Formatted Title
So Many PFAS Regulations, So Much Confusion: Practical Considerations Balancing Federal and State Oversight
Background/Objectives
PFAS became contaminants of emerging concern in the early 2000s, but there are no enforceable federal standards for remediation and few state standards. Although sampling and analysis expertise has improved, in Washington state practical application of the state remedial guidance in June 2023 is just starting to be enacted. The Washington Department of Ecology has concluded PFAS compounds are hazardous substances under the Model Toxics Control Act (MTCA) and is starting to push investigation at non-federal cleanup sites.
Approach/Activities
An update on national PFAS guidance compared to Washington State standards, and how PFAS regulations are practically impacting facilities in Washington State. There is a lot of confusion on what all the regulatory announcements mean: are the initiatives/road maps/action plans preliminary, proposed, or final? There is even more confusion when trying to understand what PFAS compounds (2 compounds, 29 compounds, 180 compounds?) have been regulated under what programs (Toxics Release Inventory, CERCLA, RCRA, TSCA, National Drinking Water Standards). In addition, practicalities of sampling, laboratory options, timing, and planning on site characterization and remedial actions as well as waste management.
Results/Lessons Learned
While there are known impacts of PFAS across Washington State and significant sampling has been completed, the characterization and remediation are still in early days for groundwater, soil, and sediment remediation. Given that the release of Washington State remediation guidance in 2023 is based on non-enforceable State Action Levels (SALs) cleanup levels in MTCA will be done on a site-by-site basis. A summary of PFAS remediation for Washington sites will be provided. Practical advice on best practices when planning for PFAS impacts on site remedial actions will be provided taking into account the many unknowns (in comparison to more traditional remediation sites for metals or chlorinated solvents), especially in regards to unknowns like area background and the relatively few PFAS compounds regulated to date (compared to thousands of PFAS compounds on the market.)