March 2025

AFFF Cleanout: Reduce Your Risk
The U.S. Department of Defense (DOD) and the Federal Aviation Administration (FAA) are transitioning away from aqueous film-forming foams (AFFF) that have high concentrations of PFAS in favor of fluorine-free firefighting (F3) foams. Despite the increasing availability of the new F3 foams on DOD’s Qualified Product List (QPL), the transition may not be as easy as it sounds.

“Transitioning to F3 foam is far more complicated that just cleaning fire trucks,” says Jill Greene, AFFF Decontamination Lead at CDM Smith.

If sufficient decontamination is not performed, residual PFAS stuck to surfaces as supramolecular assemblies will contaminate the F3 foam. PFAS structures disassociate over time, becoming a secondary source of PFAS in F3 or rinse solutions. This is known as the “ rebound effect.”
Innovator Spotlight
 
 
How do facilities transition from AFFFs?
Jill Greene is an environmental expert who has focused her work on hydrogeologic, stormwater and hazardous waste investigations over the past 20 years. Watch this important conversation, as Jill reveals key insights on the challenge to transition from AFFF use and the team you'll need to do it.
 
 
Top Stories in PFAS
Consistent with previous updates on State-based permitting initiatives to include PFAS within NPDES permits, the San Francisco Regional Water Quality Control Board proposed to include PFAS on the renewal of the general permit. As summarized in Tables 1 and 2 of the proposal, the proposed technology-based effluent limitations for PFOA, PFOS, PFHxS, PFNA, and HFPO-DA are consistent with USEPA Drinking Water MCLs (4 ng/L for PFOA and PFOS, 10 ng/L for the rest). The specified analytical method is USEPA Method 1633, which includes 40 analytes. Additionally, accelerated monitoring (quarterly to monthly frequency) is proposed for midstream sampling for sorbent media if data indicates breakthrough (or near-term breakthrough) of a lead vessel.

DOD issues an updated technical memo detailing changes to DOD adoption of EPA Regional Screening Levels (RSLs) for investigating PFAS within the DOD Cleanup Program. The DOD is following EPA RSLs for PFAS investigation and when new toxicity information or updates are made by the EPA, DOD incorporates those changes to the extent practicable into their process. Updates include incorporating recently finalized toxicity data for PFHxS and PFDA, defaulting to Federal MCLs for PFHxS, PFOA, and PFOS for tap water, defaulting to the DOD's pooled method detection limits for PFDA for tap water and PFOA and PFDA in residential soil, and reassessing Preliminary Assessments and Site Inspections with these new RSLs.

Lawmakers are re-pursuing efforts to provide Superfund liability relief to passive receivers (e.g., small airports, small water systems) from CERCLA's hazardous substance designation. There are also efforts in parallel to provide CERCLA liability protections for drinking water and wastewater treatment systems. The sought protections would extend to public drinking water systems, public and privately owned or operated wastewater systems, municipalities overseeing stormwater permits, state water agencies, and contractors managing treatment residuals and biosolids.

California lawmakers introduced AB 794, which would require the state Water Board to advance emergency rules to establish the six National Priority Drinking Water Regulations (NPDWR) for PFOA, PFOS, HFPO-DA, PFNA, and PFHxS. The bill grants the Water Board the authority to adopt the NPDWRs "as is," regardless of whether they are repealed or amended to be less stringent. The standards would need to be adopted by January 1, 2026 if the bill is finalized.

Based on the January 20, 2025 executive order, the proposed Effluent Limitations Guidelines for PFAS under the Organic Chemicals, Plastics and Synthetic Fibers (OCPSF) Point Source Category was withdrawn from the Office of Management and Budget. Stemming from Section 7.3 of EPA Preliminary Effluent Guidelines Program Plan 15, the EPA proposed to revise ELGs for the OCPSF Point Source Category based data and responses to the Section 308 data request for PFAS to best available technology economically achievable (BAT) levels.

The European Environmental Bureau sent a letter to the President of the European Commission to request a meeting to discuss several concerns related to PFAS in drinking water and the environment. The letter requests the President’s support for the ban of PFAS chemicals, comprehensive monitoring and remediation, health, financial, and legal redress to those harmed, ensuring polluters pay, and accelerating the development and adoption of PFAS replacements.
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