As listed in the Order “PFAS is a family of more than 3,000 man-made and mostly unregulated chemicals that have been produced since the mid-1900s. They are mobile, persistent, and bioaccumulative. They are resistant to degradation in the environment and when degradation occurs, it often results in the formation of other PFAS compounds…Currently the key classes of concern are perfluoroalkyl sulfonic acids such as the long-chain perfluorooctanesulfonate (PFOS) and perfluorooctanoic acid (PFOA)… Historically, fume suppressants used in chrome plating operations often contained PFOS as an active ingredient. Although PFOS based fume suppressants have not been used in California since September 2016, these newer non-PFOS fume suppressants may contain other PFAS.”
Facilities listed in the Order should be advised that Site Investigation Workplans are due to the State by January 31, 2020. Facilities listed in the Order that do not perform chrome plating, or if fume suppressants were not used, disposed, discharged, spilled, or released in any way to the land, drains, sewers, surface water, air, and/or groundwater, a questionnaire in lieu of performing the site investigation was due to be submitted to their local RWQCB by November 25, 2019. This date is past due, but there are many facilities that may not be aware of this Order.
The purpose of the order is to determine whether the stormwater, effluent wastewater, groundwater, and/or soil at a given location is impacted by PFAS and to obtain an understanding of PFAS concentrations in the soil, groundwater, stormwater runoff, and/or effluent wastewater at these facilities. The Order requires facilities to perform the following actions:
- Submit a site investigation work plan in GeoTracker which details the various potential pathways for discharge of PFAS from your facility, and the nature of potential PFAS contamination in the soil, groundwater, stormwater, and effluent wastewater where applicable;
- Perform the site investigation; and
- Submit the results of the site investigation in a final report to the applicable Regional Water Board identified in the cover letter and upload to GeoTracker.
Facility managers should be advised that fully assessing your facility’s current or historical use of PFAS compounds may have particular implications on future management actions and planning. Also, developing a defensible work plan is critical and should consider specialized sampling and analytical techniques to ensure high quality and defensible results are obtained.
NV5’s experts provide consulting expertise, preparation of workplans, monitoring, and reporting in response to SWRCB Investigation Orders. For further assistance or to learn if your facility is subject to these regulations, or for just compliance concerns in general, give us a call at 562-495-5777 or email our Water Resources experts. David Renfrew can be reached via email at David.Renfrew@altaenviron.com.