Personal opinion as someone who understands and has quite a bit of experience working in the drinking water industry and discussing regulatory compliance. Note I'm not disputing the health risks...
Exemplary
Personal opinion as someone who understands and has quite a bit of experience working in the drinking water industry and discussing regulatory compliance. Note I'm not disputing the health risks related to PFAS but instead critical of EPA's regulatory approach discussed at the end of the video.
EPA recently announced changes to PFAS regulation which has upset some environmental groups. One thing I want to point out is the PQL or practical quantitation level aka the lowest value defined by the EPA that can be reliably measured is 4 parts per trillion (ppt), which is equal to the PFOS MCL aka maximum contaminant level which means if PFOS is detected using method 537.1 a water system is in violation. Note most MCLs are orders of magnitude higher in the range of parts per billion rather than parts per trillion. This is very much a classic example of "dose makes the poison" but on an absolute level, detecting something at the PPT, particularly PFAS is extremely challenging as chance of cross contamination for a near ubiquitous substance is quite high. I've collected this stuff before and while I was confident in my technique, it is stressful in ways other water samples are not.
Note as well that EPA's own presentation on treatment technologies (PDF) cites this paper whose results may not be effective at low concentrations which begs the question how effective are treatment options at levels closer to the MCL and for the amount of water some mid sized cities/water systems are able to produce. Take Omaha, NE which pushes out 90 MGD a day : how is it feasible for them to achieve compliance at this scale?
Another thing the video doesn't discuss is the fact that removal =/= destruction and what may end up happening is the creation of concentrated PFAS wastestreams from water filtration processes: filtration plants need to get rid of this stuff but how? Incinerators are hit or miss as if the critical temps aren't met, then you end up creating a PFAS plume in what you're burning off. You can't just dump this stuff in a landfill either, you just create another environmental disaster in waiting.
Note as well is this whole video talks about the role of Dupont and 3M but where is the federal action against these individuals? Why are water/wastewater systems being regulated for a problem they did not create? We're regulating a few dozen PFAS compounds when thousands exist, how effective is this decision by the EPA? My question is always, what viable actions are available to water systems? So far, my question has yet to be answered.
Generally speaking I'm a huge fan of the EPA, I've built my career around understanding their decisions but this PFAS one made zero sense in the context of reality. The same goes with some of the provisions found in the former Lead and Copper Rule Revisions and the recent Lead and Copper Rule Improvements. Based on my conversations with EPA employees and other federal government officials, it appears that EPA has a lack of real world perspectives informing decisions and instead of talking to medium or small water systems about their concerns and difficulties, they're more willing to listen to shit "advocacy" groups like EWG whose objectives and goals don't really align with water systems overall goal of providing safe drinking water.
TL;DR edit - Here are my concerns and why imo, EPA fucked this one up
What technologies effectively remove PFAS for systems who produce at a level of 10s of MGD per day? So far I've seen none
What is the benefit of single digit ppt reductions of PFAS for systems with low detectable PFAS levels? Does the money and environmental impact of installing treatment methods for single level actual offer benefits over known benefits like infrastructure improvement projects or source water protection efforts
What technologies exist to eliminate PFAS, not just destroy it? So far it's just sequestering/removal which is an environmental justice disaster waiting to happen
Where is the action on PFAS producers? Why isn't the government pursuing action against 3M and Dupont and using the penalties to fund remediation projects for water systems? Why does this fall on utilities hands? I mean I think we all know why but this is the biggest issue I have.
Personal opinion as someone who understands and has quite a bit of experience working in the drinking water industry and discussing regulatory compliance. Note I'm not disputing the health risks related to PFAS but instead critical of EPA's regulatory approach discussed at the end of the video.
EPA recently announced changes to PFAS regulation which has upset some environmental groups. One thing I want to point out is the PQL or practical quantitation level aka the lowest value defined by the EPA that can be reliably measured is 4 parts per trillion (ppt), which is equal to the PFOS MCL aka maximum contaminant level which means if PFOS is detected using method 537.1 a water system is in violation. Note most MCLs are orders of magnitude higher in the range of parts per billion rather than parts per trillion. This is very much a classic example of "dose makes the poison" but on an absolute level, detecting something at the PPT, particularly PFAS is extremely challenging as chance of cross contamination for a near ubiquitous substance is quite high. I've collected this stuff before and while I was confident in my technique, it is stressful in ways other water samples are not.
Note as well that EPA's own presentation on treatment technologies (PDF) cites this paper whose results may not be effective at low concentrations which begs the question how effective are treatment options at levels closer to the MCL and for the amount of water some mid sized cities/water systems are able to produce. Take Omaha, NE which pushes out 90 MGD a day : how is it feasible for them to achieve compliance at this scale?
Another thing the video doesn't discuss is the fact that removal =/= destruction and what may end up happening is the creation of concentrated PFAS wastestreams from water filtration processes: filtration plants need to get rid of this stuff but how? Incinerators are hit or miss as if the critical temps aren't met, then you end up creating a PFAS plume in what you're burning off. You can't just dump this stuff in a landfill either, you just create another environmental disaster in waiting.
Note as well is this whole video talks about the role of Dupont and 3M but where is the federal action against these individuals? Why are water/wastewater systems being regulated for a problem they did not create? We're regulating a few dozen PFAS compounds when thousands exist, how effective is this decision by the EPA? My question is always, what viable actions are available to water systems? So far, my question has yet to be answered.
Generally speaking I'm a huge fan of the EPA, I've built my career around understanding their decisions but this PFAS one made zero sense in the context of reality. The same goes with some of the provisions found in the former Lead and Copper Rule Revisions and the recent Lead and Copper Rule Improvements. Based on my conversations with EPA employees and other federal government officials, it appears that EPA has a lack of real world perspectives informing decisions and instead of talking to medium or small water systems about their concerns and difficulties, they're more willing to listen to shit "advocacy" groups like EWG whose objectives and goals don't really align with water systems overall goal of providing safe drinking water.
TL;DR edit - Here are my concerns and why imo, EPA fucked this one up
What technologies effectively remove PFAS for systems who produce at a level of 10s of MGD per day? So far I've seen none
What is the benefit of single digit ppt reductions of PFAS for systems with low detectable PFAS levels? Does the money and environmental impact of installing treatment methods for single level actual offer benefits over known benefits like infrastructure improvement projects or source water protection efforts
What technologies exist to eliminate PFAS, not just destroy it? So far it's just sequestering/removal which is an environmental justice disaster waiting to happen
Where is the action on PFAS producers? Why isn't the government pursuing action against 3M and Dupont and using the penalties to fund remediation projects for water systems? Why does this fall on utilities hands? I mean I think we all know why but this is the biggest issue I have.
The origin of PFAS