Maintaining Community Trust Through the Evaluation Process for PFAS Pollutant Mitigation

BY JOAN OPPENHEIMER | PASADENA, CA

Community trust in clean water utility environmental services is dependent upon continual achievement of routine high-performance operations. This trust can rapidly diminish when service providers face emerging challenges that threaten to disrupt established systems and protocols.

Publicity focused on the ubiquitous occurrence and potential toxicological impacts of environmentally persistent perfluoroalkyl substances (PFAS) are forcing many clean water utilities to view these compounds as critical drivers of change to their existing operations. PFAS concerns are particularly impactful to utilities because their facilities act as watershed collection and redistribution centers of these recalcitrant compounds. This has put clean water utilities in the difficult position of addressing a problem they did not create as they find themselves “holding the bag” in terms of PFAS management.

Charting a prudent future course of action requires clean water agencies to characterize the concentrations of PFAS in their effluents and biosolids, engage in scientific and regulatory dialogue around PFAS treatment and disposal options, and effectively communicate planning activities being implemented to mitigate community risks. NACWA has been actively engaged in PFAS advocacy efforts due to their broad implications to existing utility operations and the potential misalignment of PFAS management options with other sustainability objectives – including reducing energy demands and greenhouse gas emissions.

NACWA published an initial study in 2019 on the cost impact of PFAS to clean water utilities, but the geographic scope was narrow and monetization impacts were restricted to biosolids handling issues within the regulatory guidance in place at the time. But the rapidly evolving PFAS regulatory landscape prompted NACWA’s recent decision to fund a follow-on study of potential cost impacts on clean water utilities, which will be completed by Stantec’s Institute for Water Technology & Policy. Recent regulatory developments include proposed federal Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) designation of perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) as hazardous substances, regionally implemented biosolids land application restrictions, regionally mandated PFAS monitoring and source control activities, and EPA’s lowering of the public health goal for PFOA and PFOS in drinking water by three orders of magnitude.

This new study will provide an update on PFASdriven cost impacts via a survey of NACWA utility members. The survey will solicit broad geographic coverage on the costs attributable to monitoring and source control activities. Additionally, it will update current costs of biosolids treatment and handling activities.

Presentation of the statistically aggregated survey data will provide relevant clean water sector PFAS cost impacts while ensuring response anonymity. The data will be parsed in multiple ways to better understand key cost drivers. Associated meta data will be displayed to clearly define the completeness and representativeness of the reported information.

Cost impacts obtained from clean water utilities without PFAS impacts will also be collected to serve as negative cost controls. Budgetary level cost evaluations will also be performed for a small number of subsequent case studies to capture a more detailed understanding of ongoing response activities as well as treatment and cost uncertainties.

The investigation intends to also capture planning level activities related to emerging PFAS destruction technologies (i.e., pyrolysis, gasification, thermal oxidation, super critical water oxidation, hydrothermal liquefaction, etc.). Value added services include a qualitative triple bottom line impact analysis of alternative PFAS management strategies. The economic data from the survey and the subsequent case studies will be incorporated into the report and a technical brief summarizing promising treatment systems under evaluation for PFAS capture and destruction will also be included.

Many clean water utilities will continue to face PFAS-driven challenges related to implementing cost-effective treatment alternatives. The ability to make these decisions in a manner supportive of public trust – and with ratepayer affordability in mind – is highly dependent on the acquisition of defensible industry data and an understanding of critical knowledge gaps in a transparent and credible fashion. This NACWA study is a crucial step forward in understanding the cost implications of PFAS mitigation solutions and the potential risks and benefits of viable alternatives. Its findings will be even more important as PFAS regulatory guidance is outpacing scientific knowledge and detailed understanding of engineered treatment solutions.