Department of Energy releases initial report on PFAS at DOE sites

The Periodic | By WALKER LIVINGSTON, ESQ

Nov. 30, 2022

The Department of Energy (DOE) published a new report on per- and polyfluoroalkyl substances (PFAS) at DOE sites around the country. The report details the sites and concentrations where PFAS was discovered as well as what the DOE expects regarding PFAS over the next several years based on its PFAS Strategic Roadmap.

Regulatory background

  • Per- and polyfluoroalkyl substances (PFAS) are a large class of chemicals with a wide array of uses in industry. EPA has not finalized an overarching definition for PFAS, but many organizations define PFAS as any substance that contains at least one fully fluorinated carbon atom. PFAS are incredibly stable substances, which aids their use in firefighting foams and stain-resistant textiles, but this stability also means that PFAS persist in the environment and do not readily break down. This has led to PFAS often being called “forever chemicals” due to their extended half-life.
  • PFAS are water-soluble, which means that the chemicals can easily migrate long distances in groundwater or surface water. PFAS are also persistent in the environment and do not break down readily as the carbon-fluorine bonds that hold the molecules together are extremely strong.
  • PFAS contamination originates from industrial facilities where PFAS are manufactured or used, as well as from military bases, commercial airports, and petroleum refineries that use aqueous film-forming foams (AFFFs) containing PFAS. In addition, the disposal of all the consumer goods coated with PFAS end up in landfills which can leach PFAS into the groundwater and soil.
  • In 2016, the EPA designated PFAS as emerging contaminants and set a drinking water health advisory for perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) at 70 parts per trillion (ppt), combined. In 2022, the EPA updated these health advisories for PFOA and PFOS to 0.004 ppt and 0.02 ppt, respectively.
  • In 2021, the EPA created the Council on PFAS to develop a PFAS strategy for reducing use and remediation of PFAS contamination. The EPA Council on PFAS later published the PFAS Strategic Roadmap for 2021 to 2024, which outlines the Agency’s plans for PFAS over the next several years.
  • In 2019, the DOE established an internal PFAS Working Group to act as an information exchange and communication medium between DOE subgroups. The DOE’s National Laboratories (such as FermiLab and Brookhaven National Laboratory) have assisted the DOE with new research on PFAS identification, quantification, treatment, remediation, and destruction. This led to the PFAS Strategic Roadmap for 2022-2025 issued by DOE in August 2022, which outlines the Department’s plans for PFAS in the future.

Department of Energy report

  • The DOE solicited information from DOE-controlled sites across the country for a survey of PFAS materials and contamination at each site. The DOE collected information from 53 total DOE sites, including sites under the National Nuclear Security Administration (NNSA), Naval Reactors Program (NR), Office of Science (SC), and more.
  • The survey sampled PFAS in drinking, surface, and ground water, and identified facilities at the sites that hold or had held PFAS-containing materials, which were analyzed and summarized in the DOE’s report.
  • Drinking water proved to be one of the most studied areas of the report, but also one of the areas where the lowest concentrations of PFAS were found. For the nine sites that had on-site water facilities, only Brookhaven National Laboratory in New York and Idaho National Laboratory detected PFAS in on-site drinking water.
  • Eight other sites conducted onsite sampling for PFAS further than drinking water, with each site detecting PFAS in one form or another. Several of these sites are located in the Oak Ridge Reservation in Tennessee . Many of these detections were due to the presence of AFFFs in fire suppression devices or systems at the sites, which normally contain PFAS.
  • Four sites actively monitor PFAS concentrations at locations throughout the sites: Brookhaven, Los Alamos National Laboratory, Rocky Flats, and Savannah River Site. Brookhaven represents one of the most studied sites, consisting of 360 groundwater monitoring wells, 170 temporary wells, 11 groundwater treatment systems, and Brookhaven’s wastewater treatment plant. Brookhaven is also the only site where PFAS concentrations have been detected beyond the DOE site boundaries.

Implications of the report

  • Based on the rise in interest in regulating and remediating PFAS across the United States, many of the sites surveyed have been contacted by regulators or stakeholders regarding PFAS contamination at the sites. Based on the DOE PFAS Strategic Roadmap, the Department plans to better inventory current and historic PFAS use at DOE sites across the country. The Department still expects to complete the actions in the Roadmap by 2025 and will release a progress report on the actions that year.
  • Although there may not be specific regulations directly promulgated because of this report, the consistent emphasis on PFAS contamination and remediation by the federal government (not just the DOE or the EPA) means that additional regulation and remediation practices are likely going to be a continued focus for years to come.

Contains previous research by Walker Livingston.

To contact the author of this analysis, please email Walker Livingston ( [email protected])
To contact the editor of this analysis, please email Patricia Iscaro ( [email protected])

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