Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water

What are PFAS and why do they matter for Ohio drinking water?

Per- and polyfluoroalkyl substances (PFAS) are a family of over 4,000 man-made chemicals used for years in everyday items such as nonstick cookware, water-resistant clothing, and personal care products. With strong carbon-fluorine bonds, these chemicals are extremely effective in making everyday items more resistant to stains, grease, and water. They have been widely used to manufacture paper and cardboard packaging, carpeting, leather products, textiles, and personal care products, and extensively in materials with non-stick properties. PFAS have also been widely used in fire suppression foams, at military installations and fire training facilities. Two specific chemicals of the PFAS family, PFOA and PFOS, have been the most extensively produced and most widely studied to date.

The major source of exposure to PFAS is through ingestion. Data suggest that PFAS are not easily or readily metabolized by the human body and are commonly found in human blood across the nation. Studies indicate potential health risks associated with PFAS exposures can include liver damage, thyroid disease, elevated cholesterol, decreased antibody response to vaccines, pregnancy-induced hypertension, decreased fertility, small decreases in birthweight, and developmental and immune toxicity.

While PFAS do not occur naturally, they may be found throughout the environment due to a long history of manufacturing and use. PFAS chemicals are very stable and do not easily biodegrade. PFAS contamination in soils is of particular concern for drinking water due to potential impacts to surface and ground water sources.

How did Ohio’s PFAS Action Plan come about?

On Sept. 27, 2019, Governor Mike DeWine announced the establishment of an inter-agency workgroup to address the emerging issue of PFAS in Ohio, both for the protection of natural resources and public health. He directed the Ohio Environmental Protection Agency (Ohio EPA) and Ohio Department of Health (ODH) to work together on developing a statewide PFAS action plan to address potential threats to both public and private drinking water systems.

Earlier in 2019, Governor DeWine, along with 14 governors, signed a letter to both the United States Senate and House Armed Services Committees calling for more comprehensive national legislation on PFAS and action to address PFAS contamination in and around military bases.

While the initial focus of the action plan is on potential risks associated with PFAS in drinking water, there are other emerging areas of national research related to PFAS, including identifying safer chemical substitutes, soil remediation technologies, and other treatment methods.

Who regulates public and private water systems in Ohio?

Public water systems are regulated by the Ohio EPA:

• Community water systems (CWS) serve at least 15 service connections used by year-round residents or regularly serve at least 25 year-round residents. Examples include cities, mobile home parks, and nursing homes.
• Non-transient, non-community systems (NTNC) serve at least 25 of the same persons over six months per year. Examples include schools, hospitals, and factories.

Private water systems are regulated by the ODH. Private water systems are defined as any water system for the provision of water for human consumption if the system has fewer than 15 service connections and does not regularly serve an average of at least 25 individuals at least 60 days out of the year (e.g., private homes, small churches).

What is the history of PFAS detections in Ohio?

The Safe Drinking Water Act requires U.S. EPA to identify up to 30 unregulated contaminants to be monitored by public water systems every five years. The third cycle of the Unregulated Contaminant Monitoring Rule required monitoring for 28 chemicals and included six PFAS chemicals. In Ohio, 186 public water systems participated in the monitoring during 2013-2015. As a result, one public water system serving Wright-Patterson Air Force Base (WPAFB) reported PFAS at elevated levels.

In 2016, the U.S. EPA set a health advisory level (HAL) of 70 parts per trillion (ppt) for PFOA and PFOS in drinking water. U.S. EPA is working on a national framework to set regulatory standards for PFAS, including national safe drinking water standards (known as a maximum contaminant level, or MCL).

The establishment of the HAL prompted additional coordination between Ohio EPA, communities, and military installations. There has been ongoing data collection, assessment, and coordination between WPAFB, Ohio EPA, and the City of Dayton to monitor impacts to public water systems that serve both WPAFB and the City of Dayton.

As a proactive measure, the Ohio National Guard also worked with Ohio EPA to obtain sample results for private water supply wells near its bases, including former fire training areas. As a result, one private well near the Toledo Air National Guard base was connected to a public water system due to the detection of contamination.

PFAS contamination has also been identified from manufacturing activities associated with the Chemours (formerly DuPont) Washington Works facility near Parkersburg, West Virginia. Remediation requirements, including treatment for several public and private water supply systems, are included in a federal consent order entered into between U.S. EPA, Chemours, and DuPont.

What are the six objectives of the PFAS Action Plan?

Objective 1: Gather sampling data from public water systems statewide

Ohio EPA will coordinate sampling of approximately 1,500 public water systems statewide. These systems provide water to cities, mobile home parks, schools, and daycares and serve approximately 90 percent of Ohio’s population.

Raw and finished water samples will be collected, with a goal of completing sampling by the end of 2020. Finished water samples will be collected at an entry point to the distribution system, after treatment or chemical addition. Sampling will be coordinated by Ohio EPA under contracts with qualified consultants and laboratories, with analyses conducted per a quality assurance project plan (QAPP) and U.S. EPA-approved methods. Some sampling may also be conducted by trained Ohio EPA technicians and analyzed by Ohio EPA’s Division of Environmental Services (DES). Results will be published on Ohio’s PFAS web page.

Objective 2: Assist private water system owners

ODH will evaluate the PFAS source water results from the public water systems sampled by Ohio EPA. If data suggest nearby private water system sources may be contaminated, ODH will coordinate with local health districts and private water system owners on response measures, including testing recommendations and treatment options. ODH has established fact sheets, guidance, and videos on health effects, exposure reduction, and treatment/removal systems, available on Ohio’s PFAS webpage.

Objective 3: Establish Action Levels for drinking water in Ohio

There are currently no national drinking water standards for PFAS compounds; MCLs are under consideration by U.S. EPA. The Ohio Action Levels for PFOA and PFOS utilize the established U.S. EPA HALs. Because HALs are not available for other PFAS chemicals, the Ohio Action Levels for GenX, PFBS, PFHxS, and PFNA are calculated using the U.S. EPA’s established Drinking Water Equivalent Level method and toxicity data. These levels will be re-evaluated as U.S. EPA finalizes toxicity assessments. Ohio EPA and ODH will use these action levels as thresholds in providing guidance to drinking water system owners/operators.

Ohio EPA will establish response protocols for public water systems when action levels are exceeded, including public notification and issuance of drinking water advisories. ODH will establish response protocols for private water systems when action levels are exceeded.

Detection levels are based on the lowest achievable method reporting limits (MRL) by the laboratory. A survey of state and federal laboratories at the time of writing indicated achievable MRLs of 5 ppt for PFOA, 5 ppt for PFOS, 25 ppt for GenX, 5 ppt for PFBS, 5 ppt for PFHxS, and 5 ppt for PFNA.

PFAS chemicals referenced: PFOA (Perfluorooctanoic Acid), PFOS (Perfluorooctane Sulfonate), GenX (HFPO dimer acid), PFBS (perfluorobutanesulfonic acid), PFHxS (perfluorohexane sulfonic acid), and PFNA (perfluorononanoic acid).

Objective 4: Identify resources for community preventative and long-term measures

Ohio EPA’s Division of Environmental and Financial Assistance will provide communities with information on available loans and technical assistance for planning, design, and installation of treatment or other infrastructure improvements. Ohio EPA will support source water protection capabilities, including source water protection workshops. ODH will coordinate to identify resources to assist private water system owners with sampling, analysis, and installation and maintenance of water treatment systems.

Objective 5: Develop and disseminate educational information

Ohio EPA and ODH will collaborate on educational information delivered through a PFAS web page, social media, and other channels. Topics will include:

• Results/data from public water system sampling
• Health-based information on PFAS exposure and risks
• Interpretation of detections
• Information on reducing potential exposure risks
• Public and private water systems toolkits directing responses to detections and action level exceedances
• Technical support documentation and helpful resources
• Guidelines and educational information for private water system owners
• Updates on PFAS-related activity occurring at the national level

Objective 6: Continue ongoing engagement as science and regulation evolve

Other emerging areas of national research include development of analytical methods, identifying safer chemical substitutes for PFAS, addressing other exposure pathways, and PFAS treatment and remediation technologies. Ohio EPA and ODH will keep abreast of these developments, adapt the plan as the science and national regulatory framework unfold, and continue to network with research organizations and other states.