Yesterday’s EPA PFAS plan does nothing except to study for a year or more what has already been studied. Where are the limits on amounts of these firefighting chemicals in water that would enable EPA or GA-EPD to test private wells, for example for the PFAS that got into groundwater from Moody Air Force Base’s Wastewater Treatment Plant, causing Moody’s report to say be careful eating fish caught in Beatty Branch or Cat Creek, upstream from the Withlacoochee River? Where are the funds and methods to remediate the problem and to stop it getting worse?

Figure 25 Waste Water Treatment Plant (AFFF Area 8) PFBS, PFOA, and PFOS in Soil and Sediment

U.S. Environmental Protection Agency (EPA), 14 February 2018, EPA’s Per- and Polyfluoroalkyl Substances (PFAS) Action Plan,

This Action Plan describes the EPA’s approach to identifying and understanding PFAS, approaches to addressing current PFAS contamination, preventing future contamination, and effectively communicating with the public about PFAS. The Action Plan describes the broad actions the EPA has underway to address challenges with PFAS in the environment, including next steps on the four PFAS management actions the EPA announced at the May 2018 National Leadership Summit. The four actions announced at the Summit were:

• Initiating steps to evaluate the need for a maximum contaminant level (MCL) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS);
• Beginning the necessary steps to propose designating PFOA and PFOS as “hazardous substances” through one of the available federal statutory mechanisms1;
• Developing groundwater cleanup recommendations for PFOA and PFOS at contaminated sites;
• Developing toxicity values or oral reference doses (RfDs)2 for GenX chemicals3 and perfluorobutane sulfonic acid (PFBS).

In addition to these significant actions, the EPA’s PFAS Action Plan identifies more short-term and longterm actions that are currently being implemented to understand and address PFAS. Short-term actions include:

• Developing new analytical methods and tools for understanding and managing PFAS risk;
• Promulgating Significant New Use Rules (SNURs) that require EPA notification before chemicals are used in new ways that may create human health and ecological concerns; and
• Using enforcement actions to help manage PFAS risk, where appropriate.

Short-term actions are generally taking place or expected to be completed within two years.

Two years is an interesting definition of short-term. And that means the “four actions announced at the Summit” apparently will take more than two years.

I agree with Delaware Riverkeeper Network’s statement:

Essentially, EPA announced they are going to study further whether or not they will consider setting federal MCLs, a “plan” that lacks any sense of urgency and offers no timely relief to people exposed to these highly toxic compounds in their water.

Georgia could do what Pennsylvania is doing. Susan Phillips and Jon Hurdle, WHYY, 15 February 2019, Pa. to begin its own process of setting health limit for two PFAS chemicals,

Pennsylvania will begin the process of setting its own health limits for two toxic PFAS chemicals because it’s unclear when the federal government will set national standards, the Department of Environmental Protection said late Thursday.

However, it’s not clear why Pennsylvania thinks much more study is needed.

Mark Cuker, an environmental attorney, and member of the grassroots group Buxmont Coalition for Safer Water, says Pennsylvania should act quickly by consulting the science produced by New Jersey’s Drinking Water Quality Institute, a panel of scientists that advises the state’s DEP. The DWQI recommended a much lower safety standard for PFAS chemicals than the EPA’s current advisory of 70 parts per trillion. That recommendation includes a maximum contaminant level of 14 ppt for PFOA and 13 ppt for PFOS and PFNA, which has been adopted by other states.

Cuker says there’s no reason to reinvent the wheel.

“New Jersey did comprehensive scientific analyses by top-flight people,” said Cuker. “Large compendiums of hundreds and hundreds of pages. It was good enough for California, it was good enough for New York. It should be good enough for Pennsylvania. This is not action, this is just words.”

Maybe Georgia and Florida should move along like Pennsylvania and set their own PFAS limits. Maybe they should shortcut the process by drawing on what New Jersey (and Michigan and North Carolina) already did.

Moody AFB, GA-EPD, and GA Dept. of Health all say they lack the authority to test private wells for PFAS. Georgia and Florida and Congress need to give them that authority, and funding to do it, and then to remediate the problem.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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