The U.S. Environmental Protection Agency (EPA) considers chemicals and contaminants of emerging concern (CCECs), or “emerging contaminants,” to be chemicals or substances that are not currently regulated, have been detected in the environment, and may pose a real or potential risk to human or ecological health. New chemicals and chemicals previously thought to be benign are identified as CCECs as toxicological science and detection capabilities continue to evolve. For more than 10 years, EA has provided the Department of Defense, industry, state agencies, and municipalities with innovative solutions to the challenges associated with CCECs. Our CCEC subject matter expert group of scientists, toxicologists, regulatory experts, and engineers are at the forefront of CCECs (including per- and polyfluoroalkyl substances [PFAS]) research related to environmental behavior, toxicity, and effective methods to isolate and treat CCECs that pose risks.
Contact Paul Caprio, P.G., Vice President, Director of Chemicals and Contaminants of Emerging Concern.
Understanding how much and what kind of PFAS in your system or site is a vital first step in addressing PFAS impacts. EA has performed PFAS sampling and/or characterization support at 150+ sites across the United States. These sites include sampling construction-generated waste; performing site inspections; performing remedial investigations; and sampling and/or monitoring wastewater treatment plants, drinking water treatment systems, and residential drinking water wells. We have developed training programs for EA’s field staff to take additional PFAS sampling precautions required to avoid cross-contamination and to train wastewater treatment plant and drinking water plant operators to collect PFAS samples at their own facilities. Our chemists and scientists are experts in analyzing and interpreting PFAS data using several analytical methods including EPA Methods 533 and 537 for drinking water, modified EPA Method 537 and EPA Draft Method 1633 for non-drinking water media, and Other Test Method-45 for PFAS in air.
EA also offers value-added advanced sampling and characterization tools such as:
Due to the prevalence of PFAS in drinking water and the low drinking water health advisories, EPA released in June 2022, many state, local, and federal government agencies have prioritized treating PFAS in drinking water. EA has designed, oversaw installation, and provided operation and maintenance services for granular activated carbon and ion exchange systems, two of the most prevalent and economical treatment technologies, ranging from point-of-use and whole-house drinking water treatment systems to municipal drinking water systems capable of pumping and treating flow rates between 800 and 1,200 gallons per minute. EA has also evaluated other technologies such as reverse osmosis as part of the design process to provide our clients with the best and most affordable solutions to meet their specific needs.
Another priority for many clients is treating ongoing sources of PFAS into the environment such as releases of PFAS-impacted stormwater and wastewater. Given the complexity of these media, additional steps may be required to remove PFAS prior to discharge. Additionally, given the uncertainty of upcoming PFAS regulations and how they may affect methods for disposal of investigation-derived waste (IDW), many clients have been stockpiling their IDW until further guidance is released. However, stockpiling IDW comes with its own drawbacks, such as regulatory or public pressure to remove the waste, lack of space, and the potential for accidental releases from storage areas. Treating IDW for beneficial re-use could provide clients with a more cost-effective method for handling IDW. EA can support treatment of these complex matrices with our dedicated treatability studies laboratory, EnviTreat, which has the capability to perform treatability studies and design/build custom bench-scale and pilot-scale units to optimize treatment processes for PFAS and other contaminants in wastewater and drinking water.
With a portfolio of PFAS projects in 46 states, including projects with portfolios of multi-state sites, EA is constantly monitoring federal and state PFAS regulations to ensure our clients meet regulations. We support client communications with regulators at every step of a project to get buy-in along the way to prevent unnecessary schedule delays. For example, we have supported clients in interfacing with regulators to obtain regulatory approval of work plans and documents, including getting regulatory approval to fast-track work planning documents as needed to achieve our clients’ goals and project constraints (e.g., to take advantage of a short arctic field season or to meet construction design deadlines) and in negotiating development of appropriate screening levels when there are no state or federal regulations in place. Our staff also participate in the Interstate Technology and Regulatory Council’s PFAS work group and American Council of Engineering Companies Water Energy and Environment workgroup; therefore, EA knows well in advance of any pending state or federal level PFAS legislation, initiatives, or regulatory actions. We have also developed a timeline of the milestones listed in EPA’s PFAS Strategic Roadmap.
Our team is also keeping a close eye on impending regulations that will impact our clients’ permitting requirements, such as effluent discharge limits for PFAS under the NPDES program, maximum contaminant levels for drinking water systems, and designation of certain PFAS as hazardous substances. We are working to prepare our clients for these eventual additional compliance requirements, including developing a tool to help wastewater and drinking water system operators identify risks and response actions appropriate for their specific system. We can also work with clients to identify what upcoming regulatory actions will affect them, how and when they will be affected, the approximate cost impacts on their operations, and actions they can take to prepare and minimize regulatory impacts. This includes working with airports and government aviation authorities to review past use of firefighting PFAS containing aqueous film-forming foams, evaluate their potential liabilities, and help mitigate those liabilities. As more PFAS are added to the Toxic Release Inventory (TRI) list (180 PFAS in Reporting Year 2022, 189 in Reporting Year 2023), EA can also help clients stay on top of their TRI reporting requirements.
EPA’s December 2020 Interim Guidance on Destroying and Disposing of Certain PFAS and PFAS-Containing Materials That Are Not Consumer Products lists three readily available solutions to disposing of PFAS-impacted IDW, construction waste, and other waste streams: thermal treatment, deep well injection, and landfilling. Of these three technologies, only thermal treatment can destroy PFAS; however, there is still research that needs to be done to fill in data gaps that assure the technology is effective, cost efficient, safe, and complies with applicable regulations. EA has been supporting industry- and federal-funded research to fill these data gaps for thermal technologies, including thermal desorption and incineration.
Our experts are also active in the research community and stay appraised of other remediation and treatment technologies in development. We can apply this knowledge to assist clients make informed decisions on the best path forward for their specific remediation projects.
PFAS, having been featured in movies, documentaries, books, and news stories, is a high-visibility topic of concern for the public. Historical PFAS releases have resulted in PFAS impacts on drinking water and PFAS-related fish consumption advisories. Additionally, science about other methods of human and environmental exposure is still in development, and the United States has a patchwork of different regulations across the country. All of these factors have resulted in an uptick in PFAS-related public affairs activities for commercial and government entities. EA has supported clients to prepare educational materials for public use, participate in public meetings to provide technical expertise as necessary, and obtain right-of-entry approval for sampling and drinking water mitigation work for private properties. PFAS can be a sensitive topic for a community, and having experienced risk communication staff on a project will help get stakeholder buy-in to project plans and prevent unexpected schedule delays, particularly for projects involving off-site work.
EA’s risk assessors are at the cutting edge of PFAS toxicology research, and have been involved in leading Department of Defense-funded research and projects involving the ecotoxicity of PFAS and mixtures of PFAS on fish, avian, and reptile species and on evaluating exposures and risk associated with the consumption of PFAS-impacted fish tissue and groundwater. Our risk assessors have valuable experience supporting development of remedial investigation work plans that will provide the data needed to perform risk assessments that will meet regulatory requirements and experience evaluating the risk that PFAS-impacted soil, groundwater, sediment, and surface water has on human health and the environment. Additionally, our human health and ecological risk assessors are experienced in food-web modeling, chemical fingerprinting for source attribution, fate and transport analyses, risk-based threshold determination (including calculating the risk threshold for the PFNA, PFHxS, PFBS, and HFPO-DA as a mixture in accordance with the 2023 draft Maximum Contaminant Levels), cleanup goal assessment and development, and equilibrium model applications. EA also has a nationally certified Ecotoxicology laboratory that can perform toxicity testing of PFAS-impacted soil and sediment to support risk assessments and remediation efforts.
Although much of the focus on CCECs these days is around PFAS, EA is staying at the forefront of new CCECs and other CCECs currently being investigated, such as 1,4-dioxane, pharmaceutical wastes, and more. EA has experience working on 1,4-dioxane sites from investigation through remediation and long-term monitoring. Additionally, our nationally certified Ecotoxicology laboratory provides toxicity identification evaluations to forensically evaluate and “fingerprint” causative agents, including new CCECs, and product toxicity testing to develop toxicological information for product formulations that can be used for safety data sheets, hazard classifications, and chemical labeling. Our EnviTreat laboratory performs state-of-the-art bench-scale and custom pilot units (to simulate full-scale reactors) for industrial/municipal waste stream to optimize treatment processes to remove or transform a variety of contaminants of emerging concern, including 1,4-dioxane, PFAS, plastics, pharmaceutical wastes, pyrotechnical wastes, ethylenediaminetetraacetic acid [EDTA], and personal care product manufacturing waste. EA’s Contaminated Site Assessment and Remediation group integrates robust CSMs, innovative high-resolution site characterization (HRSC) methods, and pilot-scale/full-scale remediation technology implementation for recalcitrant and emerging contaminants.
Both our Engineering Services group and our EnviTreat laboratory were involved in understanding and solving the COVID-19 crisis. These projects included sampling wastewater for SARS-CoV-2, and working with pharmaceutical companies to determine the impact of SARS-CoV-2 vaccine wastewater on municipal treatment systems.