AAAS EPI Center and GLLC Roundtables

AAAS EPI Center and the Great Lakes St. Lawrence Legislative Caucus Roundtables: Per- and Polyfluoroalkyl Substances (PFAS) and Drinking Water

Agenda Roundtables 1 & 2: Information Overview Wednesday, December 2 1:00-2:30 pm ET Friday, December 4 3:00-4:30 pm ET

Goals : •

Provide a high-level overview of the scientific evidence for PFAS and drinking water; • Connect decision-makers with scientific experts, as well as other colleagues addressing these issues, who can help inform how to engage with constituents and fellow policy makers and incorporate scientific information into their decision-making; • Discuss how scientific evidence is and is not informing decision-making, such as understanding when and why PFAS found in drinking water (and other exposure pathways) are of concern to communities, how to assess where those substances are coming from and who is responsible for mitigating exposure, and how best to understand options for reducing if not eliminating risks posed by these substances; and • Identify opportunities and challenges communities are facing based on disproportionate impacts from drinking water contamination. Welcome, Background, Goals, Agenda Review and Protocols ( 10 minutes ) o Lisa Janairo, Program Director, Council of State Governments, Manager, Great Lakes-St. Lawrence Legislative Caucus o Rebecca Aicher, Project Director, EPI Center o Abby Dilley, Vice President of Programs, RESOLVE

Scientific Overview of Per- and Polyfluoroalkyl Substances (2 0 minutes ) o Laurel Schaider, Research Scientist, Silent Spring Institute ( 15 minutes ) o Questions and Answers ( 5 minutes )

Addressing Community Risks Posed by PFAS Contaminants (10 minutes) o Phil Brown, Distinguished Professor, Northeastern University

Community Case Example from New Hampshire (20 minutes) o Hon. Wendy Thomas, New Hampshire State Legislator, Merrimack, NH o Shaun Mulholland, City Manager, Lebanon, NH

Facilitated Questions, Answers and Discussion ( 15 minutes )

Additional Information Needs and Opportunities, and Wrap Up ( 10 minutes )

Evaluation and Adjourn ( 5 minutes)

Agenda Roundtable 3: Opportunities and Challenges to Addressing PFAS in Drinking Water Wednesday, December 9, 1:00-2:30 pm ET

Goals :

• Build on the informational overview session and insights gained from other examples to probe options for addressing risks posed by PFAS contaminated drinking water, including prioritizing disproportionate impacts for action; • Discuss the necessity of communicating with constituents and engaging community stakeholders in working constructively together to address PFAS; and • Determine any additional information that could support further deliberations and decision- making among colleagues to reduce if not eliminate the risks posed by PFAS. Welcome, Background, Goals, Agenda Review and Protocols ( 10 minutes ) o Lisa Janairo, Program Director, Council of State Governments, Manager, Great Lakes-St. Lawrence Legislative Caucus o Rebecca Aicher, Project Director, EPI Center o Abby Dilley, Vice President of Programs, RESOLVE

Brief Participant Introductions ( 5 minutes)

Case Examples: How are Michigan and North Carolina responding to PFAS? ( 30 minutes) o Steve Sliver, Executive Director, Michigan PFAS Action Response Team (MPART) o Jeff Warren, Executive Director, North Carolina Policy Collaboratory

Facilitated Interactive Panel Discussion ( 15 minutes)

Breakout Session: Engaging with your Community on PFAS ( 20 minutes) o Workshopping Community Strategies o Workshopping Risk Communication

Additional Informational Needs and Potential for GLLC Legislative Action ( 10 minutes )

Wrap Up and Adjourn

AAAS EPI Center and the Great Lakes St. Lawrence Legislative Caucus Roundtables: Per- and Polyfluoroalkyl Substances (PFAS) and Drinking Water

Speaker Biographies

Laurene Allen is a community based clinical social worker, co-founder of the Merrimack Citizens for Clean Water (Cleanwaternh.org) community action group and a founding member of the National PFAS Contamination Coalition. She started advocating for the needs of residents in Merrimack, NH after learning in 2016 that her family and community members were impacted by industry attributed PFAS contamination. In addition to community engagement, education and advocacy efforts on a local, state and federal level, Laurene has focused on raising awareness of community health impacts believed to be associated with past and ongoing PFAS exposure. Together with citizen activists from across the nation, she has also been involved in shaping a collaborative platform of the needs of all PFAS exposed communities. Laurene strongly believes that PFAS impacted community members are their own experts as illustrated by facilitating a community designed and led health survey. The co- authored paper of the process has been published in the journal, Environmental Health (https://www.readcube.com/articles/10.1186/s1294 0-019-0513-3).

Phil Brown is University Distinguished Professor of Sociology and Health Science at Northeastern University, where he directs the Social Science Environmental Health Research Institute and co- directs its PFAS Project lab. He is PI of the past NSF grant “ Perfluorinated Chemicals: The Social Discovery of a Class of Emerging Contaminants” and the current NSF grant “The New Chemical Class Activism: Mobilization Around Per- and Polyfluoroalkyl Substances.” He is Multiple PI of an NIEHS grant which studies children’s immune responses to PFAS and community response to contamination, and develops a report-back and information exchange. He helped organize 2017 and 2019 PFAS conferences.

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for Community Health) study, a researcher- community partnership that is evaluating PFAS exposures and immune system effects in children in communities with PFAS water contamination and developing an online resource center for PFAS- affected communities. She is also the lead investigator of the Massachusetts PFAS and Your Health Study, part of the CDC’s PFAS Multi-Site Health Study. She co-leads the Community Engagement Core for the STEEP (Sources, Transport, Exposure and Effects of PFASs) Superfund Research Program at the University of Rhode Island, including a study to evaluate PFAS levels in private wells on Cape Cod and identify contamination sources. She is a technical advisor to ATSDR’s Community Assistance Panel at the Pease Tradeport in Portsmouth, NH. Before joining Silent Spring Institute, she was a research associate at the Harvard T.H. Chan School of Public Health. Dr. Schaider earned her master's and PhD in Environmental Engineering at the University of California, Berkeley, and a bachelor’s degree in Environmental Engineering Science from MIT. She currently holds an appointment as a visiting scientist at the Harvard T.H. Chan School of Public Health.

Shaun Mulholland is the City Manager for the City of Lebanon, NH. He also serves as the Chairman of the Board of Directors for the New Hampshire Municipal Association. The City operates a landfill and solid waste facility which serves 22 municipalities in NH and VT.

Dr. Laurel Schaider is a Research Scientist at Silent Spring Institute, where she leads the Institute’s water quality research on PFAS and other contaminants of emerging concern. Her areas of expertise include environmental chemistry, environmental engineering, and exposure assessment. Her research focuses on characterizing PFAS exposures from drinking water, identifying other sources of PFAS exposure such as food packaging, understanding health effects associated with PFAS, investigating socioeconomic disparities in exposures to drinking water contaminants, and working with communities to develop research studies and resources to address their concerns. Dr. Schaider is the lead principal investigator for the PFAS-REACH (PFAS Research, Education, and Action

Steve Sliver was named Executive Director of the Michigan PFAS Action Response Team (MPART) in February 2019. He is responsible for coordinating Michigan’s unique, multi-agency approach to address per- and polyfluoroalkyl substances contamination across the state. A 33-year veteran of state government, he is the former assistant director of the Michigan Department of Environment, Great

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Lakes, and Energy (EGLE) Materials Management Division, responsible for promoting recycling and waste utilization, pollution prevention, ensuring the proper management of materials under the hazardous waste and liquid industrial by-products, solid waste, scrap tire, medical waste, and e-waste programs, and protecting the public and environment from the hazards associated with radioactive materials. Steve obtained his bachelor’s degree in environmental engineering from Michigan Technological University in 1985.

Jeff Warren , PhD, is executive director of NC Policy Collaboratory. Formally trained as a marine geologist, Jeff Warren has spent the past fifteen years in State-level science policy positions, including the coastal hazards policy specialist for the North Carolina Division of Coastal Management (2004 to 2010) and the science advisor for the North Carolina Senate President Pro Tempore (2011 to 2017). Warren earned his BSc from the University of Arizona (1994), his MSc from Auburn University (1997), and his PhD from the University of North Carolina at Chapel Hill (2006). Warren’s academic research included field sites in the southeastern US, northern Mexico, the East and South China Seas, and Antarctica.

Hon. Wendy Thomas is a member of the New Hampshire House of Representatives representing Hillsborough County, District 21 including the town

of Merrimack, NH. She is a member of the Resources, Recreation, and Development

Committee. She is also a member of the Commission on the Environmental and Public Health Impacts of Perfluorinated Chemicals, Hillsborough County Executive Council, University of New Hampshire Cooperative Extension Hillsborough County Advisory Council, and Protecting Unprotected Water Sources Legislative Committee. She is the state director of Women in Government and state lead for the National Caucus of Environmental Legislators. She is a founder and member of the Saint-Gobain Merrimack Community Advisory Council and a climate and environmental speaker

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Addressing Per- and Polyfluoroalkyl Substances (PFAS) in Drinking Water: Guides for Local and State Leaders

NOVEMBER 2020

This publication is available online at aaas.org/programs/epi-center/pfas-guides Released November 2020

Suggested citation: American Association for the Advancement of Science Center for Scientific Evidence in Public Issues 2020. Addressing Per- and Polyfluoroalkyl Substances (PFAS) in Drinking Water: Guides for Local and State Leaders. Washington, DC: AAAS Center for Scientific Evidence in Public Issues. aaas.org/programs/epi-center/pfas-guides

©2020 American Association for the Advancement of Science This work is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License.

AAAS Center for Scientific Evidence in Public Issues The Center for Scientific Evidence in Public Issues (AAAS EPI Center) is an initiative of AAAS designed to deliver clear, concise, and actionable scientific evidence to policymakers and other decision-makers. The AAAS EPI Center synthesizes and distills scientific evidence on key societal issues in a way that makes it clear how that evidence can inform policy-making and decisions at the local, state, and federal levels. We make it easier for people to access relevant scientific evidence and expertise. The American Association for the Advancement of Science (AAAS) is the world’s largest general scientific society with nearly 250 affiliated societies and academies of science and is the publisher of the Science family of journals.

Visit us at aaas.org/epicenter Follow us on Twitter @AAASepiCenter Contact us epicenter@aaas.org

American Association for the Advancement of Science 1200 New York Ave, NW, Washington, DC 20005 202-326-6400

NOVEMBER 2020

Per- and polyfluoroalkyl substances (PFAS) pose particular challenges to local and state leaders seeking to protect the health of residents. Uncertainties about the risk of various PFAS, the evolving science, and the variability among policies and standards make addressing these emerging contaminants difficult. States in the Great Lakes region are among those leading the effort to evaluate and address PFAS contamination, and are participating in a number of critical research studies and monitoring efforts. An initiative of the American Association of the Advancement of Science (AAAS), the Center for Scientific Evidence in Public Issues (EPI Center) delivers clear, concise, and actionable scientific evidence to policymakers and other decision-makers. The following guides were developed in the fall of 2020 by the AAAS EPI Center to help local and state leaders understand the current scientific evidence as they evaluate the risk of PFAS contamination in drinking water. The AAAS EPI Center is pleased to host virtual roundtable discussions with the Great Lakes St. Lawrence Legislative Caucus (GLLC) to foster collaboration among Great Lakes states and provinces. We hope that participants will benefit from a review of the most recent scientific evidence, and together explore options to address the risks posed by PFAS contaminated drinking water, including how to prioritize action most effectively. These guides are being distributed for the first time to GLLC members attending the virtual roundtable discussions. As the first people to receive these guides, we welcome your feedback on the materials. We hope the guides will be of assistance as you continue to engage your community members, drinking water providers, local and state regulatory agencies, and federal agencies to address PFAS contamination. Thank you for joining us to share your experiences and discuss strategies to minimize the harm posed by PFAS in the Great Lakes region and across the country. Please do reach out if you have any questions about PFAS or other issues in the Great Lakes.

Rebecca Aicher, Project Director, AAAS EPI Center, raicher@aaas.org

Visit us at aaas.org/epicenter Follow us on Twitter @AAASepiCenter Contact us epicenter@aaas.org

Addressing Per- and Polyfluoroalkyl Substances (PFAS) in Drinking Water: Guides for Local and State Leaders

GUIDES Scientific Overview of PFAS and Drinking Water Monitoring and Occurrence of PFAS in Drinking Water Treatment and Mitigation of PFAS in Drinking Water PFAS Risk Communications

These guides were developed to help local and state leaders understand the current scientific evidence as they evaluate the risk of PFAS contamination of drinking water. The guides can help people engage their community members, drinking water providers, local and state regulatory agencies, and federal agencies to address PFAS in drinking water. A class of thousands of synthetic organic chemicals, not enough is known about the health impacts of most PFAS, but even small doses of several of the most-researched compounds can lead to health issues. Detected in drinking water and drinking water sources throughout the United States, the chemical properties of PFAS make them difficult to treat and remove using conventional water treatment processes.

For more information, contact Rebecca Aicher , Project Director, AAAS EPI Center at raicher@aaas.org .

Visit us at aaas.org/epicenter Follow us on Twitter @AAASepiCenter Contact us epicenter@aaas.org

Addressing Per- and Polyfluoroalkyl Substances (PFAS) in Drinking Water: Guides for Local and State Leaders

TABLE OF CONTENTS Scientific Overview of PFAS and Drinking Water Introduction to Per- and Polyfluoroalkyl Substances (PFAS) PFAS Toxicology: PFAS Can Lead to Health Implications

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3 4 6 7 9 9

PFAS in the Environment PFAS Exposure Pathways

PFAS in Drinking Water Are Largely Unregulated in the United States

Overview of Current PFAS Research

Key Takeaways

References

10

Monitoring and Occurrence of PFAS in Drinking Water PFAS Contamination of Drinking Water

12 12 13 15

PFAS Contamination Calls for a “One Water” Approach

Existing Data Can Help Determine a Community’s Risk of PFAS Contamination Communities at Risk of PFAS Contamination Should Develop a Robust Monitoring Plan

Useful Tips for PFAS Sampling

18 19 20

Key Takeaways

References

Treatment and Mitigation of PFAS in Drinking Water PFAS and Drinking Water

21 21 22 28 28 29 31 31 34 35 41 41 42 42

Removing PFAS from Drinking Water Effective PFAS Treatment Methods

Promising New PFAS Treatment Methods Are In Development

Key Takeaways

References

PFAS Risk Communications What are PFAS?

Risk Communication for PFAS Engaging the Community

Developing Your PFAS Risk Communications Plan

Responding Reactivley Additional Resources

Key Takeaways

References

Relevant Key Words and Definitions

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Addressing Per- and Polyfluoroalkyl Substances (PFAS) in Drinking Water

Scientific Overview of PFAS and Drinking Water

Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

Introduction to Per- and Polyfluoroalkyl Substances (PFAS) A class of thousands of synthetic organic chemicals, per- and polyfluoroalkyl substances (PFAS) are found in a variety of industrial and consumer applications, from clothing and food wrappers to firefighting foam. Designed for long-term stability, temperature resistance, friction reduction, and oil and water repellency, PFAS, often referred to as “forever chemicals,” do not easily break down in the environment. Not enough is known about the health impacts of most PFAS, but even small doses of several of the most-researched compounds can lead to health issues. Anyone can be exposed to these toxic substances 2 . These guides were developed to help local and state leaders understand the current scientific evidence as they begin to address potential PFAS contamination. The information in these guides can help people engage community members, drinking water providers, local and state regulatory agencies, and federal agencies to address PFAS in drinking water. This first guide provides an overview of the current scientific evidence of PFAS occurrence and toxicology, as well as what remains unknown and requires additional research. It explains the properties, history, toxicology, exposure routes, and the current status of federal and state regulations of PFAS. Detected in drinking water and drinking water sources throughout the United States, the chemical properties of PFAS, such as the strength of the carbon-fluorine bonds, make them difficult to treat and remove using conventional water treatment processes. In 2016, the U.S. Environmental Protection Agency (EPA) developed a lifetime health advisory level of 70 nanograms per liter (ng/L) or parts per trillion (ppt) for two PFAS: perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA), individually or combined. This health advisory, however, is not an enforceable standard. In the absence of enforceable federal regulations, several U.S. states adopted or PFAS include thousands of synthetic chemicals and are made up of carbon chains in which at least one carbon atom is “perfluorinated,” meaning that other than its carbon-atom neighbors, it is bonded only to fluorine atoms. Three primary characteristics, as described in Figure 1 , differentiate PFAS from other chemicals and add to their chemical stability 3 . First, PFAS have carbon chain backbones that can vary in chain length (number of carbon atoms) and impact their chemical stability, toxicity, and persistence in the environment. Their different chemical structures make for diverse chemical properties and unique chemical names such as PFOS and PFOA. proposed drinking water standards for specific PFAS. PFAS Have Unique Chemical Properties

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

Figure 1 - Chemical Structure of PFOS (Example Structure of a PFAS Chemical)

The carbon chain can be designated as “long-chain” or “short-chain” PFAS 4 . Long-chain PFAS are the PFAS most commonly found in the environment and are sometimes referred to as “legacy” PFAS, as they have been in use for their stable, water-repellent properties since the 1940s. While some U.S. manufacturers phased some of these legacy PFAS out of certain products and processes in the early 2000s, their persistence means that they continue to be present in the environment 5 . Long-chain PFAS include those that have a sulfonic acid functional group (made up of a sulfur atom, oxygen, and hydrogen atoms — SO 3 H) and contain six or more carbons, or those that have a carboxylic acid functional group (made up of carbon, oxygen, and hydrogen atoms — COOH) and contain eight or more carbons. Long-chain PFAS include PFOA and PFOS, which are the most commonly recognized PFAS. Short-chain PFAS that have been utilized as replacements to long-chain PFAS are also persistent, and some may bioaccumulate and induce adverse human health effects. These PFAS are mobile and are even more difficult to remove from water 6 . Short-chain PFAS are those with a sulfonic acid functional group and five or fewer carbons, or those with a carboxylic acid functional group and seven or fewer carbons. Short-chain PFAS are just as difficult to break down, are just as persistent in the environment, and are widely used in industries 6 . Another unique aspect to PFAS is the strength of carbon-fluorine bonds , which makes PFAS resistant to breakdown through conventional water treatment processes 3 . Due to their high thermal and chemical stability, PFAS are often referred to as “forever chemicals.” Lastly, functional groups also can increase or decrease the likelihood of a particular PFAS to persist and accumulate. Thousands of PFAS Have Been Produced The EPA estimates that thousands of PFAS have been developed and used in industrial and consumer applications since the 1940s, but only about 600 PFAS are currently approved for commercial use in the U.S. 7 . PFAS are used in applications such as firefighting foam, furniture chemical coatings, food product containers (e.g., pizza boxes, wrappers), and water-repellent materials used in clothing (e.g., raincoats). Despite numerous industry uses, detecting each PFAS in the environment may not be possible due to

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

analytical limitations, as the most commonly used EPA-approved laboratory method (537.1) can only measure 24 PFAS that may be on the global market, according to a recent inventory 4 . National Attention Given to PFOA and PFOS The National Health and Nutrition Examination Survey (NHANES), conducted by the Centers for Disease Control and Prevention (CDC), detected 4 PFAS (PFOA, PFOS, PFHxS, and PFNA) in greater than 98% of 2,000 blood samples collected in 2003 and 2004 8 . Due to their decades of widespread use, PFOA and PFOS are the PFAS most prevalent in the environment and in humans, so the health effects of these two PFAS are the most widely studied. They have been linked to adverse health effects, such as developmental issues in fetuses, testicular cancer, kidney cancer, liver effects, immune system effects, preeclampsia, and elevated blood pressure during pregnancy, thyroid impacts, ulcerative colitis, and high cholesterol. Historically, the primary applications of PFOA included protective coatings and the production of nonstick surfaces, and those of PFOS included firefighting foam and water-repellent or stain-resistant products 9,10 . Because of research that revealed harmful health effects, PFOS was phased out of production in the United States from 2000 to 2002, and eight major companies agreed to phase out the production and use of PFOA and some PFOA-related chemicals in 2006 as part of the EPA’s PFOA Stewardship Program 11 . However, PFOA, PFOS, and other legacy PFAS may still be manufactured in other countries and may be present in materials imported into the U.S. 12 . Alternative PFAS developed as replacements, including several short- chain PFAS, are still in production today and may pose problems 13 . PFAS Toxicology: PFAS Can Lead to Health Implications Research has shown that some PFAS, such as PFOA and PFOS, can have adverse health effects at trace levels (ng/L or ppt) . While research into the potential health implications of these PFAS indicates reason for concern, there are still toxicological unknowns. Very little is known about a majority of PFAS, including half- life, toxicity, and bioaccumulation data. The Interstate Technical and Regulatory Council (ITRC) frequently updates its toxicological database as new health-related data become available 14 . Table 1 presents current knowns and unknowns related to PFAS impacts on human health 14–18 .

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

Table 1 - Known and Unknown PFAS Human Health Implications

KNOWNS

UNKNOWNS

• Most people in the U.S. have been exposed to PFAS and as of 2004, 98% of Americans had PFAS in their blood 8 . • Exposure to certain PFAS may lead to liver damage, thyroid issues, testicular and kidney cancer, immune deficiencies, developmental effects, reproductive issues, and cardiovascular effects. • Long-chain PFAS have longer half-lives in humans (> 1 year) than short-chain PFAS (days to months), meaning long-chain PFAS take longer to exit the body after consumption.

• There is minimal information about a majority of individual PFAS, including half-life, toxicity, and bioaccumulation data. • Short-chain vs. long-chain PFAS toxicity is still under investigation and largely uncertain 6 . • Carcinogenicity studies are only available for four PFAS (PFOS, PFOA, PFHxS, and GenX). • Comprehensive epidemiological studies of communities with a known PFAS source, with the exception of PFOA, are generally lacking. Some small sample size studies have investigated community effects, such as the C8 Science Panel and Faroe Islands Exposure Study 17,19 . • Toxicological data for PFAS mixtures are unavailable but currently under investigation and noted by several as an important data gap for future research 20,21 . • Biomonitoring data are somewhat limited for a majority of PFAS.

PFAS in the Environment PFAS are used in consumer products, industrial applications, and firefighting foam . PFAS have been found in everyday items such as nonstick cookware, stain-resistant upholstered furniture, waterproof clothing, pizza boxes, dental floss, fast food wrappers, microwave popcorn bags, waxes, and paints. Industrial applications of PFAS include uses such as chrome plating, electronics manufacturing, and oil and mining operations. PFAS-based firefighting foams, known as Class B aqueous film-forming foams (AFFF), are designed to extinguish high-risk fires involving flammable liquids (e.g., gasoline, alcohol). The Department of Defense (DoD) and the Federal Aviation Administration (FAA) currently require use of AFFF at military airfields and many civilian airfields, but this is being phased out in the next several years (by 2023) following congressional action 22 . The DoD is currently researching effective alternative foams. PFAS Can Enter the Environment from Several Sources There are multiple ways for PFAS to enter the environment, which can be classified as primary and secondary sources. Primary sources produce PFAS contamination, whereas secondary sources convey contamination produced by primary sources. Figure 2 presents examples of primary and secondary sources of PFAS that contribute to accumulation in the environment and, specifically, drinking water. Due to their strong carbon-fluorine bonds, PFAS do not significantly biodegrade, which makes them persistent in the environment and enables them to impact groundwater, surface water, and ecosystems.

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

Figure 2 – Examples of Primary and Secondary Sources of PFAS in the Environment

AFFF is used to extinguish flammable liquid fires. The largest stocks of AFFF are stored at commercial and private airports, military sites, chemical plants, and aboveground petroleum storage tank facilities. Many fire departments still use AFFF for training and emergency response. When AFFF is used, runoff may enter sewer or stormwater systems. Industrial facilities and incineration facilities can release PFAS into the environment through liquid discharge, solid waste, disposal of contaminants in soil, and/or air emissions . Industrial facilities in the U.S. have largely phased out PFOS and PFOA but continue to use short-chain PFAS in some applications. Incineration is one of the main methods used to destroy PFAS. Incineration facilities may discharge PFAS into the air during the incineration of materials if they are not heated to the correct destruction temperature. These materials include media and resin used during the treatment of PFAS in drinking water facilities 23,24 . PFAS-containing air emissions may deposit PFAS back into the environment through settling and precipitation. Research is ongoing to characterize PFAS behavior in air emissions and determine the conditions required for the destruction of PFAS during high-temperature incineration. Additional research is needed to establish standard methods for PFAS testing in air and enhance our understanding of PFAS emissions and control options. Wastewater treatment plant effluent and biosolids can contain PFAS. Because PFAS are used in many consumer products, they can be present in the wastewater conveyed by sewer systems to municipal wastewater treatment plants (WWTPs). Additional PFAS sources in WWTPs include AFFF runoff and PFAS- contaminated industrial waste 25 . WWTPs are not equipped to remove significant levels of PFAS, which then may be present in treated wastewater that is discharged into surface waters or in the sewage sludge produced during the wastewater treatment process. This sludge is either disposed of or further treated to form biosolids, which can be applied to agricultural land as fertilizer. Landfills receive a wide range of products containing PFAS, such as non-stick cookware, fast food wrappers, furniture, and water-resistant clothing. As rainwater filters down through landfills, it accumulates PFAS and

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

other chemicals from decomposing products. This water, along with liquid from products’ natural decomposition, is known as landfill leachate . Leachate containing PFAS can enter the environment through leaks in landfill liners. Additionally, landfill leachate is sometimes conveyed to WWTPs that ultimately discharge treated wastewater to surface waters. Like WWTPs, landfills do not produce PFAS but may serve as conduits for PFAS into water sources. The inability of PFAS to biodegrade makes them highly persistent in the environment, and some of the more mobile PFAS can travel through air and water to impact both groundwater and surface waters. Figure 3 shows examples of how PFAS can travel through the environment from sources to water bodies. Figure 3 - PFAS Mobility in the Water Cycle

PFAS Exposure Pathways Concern over PFAS contamination of drinking water supplies has grown over the last decade as health studies have linked exposure to particular PFAS with harmful health effects 14–18 . To estimate public health exposure and risk, the EPA uses an assumption that 20 percent of PFOS and PFOA human exposure comes from drinking water, while the remaining 80 percent comes from alternative

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

pathways. However, exposure through drinking water may be higher in areas where PFAS are detected in source waters. People can be exposed to PFAS through the following exposure pathways: • Drinking water – Private wells, municipal water supplies, bottled water. • Consumer products – Food packaging, stain- and water-resistant clothing, carpets, and furniture. • Food consumption – Food enclosed with packaging containing PFAS, possibly in food grown where biosolids are applied or from animals exposed to PFAS. • Air emissions – Areas where air emissions or dust containing PFAS are present. • Occupational exposure – People working manufacturing jobs where PFAS are used or produced, firefighters, landfill operators, and PFAS-containing biosolids applicators. PFAS in Drinking Water Are Largely Unregulated in the United States There is currently no enforceable federal standard for PFAS in drinking water. The EPA is developing a regulatory determination for PFOS and PFOA in drinking water. The EPA considers several criteria during the regulatory determination process under the Safe Drinking Water Act (SDWA), including adverse health effects, occurrence, detection frequency, and treatability 26 . Research related to each of these criteria is ongoing. Therefore, it could be months or years before a federal regulatory determination is complete. Several states have set maximum contaminant levels (MCLs) for drinking water, for as many as six PFAS compounds, and others are in the process. The regulatory process discussed below applies to the drinking water sector. EPA Required Public Water Systems to Gather Data on PFAS Published by the EPA every five years, the Unregulated Contaminant Monitoring Rule (UCMR) requires certain public drinking water systems, primarily those that serve more than 10,000 individuals, to sample the water they distribute for up to 30 contaminants that are not federally regulated. UCMR contaminants are generally considered to be emerging contaminants, such as PFAS. Key provisions of the UCMR, including contaminants sampled and results, can be found on the EPA’s website 27 . UCMR 3 was conducted from 2013 to 2015 and included sampling for six PFAS — PFOS, PFOA, PFBS, PFHxS, PFHpA, and PFNA. PFOS and PFOA were detected in 1.9% and 2.4% of public water systems, respectively. However, select water systems were tested and only these six PFAS were measured. Reporting limits during testing were relatively high (10 to 90 ng/L) compared to current analytical capabilities; therefore, PFAS reported as “not detected” could still be present but at levels below the historical reporting limits. UCMR 4, conducted from 2018-2020, did not include any PFAS. UCMR 5, to be conducted from 2022 to 2026, will include additional PFAS. The list is still being finalized, but the current plan is for 29 of the 30 contaminants in UCMR 5 to be PFAS. UCMR 5 will also include additional water systems that were not included in UCMR 3. It is expected to provide information related to additional PFAS occurrence and exposure.

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

The EPA Developed Lifetime Health Advisory Levels for PFOS and PFOA Following UCMR 3, the EPA established non-enforceable lifetime health advisory levels for PFOS and PFOA in 2016. The lifetime health advisory level for PFOS and PFOA is 70 ng/L (or 70 ppt) based on the estimated exposure for the most at-risk population — pregnant and nursing women. The lifetime health advisory assumes a drinking water consumption of 0.054 liters per kilogram of body weight per day and that drinking water consumption makes up 20% of a human’s PFOS and PFOA exposure. However, exposure can be higher in areas with PFOS and PFOA present in drinking water supplies. Additional details regarding these assumptions are provided in EPA’s Drinking Water Health Advisories for PFOA and PFOS webpage 28 . The EPA Is Taking Steps Toward Establishing a Drinking Water Standard for PFAS The EPA developed a PFAS Action Plan in 2019 to advance its support for cleanup efforts, toxicology, monitoring in drinking water, emerging research, cleanup enforcement, and risk communication 29 . One of the major provisions of the Action Plan was to decide, by the end of 2019, whether to regulate PFOS and PFOA under the SDWA 30 . In February 2020, the EPA made a preliminary determination to regulate PFOS and PFOA. After review of the public comments received on this determination, the EPA must issue a final determination. If the EPA chooses to proceed with the regulatory process laid out in the SDWA, it will have up to 4.25 years to establish MCLs. As part of the PFAS Action Plan, EPA also will consider whether there is a need to regulate PFAS beyond PFOS and PFOA. Regulating PFAS by Chemical Characteristics Some experts and environmental advocates suggest regulating PFAS as a class rather than each chemical individually (i.e., establishing a single drinking water standard for the entire PFAS family). Other potential regulatory strategies include regulating groups of PFAS, also referred to as subclasses, that have similar chemical properties (e.g., perfluorinated carbon chain length, functional groups, degradation products), common adverse health effects, co-occurrence with other PFAS, or a combination of these characteristics. States Are Developing PFAS Guidance In the absence of enforceable federal regulations, several states have set MCLS for drinking water, and other states are in the process of doing so 31 . Federal and state PFAS health advisory levels, MCLs (established and proposed), guidance levels, and action levels differ due to the various toxicological endpoints and assumptions used in referenced studies. The EPA and states use toxicological evaluations (both federal- and state-conducted studies) to determine PFAS toxicity. For example, the EPA used a developmental endpoint for PFOA and PFOS exposure, whereas some states use a liver or an immune endpoint 32 . Additionally, some states have set levels for additional PFAS (besides PFOA and PFOS) that were determined to have adverse health effects or be more heavily present in drinking water supplies. For a complete list of state and federal PFAS guidance, please visit the ITRC and American Water Works Association (AWWA) PFAS regulation summaries 33,34 .

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

Overview of Current PFAS Research Extensive research is being conducted by scientists in universities, government agencies, and the private sector to better understand PFAS occurrence, transport, detection, toxicity, exposure, and treatability. These agencies include DoD, the National Institute of Environmental Health Sciences (NIEHS) through the National Institutes of Health (NIH), EPA, and others 26,35,36 . To fulfill the goals laid out in its PFAS Action Plan, the EPA is continuing to conduct research related to PFAS detection in water, wastewater, landfill leachate, air emissions, soils, and other matrices. In September 2019, the CDC and the Agency for Toxic Substances and Disease Registry (ATSDR) announced the start of a study to investigate the health effects from PFAS-contaminated drinking water, which is the first study to look at health effects from PFAS at multiple sites across the U.S. 37 Additionally, several other programs are underway. For example, the Sources, Transport, Exposure and Effects of PFASs (STEEP) Superfund Research Program, headed by the University of Rhode Island, is directly addressing the human exposure pathways by fingerprinting drinking water and fish 38 . Key Takeaways After decades of use in everything from clothing to firefighting foam, PFAS are ubiquitous in the environment. As concern over PFAS contamination of drinking water grows, not enough is known about the adverse health impacts of most PFAS. Research continues to reveal more about PFAS toxicity and fate in the environment. • PFAS enter the environment from numerous sources and have been detected in drinking water sources throughout the U.S. • PFAS are difficult to remove from drinking water sources because of their unique chemical properties, particularly their persistence in the environment, mobility in water systems, and potential for bioaccumulation. • PFAS have been detected in treated drinking water at ng/L (ppt) levels. • PFOA and PFOS are known to cause adverse health impacts at these low levels, and research related to health impacts of an increased number of PFAS is ongoing. • Federal regulations for PFAS in drinking water do not currently exist, but the EPA is in the process of deciding whether to establish enforceable standards (i.e., MCLs) for PFOS and PFOA levels in public drinking water. • Some states have set advisory guidelines or MCLs for various PFAS or groups of PFAS in public drinking water. • Research related to PFAS contamination is ongoing and has significantly advanced our understanding of PFAS health impacts and best practices for the prevention of future PFAS contamination, mitigation of existing contamination, and treatment of PFAS in drinking water. However, many unknowns remain, and extensive research is underway to address these unknowns.

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

References 1.

Buck RC, Franklin J, Berger U, et al. Perfluoroalkyl and Polyfluoroalkyl Substances in the Environment: Terminology, Classification, and Origins. Integr Environ Assess Manag . 2011;7(4):513-541. doi:10.1002/ieam.258 2. ATSDR. PFAS in the US population. Published June 24, 2020. Accessed October 6, 2020. https://www.atsdr.cdc.gov/pfas/health- effects/us-population.html 3. ITRC. Physical and Chemical Properties of PFAS. Published 2020. https://pfas-1.itrcweb.org/4-physical-and-chemical-properties/ 4. ITRC. PFAS - Per- and Polyfluoroalkyl Substances. PFAS Chemistry and Naming Conventions, History and Use of PFAS, and Sources of PFAS Releases to the Environment. Published April 14, 2020. Accessed June 15, 2020. https://pfas-1.itrcweb.org/2-pfas-chemistry-and- naming-conventions-history-and-use-of-pfas-and-sources-of-pfas-releases-to-the-environment-overview/ 5. AWWA. Per- and Polyfluoroalkyl Substance (PFAS) Overview and Prevalence. Published August 2019. https://www.awwa.org/Portals/0/AWWA/ETS/Resources/Per-andPolyfluoroalkylSubstances(PFAS)- OverviewandPrevalence.pdf?ver=2019-08-14-090234-873 6. Brendel S, Fetter É, Staude C, Vierke L, Biegel-Engler A. Short-chain perfluoroalkyl acids: environmental concerns and a regulatory strategy under REACH. Environ Sci Eur . 2018;30(1). doi:10.1186/s12302-018-0134-4 7. Humphreys EH, Tiemann M. PFAS and Drinking Water: Selected EPA and Congressional Actions. Congressional Research Service . Published online August 20, 2019:23. 8. Calafat AM, Wong L-Y, Kuklenyik Z, Reidy JA, Needham LL. Polyfluoroalkyl chemicals in the US population: data from the National Health and Nutrition Examination Survey (NHANES) 2003–2004 and comparisons with NHANES 1999–2000. Environmental health perspectives . 2007;115(11):1596-1602. 9. NIH. Perfluorooctanesulfonic acid. Published 2020. Accessed August 6, 2020. https://pubchem.ncbi.nlm.nih.gov/compound/74483 10. Alaska Division of Environmental Conservation. Per- and Polyfluoroalkyl Substances (PFAS). Published 2020. Accessed October 12, 2020. https://dec.alaska.gov/spar/csp/pfas/ 11. US EPA. Risk Management for Per- and Polyfluoroalkyl Substances (PFAS) under TSCA. US EPA. Published May 12, 2015. Accessed August 6, 2020. https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-and-polyfluoroalkyl- substances-pfas 12. US EPA. Basic Information on PFAS. US EPA. Published March 30, 2016. Accessed October 12, 2020. https://www.epa.gov/pfas/basic- information-pfas 13. ITRC. PFAS Reductions and Alternative PFAS Formulations – PFAS — Per- and Polyfluoroalkyl Substances. Published 2020. Accessed August 13, 2020. https://pfas-1.itrcweb.org/2-4-pfas-reductions-and-alternative-pfas-formulations/ 14. ITRC. PFAS - Per- and Polyfluoroalkyl Substances. Human and Ecological Health Effects of select PFAS. Published April 14, 2020. Accessed June 15, 2020. https://pfas-1.itrcweb.org/7-human-and-ecological-health-effects-of-select-pfas/ 15. Winquist A, Steenland K. Perfluorooctanoic acid exposure and thyroid disease in community and work cohorts. Epidemiology . 2014;25(2):255-264. 16. Savitz DA, Stein CR, Bartell SM, et al. Perfluorooctanoic acid exposure and pregnancy outcome in a highly exposed community. Epidemiology . 2012;23(3):386-392. 17. C8 Science Panel. The Science Panel Website. Published January 22, 2020. Accessed June 24, 2020. http://www.c8sciencepanel.org/ 18. Frisbee SJ, Brooks, Jr. AP, Maher A, et al. The C8 Health Project: Design, Methods, and Participants. Environ Health Perspect . 2009;117(12):1873-1882. 19. Grandjean P, Heilmann C, Weihe P, et al. Estimated Exposures to Perfluorinated Compounds in Infancy Predict Attenuated Vaccine Antibody Concentrations at Age 5-Years. J Immunotoxicol . 2017;14(1):188-195. doi:10.1080/1547691X.2017.1360968 20. ATSDR. Potential health effects of PFAS chemicals. Published June 24, 2020. Accessed October 12, 2020. https://www.atsdr.cdc.gov/pfas/health-effects/index.html 21. Goodrum PE, Anderson JK, Luz AL, Ansell GK. Application of a Framework for Grouping and Mixtures Toxicity Assessment of PFAS: A Closer Examination of Dose Additivity Approaches. Toxicol Sci . Published online 2020. doi:10.1093/toxsci/kfaa123 22. ITRC. Firefighting Foams – PFAS — Per- and Polyfluoroalkyl Substances. Published 2020. Accessed August 13, 2020. https://pfas- 1.itrcweb.org/3-firefighting-foams/#3_8 23. Ryan J. EPA PFAS Air Emission Measurements: Activities and Research. Presented at the: EPA Region 9 Laboratory Technical Information Group Meeting; June 4, 2019; San Francisco, CA. Accessed June 24, 2020. https://cfpub.epa.gov/si/si_public_record_report.cfm?Lab=NRMRL&dirEntryId=345762 24. American Chemical Society. Winds spread PFAS pollution far from a manufacturing facility. Published May 27, 2020. Accessed June 24, 2020. https://www.acs.org/content/acs/en/pressroom/newsreleases/2020/may/winds-spread-pfas-pollution-far-from-a- manufacturing-facility.html 25. Michigan Department of Environment, Great Lakes, and Energy. PFAS Response - Wastewater Treatment Plants / Industrial Pretreatment Program. Accessed October 12, 2020. https://www.michigan.gov/pfasresponse/0,9038,7-365-88059_91299---,00.html 26. EPA. How EPA Regulates Drinking Water Contaminants. Published January 27, 2020. Accessed June 16, 2020. https://www.epa.gov/sdwa/how-epa-regulates-drinking-water-contaminants 27. EPA. Monitoring Unregulated Drinking Water Contaminants. Third Unregulated Contaminant Monitoring Rule. Published December 9, 2016. Accessed June 15, 2020. https://www.epa.gov/dwucmr/third-unregulated-contaminant-monitoring-rule 28. EPA. Ground Water and Drinking Water. Drinking Water Health Advisories for PFOA and PFOS. Published February 13, 2019. Accessed June 15, 2020. https://www.epa.gov/ground-water-and-drinking-water/drinking-water-health-advisories-pfoa-and-pfos

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Scientific Overview of PFAS and Drinking Water | AAAS EPI Center

29. EPA. PFOA, PFOS and Other PFASs. EPA’s PFAS Action Plan. Published February 28, 2020. Accessed June 15, 2020. https://www.epa.gov/pfas/epas-pfas-action-plan 30. EPA. Contaminant Candidate List (CCL) and Regulatory Determination. Regulatory Determination 4. Published June 15, 2020. Accessed June 15, 2020. https://www.epa.gov/ccl/regulatory-determination-4 31. ITRC. PFAS Water and Soil Values Table Excel file. Published 2020. Accessed January 14, 2020. https://pfas-1.itrcweb.org/wp- content/uploads/2020/10/ITRCPFASWaterandSoilValuesTables_SEP_2020-FINAL.xlsx 32. Barlow CA, Boyd CA, Kemp MJ, Parr KAH. PFAS Toxicology – What is Driving the Variation in Drinking Water Standards. Published online June 2019:18. 33. ITRC. PFAS - Per- and Polyfluoroalkyl Substances. Basis of Regulations. Published September 30, 2019. Accessed June 16, 2020. https://pfas-1.itrcweb.org/8-basis-of-regulations/ 34. AWWA. Per- and Polyfluoroalkyl Substances (PFAS) Summary of State Policies to Protect Drinking Water. Published May 2020. https://www.awwa.org/LinkClick.aspx?fileticket=nCRhtmGcA3k%3d&portalid=0 35. DOD. PFAS: A National Issue That Needs a National Solution. Published 2020. Accessed July 10, 2020. https://www.defense.gov/Explore/Spotlight/pfas/ 36. NIH. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). National Institute of Environmental Health Sciences. Published 2020. Accessed October 12, 2020. https://www.niehs.nih.gov/health/topics/agents/pfc/index.cfm 37. Centers for Disease Control and Prevention. CDC and ATSDR Award $7 Million to Begin Multi-State PFAS Study. Published September 23, 2019. Accessed June 16, 2020. https://www.cdc.gov/media/releases/2019/p0923-cdc-atsdr-award-pfas-study.html 38. STEEP. About PFASs. Published 2020. Accessed October 12, 2020. https://web.uri.edu/steep/pfas/

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Addressing Per- and Polyfluoroalkyl Substances (PFAS) in Drinking Water

PFAS Monitoring and Occurence in Drinking Water

Monitoring and Occurrence of PFAS in Drinking Water | AAAS EPI Center

PFAS Contamination of Drinking Water Several of the most-researched per- and polyfluoroalkyl substances (PFAS) have been linked to human health issues at small doses and detected in drinking water and drinking water sources throughout the United States. A class of thousands of synthetic organic chemicals, PFAS are found in a variety of industrial and consumer applications from clothing and food wrappers to firefighting foam and after decades of use, PFAS contamination is widespread 1 . The chemical properties of PFAS, particularly the strength of the carbon-fluorine bonds, make them difficult to treat and remove using conventional water treatment processes. This guide describes how communities can evaluate the risk of PFAS contamination by leveraging existing data and conducting sampling of water and other environmental matrices (e.g., soil) to identify potential PFAS sources that may need remediation. For more information on the basics of PFAS chemical properties, toxicity, and more, please see the AAAS EPI Center’s PFAS and Drinking Water: A Scientific Overview. Evaluating PFAS occurrence in drinking water requires a robust monitoring plan. A PFAS monitoring plan should consider sampling locations, frequencies, cost, and other water quality parameters. Potential sampling locations include drinking water distribution systems, drinking water treatment plants (referred to as WTPs), and WTP source waters. PFAS monitoring can occur over a period of months to years, depending on location, number of contamination sources, and watershed characteristics. PFAS analysis can be costly since limited analytical techniques are available to measure PFAS levels in water and because the cost for analysis can range from $200 to $350 per water sample. Monitoring additional water quality parameters is also important since these can help identify contamination sources and influence the efficacy of different treatment approaches. PFAS Contamination Calls for a “One Water” Approach While the focus of this guide is to examine the impacts of PFAS on drinking water, the persistent nature of PFAS make them ubiquitous in the water cycle. For that reason, addressing PFAS contamination requires a holistic approach that considers more than just drinking water alone. The One Water concept is a holistic approach to more effectively manage drinking water, wastewater, stormwater, surface water, and groundwater together. PFAS epitomize “One Water” contaminants; they are present in all parts of the water cycle and will concentrate over time. Evaluating PFAS from a One Water perspective allows scientists and engineers to understand PFAS migration from a source into the environment and determine the best management point . WTPs typically utilize groundwater or surface water as raw water sources for treatment. After the drinking water is used by the community, it is conveyed to municipal wastewater treatment plants (WWTPs) through sewer systems. Once treated through the WWTP, the water is discharged into surface waters, which may serve as drinking water supplies for downstream communities after some time in the environment. The One Water concept is illustrated as a simplified schematic shown in Figure 1 .

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