Per- and Polyfluoroalkyl Substances (PFAS) in Drinking Water

US EPA Proposed National Primary Drinking Water Regulation for PFAS in Drinking Water

On March 14, 2023 EPA released the proposed National Primary Drinking Water Regulation (NPDWR) for PFOA and PFOS, along with four additional PFAS. EPA is proposing to set a Maximum Contaminant Level (MCL) of 4 parts per trillion (ppt) for PFOA and 4 ppt for PFOS. In addition to these two MCLs, EPA is proposing to address four additional PFAS (GenX, PFBS, PFNA, and PFHxS) as a mixture using a Hazard Index. The Hazard Index is a tool typically used to evaluate potential health risks from exposure to chemical mixtures. This approach has been used in other EPA programs, such as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), but this is the first time it has been used for a drinking water standard. Additionally, EPA is proposing Maximum Contaminant Level Goals (MCLGs) for each of the six PFAS. A breakdown of the MCLs and MCLGs is shown on the table below.

PFAS Compound 

Proposed MCLG 

Proposed MCL 

PFOA 

0 ppt 

4.0 ppt 

PFOS 

0 ppt

4.0 ppt

PFNA 

 

1.0 (unitless Hazard Index) 

 

1.0 (unitless Hazard Index) 

PFHxS 

PFBS 

HFPO-DA (GenX) 

 

For the Hazard Index, the rule proposes a ratio for each of the four PFAS to be used to calculate a compliance value based on detected levels of the four PFAS. If the sum of those four ratios is at or above 1.0, then water systems will be expected to reduce the levels of these PFAS. Depending on the level of contamination found, water systems may need to take action even if only one of the four PFAS is present. EPA will be creating a webpage with a calculator tool for water systems to determine their Hazard Index.

Following publication in the Federal Register, a 60-days public comment opened. EPA will held two informational webinars about the proposed PFAS NDPWR on March 16, 2023, and March 29, 2023. The webinars were similar, with each intended for specific audiences. The webinar recordings and presentation materials are available here.

EPA held a public hearing on May 4, 2023, where members of the public could provide verbal comments to EPA on the rule proposal. A recording of the public hearing is available here.

EPA has provided facts sheets for the public and FAQs specifically for primacy agencies to help with the rollout of this proposal. See the links below:

Drinking Water

  • The VDH Office of Drinking Water is working closely with water utility providers to monitor the water that is provided to Virginia residents.
  • Health advisories are not enforceable and are provided so that state and tribal agencies can make informed decisions.
  • According to the EPA, public water systems without detectable levels of PFOA and PFOS should continue to monitor for PFAS if they are concerned about potential contamination, but EPA is not recommending additional actions.
  • VDH advises Public Water Systems that detect PFAS in their drinking water to take steps to inform customers, undertake additional sampling to assess the level, scope, and source of contamination, and examine steps to limit exposure.
  • Activated carbon, Ion exchange and high-pressure membranes have been demonstrated to remove PFAS from drinking water systems.
  • The EPA is not recommending bottled water for communities based solely on concentrations of PFAS in drinking water that exceed the health advisory levels. In addition, the Food and Drug Administration has not established standards for contaminants such as PFAS in bottled water.

House Bill (HB) 586, 2020 Acts of Assembly Chapter 611, requires the State Health Commissioner to convene a workgroup to study the occurrence of six specific PFAS, including perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), perfluorobutyrate (PFBA), perfluoroheptanoic acid (PFHpA), perfluorohexane sulfonate (PFHxS), perfluorononanoic acid (PFNA) and other PFAS, as deemed necessary, that may be present in drinking water from waterworks, identify possible sources of such contamination, and evaluate approaches to regulating PFAS.  The PFAS Workgroup may recommend maximum contaminant levels (MCLs) for inclusion in regulations of the Board of Health applicable to waterworks.

The legislation requires the workgroup to “determine current levels of PFOA, PFOS, PFBA, PFHpA, PFHxS, PFNA, and other PFAS, as deemed necessary, contamination in the Commonwealth’s public drinking water, provided that in making such determination of current levels, the Department of Health shall sample no more than 50 representative waterworks and major sources of water[.]”  As this refers specifically to “public drinking water” and “waterworks,” the workgroup’s efforts will focus on “water supplies” and “waterworks,” as those terms are defined in the Public Water Supplies Law, Code of Virginia§ 32.1-167, and Waterworks Regulations, 12VAC5-590-10.[1] The PFAS Workgroup must report its findings to the Governor and legislative committees by December 1, 2021. HB1257, 2020 Acts of Assembly Chapter 1097, directs the Board of Health to adopt regulations establishing MCLs for PFOA, PFOS, and other PFAS as it deems necessary; hence, the PFAS Workgroup’s recommendations for MCLs is a critical objective.

 

PFAS Workgroup Members Updated October 19, 2020
Category Name Organization
1 Community Waterworks serving > 50,000 consumers Chris Harbin/Jillian Terhune Norfolk Department of Public Utilities
2 Community Waterworks serving > 50,000 consumers David Jurgen City of Chesapeake Department of Public Utilities
3 Community Waterworks serving > 50,000 consumers Jamie Bain Hedges DGM., Fairfax Water
4 Community Waterworks service > 50,000 consumers Mike Hotaling Newport News
5 Community Waterorks serving > 50,000 consumers Michael McEvoy Western Virginia Water Authority (Roanoke Area)
6 Community Waterworks serving ˃ 50,000 consumers Jessica Edwards-Brandt Loudoun Water
7 Community Waterworks service > 50,000 consumers (Advocacy Group That Represents Waterworks) Russ Navratil/Geneva Hudgins VW AWWA/Henrico County
8 Community Waterworks serving 50,000 consumers (Private Company) Christian Volk Virginia American Water
9 Community Waterworks serving < 50,000 consumers (Private Company) John J. Aulbach/Dan Hingley Aqua Virginia
10 Community Waterworks serving < 50,000 consumers Mark Estes Halifax County PSA
11 Community Waterworks serving < 1,000 consumers Wendy Eikenberry Augusta County Service Authority
12 Advocacy Group that represents Waterworks Andrea W. Wortzel Mission H2O
13 Advocacy Group that represents Waterworks Steve Herzog/Paul Nyffler Virginia Water Environment Association
14 Manufacturer with Chemical Experience Stephen P. Risotto Henry Bryndza American Chemistry Council
15 Environmental Organization Anna Killius James River Association
16 Environmental Organization Phillip Musegaas Potomac Riverkeeper Network
17 Environmental Organization Michael Town Christopher Leyen Virginia League of Conservation Voters
18 VDEQ Representative Jeff Steers Virginia Department of Environmental Quality
19 Consumer of Public Drinking Water Dr. William Mann Commonwealth Citizen
20 VDH ODW Staff -Technical Expert Robert Edelman Director of Technical Services
21 Virginia State Toxicologist Dwight Flammia State Toxicologist
22 VDH Local Health Department Noelle Bissell Director, New River Health District
23 VDH ODW Staff Dan Horne SEVFO Director
24 Facilitator Dwayne Roadcap/Nelson Daniel VDH Director, Office of Drinking Water
25 Organizer / Chair Tony Singh VDH Deputy Director, Office of Drinking Water

 

VA PFAS Meetings:

VA PFAS Workgroup and sub group meeting agenda, minutes and recordings are available here:
Workgroup Meetings:

Virginia PFAS Workgroup Meeting Meeting Agenda & Meeting Minutes Meeting Recording
October 20, 2020 Click Here N/A
January 19, 2021 Click Here Recording
March 04 2021 Agenda / Minutes Recording
April 29, 2021 Agenda N/A
July 27,2021 Click Here Recording
September 10, 2021 Click Here Recording

Subgrouproup Meetings:

PFAS Subgroup Name & Date Health & Toxicology Occurence & Monitoring Policy & Regulations Treatment Technologies
December 2020 MeetingAgenda & Meeting Minutes
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January 2021 MeetingAgenda & Meeting Minutes
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The Workgroup is in the process of designing a PFAS Sampling & Monitoring study in Virginia drinking water. Per HB586, no more than 50 waterworks and/or water sources will be covered under this sampling event. Selection of such waterworks and water sources will be based on two major criteria i.e. protecting public health, and maximum risk reduction.

Sample Training Webinar slides from April 14, 2021:  Sampling for PFAS & What to Expect after Sampling

Below is the VA PFAS Sampling Training Video.

 

PFAS may enter a person’s body when they drink water or eat food that has been contaminated with PFAS. Unborn babies may be exposed to PFAS if their mother ingests PFAS while she is pregnant, and babies may be exposed through breastmilk. Inhalation of PFAS contaminated water can be a source of industrial exposures for employees (see the Business and Employee Exposure section below). PFAS are also present in many consumer products. Studies in humans and animals show that there may be negative health effects from exposure to certain PFAS. Completely stopping exposure to PFAS is not practical, because they are so common and present throughout the world.

Robert Edelman, PE

Director, Division of Technical Services

Phone: (804) 864-7490

Email: Robert.Edelman@vdh.virginia.gov

 

Dwayne Roadcap

Office Director, VDH Office of Drinking Water

Phone: (804) 864-7522