EPA Finalizes National Primary Drinking Water Regulation for Certain PFAS
On April 10, 2024, EPA announced the final National Primary Drinking Water Regulation (NPDWR) for six PFAS.
On April 10, 2024, EPA announced the final National Primary Drinking Water Regulation (NPDWR) for six PFAS. To inform the final rule, EPA evaluated over 120,000 comments submitted by the public on the rule proposal, as well as considered input received during multiple consultations and stakeholder engagement activities held both prior to and following the proposed rule. EPA expects that over many years the final rule will prevent PFAS exposure in drinking water for approximately 100 million people, prevent thousands of deaths, and reduce tens of thousands of serious PFAS-attributable illnesses.
EPA is also making unprecedented funding available to help ensure that all people have clean and safe water. In addition to today’s final rule, $1 billion in newly available through the Bipartisan Infrastructure Law to help states and territories implement PFAS testing and treatment at public water systems and to help owners of private wells address PFAS contamination.
EPA finalized a National Primary Drinking Water Regulation (NPDWR) establishing legally enforceable levels, called Maximum Contaminant Levels (MCLs), for six PFAS in drinking water. PFOA, PFOS, PFHxS, PFNA, and HFPO-DA as contaminants with individual MCLs, and PFAS mixtures containing at least two or more of PFHxS, PFNA, HFPO-DA, and PFBS using a Hazard Index MCL to account for the combined and co-occurring levels of these PFAS in drinking water. EPA also finalized health-based, non-enforceable Maximum Contaminant Level Goals (MCLGs) for these PFAS.
The final rule requires:
Public water systems must monitor for these PFAS and have three years to complete initial monitoring (by 2027), followed by ongoing compliance monitoring. Water systems must also provide the public with information on the levels of these PFAS in their drinking water beginning in 2027.
Public water systems have five years (by 2029) to implement solutions that reduce these PFAS if monitoring shows that drinking water levels exceed these MCLs.
Beginning in five years (2029), public water systems that have PFAS in drinking water which violates one or more of these MCLs must take action to reduce levels of these PFAS in their drinking water and must provide notification to the public of the violation.
Recent Posts
Combating Burnout: Key Strategies for a Healthier Workplace
Exploring the shadowy impact of workplace stress, this article delves into how pervasive job-related burnout threatens personal well-being and dampens productivity and communication. Discover essential strategies for employers to foster a supporti...
Workplace stress is a significant yet often overlooked safety risk that can impact a number of people. According to research by the American Institute of Stress, 83% of workers in the United States experience stress related to their jobs.1 Workplace stress causes, on average, 120,000 deaths each year.2 This stress doesn't just impact personal well-being; it also undermines job performance, productivity, and interpersonal communication.
There are many different causes of workplace stress. Concerns about job security, such as the fear of reduced hours or layoffs, can weigh on employees. Similarly, taking on additional responsibilities without adequate support or feeling unable to take sufficient breaks can increase stress levels. A significant stressor for many is being unable to maintain a healthy work-life balance, especially if there is an expectation to respond to work-related emails and answer work calls during personal time.
While the list of stressors extends beyond these examples, the collective impact can significantly affect your overall well-being. Fortunately, there are steps employers can take to alleviate workplace stress. A survey conducted by the American Psychological Association in 2021 revealed that over 87% of employees believe employers can help alleviate stress by offering flexible work hours, promoting the use of PTO, or encouraging employees to take regular breaks throughout the day.3 These proactive measures not only improve employee satisfaction but also foster a healthier and more productive work environment. The World Health Organization estimates that for every dollar an employer spends on mental health concerns, they receive a return of four dollars.1 Investing in mental health support benefits individuals and produces a return for employers, highlighting the importance of employee well-being in the workplace.
When we are stressed, fatigued, or mentally unwell, our ability to perform tasks safely and effectively is decreased. By addressing mental health concerns and providing support, employers promote a healthier work environment and enhance overall safety. Take some time to see what kinds of support your workplace offers.
1 World Health Organization. “Mental Health at Work.” 2022. https://www.who.int/teams/mental-health-and-substance-use/promotion-prevention/mental-health-in-the-workplace.
2 Goh, J., Pfeffer, J., & Zenios, S. A. “The relationship between workplace stressors and mortality and health costs in the United States.” March 13, 2015. Management Science, 62(2), 608-628
3 American Psychological Association. “Vacation Time Recharges US Workers, but Positive Effects Vanish within Days, New Survey Finds.” June 27, 2018. https://www.apa.org/news/press/releases/2018/06/vacation-recharges-workers.
Recent Posts
Using Artificial Intelligence to Interpret and Predict ESG Initiatives
I think there is a misunderstanding in today’s world regarding what AI is and what it can do. The latest trend is generative AI, a form of artificial intelligence capable of generating new content. This can be seen from things like ChatGPT, which can write entire novels when given a prompt on a particular subject, or DALL-E, which can create amazing images. Not every AI falls into this category, though. Other types of AI, such as predictive analytics and machine learning algorithms, are also relevant. This distinction is helpful in realizing that AI cannot independently generate completely new ideas; AI models are trained on existing data and patterns. Recognizing this fact will help set realistic expectations for what AI can and cannot do. It will not create an unknown product that the world has never seen.
“If the hot new fad is AI, surely there must be some way to incorporate that into our current business to make us more efficient.” The answer is yes! AI algorithms can analyze large datasets to identify trends, assess environmental impacts, or evaluate organizational social governance practices.
AI can make all aspects of your company’s environmental, health, and safety goals more efficient. You can leverage current AI tools with no platform by feeding it your data and asking for suggestions on improvements. For example, you can train generative AI with your current accident data. With a few of the correct prompts, it can generate a safety plan to help improve worker safety or perhaps identify vulnerabilities you haven’t even thought of.
In the future, AI will not only interpret existing data but also predict our future goals. Using predictive analytics and AI-driven forecasting models, we can anticipate environmental risks, forecast resource demands, and predict social trends. Looking further into the future, I can envision a scenario where workers wear AI components to help them identify hazards, prevent injuries, or even maximize their productivity.
There are some drawbacks to AI that also need to be considered. Ultimately, the predictive models are only as good as the data given to them. Companies are also responsible for protecting private individual data. It’s essential to make sure the data is high-quality and ethically handled. Companies must have a transparency and accountability policy regarding sensitive data.
AI technologies will have a positive and profound impact on sustainability, social responsibility, and corporate governance, and I encourage you to begin researching how AI data-driven models can help your company right now.
Recent Posts
Industrial Stormwater Best Management Practices
Stormwater is the water that originates from precipitation such as heavy rain or meltwater from hail or snow. Many industrial facilities introduce materials to stormwater through the outdoor storage, handling, and transfer of product materials, by-products, and waste products. These industrial products often contain pollutants such as metals, oil, and grease which negatively impact stormwater runoff. Additionally, industrial activities can cause erosion and sediment problems that also impact stormwater runoff.
Best Management Practices (BMPs) are pollution control measures designed to prevent or reduce the effects of pollutants in stormwater runoff from industrial stormwater discharges. Some BMPs are specific and well-defined, while others are general in nature. Facilities determine which BMPs to use based on permit requirements, the facility’s specific industrial materials, and the facility’s specific activities.
BMPs should be considered as a system or series of activities that may include non-structural and structural BMPs.
Non-structural BMPs are management techniques implemented through simple daily duties. The facility identifies and implements site-specific BMPs which have a direct impact on the day-to-day operations. Some of the more common non-structural BMPs include good housekeeping, eliminating and reducing exposure, management of salt and/or industrial storage piles, management of runoff including soil and erosion prevention, and dust control.
Structural BMP options vary depending on the pollutants each can treat, efficiency, maintenance issues and limitations of controls. Structural BMPs are more technical in nature and advanced technical expertise is required to make informed decisions about implementing structural stormwater BMPs. It
is suggested to consult with a licensed professional engineer early in the decision process. Common structural BMPs include sedimentation systems (e.g. retention ponds), infiltration systems (e.g. stormwater trenches), filtration systems (e.g. vegetative filters), and proprietary systems (e.g. vortex separators).
Federal regulations require stormwater discharges associated with specific categories of industrial activity to be covered under a National Pollutant Discharge Elimination System (NPDES) permit. EPA has developed a fact sheet for each of the 29 industrial sectors regulated by the NPDES permits. Each fact sheet describes the types of facilities included in the sector, typical pollutants associated with the sector, and types of stormwater control measures used to minimize the discharge of the pollutants. These BMP fact sheets are a great starting point for determining the various pollutants which cause stormwater pollution at a facility and provide BMPs that are applicable to a specific industrial facility operation.
Regular inspections of a facility’s BMPs are required by the NPDES permits. These inspections are integral in determining if structural and nonstructural BMPs are properly functioning, require maintenance, or need to be changed. Inspections also determine the accuracy of the facility’s written stormwater plan, as all observations and any changes made as a result of the inspections must be documented in the written plan.
For more information on BMPs for stormwater, check out EPA.gov or reach out to your Cornerstone Team directly.
Recent Posts
Stormwater "Red Flags"
Many years ago, I interned for the local County Health Department and assisted them with water quality monitoring. The department monitored the water quality from twelve points along the rivers and streams in the county. Rain or shine, I headed out every Wednesday morning to collect samples. At each location, I pulled on the hip waders and walked a few meters from the shore to measure oxygen levels and collect a sample for the lab. Every week I plated petri dishes and counted E. coli colonies. Some days the water quality of the river was excellent and other days the bacteria levels (E. coli) in the river were dangerously high. What spiked the levels of bacteria levels in a body of water that moved over 30,000 cubic feet per minute? Rainfall, or more accurately: the pollution that the rainfall carried.
I later found out that some of the sampling locations were near animal farms, hence the E. coli. Water is often called the ‘universal solvent’ because more substances dissolve in water than in any other liquid. The Clean Water Act defines the term “pollutant” broadly.
“[A pollutant] includes any type of industrial, municipal, and agricultural waste discharged into water. Some examples are dredged soil, solid waste, incinerator residue, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt and industrial, municipal, and agricultural waste.”
The Environmental Protection Agency and state governments work hard to protect waters through the implementation of the National Pollutant Discharge Elimination System (NPDES) permit program. Many industries obtain NPDES general stormwater permit coverage if they discharge into water of the United States. Sampling from a site’s discharge point(s) is an important part of the general NPDES permit. The data is compared with benchmark thresholds as an indicator of the effectiveness of the permit and stormwater control measures. Unlike an air permit, a stormwater sample result that exceeds one of the benchmark thresholds is often considered a “red flag” as opposed to a violation.
No one wants to have a “red flag” when they submit their stormwater results, but it may point to a problem with an exposed pollutant source at your site or a stormwater control measure that is not working correctly. Stormwater regulations protect our waters and, ultimately, protect our drinking water and health. As cliché as this sounds, our actions upstream impact our water downstream. Whether it’s general housekeeping at your facility or making sure a driver safely transfers material from your site, every action matters. Monitoring the exterior of your facility weekly is a great activity to ensure your site is not unintentionally polluting. Atypical events such as a leak or spill that was not cleaned up can be caught in time before the rainfall.
Remember that rivers, despite their size and capacity, can be significantly impacted by our actions. Let’s minimize the pollution the rain carries to keep the rivers healthy.