[CPEO-MEF] ASTSWMO PFAS Recommendations

[Lenny Siegel <LSiegel@cpeo.org>]

In August, the State Federal Coordination Focus Group of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) issued a 17-page report, "Lessons Learned Addressing Contaminants of Emerging Concern (CEC) at Federal Facility Cleanups.” See https://astswmo.org/files/Resources/CEC-SC/2024-08-CEC-Lessons-Learned-Paper.pdf. The document focuses on PFAS, today’s dominant class of emerging contaminants.

I am pasting the recommendations below.

Lenny

RECOMMENDATION: DEVELOP PROACTIVE FRAMEWORKS TO ADDRESS CONTAMINANTS OF EMERGING CONCERN BEFORE THE NEED ARISES

The evolving nature of CECs requires policy frameworks and structures that meet their changing challenges. States and Federal Agencies need organizational structures that can identify potential CECs early on and assist their organizations in developing and coordinating proactive steps to address them. DoD has established a structure for identifying and developing enterprise-wide recommendations for CECs. The Scan-Watch-Action process provides a formal structure by which DoD identifies compounds for further study based on DoD use, synthetizes the science, and makes formal recommendations through its Emerging Chemicals of Concern Governance Council. The program has allowed DoD to proactively examine and prioritize evaluations of lead, hexavalent chromium, and PFAS through the years, even if some problems remain.

Several States have developed similar programs, and in January 2023 ASTSWMO’s Contaminants of Emerging Concern Steering Committee issued recommendations for States seeking to establish their own CEC programs. The Steering Committee found 3 major recommendations for States seeking to develop such programs: leadership engagement, defining the scope of the program, and maintaining the ability to compile and assess information. Where practical, the State Federal Coordination Focus Group recommends States develop CEC frameworks in a manner consistent with the Steering Committee’s recommendations.

The SFC FG research did not find any specific or formally established EPA program tasked with compiling, evaluating, and coordinating CEC related topics akin to DoD’s ECGC. Instead, each office identified as having a role in identifying CECs appears to act independently unless otherwise directed. The SFC FG recommends EPA create a standing office tasked with coordinating the efforts of other programs and focused on agency-wide considerations. In the past this created some confusion about which approach or values to use when addressing CECs (e.g., health advisory numbers vs RSLs, etc.). The SFC FG commends the work EPA has done creating and implementing its PFAS Roadmap, however actions to address future CECs could be implemented more quickly if there is a defined organizational and policy framework in place at the time of their discovery.

RECOMMENDATION: MAINTAIN TRANSPARENCY AND COMMUNITY ENGAGEMENT FOR PROPER RISK COMMUNICATION

Community engagement is an important component of Federal Facility cleanups, and even more critical when CECs have the potential to impact the surrounding communities. Without proper engagement, concerned community members will seek other sources of information that may not have the most up-to-date information regarding CECs. The proper use of community engagement best practices can mitigate this phenomenon, enhance cooperation from communities during investigations and remedial actions, and increase the chances of community acceptance of remedial actions.

RECOMMENDATION: STAKEHOLDERS SHOULD NOT ASSUME CONTAMINANTS OF EMERGING CONCERN BEHAVE THE SAME AS OTHER CONTAMINANTS

The unique properties of CECs present challenges to traditional understandings of contaminant fate and transport since organo-pesticides and PCBs were identified as the first known persistent organic pollutants that could move through the food chain. As time goes on, newly identified pathways or exposure routes can drive risks to communities and the environment that were unaccounted for. Through fish consumption of PCBs, vapor intrusion from organic solvents, or prenatal exposures to TCE, the scientific community regularly finds gaps in our knowledge and understanding of how some contaminants move through the environment and impact communities and the environment. One challenge to addressing PFAS is its unique properties which allows it to move through the environment more quickly than other compounds and to bioaccumulate through a different mechanism than traditional persistent organic pollutants. This means that many existing models for the prediction of groundwater flows and bioaccumulation are not applicable to these compounds. When dealing with CECs, State regulators should push their Federal partners to fully characterize releases of CECs, and not use short cuts based on assumptions from the behavior of other compounds.

—

Lenny Siegel
Executive Director
Center for Public Environmental Oversight
A project of the Pacific Studies Center
LSiegel@cpeo.org
P.O. Box 998, Mountain View, CA 94042
Voice/Fax: 650-961-8918
http://www.cpeo.org
Author: DISTURBING THE WAR: The Inside Story of the Movement to Get Stanford University out of Southeast Asia - 1965–1975 (See http://a3mreunion.org)

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