Presentation_02L_PFASStd_13Mar2024

PFAS Groundwater Quality Standards Rulemaking Update
Groundwater and Waste Management Committee, March 13, 2024
Established as the least of the following: *
1.Systemic/non-cancer threshold concentration
2.Concentration which corresponds to an incremental lifetime cancer
risk of 1x 10-6
3.Taste threshold limit value
4.Odor threshold limit value
5.Maximum contaminant level
6.National secondary drinking water standard
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Developing Groundwater Quality Standards
( * ) 15A NCAC 02L .0202 (d)
Established as the least of the following: *
1.Systemic/non-cancer threshold concentration
2.Concentration which corresponds to an incremental lifetime cancer
risk of 1x 10-6
3.Taste threshold limit value
4.Odor threshold limit value
5.Maximum contaminant level
6.National secondary drinking water standard
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Developing Groundwater Quality Standards
( * ) 15A NCAC 02L .0202 (d)
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Existing Requirements in 15A NCAC 02L .0202
•.0202(c) states in part: “substances which are not naturally occurring and for
which no standard is specified shall not be permitted in concentrations at or
above the practical quantitation limit….”
•.0202(b)(1): “Where the standard for a substance is less than the PQL, the
detection of that substance at or above the PQL constitutes a violation of the
standard.”
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Background – Previously Proposed PFOA/PFOS Standard
•2020 – EMC proposed a total PFOA/PFOS standard of 70 ng/L (ppt)
•Based on EPA’s 2016 Drinking Water Health Advisory
•Public comments requested:
•Lower PFOA/PFOS standard
•November 2021 – EMC did not adopt a PFOA/PFOS standard
•Hearing Officer acknowledged ongoing studies
•DEQ committed to continue evaluating developing science and newly
published data on PFAS compounds
DRAFT PFAS Groundwater Quality Standards
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PFAS Compound
DRAFT
Calculated 02L
Standard (ng/L) *
EPA PQL (ng/L) **
1 PFOS 0.7 4.0
2 PFOA 0.001 4.0
3 HPFO-DA (GenX)20 5.0
4 PFBS 2,000 3.0
5 PFBA 7,000 5.0
6 PFHxA 4,000 3.0
7 PFNA 20 4.0
8 PFHxS 10 3.0
( * ) DRAFT proposed groundwater standards as presented to stakeholders – NOT FINAL and subject to change.
( ** ) PQL from U.S. EPA’s Economic Analysis for Proposed PFAS National Primary Drinking Water
Regulation (draft), or for PFBA and PFHxA, set using the same methodology).
Plan Implementation Timeline
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Department of Environmental Quality - Waste Management
•February 2024: Hold multiple stakeholder meetings to discuss implementation plan and concerns.
•By end of 2024: Expect to complete initial screening and notice to complete initial monitoring for PFAS.
•2025-26: Identify sites with exceedances of groundwater quality standards for the eight PFAS chemicals (either PQL or proposed standards).
•2026-27: Begin steps for assessment and remediation at sites where PFAS exceedances are identified (aside from immediate actions needed).
•Completion of remediation will vary by site and will depend on site-specific factors and type of remediation.
DWM Stakeholder Meetings
•The Division of Waste Management (DWM) held stakeholder meetings on January 22 and February 8 and 22, 2024.
•The following waste management stakeholder groups were invited to participate in one of these meetings:
•NC Solid Waste Association of North America (and local government members)
•NC Chapter of the National Waste and Recycling Association
•NC Association of County Commissioners
•NC League of Municipalities
•NC Manufacturer’s Alliance
•NC Department of Agriculture and Consumer Services
•NC Farm Bureau
•Groundwater Professionals of NC
•NC Association of Launders and Cleaners
•Environmental Consultants
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DWM Stakeholder Meeting Feedback
Below are some topics of concern to stakeholders based on feedback:
•Standard calculation (such as basis on EPA toxicity calculation/approval –
DWM provided links to the November 2023 EMC presentation on toxicity after
the meetings)
•Standard implementation (such as varying PQLs for standards lower than the
PQL, consideration of background/upgradient concentrations for exceedances)
•Determination of responsible parties at existing sites (no site baseline data
available)
•Lab capacity for PFAS analysis
•Impacts on landfills as they reach the end of post-closure care
•Impacts to private drinking water wells and determination of contamination in
comparison to proposed/future drinking water standards
•Consideration of PFAS mixtures
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Next Steps
•DEQ has not changed the proposed amendments or the strategy for the fiscal note following the stakeholder meetings.
•Revising implementation plan to add detail to address stakeholder concerns.
•Plan to hold a stakeholder meeting for environmental organizations.
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Questions?
Jessica Montie
Environmental Program Consultant
Division of Waste Management
NC DEQ
[e-mail]