PFAS Emerging Contaminants

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PFAS Emerging ContaminantsTony R. Anthony CPG, CHMM, LEED-AP

IS THE THREAT OF PFASCONTAMINATION A REC?

Pervasive Throughout the USA

Known PFAS Contamination

PFAS Concentration in Blood

WHAT ARE PFAS?Don’t worry ! Just a little science.

Polyfluoroalkyl Substances Over 2,000 PFAS Compounds Perfluorooctanesulfonic acid(PFOS) Perfluorooctanoic acid (PFOA)

PFAS – General ChemistryFluorocarbon TailStrong BondsHydrophobicOleophobicFunctional GroupStrong to weak acidsHydrophilic

Difficulty in Sample Collection andLaboratory AnalysisSample CollectionPFAS-free waterPFAS-free sample equipment100% cotton clothing(wash 6X no fabric softener)Boots without water proofingNitrile glovesTrip – Equipment BlanksNo Personal Care ProductsTyvek Laboratory AnalysisDrinking Water Method 537Reports 14 compoundsMethod 537 – modifiedAcid WashReport Additional CompoundsASTM Method 7979Minnesota uses a versionSW-846 method to be released this yearand likely based on ASTM method

TOXICOLOGY

Animal Exposure – Lau Et al. (2006) Basis for the 70 ppt EPA Advisory Level PFOA exposure to mice Toxicity Endpoints– Neonatal eye opening– Neonatal body weight– Reduced phalangeal ossification (bonedevelopment)– Maternal Liver Weight

Human Exposure - C8 Science Panel Studied Exposure in Mid-Ohio Valley Releases from DuPont’s WashingtonWorks Plan Chosen by both DuPont and Plaintiffsfor legal settlement Conclusions in form of “Probable Links”

PFAS Blood Levels in C8 Areas

Human Exposure - C8 Science Panel High CholesterolUlcerative ColitisThyroid DiseaseTesticular CancerKidney CancerPregnancy–Induced Hypertension

UNCERTAINTY

Toxicology – Key Points Most epidemiological (human) andanimal (laboratory) studies on PFOAand PFOS Both PFOA and PFOS bioaccumulate inhuman blood. PFOA and PFOS persists in humans foryears, but in rats and mice for onlydays.

ATSDRWhen referring to PFOA and PFOS, “lack ofconsistency between effects observed in humansand those observed in laboratory animals.”vs

Lau Study compared to C8 Panel Lau Toxicity Endpoints– Neonatal eye opening– Neonatal body weight– Reduced bonedevelopment (young)– Maternal Liver Weight C8 Panel No Probable Links–––––No Link birth defectsNo Link low birth weightNo Link miscarriage - stillbirthsNo Link osteoarthritis (aged)Probable Link pregnancyinduced hypertension

CONSERVATIVE ENOUGH?Oh no, here comes more science!

Calculation of Reference Dose1. Lowest Effect Level (mice) is 1 mg/kg-d2. Adjust to humans to account for longer half-life;now 0.0053 mg/kg-d3. Conversion from LOAEL to NOAEL – 10Inter-species – 3Sensitive Individuals – 1010 x 3 x 10 300 Uncertainty Factor4. Adjust for uncertainty factor; 0.000018 mg/kg-dMinnesota Department of Health, Toxicology Summary for: PFOA, May 2017USEPA Drinking Water Health Advisory for PFOA, May 2016

Calculation of Drinking WaterUSEPA Equation:𝑅𝑅𝑅𝑅𝐷𝐷 𝑏𝑏𝑏𝑏𝐷𝐷𝐷𝐷𝐷𝐷𝐿𝐿 EL - Drinking Water Equivalent LevelRfD – Refence Dosebw – Body WeightDWI – Drinking Water IntakeRSC - Relative Source ContributionRfD – 1.8 x 10-5 mg/kg-d (from 1.0 mg/kg-d)bw – 70 kgDWI – 2.0 l/day or 3.6 l/dayRSC – 20% (80% from background)USEPA Drinking Water Health Advisory for PFOA, May 2016

Calculation of Drinking WaterWhat is an appropriate water ingestion rate?𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 𝑚𝑚𝑚𝑚 𝑑𝑑 70 𝑘𝑘𝑘𝑘𝑘𝑘𝑘𝑘20%2.0 𝑙𝑙 𝑑𝑑 𝑎𝑎𝑎𝑎0.000018DWEL 126 ppt (RSC 80%)𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 𝑚𝑚𝑚𝑚 𝑑𝑑 70 𝑘𝑘𝑘𝑘𝑘𝑘𝑘𝑘20%3.6 𝑙𝑙 𝑑𝑑 𝑎𝑎𝑎𝑎0.000018DWEL 70 ppt (RSC 80%)USEPA 95th percentile ofconsumer-only lactating women.USEPA Exposure Factors Handbook:2011 Edition, September 2011

Calculation of Drinking WaterWhat is an appropriate Relative Source Contribution?𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 𝑚𝑚𝑚𝑚 𝑑𝑑 70 𝑘𝑘𝑘𝑘𝑘𝑘𝑘𝑘20%2.0 𝑙𝑙 𝑑𝑑 𝑎𝑎𝑎𝑎0.000018DWEL 126 ppt (Background 80%)DWEL 315 ppt (Background 50%)DWEL 504 ppt (Background 20%)𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 𝑚𝑚𝑚𝑚 𝑑𝑑 70 𝑘𝑘𝑘𝑘𝑘𝑘𝑘𝑘20%3.6 𝑙𝑙 𝑑𝑑 𝑎𝑎𝑎𝑎0.000018DWEL 70 ppt (Background 80%)DWEL 175 ppt (Background 50%)DWEL 280 ppt (Background 20%)USEPA Drinking Water Health Advisory for PFOA, May 2016

Calculation of Drinking WaterWhat if we used a different RfD, DWI, and RSC?𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 𝑚𝑚𝑚𝑚 𝑑𝑑 70 𝑘𝑘𝑘𝑘𝑘𝑘𝑘𝑘50%2.0 𝑙𝑙 𝑑𝑑 𝑎𝑎𝑎𝑎0. 0018DWEL 31 ppb

HOW DO WE COMPARE?

THE LAWSUITSand future movies .

Class–Action Suits Mid-Ohio Valley (DuPont) Alabama municipalities (3M et el) Michigan PFAS sites with Willow GroveNaval Air Station in Pennsylvania Minnesota (3M)

Mid-Ohio Valley - DuPontC8 Science Advisory Panel2018 – 671 million settlementOhio AG files suit2017- Consent order for cleanup to70 ppt.2005 – DuPont pays 16.5 million toEPA to settle TSCA violations1999 – Taft Stettinius & Hollister filesuit for health damage tofarmer Tenant’s cattle.

Alabama Litigation Background Leading Up to Litigation2007 CDC StudiesState Sampling Water Systems2008-2009 EPA Water System Sampling2009 EPA Provisional Health Advisory2013 Spring EPA issued fact sheet for PFCdetected Decatur, AL – detected but belowPHA levels– 2016 EPA Issued Health Advisory forPFOA/PFOS– May 20, 2016 AL DPH New Release IDmunicipal systems with PFOA/PFOS EPAAdvisory levels–––––

Alabama Litigation 10-5-2015 WEST MORGAN-EAST LAWRENCE WATER ANDSEWER AUTHORITY v. 3M CO, DYNEON, L.L.C., and DAIKINAMERICA, INC. –seeks money for treatment system 6-24-2016 TENN. RIVERKEEPER, INC. V. 3M CO. [plusmunicipalities] seeks cleanup of landfills leaching to river 9-22-16 THE WATER WORKS AND SEWER BOARD OF GADSDENv. 3M [plus 30 carpet manufacturers and suppliers] – seeksmoney for treatment systems upgrades 5-15-2017 THE WATER WORKS AND SEWER BOARD OF THETOWN OF CENTRE v. 3M [plus 35 carpet manufacturers] seeksmoney for treatment systems upgrades

Alabama Litigation

Minnesota – 3M Company PFAS contaminated groundwaterdiscovered in 2002. UC Berkley Study– Increase in premature birthsand low birth weight Minnesota AG files suit against3M Company. Bottled water and filtrationsystems for some municipalhomes. 2018 3M settles for 850 million.

Michigan – Wurtsmith Air Force Base US Air Force claims “sovereignimmunity” to avoid compliancewith state law. Municipal drinking watersystem expanded. Homes provided drinking watertreatment sytems GAC Groundwater Treatment Fish Advisory

Michigan – Wolverine Former Tannery andLandfill USEPA Order. State of Michigan Law Suit Possible Class-action

IS THE THREAT OF PFASCONTAMINATION A REC?

Regulation No federal regulation Some state regulation Are PFAS HazardousSubstances or only HazardousMaterials?

High Risk PropertiesAirportsLandfillsMetal plating operationsLeather TanneryCardboard or coated papermanufacturing Chemical plant Carpet manufacturing

EPA PFAS Links “PFAS, including PFOA and PFOS, are not listed as CERCLAhazardous substances, but in some circumstances could beresponded to as CERCLA pollutants.”Laws and Regulations Link: https://www.epa.gov/pfas/pfas-lawsand-regulations PFOS and PFOA EPA Drinking Water Health AdvisoryEPA Actions: https://www.epa.gov/pfas/epa-actions-address-pfas Health pfas#health Community engagement SW-846 endium

PFAS Emerging ContaminantsTony R. Anthony CPG, CHMM, LEED-AP

PFAS-free water PFAS-free sample equipment. 100% cotton clothing (wash 6X no fabric softener) Boots without water proofing. Nitrile gloves. Trip – Equipment Blanks. No Personal Care Products. Tyvek Laboratory Analysis Drinking Water Method 537 Reports 14 compounds. Method 537 – modified

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