Presentation_PFAS-02L-GWStandards_Cost-Benefit_Montie-Bolyard

PFAS Groundwater Quality Standards Rule Fiscal Impacts:
Cost-Benefit Analysis Approach
Groundwater and Waste Management Committee, January 10, 2024
Desired Outcome of the Fiscal Note
•For Stakeholders
•Rationale regarding why a rule change is necessary.
•The problem the rule change is addressing and how.
•Affected entities are identified.
•Costs and benefits are addressed.
•For Decision-makers (e.g., EMC)
•Provides necessary tools and information to make decisions.
•Identifies relative magnitude and distribution of costs and benefits and net impacts.
•Provides comparison to baseline and other alternative approaches.
•Illustrates uncertainty levels and degree of confidence in expected outcomes.
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Regulatory Impact Analysis Requirements for
Office of State Budget and Planning Certification
•Adherence to G.S. 150B-21.4: Administrative Procedures Act (Fiscal and
Regulatory Impact Analysis on Rules)
•Assess the impacts on all affected entities
•Demonstrate that sufficient state funds are available to implement the rule.
•Adherence to economic principles in G.S. 150B-19.1 such as:
•Seek to reduce burden on regulated entities
•Consider cumulative effect of rules
•Consider sound, reasonably available information
•Achieve rule objective in cost-effective and timely manner
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Key Starting Point
•Baseline: Existing remediation requirements in 02L Section .0100, and existing groundwater quality standard requirements in 02L Rule .0202, which states:
“…substances that are not naturally occurring and for which no standard is specified in Paragraphs (h) or (i) of this Rule shall not be permitted in concentrations at or above the practical quantitation limit….”
•Proposed Rule Amendment: numeric standards added for 8 PFAS with known toxicological data.
•Calculating and comparing costs for assessment, monitoring, treatment and remediation of PFAS under existing rule vs. the proposed rule.
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Quantitative Cost-Benefit Analysis Approach
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Potential Savings
•Estimate the potential savings of the proposed PFAS regulatory change for some sites where savings could apply.
Existing Expenses
•Estimate the potential expenses associated with PFAS treatment/ remediation under existing rules, if warranted.
Reduced need to Conduct Site Assessment and/or Monitoring
Reduced need to Install Treatment/ Remediation System
Reduced Remediation Timeframe
Expenses for Site Assessment and Monitoring if warranted
CapEx for Treatment/ Remediation System if warranted
Expense for Continued O&M of Treatment System, if warranted
Groundwater Assessment and Monitoring
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•Sites may already be doing groundwater monitoring, assessment, and/or remediation for other constituents.
•In many cases, may just need to add additional costs for PFAS-specific sampling protocols, supplies, staff time, and analysis costs.
•A site may need to install wells or add more wells for assessment (ex: add 1 upgradient and 2 downgradient)
•Costs would be per sampling event and may be lower when combined with sampling for other constituents.
•Frequency of sampling events is based on site type (ex: landfills are 1 to 2 times per year)
•Continued monitoring will be based on outcomes of site assessment and extent of impacts.
Type of Remediation/Remedy Selected
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•Where remediation is warranted, costs would vary based on site-specific factors and the type of remediation selected.
•Solid Waste Landfill Example: Requirements for selection of a remedy is found under 15A NCAC 13B .0545 and .1636 for sanitary landfills subject to those rules.
•Certain types of DWM sites with no off-site impacts also have the option of using risk-based remediation.
Remediation Treatment Cost Components
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Capital Expenditure
(CapEx)
Initial investment in
treatment infrastructure
Operation and
Maintenance (O&M)
Recurring costs to
operate treatment
system (annual basis)
Repair and Replacement
Based on equipment life
and calculated as a %
of CapEx
Remediation Treatment Overview – Technology Review
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Conducted a comprehensive treatment evaluation – focused on shelf-ready technologies
Treatment Type Removal Mechanism Residual Type
Granular Activated Carbon
(GAC)Adsorption to Media Media
Ion Exchange (IX)Adsorption to Media Media
Reverse Osmosis (RO)Filtration (membrane)Concentrate (liquid)
Qualitative Benefit Categories
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•Regulatory Certainty for Environmental and Economic Purposes
•Assists state and local governments and the private sector with quicker decision-making and planning when all parties are clear on the limit that determines an exceedance.
•Assists all parties with decision-making and planning for the type of remediation (including risk-based procedures), and the timeframe needed.
•Clarification on Human Health Impacts
•Groundwater quality standards are established based on human health information, whereas the PQL is based on laboratory capability and consistency.
Sources for Data and Methodology
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•Existing remediation requirements and established procedures

•EPA Economic Analysis for Proposed PFAS National Primary Drinking Water Regulation
•Other states reports (WI, PA, NJ, MI)
•Academic and Research Institution papers
Summary of Net Impacts
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•Results will be reported as net impacts (benefits & costs) and net present value.
•Net Present Value (NPV) represents the value of the expected effect of the rules and is calculated as the sum of the net impact over time, discounted to a present-day dollar value equivalent.
•Sensitivity Analysis: describes uncertainties, key assumptions, research or data limitation and how their variability affects results.
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Questions?
Stephanie C. Bolyard, PhD
Senior Engineer to the Assistant Secretary
Secretary’s Office
NC DEQ
[e-mail]
Jessica Montie
Environmental Program Consultant
Division of Waste Management
NC DEQ
[e-mail]