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Takeaways from the EPA's PFAS Action Plan Announcement

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FaucetCharles Neslund, Scientific Officer, Eurofins Lancaster Laboratories Environmental

On February 14, 2019 the US EPA publicly announced the finalization of the PFAS Action Plan that we have been anticipating since the National Leadership Summit in May 2018. Acting Administrator Andrew Wheeler presented the plan from the Philadelphia offices of EPA Region 3. This location is significant because the second of the community engagement meetings from last summer was held in nearby Horsham, Pennsylvania.

Wheeler laid out five steps in the action plan:

  1. He debunked false information that indicated EPA may not proceed with establishing Maximum Contaminant Levels (MCLs).  Instead he claims that EPA will “propose a regulatory determination” for establishing MCLs for PFOA and PFOS, which is the next step in the MCL process.

  2. EPA is continuing its efforts to get PFOA and PFOS listed as hazardous substances under Superfund. What I thought was particularly interesting was that he indicated that EPA has used the current Health Advisory Levels (HALs) for enforcement actions at eight different sites.

  3. They are going to expand the focus of monitoring for PFAS. Wheeler indicated that PFAS will be a part of the next UCMR action, but did not commit to which PFAS would be monitored under the next UCMR.

  4. EPA plans to continue expanding research efforts for developing analytical methods for the evaluation of groundwater, soil and other matrices. We all know that there are efforts at various stages to create methods under SW-846 to address non-drinking water matrices.

  5. They are working with many other federal agencies, including the Department of Defense, to “build a toolbox” for explaining impacts from PFAS.

In all, what Wheeler presented was unprecedented in the scope and actions of EPA since its inception. Many people in (and out of) this industry agree that EPA needs to get out in front of the PFAS issue to help “normalize” the responses, action limits and overall approach to PFAS that the states are taking.

We at Eurofins Environment Testing intend to stay on top of these initiatives so that we are prepared to serve our clients with their responses to impacts from PFAS.