PFAS Remediation

Capabilities

Core Competencies

• Testing, Designing, and developing robust PFAS treatment strategies considering all variables and outcomes.

DIFFERENTIATORS

• A proven commercialized, sustainable approach to tackle the global PFAS problem.
• Technology that has been awarded EPA licenses for the mobile treatment of PFAS.
• PFAS treatment technology is “Best in Class” for waste minimization.
• Removal rates being achieved are currently the most efficient in reducing residual levels below existing detection limits.

capabilities – 2022 epa pfas update

On December 5, 2022, EPA issued a new guidance memorandum that outlines how states can monitor for discharges of PFAS and take steps to reduce them. PFAS are synthetic chemicals with wide commercial and industrial applications, including firefighting foams, greaseproof food wrapping, nonstick cookware, water-repellent fabrics, carpets, and textiles. This new guidance aligns wastewater and stormwater NPDES permits and pretreatment program implementation activities with the goals of EPA’s PFAS Strategic Roadmap.  

EPA’s guidance memorandum provides recommendations for both industrial direct dischargers and publicly owned treatment works (“POTW”). These recommendations encourage states to use the most current sampling and analysis methods in their NPDES programs to identify known or suspected sources of PFAS so that they can take actions under their pretreatment and permitting authorities.

three key takeaways

As a result of EPA’s guidance, state wastewater permitting authorities may more aggressively seek to identify and regulate users of PFAS, even if such uses are unintentional. This could include, for example, implementing permit terms that would require dischargers to evaluate potential sources of PFAS and eliminate them.

EPA’s recommendation that state NPDES permitting authorities provide notification to downstream public water suppliers could create liability risks for PFAS dischargers.

In light of EPA’s and states’ continued regulatory scrutiny of PFAS, including EPA’s recent proposed rules on PFAS TRI Reporting and the designation of certain PFAS as a CERCLA Hazardous Substance, manufacturers should consider evaluating potential sources of PFAS in their operations and supply chain to better understand the potential risk and to develop mitigation strategies. 

Test Methods

Drinking Water

• EPA Test Method 537.1 (18 compounds compliance method)
  • An EPA validated method, Method 537.1 was developed to replace Method 537 and is commonly used for drinking water compliance. In addition to analyzing for the 14 compounds covered by Method 537, Method 537.1 also analyzes for four replacement PFAS*, Including 11CI-PF3OUdS, 9CI-PF3ONS, ADONA, and HFPO-DA (also known as Gen X).
• EPA Test Method 533 (25 compounds test method)
  • Method 533 expanded the number of PFAS compounds that can be analyzed for in drinking water samples. Method 533 also utilizes isotope dilution, providing additional quality control for accuracy of reporting, especially at ppt levels. Method 533 does not replace Method 537.1, but together, the tests can be used to analyze for 29 PFAS compounds. Method 533 is also commonly used for drinking water compliance, and both Methods 533 and 537.1 will be required for UCMR 5 compliance.
• Other: Non-targeted PFAS Total Organofluorines

Ground and Surface Waters

PFAS by Isotope Dilution: Used for ground and surface waters, wastewater, Leachate, sludge and biosolids, soil & other solids, BIOTA, AFFF.

Designed for non-potable water, solids, biota, and biosolids, PFAS by Isotope Dilution follows all of the rigorous quality control standards outlined in DOD QSM B-15. Able to quantitate 40 PFAS compounds, this method is widely applicable to both DOD and commercial/industrial applications.

DOD QSM v5.3, v5.4: Covers Drinking Water, Ground and Surface Waters, Leachate, Wastewater, Sludge, Biosolids, Soil and other solids, BIOTA, AFFF (2022 Update has not modified).

The DOD QSM (Quality Systems Manual is not a test method per se. Instead, it is a set of protocols to be used for DOD projects. QSM 5.3 and 5.4 are also applicable to civilian projects upon the client organization’s direction (e.g., in the absence of an applicable final US EPA test method), and CFPR adheres to them unless other SOPs are required for regulatory purposes.

• QSM v5.3 Table B-15 lists the specific requirements for analyzing PFAS in matrices other than drinking water. QSM v5.4 was published in late 2021, adding Table B-24 to refine Draft Method 1633 for DOD projects. Both QSM v5.3 and v5.4 are currently valid, but it’s anticipated that these versions will be superseded by QSM v6.0 when it is finalized. (2022 Update has not modified the original draft).

EPA SW-846 Method 8327: Covers ground and surface water, leachate, wastewater, sludge, and biosolids.

Published as final in June of 2021, Method 8327 is designed for non-potable waters, including surface water, groundwater, and wastewater.

EPA Draft 1633: Covers WASTEWATER, SURFACE WATER, GROUND WATER, SOILS, BIOSOLIDS, TISSUES, LEACHATE, AND SEDIMENT

Published in August of 2021, Draft Method 1633 closely resembles PFAS by Isotope Dilution and can quantitate 40 compounds across a wide range of solid and aqueous matrices. Method 1633 will likely replace all laboratory-specific SOPs as well as state and DOD-specific guidance and methods. Method 1633 will also play a vital role in the EPA’s efforts to study, monitor, and regulate PFAS in nearly all matrices and regulatory programs except drinking water. (2022 Update has not modified the original draft).

• Methods to quantify the total organic fluorine in a liquid sample without extraction to a carbon media. Without the need for extraction, PFAS levels can be deemed a more robust test method as extraction efficiency concerns are not an issue. Adsorbable Organofluorines (AOF).
• Current PFAS test methods can analyze roughly 40 compounds. That’s less than 0.1% of the approximately 4,700 CAS-registered compounds classified as PFAS. CFPR’s testing for total PFAS can provide a more complete picture of PFAS contamination to support remediation, destruction, and control efforts.
• AOF/EP Draft Method 1621: AOF measures adsorbable organic fluorine in a liquid matrix.
  • The U.S. EPA is in the process of validating a test method for AOF as Draft Method 1621. The EPA Office of Water describes Draft Method 1621 as a “Screening Method for the Determination of Adsorbable Organic Fluorine (AOF) in Aqueous Matrices by Combustion Ion Chromatography (CIC).” As drafted, this method can quantify total organic fluorine at the parts-per-billion level in all aqueous matrices.

Solids

EPA Draft SW-846 Method 8328

The EPA is also collaborating with the DOD to develop SW-846 Method 8328, a test method for analyzing PFAS in solid waste. Once finalized, this method is expected to be very similar to Draft Method 1633, with additional SOPs for solid waste and to support RCRA compliance. The method will also be widely used for DOD projects with the addition of QSM controls.

Other Methods

• ISO2501: Determination of perfluorooctanesulfonate (PFOS) and perfluorooctanoate (PFOA) — Method for unfiltered samples using solid phase extraction and liquid chromatography/mass spectrometry
• ASTM D7968: Standard Test Method for Determination of Polyfluorinated Compounds in Soil by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
• ASTM 7979: Standard Test Method for Determination of Per- and Polyfluoroalkyl Substances in Water, Sludge, Influent, Effluent and Wastewater by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
• ASTM F2931: Standard Guide for Analytical Testing of Substances of Very High Concern in Materials and Products