Joe Green and Steve Humphreys wrote on our sister blog, Kelley Green Law:
” suspected contamination” with per- and polyfluoroalkyl substances (“PFAS”). Even more concerning is the authors’ assertion that this number is almost certainly a dramatic underestimate of the number of PFAS-contaminated sites, given the limited availability of data and the conservative mapping methodology used.
Published on October 11, the article “Presumptive Contamination: A New Approach to PFAS Contamination Based on Likely Sources” (published in Environmental Science and Technology Letters), aims to fill existing data gaps by postulating that “[I]In the absence of high-quality data to the contrary, PFAS contamination is likely near facilities known to produce, use and/or release PFAS, and to protect public health, the existence of PFAS in these locations should be assumed until test data are available.
Based on existing research, test data, and environmental reports, the authors argue that PFAS contamination can be inferred at three types of facilities:
(1) Fluorinated Aqueous Film Forming Foam (“AFFF”) Discharge Sites: military sites, airports, firefighting training sites, and “high hazard flammable liquid fire” sites such as those associated with the oil and gas extraction, oil refineries, storage facilities and chemical manufacturing, as well as railway accidents.
(2) Industrial facilities that produce or use PFAS: identified largely by the limited number of facilities that reported using PFAS under the US Agency’s Toxic Release Inventory (“TRI”) program Environmental Protection Agency (“EPA”).
(3) Sites related to PFAS-containing waste: Including PFAS-contaminated effluent and sludge from sewage treatment plants (“WWTP”), as well as solid waste disposal sites.
Using mapping technology, the study identified 57,412 “suspected PFAS contamination” sites in the United States, including 49,145 industrial facilities, 4,255 sewage treatment plants, 3,493 military sites and 519 major airports. Sites are identified in the publicly available map of PFAS Contamination Sites and Community Resources, available at www.pfasproject.com.
The authors note that “state and federal agencies can use a suspected contamination approach to identify and prioritize locations for monitoring, regulation, and remediation.”
The insights from this study are particularly noteworthy in the wake of the EPA’s August 2022 proposal to add two PFAS chemicals (PFOA and PFOS) to the list of hazardous substances under the Superfund program. Clearly, the scale of PFAS contamination in the United States is extraordinary and increases the potential for thousands of cleanup (and enforcement) actions at sites across the country.
Learn more about PFAS on our Kelley Green blog.