Complying With The EPA's First Limits On Toxic 'Forever Chemicals' For Public Drinking Water
By Cody P. Bann
Monitoring and reporting software helps utilities meet compliance requirements.
In March 2023, the U.S. EPA released their proposed National Primary Drinking Water Regulation Standards (NPDWR) for per- and polyfluoroalkyl substances (PFAS) and is on track to finalize the regulations by the end of the year or early 2024.* The proposed NPDWR includes requirements for regulatory limits, monitoring, and public notification and treatment. While the ruling has a three-year implementation schedule, since the time for public input has closed and the regulations may be starting soon, this is the perfect time to break down the new ruling. It’s important to also examine the costs and funding sources, ramifications if municipalities exceed the thresholds, how this is playing out amongst industry groups and communities, and monitoring and reporting requirements.
National Primary Drinking Water Regulation Overview
The Safe Drinking Water Act empowers the EPA to set limits on contaminants in public water systems — utilities that serve at least 15 connections or 25 people or more. Those include 148,000-plus public water systems in the U.S. that provide drinking water to 90% of residents. This would be the first time EPA has regulated a new chemical in drinking water since the 1990s.
Last spring, the EPA announced its proposal to develop NPDWR for six PFAS. These include PFOA, PFOS, PFNA, PFBS, HFPO-DA (GenX chemicals), and PFHxS. Under this proposal, the EPA would establish maximum contaminant levels (MCLs) for PFOA and PFOS, as well as a combined Hazard Index for PFNA, PFBS, GenX, and PFHxS. The Hazard Index is a tool used to evaluate health risks of simultaneous exposure to mixtures of related chemicals.1 If this ruling is passed, states will be required to have a standard that is no less strict than the NPDWR.
The EPA anticipates that if this new regulation is fully implemented the rule will prevent tens of thousands of serious PFAS-attributable illnesses or deaths. If finalized, the rule would establish the first national standard for PFAS in public water supplies, bringing uniformity to a jumble of state regulations. States where PFAS limits are less stringent than the proposed standards would have to revise them to match or surpass the federal standard. States without any limits must enact their first PFAS drinking water rules.2
Public water suppliers must begin testing for the chemicals. The draft rule proposes MCLs of 4 ppt for PFOA and PFOS — the lowest reliable threshold of detection. Those who find more would be required to notify the public and upgrade treatment technologies or take other action.
What’s The Cost?
Nationwide, the rule could cost anywhere from $772 million to $1.2 billion to implement each year, depending upon interest rates, according to EPA estimates. But it would also deliver $908 million to $1.2 billion in health and economic benefits — including avoided treatment for ailments linked to PFAS. The agency acknowledged a range of uncertainty in estimating costs and benefits.
However, industry groups representing water utilities have expressed concerns that the proposed standards would exceed the additional funding provided by the agency. The American Water Works Association (AWWA) said the rule as proposed would require more than 5,000 water systems to develop new water sources or install advanced treatment technologies. Another 2,500 water systems in states with established standards would need to adjust their existing PFAS treatment systems.
A study released by AWWA last year found that the estimated national cost for water systems to install treatment systems to remove PFOA and PFOS to levels required by the EPA proposal would exceed $3.8 billion annually.
“The vast majority of these treatment costs will be borne by communities and ratepayers, who are also facing increased costs to address other needs, such as replacing lead service lines, upgrading cybersecurity, replacing aging infrastructure and assuring sustainable water supplies,” the AWWA said.3
The EPA has responded to this pushback regarding costs that, thanks to the Bipartisan Infrastructure Law (BIL), water utilities have significant funding options for PFAS treatment, including $4 billion through the Drinking Water State Revolving Fund (DWSRF), $5 billion through EPA’s Emerging Contaminants in Small or Disadvantaged Communities Grant Program, and an additional $12 billion in BIL DWSRF funds for safer drinking water.
Exceeding Thresholds And Real-Time Information
Monitoring is a core component of a NPDWR and assures that water systems are providing necessary public health protections. To that end, the EPA is requiring PWSs to monitor for PFOA, PFOS, PFHxS, HFPO-DA and its ammonium salt, PFNA, and PFBS in drinking water that build upon EPA's Standardized Monitoring Framework for Synthetic Organic Compounds where the monitoring frequency for any PWS depends on previous monitoring results. This proposal includes flexibilities related to monitoring, including flexibilities for systems to use certain, previously collected data to satisfy initial monitoring requirements in this proposal as well as reduced monitoring requirements in certain circumstances.4
Since the monitoring frequency for any PWS depends on previous monitoring results, analyzing historical data allows operations management to identify patterns, trends, and anomalies that may otherwise go unnoticed.
Given the extremely low concentrations deemed acceptable, there are no real-time analytical methods for PFAS. Currently, approved EPA methods of measurements involve the use of solid-phase extraction (SPE) to concentrate the sample followed by LC-MS/MS analysis. This method provides information regarding compound occurrence and concentrations based on multiple lines of evidence,5 and samples are shipped off to a laboratory for analysis. However, there are real-time values that measure the efficiency of the processes that actively remove PFAS. For those plants operating in environments at risk for exceeding the limits, monitoring of such processes becomes more important. New investments in assets like GAC (granular activated carbon) filters, ion exchange, and reverse osmosis will require ongoing maintenance and monitoring, which is where real-time monitoring and remote notification can be helpful.
Again, while there currently isn’t a way to utilize real-time monitoring to check if utilities are exceeding threshold levels, if they know the reverse osmosis system isn’t operating efficiently, for example, and that system is what reduces PFAS to acceptable levels, then this equipment needs to be checked and more closely monitored.
Reporting
Reports provide a visualization of this historized process information and correlate related process variables, compute metrics on that data, and visually graph such data for easier pattern and anomaly detection. These reports are created through third-party software that seamlessly integrates with PLCs, SCADA, and historian systems. Advanced reporting solutions can even pull information from remote alarm notification software, allowing further analysis and optimization of condition response times.
Reporting software enables organizations to turn raw process data into actionable information, thereby increasing efficiency and reducing costs. Furthermore, automated reporting solutions streamline regulatory compliance by collecting data from various sources like SCADA, LIMS, and manual entry. As the data is collected it is summarized as key metrics — flow totals or turbidity threshold analysis. These advanced reporting solutions offer templates for compliance, making it easy to populate and publish in the format required by regulatory authorities like the EPA.
Big Impact
Given that PFAS is one of the world’s most intractable pollutants, the EPA is moving forward with this new regulation to prevent future health risks. While complying with the regulation will be challenging, utilizing technology like monitoring and reporting software will help utilities meet the requirements and make a difference in their communities’ drinking water for generations.
*As of the article deadline, the regulations were not finalized.
References:
- https://dep.nj.gov/pfas/2023-epa-pfas-rule-proposal/ (accessed December 5, 2023).
- https://pbswisconsin.org/news-item/what-epas-nationwide-pfas-rule-means-for-wisconsin-drinking-water/#:~:text=Though%20long%20sought%20by%20environmental,drill%20for%20cleaner
%20water%20sources (accessed December 5, 2023). - https://rollcall.com/2023/03/22/utilities-see-new-costs-in-proposed-pfas-water-rule/ (accessed December 5, 2023).
- https://www.federalregister.gov/documents/2023/03/29/2023-05471/pfas-national-primary-drinking-water-regulation-rulemaking (accessed December 6, 2023).
- https://www.sciencedirect.com/science/article/abs/pii/S2214158823000041#:~:text=PFAS
%20analysis%20is%20performed%20using,in%20the%20low%20ppt%20range. (accessed December 12, 2023).
Cody P. Bann is director of engineering at Austin, TX-based SmartSights and may be reached at cody.bann@smartsights.com. SmartSights, previously known as WIN-911 and SyTech, is a global leader in data-drive analytics, reports, and notifications, serving the industrial sector. By providing comprehensive visibility into critical infrastructure management, SmartSights enables swift problem resolution, waste reduction, and cost efficiencies elevating operation performance.