rork Detected in BACWA Phase I PFAS Study aEmfs-11s,NG TOP Emi.ms,NG ■Emfsi—,LFG TOPEmi-ons,LPG 20 40 analytes targeted by Enthalp Analytical; 14 analytes detected by LC/MS/MS Samples were oxidized to analyze terminal target PFAS compounds (TOP — total oxidizable precursor, potential for formation) Detected PFAS analytes in BACWA Phase 1 PFAS study and this furnace testing PFOA and PFOS were not top contributors in detected furnace emissions (proposed designation as CERCLA hazardous substances) November 16, 2022 REEP Committee Meeting Agenda Packet - Page 31 of 35 Page 12 of 12 21 22 November 16, 2022 REEP Committee Meeting Agenda Packet - Page 32 of 35