STATE WATER BOARD: PFAS in California

Staff presents results from the ongoing statewide PFAS investigations

Per and polyfluoroalkyl substances (or PFAS) are a group of manufactured compounds widely used in industrial and consumer products because they are resistant to heat, water, and oil.  PFAS are commonly found in products such as non-stick cookware, furniture, clothing, cosmetics, lubricants, paint, carpets, pizza boxes, popcorn bags, and many others.  They are highly resistant to degradation, and, as a result, PFAS may not be completely removed during standard wastewater treatment processes and may be released into the environment.   The possible occurrence of PFAS in water being used to recharge California’s depleted aquifers – a key component of SGMA – is particularly concerning.

In March 2019,  the State Water Resources Control Board began a program of phased investigations of drinking water supplies and various businesses throughout the state thought to have the highest likelihood of releasing PFAS to the environment, such as airports, landfills, and drinking water wells near those sites.   Although the areas with the most PFAS contamination are concentrated largely in Los Angeles, Orange, and Riverside counties, contaminated wells are found statewide in both rural and urban areas. 

At the April 5 meeting of the State Water Board, staff updated the board members on the results of the ongoing studies and the Board’s efforts to address PFAS.

Wendy Linck, Senior Engineering Geologist with the Division of Water Quality, began the presentation by noting that per- and polyfluoroalkyl substances (or PFAS) are a very large class of chemicals; there are thousands of them being used in commerce and industrial applications.  There are so many different PFAS substances that identifying them is a challenge.   Currently, we can test for approximately 40 to 70 of these chemicals and know their concentration, but the rest of them remain a mystery.

“We can now utilize some of the latest research using non-target analysis, whereby high-resolution mass spectrometry can measure molecular mass to identify them, but without chemical standards, we’ll never be able to quantify their concentration,” she said.

The PFAS chemicals that we can test for currently are based on a combination of chemicals that have been phased out of use because of their high toxicity to humans and the environment, specifically perfluorooctanoic acid (or PFOA), perfluorooctanoic sulphonic acid (PFOS), and some of their replacement chemicals.

PFAS in California’s environment

The primary investigatory objective of the statewide order was to gather information on the occurrence of PFAS in California’s drinking water sources and watersheds.  The data that has been collected is being evaluated to identify impacted drinking water wells and identify areas where additional work is needed.

There are no PFAS chemical formulators in California, which is an industry with a high potential to severely impact drinking water.  However, some California industries use products containing PFAS as part of their industrial activities, and numerous consumer products containing PFAS are disposed of in landfills.

To determine the extent of the impact of these sources, the Board issued investigative orders to airports, landfills, chrome platers, wastewater treatment implants, and oil field terminals and refineries, requiring them to complete sampling efforts.  Most of them are one-time sampling efforts to determine the presence or absence of PFAS.  However, wastewater treatment plants were sampled quarterly over one year.  Public water systems were tested based on previous PFAS detections from the US EPA and in the vicinity of airports, landfills, and military sites across the state.  The Department of Defense is performing its own separate investigation, sampling their on-base drinking water supply wells and other potential sources of PFAS.

Sample results are being evaluated by the districts within the Division of Drinking Water for public water supply and by the regional water boards for the industry-type source areas.

To identify potential PFAS waste streams going into wastewater systems, the Board included a survey as part of the investigative orders sent to wastewater treatment plants.  The survey’s objective was to understand more about the types of industrial sources coming into the plant, specifically sources that could be attributed to the use of PFAS.

Based on the information gathered from the survey responses, about 30% of the wastewater treatment plants receive only residential and commercial flow.  Industries with significant potential PFAS source areas like airports, landfills, and military and fire training centers comprise about 14% of the industrial waste stream out of approximately 57% of the industrial waste stream that could potentially have PFAS.  However, it does appear that this is relatively limited.

Based on the data being reported back from these investigations, board staff is getting a sense of the magnitude of the impact, as well as the data gaps.  The red-colored cells in the chart represent areas where the most significant concentrations are reported, including airports and leachate in landfills.

“These concentrated sources of PFAS are impacting groundwater, but for public water supply, these impacts are so far limited to some areas at some military facilities and some in Southern California,” said Ms. Linck.

Other observations from the data include emissions from chrome plating operations that likely impact stormwater, but the loading into wastewater systems varies.

Ms. Linck noted that the one-year of quarterly sampling of influent wastewater at the wastewater treatment plants generally indicated low concentrations of PFAS.  Effluent concentrations can be higher than influent, but the values are still relatively low.

The highest concentrations being reported at wastewater treatment plants are in groundwater monitoring wells, which is likely from the historical accumulation of these chemicals being discharged.  There are a few occurrences where influent concentrations are elevated during a quarter, but that is not consistent.  Biosolids are very low and do not exceed any screening levels published by any other states.

Ms. Linck acknowledged more focus is needed on evaluating surface water, sediment, and stormwater.

This graph shows the median concentrations of PFAS chemicals reported to date in samples collected from airports, landfills, and wastewater treatment plants.  She noted that the median concentrations in the samples were below 100 nanograms per liter, except for landfill leachate.

“Overall, there are areas where PFAS concentrations are much higher at point source locations, but the occurrence data so far is indicating that statewide, based on the analytes being measured, there are no widespread impacts,” she said.

The data does indicate the presence of PFAS in wastewater.  Instead of looking at specific PFAS analytes, all of the analytes were summed to determine concentration.  Ms. Linck explained that the quarterly effluent results were summed, and then the quarters averaged to a single number; non-detects were assumed to be equal to the detection limit.   Different colors categorize the summed PFAS concentrations; the ranges shown for the green-colored dots are either all non-detectable results at the lowest range or a mix of detectable analytes and non-detects for the next range above.

Plants that receive wastewater from residential sources are shown as triangles.  Those plants that both receive residential and industrial flow are shown as circles.  Ms. Linck noted that the highest concentrations of effluent wastewater are at both types of plants.  Preliminary analysis shows that some plants with low flow volumes also have the highest PFAS summed concentrations.

The occurrence data of PFAS in groundwater is shown on the map.  The pollution burden percentiles were obtained from Cal Enviroscreen.  Overall PFAS summed concentration in groundwater statewide is also less than 1000 nanograms per liter, but there are many occurrences where point sources indicate much higher levels.  The highest levels – by orders of magnitude – occur at the airports from the use of the AFFF (Aqueous Film Forming Foam, a fire suppressant used to extinguish flammable liquid fires such as fuel fires.)  Most of the highest levels reported at wastewater treatment plants are from groundwater monitoring wells positioned near the percolation ponds. 

Pollution burden is an indicator of potential cumulative effects from the multiple types of environmental exposure and the inherent vulnerabilities in communities.

“Initial observations indicate some alignment with those communities with the highest pollution burden shown by the darker shaded areas on this map, but not necessarily in all areas,” said Ms. Linck.  “Industry-related investigations for PFAS are located in highly industrialized areas where actual resident populations are very low.”

PFAS and the drinking water supply

Dan Newton, the Assistant Deputy Director for the Division of Drinking Water, then discussed the occurrence of PFAS in drinking water supply wells.

The map shows the occurrence of PFOA and PFOS in drinking water supply wells.  The yellow dots are wells that exceed the notification level; the red squares are wells that exceed the response level for PFOA and/or PFOS.

“At this time, with the orders we have out, almost a quarter of the wells we’re sampling are within the highest pollution burden percentile,” he said.  “The Division of Drinking Water currently has 20 permits issued for the treatment of PFAS.  And we have about another 30 in the works.”

This chart below shows the percent detections of the landfills, wastewater treatment plants, and airport investigations superimposed with the 18 analytes in drinking water that can be detected using EPA method 537.1.  The source investigations use another method that can detect about 40 analytes.  The red dots show the 18 analytes that can be detected with method 537.1.

“As expected, where we’re finding it in our source sites, it’s showing up in our supply wells,” he said.  “Again, we can only measure 18 of those.”

The rectangles show those analytes that can be detected by method 533; Method 533 picks up another five analytes that 537 doesn’t pick up.  

“Method 533 will better represent what is in our drinking water as to what we’re finding in our source investigations,” said Mr. Newton.  “So the Division has plans this summer to issue new orders for monitoring in supply wells to move to method 533.”

Method 537.1 measures 18 analytes; since there can be as many as 10,000 PFAS analytes, there is a very limited scope in what is being measured in drinking water supply wells or source investigations.

So the PFAS team undertook a study with nine specific wells throughout the state, selected based on their PFAS signature and their location near a source site.  They used five different methods, including two with a broad-spectrum analysis.

The green bar on the right shows the amount of mass found using Method 537.1; it is quite different than the amount found using DoD QSM, represented by the gray bar, so moving to Method 533 will help pick up the missing mass, he said. 

The blue bars show the large mass being missed using traditional methods that were found using total organofluorine methodology or TOF. 

“I believe that is enough of an input to us to check the feasibility of exploring a broad spectrum method to test for PFAS in water,” Mr. Newton said.  “Not only that, it supports a treatment technology MCL approach which is somewhat unique from what we’ve normally done.  Right now, we’re measuring 18 analytes, moving to 30 possibly, but there could be hundreds or thousands of analytes of concern.  So rather than chasing these analytes one by one with notification levels, response levels, and subsequent MCLs, the treatment technology MCL approach would be more of a broad brush approach that would result in the same outcome.  It could also be conducive to using a broad spectrum testing methodology, which has not yet been developed, but could be tailored to a treatment MCL approach, thereby putting us a little bit in front of the curve instead of behind it.”

He noted that other substances can be detected with the TOF approach, but it is by far the best approach for characterizing the total mass of PFAS.  So staff is researching broad-spectrum testing methodologies and collaborating with partners, agencies, other states, and entities. 

Going back to what can currently be measured, this slide shows the sum or total mass of the 18 analytes detected by Method 537.1 in the wells monitored so far.  Most are below the 50 nanograms per liter or parts per trillion, but some systems have 50 to 100 parts per trillion; there was a handful of systems well above 100 parts per trillion.

“We have MCLs and response levels for three of those analytes forthcoming and another five yet to come,” said Mr. Newton.  “So it’s a bit of a ballpark perspective of the scope of the total PFAS mass that we can find right now using methodology 537.1 – it’s a bit of a snapshot.”

The next few years will be busy, he said.  The chart shows some of the actions for the Division of Drinking Water and the Division of Water Quality’s overlaid with the EPA’s current framework.  The issuance of a notification level and response level for PFHXS is forthcoming.  The final public health goal for PFOA and PFAS will be set to initiate the MCL public process, hopefully by 2025.  The EPA might have an MCL for PFOA and PFAS by the end of 2023.

For groundwater, Ms. Linck said that the EPA is moving quite briskly with their PFAS strategic plan, which includes Method 1633, a non-drinking water method for PFAS that will test for 40 analytes in things such as surface water and sediment.  They are also looking forward to a draft release of the actual TOF method from EPA.

They are also moving forward regarding draft NPDES monitoring requirements for wastewater and stormwater discharges and providing guidance to add PFAS monitoring to the NPDES permits, which will help with source reductions.  In addition, wastewater effluent limitation guidelines for electroplating are expected in a couple of years.  Finally, there is also the possible designation of PFOA and PFAS as hazardous substances.

There is much more work to come during the rest of the year and into the next.  Additional assessment is necessary to understand the presence of PFAS in surface water; they will hopefully collect more samples from surface water intakes along several major reaches.  They hope to expand PFAS monitoring by utilizing existing programs such as the stream pollution trends monitoring program (SPOT) and the surface water ambient monitoring program (SWAMP).

They are working with the EPA and others on the nine drinking water sources to try to understand and identify the PFAS chemicals of greatest abundance for those waters.  “We can think that we can understand across the state what our PFAS fingerprint might look like by what these unknowns are of greatest abundance,” said Ms. Linck.  “And do we need to worry about them at all?”

PFAS monitoring requirements for landfills are beginning to be incorporated into permits for landfills by the regional water boards.  Effluent limitation guidelines will also include source reduction requirements that must be incorporated into pretreatment programs.

Division of Drinking Water will be reissuing orders to public water systems to analyze for PFAS using Method 533.  If warranted, new notification and response levels will be issued for those other compounds.

Funding to address PFAS

Next, Matt Pavelchik, Senior Engineering Geologist with the Division of Financial Assistance, provided an overview of the funding allocated under the Budget Act of 2021 for projects that address PFAS.

He noted that Senate Bill 170 appropriated $30 million in the fiscal year 2021-22 from the general fund to the State Water Board to provide technical and financial assistance to drinking water systems to address PFAS.  This funding must be committed to projects by June 30, 2024, and all funds must be disbursed by June 30, 2026.  An additional $50 million in funding is proposed for the fiscal year 2022-23 and an additional $20 million for the fiscal year 2023-24.

The Division of Financial Assistance intends to utilize existing funding processes to administer this PFAS funding.  The most relevant existing programs would be the Drinking Water State Revolving Fund per the intended use plan and the Safe and Affordable Drinking Water Program through their fund expenditure plan.

Staff is proposing setting aside a minimum of $20 million in funding for projects benefiting small disadvantaged communities that would be funded consistent with the Safe and Affordable Drinking Water Program’s Fund Expenditure Plan.  Proposed project types would include testing water systems for PFAS, regional-scale pilot tests and demonstration projects that could include template designs for other small systems to implement, and planning for regional consolidation efforts.

Funding proposed for other types of communities would include implementation funding for shovel-ready projects through the Drinking Water State Revolving Fund program.  Small non-disadvantaged communities and medium disadvantaged communities would be eligible for 100% of the eligible project costs.  For other communities, such as medium non-disadvantaged communities and all larger communities, the funding would be limited to 50% of the total project costs.  To receive this funding, water systems would be required to incorporate data collection and analysis to better inform statewide PFAS data.  Additionally, the State Water Board could potentially approve funding for water systems in addressing PFAS by directed board action.

The deadline for submitting informal public feedback on the PFAS funding plans was April 13.  Staff will consider the input and prepare final proposals for board consideration in June of this year.

Mr. Pavelchik also noted that new federal funding is available through the Drinking Water and Clean Water State Revolving Fund programs for projects addressing contaminants of emerging concern, including PFAS.  Over the next five years, approximately $360 million for drinking water projects and $70 million for wastewater projects is expected.  Priorities and requirements for the federal funding will be addressed in the 2022-23 Drinking Water and Clean Water State Revolving Fund Intended Use Plans, which are planned for board consideration in July of this year.

Staff’s concluding comments …

Annalisa Kihara, Assistant Deputy Director with Division of Water Quality, wrapped the presentation up by saying that addressing PFAS requires collaboration within the various regions, divisions, and offices, as the broad use of PFAS in manufacturing, industrial products, and consumer products has created many potential sources. 

PFAS impacts nearly all the Cal EPA agencies, so the Cal EPA boards, departments, and offices are taking a holistic approach and coordinating as a team to address PFAS across sectors and impact areas.  For example, the Air Resources Board has banned the use of specific PFAS chemicals in certain industries; the Department of Resources, Recycling and Recovery has prohibited intentionally added PFAS in compostable and recyclable food service packaging used at state facilities; and the Department of Toxic Substances through the Safer Consumer Products Program is pushing manufacturers to find safer alternatives to the use of PFAS as a class in consumer products such as carpets and rugs.

A deeper dive into the PFAS data collected at wastewater treatment plants

Jared Voskuhl with the California Association of Sanitation Agencies then gave a short presentation on the data that has been collected from wastewater treatment plants and analyzed with the help of CDM Smith.

Mr. Voskuhl pointed out that CASA’s member agencies are receivers of PFAS; PFAS substances are not used in treatment processes, nor are the treatment processes designed to eliminate PFAS.  He also noted the US EPA has not approved a method for sampling wastewater, so the data collected as part of this order should be deemed provisional.  It’s an important distinction to make when considering data quality and the purposes for which it may or may not be fit, he said.

There were many non-detects in the dataset, which is good news from an environmental perspective; however, it can impact data quality and pose a real risk of biasing the data analysis.  Therefore, in this instance, it is encouraged not to look at the medians of this data but rather the distributions.

PFAS compounds are found across nearly every product, from toys to food packaging, carpet, sunscreen, paper products, floor wax, wrinkle-resistant clothes and linens, and even plastic water bottles.

“So in consideration of the compounds prevalence, it should be self-evident that it is insufficient and inadequate to try to treat our way out of this problem,” said Mr. Bosco.  “A more fundamental approach should be adopted to eliminate these chemicals from ever entering the environment in the first place.  Pollution prevention is the most effective way and least expensive option for society. … with the available options for treatment in California, even when you treat for it, you’re not removing it; you’re simply transferring it into another environmental matrix.”

Dr. Roshan Aflaki with CDM Smith then further discussed the analysis.

The data set was divided into six bins based on the contribution percentage from residential and commercial sources.  There were 272 facilities; 80% of facilities have only 10% contribution from industrial sources, and 70% have less than 5% Industrial contribution.

For each bin, the PFAS analytes were grouped and summed.  Dr. Aflaki said the takeaway from here analysis was that there were a lot of non-detects in the dataset, and the profiles, independent of the waste stream and the contribution from residential and commercial sources, look very similar.

The non-detects presented challenges in analyzing the data.  Dr. Aflaki went through the different approaches, but again, independent of the approach used for the non-detects, the levels are extremely low.

For the next steps, they will take a deeper dive into the outliers and consider baselines for wastewater treatment plants.  Would the outliers benefit from source identification, or is it a data issue?  They will also look for industrial signatures for PFAS sources and the blind spots or major uncertainties in the dataset.  Dr. Aflaki closed by noting these are preliminary results.