SEPA—
United States
Environmental Protection
Agency
Multi-Industry Per- and Polyfluoroalkyl
Substances (PFAS) Study -
2021 Preliminary Report
September 2021
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United States Environmental Protection Agency
Office of Water (4303T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
EPA-821-R-21-004
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Table of Contents
Table of Contents
1. Executive Summary 1-1
2. Multi-Industry PFAS Study Background 2-1
3. PFAS Overview 3-1
3.1 PFAS Classifications and Characteristics 3-1
3.1.1 Nonpolymer PFAS 3-3
3.1.2 Polymer PFAS 3-7
3.2 Phase Out and Replacement of Certain Long-Chain PFAS with Short-Chain PFAS 3-7
3.3 Environmental Fate and Transport of PFAS 3-8
3.4 PFAS Exposure and HeaIth Effects 3-9
4. Data Collection Activities 4-1
4.1 Data Sources and Quality 4-1
4.2 Protection of Confidential Business Information 4-7
5. Review of the OCPSF Point Source Category 5-1
5.1 Industry Description, Manufacture, and Use of PFAS 5-1
5.2 Stakeholder Outreach 5-3
5.3 PFAS Wastewater Regulatory Requirements and Controls 5-4
5.4 Wastewater Characteristics 5-7
5.5 OCPSF Point Source Category Summary 5-10
6. Review of the Metal Finishing Point Source Category 6-1
6.1 Industry Description and Use of PFAS 6-1
6.2 Stakeholder Outreach 6-2
6.3 PFAS Wastewater Regulatory Requirements and Controls 6-2
6.4 Wastewater Characteristics 6-3
6.5 Metal Finishing Point Source Category Summary 6-4
7. Review of the Pulp, Paper, and Paperboard Point Source Category 7-1
7.1 Industry Description and Use of PFAS 7-1
7.2 Stakeholder Outreach 7-2
7.3 PFAS Wastewater Regulatory Requirements and Controls 7-5
7.4 Wastewater Characterization 7-5
7.5 Pulp, Paper, and Paperboard Point Source Category Summary 7-7
8. Review of the Textile Mills Point Source Category 8-1
8.1 Industry Description and Use of PFAS 8-1
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Table of Contents
8.2 Stakeholder Outreach 8-2
8.3 PFAS Wastewater Regulatory Requirements and Controls 8-2
8.4 Wastewater Characteristics 8-3
8.5 Textile Mills Point Source Category Summary 8-3
9. Review of the Commercial Airport Point Source Category 9-1
9.1 Industry Description and Use of PFAS 9-1
9.2 Stakeholder Outreach 9-3
9.3 PFAS Wastewater Regulatory Requirements and Controls 9-3
9.4 PFAS Releases Associated with AFFF Use 9-3
9.5 Commercial Airports Point Source Category Summary 9-4
10. Review of PFAS Treatment Technologies 10-1
10.1 Conventional Treatment Technologies 10-4
10.2 Adsorption 10-4
10.2.1 Activated Carbon 10-4
10.2.2 Ion Exchange Resins 10-5
10.2.3 Other Adsorbents for PFAS Removal 10-5
10.3 Membrane Filtration 10-5
10.4 Incineration/Thermal Treatment 10-6
10.5 Advanced Oxidation and Reduction Processes 10-6
10.5.1 Advanced Oxidation Processes 10-7
10.5.2 Advanced Reduction Processes 10-7
10.6 Emerging PFAS Treatment Technologies 10-7
11. References 11-1
List of Figures
Figure 1. PFAS Classes and Groups Discussed in this Preliminary Report 3-2
Figure 2. Molecular Structures of PFOA (left) and PFOS (right) 3-3
List of Tables
Table 1. Point Source Categories Included in Multi-Industry PFAS Study 2-2
Table 2. Nonpolymer PFAS Included in Collected Discharge Data and EPA's Cross-Agency PFAS Research List 3-5
Table 3. Summary of Draft and Final HeaIth Effects Information for Short-Chain PFAS, PFOA, and PFOS 3-11
Table 4. Multi-Industry PFAS Study Data Sources 4-2
Table 5. Applicability of 40 CFR Part 414 Subparts to Manufacture of Products and Product Groups 5-1
Table 6. OCPSF Facilities Identified as PFAS Manufacturers or PFAS Formulators 5-3
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Table of Contents
Table 7. PFAS Wastewater Regulatory Requirements and Controls for PFAS Manufacturers and PFAS Formulators
5-5
Table 8. PFAS Manufacturer and PFAS Formulator PFAS Wastewater Concentrations 5-8
Table 9. Chromium Electroplating Wastewater PFAS Concentrations 6-4
Table 10. Summary of AF&PA Member Company Mills Using PFAS 7-3
Table 11. Pulp, Paper, and Paperboard Wastewater PFAS Concentrations 7-6
Table 12. Textile Mill Wastewater PFAS Concentrations 8-3
Table 13. Summary of Available PFAS Treatment Technologies 10-2
Table 14. Emerging PFAS Destruction Technologies 10-8
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Abbreviations
Abbreviations
ACC
American Chemistry Council
ADONA
trade name for ammonium 4,8-dioxa-3H-perfluorononanoate, one chemical used in a 3M
fluoropolymer processing aid technology
AF&PA
American Forest and Paper Association
AFFF
aqueous film-forming foam
APFO
ammonium perfluorooctanoate (ammonium salt of PFOA)
ASTSWMO
Association of State and Territorial Solid Waste Management Officials
ATSDR
United States Department of Health and Human Services, Agency for Toxic Substances and
Disease Registry
BAF
bioaccumulation factor
BCF
bioconcentration factor
CAFE
National Oceanic and Atmospheric Administration Chemical Aquatic Fate and Effects
database
CBI
confidential business information
CDR
Chemical Data Reporting
CFR
Code of Federal Regulations
CWA
Clean Water Act
DMR
discharge monitoring report
DOD
United States Department of Defense
DONA
trade name for 4,8-dioxa-3H-perfluorononanoic acid, one chemical used in a 3M
fluoropolymer processing aid technology
DWTD
Drinking Water Treatability Database
DWTP
drinking water treatment plant
ELGs
Effluent Limitations Guidelines and Standards
EPA
United States Environmental Protection Agency
EPAOPPT
United States Environmental Protection Agency, Office of Chemical Safety and Pollution
Prevention, Office of Pollution Prevention and Toxics
ETFE
ethylene tetrafluoroethylene
F-53B
trade name for chlorinated polyfluoroalkyl ether sulfonic acids, including 9CI-PF30NS ("F-53B
major"), HCI-PF30UdS ("F-53B minor"), and their potassium salts
FAA
United States Department of Transportation, Federal Aviation Administration
FASA
perfluoroalkane sulfonamide
FASAA
perfluoroalkane sulfonamido acetic acid
FASE
perfluoroalkane sulfonamido ethanol
FCN
food contact substance notification
FCS
food contact substance
FDA
United States Department of Health and Human Services, Food and Drug Administration
FR
Federal Register
FTCA
fluorotelomer carboxylic acid
FTOH
fluorotelomer alcohol
FTSA
fluorotelomer sulfonic acid
GAC
granular activated carbon
GenX
trade name for fluoropolymer processing aid technology that involves includes HFPO-DA and
its ammonium salt
HFPO-DA
hexafluoropropylene oxide dimer acid, one chemical used in the GenX fluoropolymer
processing aid technology
IWTT
Industrial Wastewater Treatment Technology
IX
ion exchange
K-9CI-PF30NS
potassium 9-chlorohexadecafluoro-3-oxanonane-l-sulfonate (potassium salt of F-53B major)
K-llCI-PF30UdS
potassium ll-chloroeicosafluoro-3-oxaundecane-l-sulfonate (potassium salt of F-53B minor)
lb/year
pounds per year
LHA
lifetime health advisory
MCL
Maximum Contaminant Level
iv
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Abbreviations
Ml EGLE
Michigan Department of Environment, Great Lakes, and Energy
MGD
million gallons per day
NaDONA
sodium dodecafluoro-3H-4, 8-dioxanonanoate
NASF
National Association for Surface Finishing
NESHAP
National Emission Standards for Hazardous Air Pollutants
NFDHA
perfluoro-3,6-dioxaheptanoic acid
NEtFOSAA
N-ethyl perfluorooctane sulfonamido acetic acid
NEtFOSE
N-ethyl perfluorooctane sulfonamido ethanol
NEtPFOSA
N-ethyl perfluorooctane sulfonamide
ng/L
nanograms per liter
NIH
United States Department of Health and Human Services, National Institutes of Health
NJ DEP
New Jersey Department of Environmental Protection
NMeFOSAA
N-methyl perfluorooctane sulfonamido acetic acid
NMeFOSE
N-methyl perfluorooctane sulfonamido ethanol
NMePFOSA
N-methyl perfluorooctane sulfonamide
NOAA
United States Department of Commerce, National Oceanic and Atmospheric Administration
NPDES
National Pollutant Discharge Elimination System
OCPSF
organic chemicals, plastics, and synthetic fibers
PAC
powdered activated carbon
POTW
publicly owned treatment works
PFAA
perfluoroalkyl acid
PFAS
per-and polyfluoroalkyl substances
PFBA
perfluorobutanoic acid
PFBS
perfluorobutane sulfonic acid
PFCA
perfluoroalkyl carboxylic acid
PFDA
perfluorodecanoic acid
PFDS
perfluorodecane sulfonic acid
PFDoA
perfluorododecanoic acid
PFEA
per- and polyfluoroalkyl ether acid
PFECA
perfluoroalkyl ether carboxylic acid
PFECA-G
perfluoro-4-isopropoxybutanoic acid
PFESA
perfluoroalkyl ether sulfonic acid
PFESA-BP1
perfluoro-3,6-dioxa-4-methyl-7-octene-l-sulfonic acid
PFESA-BP2
Perfluoro-2-{[perfluoro-3-(perfluoroethoxy)-2-propanyl]oxy}ethane sulfonic acid
PFHpA
perfluoroheptanoic acid
PFHpS
perfluoroheptane sulfonic acid
PFHxA
perfluorohexanoic acid
PFHxDA
perfluorohexadecanoic acid
PFHxS
perfluorohexane sulfonic acid
PFMOAA
perfluoro-2-methoxyacetic acid
PFNA
perfluorononanoic acid
PFNS
perfluorononane sulfonic acid
PFOA
perfluorooctanoic acid
PFODA
perfluorooctadecanoic acid
PF02HxA
perfluoro-3,5-dioxahexanoic acid
PF030A
perfluoro-3,5,7-trioxaoctanoic acid
PF04DA
perfluoro-3,5,7,9-tetraoxadecanoic acid
PF05DA
perfluoro-3,5,7,9,ll-pentaoxadodecanoic acid
PFOS
perfluorooctane sulfonic acid
PFOSA
perfluorooctane sulfonamide
PFPE
perfluoropolyether
PFPeA
perfluoropentanoic acid
PFPeS
perfluoropentane sulfonic acid
PFSA
perfluoroalkane sulfonic acid
PFTeA
perfluorotetradecanoic acid
PFTrA
perfluorotridecanoic acid
PFUnA
perfluoroundecanoic acid
v
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Abbreviations
PITT
PFAS Innovative Treatment Team
PMPA
perfluoromethoxypropyl carboxylic acid
PTFE
polytetrafluoroethylene
RfD
reference dose
RO
reverse osmosis
SIC
United States Department of Commerce Bureau of the Census Standard Industrial
Classification system
SNUR
Significant New User Rule
TOXNET
National Institutes of Health Toxicology Data Network
TRI
Toxics Release Inventory
TSCA
Toxic Substances Control Act
Wl DNR
Wisconsin Department of Natural Resources
Hg/L
micrograms per liter
HCI-PF30UdS
ll-chloroeicosafluoro-3-oxaundecane-l-sulfonic acid (F-53B minor)
4:2 FTSA
4:2 fluorotelomer sulfonic acid
5:3 FTC A
2H, 2H, 3H, 3H-perfluorooctanoic acid
6:2 FTOH
6:2 fluorotelomer alcohol
6:2 FTSA
6:2 fluorotelomer sulfonic acid
7:3 FTC A
2H, 2H, 3H, 3H-perfluorodecanoic acid
8:2 FTSA
8:2 fluorotelomer sulfonic acid
9CI-PF30NS
9-chlorohexadecafluoro-3-oxanone-l-sulfonic acid (F-53B major)
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1—Executive Summary
1. Executive Summary
The purpose of this preliminary report is to summarize the readily available information and data the United
States Environmental Protection Agency's (EPA) Office of Water collected and reviewed concerning industrial
discharges of per- and polyfluoroalkyl substances (PFAS) from five industrial point source categories: organic
chemicals, plastics, and synthetic fibers (OCPSF) manufacturing; metal finishing; pulp, paper, and paperboard
manufacturing; textile mills; and commercial airports.1
PFAS are a family of thousands of synthetic organic chemicals that contain a chain of carbon-fluorine bonds, one
of the strongest chemical bonds. Many PFAS are highly stable, water- and oil-resistant, and exhibit other
properties that make them useful in a variety of consumer products and industrial processes. Owing to these
properties, PFAS do not easily degrade naturally and thus accumulate over time. According to the United States
Department of Health and Human Services, Agency for Toxic Substances and Disease Registry (ATSDR), the
environmental persistence and mobility of some PFAS, combined with decades of widespread use, have resulted
in their presence in surface water, groundwater, drinking water, rainwater, soil, sediment, ice caps, outdoor and
indoor air, plants, animal tissue, and human blood serum across the globe. Exposure to certain PFAS can lead to
adverse human health impacts (ATSDR, 2021).
The global regulatory community has historically been interested in two groups of PFAS: (1) long-chain
perfluoroalkane sulfonic acids (PFSAs), including perfluorooctane sulfonic acid (PFOS); and (2) long-chain
perfluoroalkyl carboxylic acids (PFCAs), including perfluorooctanoic acid (PFOA). Long-chain PFAS, including PFOA
and PFOS, were manufactured and used in the United States since the 1940s. Due to evidence of long-term
persistence and adverse health outcomes associated with long-chain PFAS, EPA implemented restrictions on the
manufacture, use, and import of certain long-chain PFAS in the United States and some manufacturers have
voluntarily phased out these chemicals. More recently, industry has developed and adopted alternative short-
chain PFAS chemistries to replace long-chain PFAS. Many short-chain PFAS are structurally similar to their long-
chain predecessors being replaced and are manufactured by the same companies. Publicly available health,
toxicity, and hazard assessments of short-chain PFAS are limited. Available information suggests short-chain PFAS
generally pose less risk to overall human health and exhibit lower persistence in humans than long-chain PFAS
such as PFOA and PFOS. However, short-chain PFAS are environmentally persistent and some demonstrate
potential to cause adverse effects on animal and human health.
This preliminary report summarizes the manufacture, use, and discharge of PFAS from facilities in the five
industrial point source categories EPA reviewed. This preliminary report presents EPA's estimates of the types and
concentrations of PFAS, including legacy long-chain PFAS and replacement short-chain PFAS, present in
wastewater discharges from these facilities. Few facilities in these industries currently have monitoring
requirements, effluent limitations, or pretreatment standards for PFAS in their wastewater discharge permits. EPA
identified available wastewater treatment technologies, such as activated carbon, ion exchange, and membrane
filtration, that may reduce PFAS in wastewater discharges from facilities in these industrial point source
categories.
1 For this study, EPA focused on PFAS manufacturers and PFAS formulators for its review of the OCPSF point source category. "PFAS
manufacturers" refers to facilities that manufacture PFAS through electrochemical fluorination, fluorotelomerization, or other processes.
"PFAS formulators" refers to facilities that blend, convert, or integrate PFAS feedstocks with other materials to produce new commercial or
intermediate products.
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2—Multi-Industry PFAS Study Background
2. Multi-Industry PFAS Study Background
The Clean Water Act (CWA) directs EPA to promulgate Effluent Limitations Guidelines and Standards (ELGs) that
specify the attainable effluent pollutant reduction based on performance of pollution control technologies which
are, or can be, employed within each industrial point source category. EPA develops ELGs on an industry-by-
industry basis. These national, technology-based controls apply to pollutants discharged from facilities directly
into surface waters of the United States or to publicly owned treatment works (POTWs). EPA's goal in establishing
ELGs is to ensure that industrial facilities with similar characteristics will, at a minimum, meet similar effluent
limitations or pretreatment standards. These effluent limitations and pretreatment standards represent the
performance of the "best" pollution control technologies, regardless of geography or the nature of their receiving
water or POTW. Although the limitations are based on performance of specific technologies, the regulations do
not require use of a specific control technology to achieve the limitations. Facilities may use any method or
technology (other than dilution) to comply with the limitations. See EPA's Industrial Effluent Guidelines webpage
for more information on ELGs.
To date, EPA has promulgated ELGs for 59 industrial point source categories. These ELGs apply to between 35,000
and 45,000 facilities that discharge to surface waters (direct dischargers), as well as another 129,000 facilities that
discharge to POTWs (indirect dischargers), in the United States. The effluent limitations for direct dischargers are
implemented through National Pollutant Discharge Elimination System (NPDES) permits issued by authorized
states or EPA regional offices. The standards for indirect dischargers are implemented through pretreatment
permits or other control mechanisms issued and enforced by POTWs, states, and EPA regional offices. EPA has
not established any national technology-based numeric standards for PFAS in industrial wastewater discharges
and none of the current ELGs establish effluent limitations or pretreatment standards for PFAS.2
As part of the statutorily required ELG planning process, EPA's Office of Water examined readily available public
information about PFAS discharges. The Preliminary Effluent Guidelines Program Plan 14 and a supporting report,
The EPA's Review of Per- and Polyfluoroalkyl Substances (PFAS) in Industrial Wastewater Discharge, published in
October 2019, describe the review activities and findings of the initial examination and identify several industries
with facilities that are likely to be discharging PFAS in their wastewater (EPA, 2019a, 2019b). EPA determined that
further data collection and study were necessary to inform decisions about how best to address industrial PFAS
discharges and announced the Multi-Industry PFAS Study. The Multi-Industry PFAS Study focuses on continuing
data collection and review of PFAS manufacture, use, control, and discharge by industries that EPA determined
were likely to be discharging PFAS in their wastewater in the preliminary review. The objectives of the Multi-
Industry PFAS Study are to:
• Examine specific industrial categories and facilities manufacturing or using PFAS.
• Identify specific industrial facilities discharging PFAS in their wastewater.
• Collect, compile, and review information and data on PFAS in industrial discharges.
• Determine the types and concentrations of PFAS discharged in wastewater, based on available data and
information collected by EPA.
• Assess availability and feasibility of control practices and treatment technologies capable of reducing or
eliminating PFAS in wastewater discharges.
EPA focused on five industrial point source categories in the Multi-Industry PFAS Study: organic chemicals,
plastics, and synthetic fibers (OCPSF); metal finishing; pulp, paper, and paperboard; textile mills; and commercial
airports.3 Table 1 describes these five point source categories, applicable ELGs in the Code of Federal Regulations
(CFR), and potential uses/sources of PFAS.
2 Where EPA has not promulgated an applicable ELG for direct or indirect dischargers, technology-based effluent limitations or
pretreatment standards may be established based on the best professional judgement of the permitting authority.
3 For this study, EPA focused on PFAS manufacturers and PFAS formulators for its review of the OCPSF point source category. "PFAS
manufacturers" refers to facilities that manufacture PFAS through electrochemical fluorination, fluorotelomerization, or other processes.
"PFAS formulators" refers to facilities that blend, convert, or integrate PFAS feedstocks with other materials to produce new commercial or
intermediate products.
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2—Multi-Industry PFAS Study Background
Table 1. Point Source Categories Included in Multi-Industry PFAS Study
Point Source
Category
Description
Uses or Sources of PFASa
Organic
Chemicals,
Plastics, and
Synthetic Fibers
(OCPSF)
Industrial facilities that manufacture
organic chemicals, plastics, synthetic
fibers or resin products, including those
that manufacture PFAS or process PFAS
in production of such products. Subject
to ELGs in 40 CFR Part 414.
- Manufacture PFAS through electrochemical
fluorination, telomerization, or other
processes.
-Polymerization processing aids.
- Production of plastic, rubber, and resin.
- Present in manufacture of commercial
chemical products (e.g., carpet cleaning sprays,
cleaning agents, protective coatings).
Metal Finishing
Industrial facilities that change the
surface of an object to improve its
appearance or durability. Includes six
primary operations: electroplating,
electroless plating, anodizing, coating,
printed circuit board manufacturing,
and chemical etching and milling.
Subject to ELGs in 40 CFR Part 433.
- PFAS-containing chemicals used as wetting
agents, mist and fume suppressants to prevent
air emissions of toxic metal fumes, agents to
reduce mechanical wear, and surface coatings
to impart certain characteristics (e.g., reduced
corrosion, enhanced appearance).
Pulp, Paper, and
Paperboard
Mills that convert wood into pulp,
paper, paperboard, and other cellulose-
based products. Subject to ELGs in 40
CFR Part430.
- PFAS-containing chemicals used to impart
products with water and grease repellency
(e.g., food packaging, coated papers).
- Recycling of paper and paperboard products
treated with PFAS.
Textile Mills
Mills that receive and prepare fibers;
transform materials into yarn, thread,
or webbing; convert yarn and webbing
into fabric or related products; or finish
these materials to produce consumer
products (e.g., thread, yarn, bolt fabric,
hosiery, towels, sheets, carpet). Subject
to ELGs in 40 CFR Part 410.
- PFAS-containing chemicals used to impart
outdoor gear, clothing, household, and other
textile products with water, oil, soil, and heat
resistance.
Commercial
Airports
Commercial facilities associated with
commercial air transport or aircraft
flight operations. Excludes facilities
operated by the United States
Department of Defense (DOD). Subject
to ELGs in 40 CFR Part 449.
- PFAS are a component of aqueous film-forming
foam (AFFF), used for exterminating
hydrocarbon fuel fires and firefighting training.
a - In general, PFAS may be used as coatings or surfactants for mechanical components (e.g., semiconductors, wiring, tubing, piping,
seals, gaskets, etc.) used at many types of industrial facilities.
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3—PFAS Overview
3. PFAS Overview
This section provides background information on PFAS, with a focus on chemicals and classes discussed in this
preliminary report, and discusses industrial trends in the manufacture, import, and use of certain PFAS;
environmental fate and transport of PFAS; and PFAS exposure and health effects. This report focuses on 52 PFAS,
listed in Table 2, for which EPA collected discharge data as part of the Multi-Industry PFAS Study and are included
in EPA's Cross-Agency PFAS Research List. As of August 2021, EPA's Cross-Agency PFAS Research List comprises
199 PFAS compiled from public and internal sources and literature searches by EPA researchers and program
office representatives (EPA, 2021a). This list includes the PFAS most frequently detected in organisms and the
environment, those included in state or federal standards, and PFAS reported in EPA's national data sets.
3.1 PFAS Classifications and Characteristics
PFAS are a family of thousands of synthetic organic chemicals characterized by linear or branched carbon-fluorine
chains connected to a functional group. For the Multi-Industry PFAS Study, EPA used the following technical
definition for PFAS:
Per- and polyfluorinated substances that structurally contain the unit R-(CF2)-C(F)(R')R" where both the CF2
and CF moieties are saturated carbons and none of the R groups (R, R', or R") can be hydrogen.
EPA's National Center for Computational Toxicology maintains a master list of more than 5,000 chemicals with
defined structures that are potential PFAS (EPA, 2020a); however, it is likely that less than half of these are
commercially active in the United States. PFAS vary widely in chemical and physical properties, behavior, and
potential risks to human health and the environment. Differences in the chemical structure, carbon chain length,
degree of fluorination, and chemical functional group(s) of individual PFAS have implications for their mobility,
fate, and degradation in the environment, as well as uptake, metabolism, clearance, and toxicity in humans,
plants, and animals.
Many PFAS are chemically and thermally stable, reduce surface tension, and are resistant to heat, water, and oil.
These properties make PFAS useful in many consumer products and industrial processes, but also make PFAS
persistent in the environment. The small size, high electronegativity, and low polarizability of the fluorine atom,
and the strength of the carbon-fluorine covalent bond are responsible for many of the unique and desirable
characteristics of PFAS. See EPA's 2019 report The EPA's Review of Per- and Polyfluoroalkyl Substances (PFAS) in
Industrial Wastewater Discharge for a summary of potential industrial sources of PFAS identified during EPA's
2019 preliminary review (EPA, 2019b).
Two processes, electrochemical fluorination and fluorotelomerization, are commonly used to manufacture PFAS.
PFAS have been manufactured and used in many industries in the United States and internationally since the
1940s, but were not widely documented in environmental samples until analytical methods became commercially
available in the 2000s. Since that time, analytical methods have been continuously developed for different
environmental media and PFAS chemicals, and to detect PFAS at lower concentrations. Today, PFAS are detected
ubiquitously in the environment, biota, and humans, and in remote areas around the globe (Gluge et al., 2020;
ITRC, 2020).
The thousands of chemicals that make up the PFAS family can be divided into two classes: nonpolymers and
polymers. Each class may contain subclasses, groups, and subgroups. Figure 1, adapted from ITRC (2020), shows
the PFAS classes and groups discussed in this preliminary report. Figure 1 is not an exhaustive list of chemical
classes and groups that may be considered PFAS. This preliminary report focuses on nonpolymer PFAS with an
emphasis on perfluoroalkyl acids (PFAAs), PFAAs precursors, and replacements for long-chain PFAS that have
been or are being phased out.
3-1
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3 PI AS Overview
Legend
Perfluoroalkyl
substances
Fluorotelomer-based
substances
Fluoropolymers
Perfluoropolyethers
(PFPEs)
Polymers
Perfluoroalkane
sulfonamide
substances
Perfluoroalkane
sulfonamides (FASAs)
Polyfluoroalkyl
substances
Perfluoroalkyl acids
(PFAAs)
Per- and
polyfluoroalkyl ether
acids (PFEAs)
N-Alkyl FASAs
Perfluoroalkyl
carboxylic acids
(PFCAs)
Side-chain fluorinated
polymers
Per- and
polyfluoroalkyl ether
carboxylic acids
(PFECAs)
Nonpolymers
Fluorotelorner
carboxylic acids
(FTCAs)
PFAS
Perfluoroalkane
sulfonic acids (PFSAs)
Perfluoroalkane
sulfonamido ethanols
{FASEs) and N-Alkyl
FASEs
Per- and
polyfluoroalkyl ether
sulfonic acids (PFESAs)
Perfluoroalkane
suifonamido acetic
acids (FASAAs) and N-
Alkyl FASAAs
Fluorotelorner sulfonic
acids (FTSAs)
Fluorotelorner
alcohols (FTOHs)
Subgroup
Subclass
Family
Group
Figure 1. PFAS Classes and Groups Discussed in this Preliminary Report
Figure 1 was adapted from ITRC (2020) and is not an exhaustive list of chemical classes and groups that may be considered PFAS.
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3—PFAS Overview
3.1.1 Non polymer PFAS
The nonpolymer PFAS class includes two subclasses, perfluoroalkyl substances (fully fluorinated carbon chain) and
polyfluoroalkyl substances (partly fluorinated carbon chain), which include various groups and subgroups of
chemicals. Table 2, at the end of this section, presents the nonpolymer PFAS for which EPA collected discharge
data for this study and are included in EPA's Cross-Agency PFAS Research List (EPA, 2021a).
Perfluoroalkyl Substances
Perfluoroalkyl substances are fully fluorinated alkane molecules consisting of a two-or-more carbon chain (tail)
with a charged functional group (head). This preliminary report discusses two groups, PFAAs and perfluoroalkane
sulfonamides (FASAs), but others exist and are receiving increasing attention as they are added to commercial
laboratory target analyte lists and detected in the environment.
PFAAs are the simplest PFAS molecules and most frequently tested for in the environment. PFAAs do not degrade
under ambient environmental conditions and are the terminal products of degradation of more complex PFAS
(precursors). Longer chain PFAAs do not naturally degrade into PFAAs with a shorter carbon-fluorine chain length.
PFAAs are divided into two main subgroups: PFCAs and PFSAs. PFCAs may be manufactured using either
electrochemical fluorination or fluorotelomerization, while PFSAs are only manufactured using electrochemical
fluorination. The PFAAs group includes the two most studied PFAS: PFOA and PFOS. PFOA and PFOS are
demonstrated to accumulate and remain in the human body for long periods of time, and to cause adverse health
outcomes in animals and humans (EPA, 2016a, 2016b). Figure 2 illustrates the chemical structure of these two
chemicals.
PFAAs are described as long-chain or short-chain PFAS as a shorthand to group PFCAs and PFSAs that may behave
similarly in the environment. PFAAs are classified as either long-chain or short-chain depending on the number of
carbons covalently bonded to fluorine. Long-chain PFCAs have eight or more carbons (seven or more carbons are
perfluorinated) and long-chain PFSAs have six or more carbons (six or more carbons are perfluorinated) (ITRC,
2020). In terms of chemical behavior, PFCAs are more analogous to PFSAs that contain one more carbon than
PFSAs that contain the same number of carbons because one carbon in the PFCA molecule is associated with the
functional group rather than the fluoroalkyl tail (e.g., the eight carbon PFCA behaves more similar to a seven
carbon PFSA than an eight carbon PFSA). Table 2 identifies short-chain PFCAs and PFSAs in blue text, while long-
chain PFCAs and PFSAs are designated in red text. EPA notes that other factors besides carbon-fluorine chain
length may affect behavior and bioaccumulation potential of PFAS.
FASAs are used as raw material in the electrochemical fluorination process to make perfluoroalkyl sulfonamido
substances that are used for surfactants and surface treatments. FASAs may degrade to form PFAAs (ITRC, 2020).
Polyfluoroalkyl Substances
Polyfluoroalkyl substances are distinguished by not being fully fluorinated. Instead, they have a nonfluorine atom
(typically hydrogen or oxygen) attached to at least one, but not all, carbon atoms, while two or more of the
remaining atoms in the carbon chain tail are fully fluorinated. The nonfluorinated bond in polyfluoroalkyl
molecules create a weak point that is susceptible to degradation, thus many of these PFAS have potential to be
transformed into PFAAs. This preliminary report discusses three groups of polyfluoroalkyl substances:
fluorotelomer-based substances, perfluoroalkane sulfonamido substances, and per-and polyfluoroalkyl ether
acids (PFEAs).
Figure 2. Molecular Structures of PFOA (left) and PFOS (right)
3-3
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3—PFAS Overview
Fluorotelomer-based substances are produced by fluorotelomerization and have an x:y naming convention
whereby x identifies the number of fully fluorinated carbon atoms and y identifies the number of carbon atoms
not fully fluorinated. Fluorotelomer-based substances are potential PFCA precursors but are not observed to
transform into PFSAs (NASF, 2019a; Zhang et al., 2016). Three subgroups are discussed in this preliminary report:
fluorotelomer carboxylic acids (FTCAs), fluorotelomer sulfonic acids (FTSAs), and fluorotelomer alcohols (FTOHs).
Perfluoroalkane sulfonamido substances have a fully fluorinated tail and also contain one or more methylene
(CH2) groups in the head of the molecule, attached to the sulfonamido spacer. Perfluoroalkane sulfonamido
substances are manufactured by electrochemical fluorination and may degrade into PFCAs and PFSAs (ITRC,
2020). Three subgroups are discussed in this preliminary report: N-alkyl FASAs; perfluoroalkane sulfonamido
ethanols (FASEs), and perfluoroalkane sulfonamido acetic acids (FASAAs).
PFEAs are manufactured by fluorotelomerization and include per- and polyfluoroalkyl ether carboxylic acids
(PFECAs) and per- and polyfluoroalkyl ether sulfonic acids (PFESAs). Certain PFECAs and PFESAs have been
developed and are used as replacements for phased out long-chain PFAAs such as PFOA and PFOS. The PFEAs
gaining the most attention are hexafluoropropylene oxide dimer acid (HFPO-DA), 4,8-dioxa-3H-perfluorononanoic
acid (DONA) and its ammonium salt (ADONA), and chlorinated PFESAs. See Section 3.2 for further discussion of
these PFEAs.
3-4
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3—PFAS Overview
Table 2. Nonpolymer PFAS Included in Collected Discharge Data and EPA's Cross-Agency PFAS Research List
Subclass
Group
Subgroup
General Chemical
Structure3
CnF2n+iR, where R =
PFAS Chemicals3
tA
Q)
U
C
CD
¦M
IA
_Q
3
LT>
I
ro
O
Perfluoroalkyl acids
(PFAAs)
Perfluoroalkyl carboxylic
acids (PFCAs)bc
-COOH
- Perfluorobutanoic acid (PFBA) (C4)
- Perfluoropentanoic acid (PFPeA) (C5)
- Perfluorohexanoic acid (PFHxA) (C6)
- Perfluoroheptanoic acid (PFHpA) (C7)
- Perfluorooctanoic acid (PFOA) (C8)
-Ammonium perfluorooctanoate (APFO) (C8)
- Perfluorononanoic acid (PFNA) (C9)
- Perfluorodecanoic acid (PFDA) (CIO)
- Perfluoroundecanoic acid (PFUnA) (Cll)
- Perfluorododecanoic acid (PFDoA) (C12)
- Perfluorotridecanoic acid (PFTrA) (C13)
- Perfluorotetradecanoic acid (PFTeA) (C14)
- Perfluorohexadecanoic acid (PFFixDA) (C16)
- Perfluorooctadecanoic acid (PFODA) (C18)
O
3
4—
L_
QJ
D.
Perfluoroalkane sulfonic
acids (PFSAs)bc
-so3h
- Perfluorobutane sulfonic acid (PFBS) (C4)
- Perfluoropentane sulfonic acid (PFPeS) (C5)
- Perfluorohexane sulfonic acid (PFHxS) (C6)
- Perfluoroheptane sulfonic acid (PFHpS) (C7)
- Perfluorooctane sulfonic acid (PFOS) (C8)
- Perfluorononane sulfonic acid (PFNS) (C9)
- Perfluorodecane sulfonic acid (PFDS) (CIO)
Perfluoroalkane
sulfonamides
(FASAs)d
Not Applicable
-SO2NH2
- Perfluorooctane sulfonamide (PFOSA)
l/l
01
O
C
CD
+-»
l/l
-O
3
Fluorotelomer-
based substances®
Fluorotelomer sulfonic
acids (FTSAs)
-CH2CH2SO3H
- 4:2 fluorotelomer sulfonic acid (4:2 FTSA)
- 6:2 fluorotelomer sulfonic acid (6:2 FTSA)
- 8:2 fluorotelomer sulfonic acid (8:2 FTSA)
l/l
">-
ru
Fluorotelomer carboxylic
acids (FTCAs)
-CH2COOH
- 2H, 2H, 3H, 3FI-perfluorooctanoic acid (5:3 FTCA)
- 2H, 2H, 3H, 3FI-perfluorodecanoic acid (7:3 FTCA)
O
L_
o
3
Fluorotelomer alcohols
(FTOHs)
-CH2CH2OH
- 6:2 fluorotelomer alcohol (6:2 FTOFI)
^>-
o
Q.
Perfluoroalkane
sulfonamido
substancesd
N-Alkyl FASAs
-S02N(R')
where R' = CmH2m+i
(m = 1, 2,4)
- N-methyl perfluorooctane sulfonamide (NMePFOSA)
- N-ethyl perfluorooctane sulfonamide (NEtPFOSA)
3-5
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3—PFAS Overview
Table 2. Nonpolymer PFAS Included in Collected Discharge Data and EPA's Cross-Agency PFAS Research List
Subclass
Group
Subgroup
General Chemical
Structure3
CnF2n+iR, where R =
PFAS Chemicals3
Perfluoroalkane
sulfonamido ethanols
(FASEs) and N-Alkyl FASEs
-S02N(R')CH2CH20H
where R' = CmFi2m+i
(171 = 0, 1, 2, 4)
- N-methyl perfluorooctane sulfonamido ethanol (NMeFOSE)
- N-ethyl perfluorooctane sulfonamido ethanol (NEtFOSE)
Perfluoroalkane
sulfonamido acetic acids
(FASAAs) and N-Alkyl
FASAAs
-S02N(R')CH2C00H
where R' = CmH2m+i
(171 = 0, 1, 2, 4)
- N-methyl perfluorooctane sulfonamido acetic acid (NMeFOSAA)
- N-ethyl perfluorooctane sulfonamido acetic acid (NEtFOSAA)
Per- and
polyfluoroalkyl
ether acids (PFEAs)
Per-and polyfluoroalkyl
ether carboxylic acids
(PFECAs)
Varies by Chemical
- Fiexafluoropropylene oxide dimer acid (FIFPO-DA)
- 4,8-dioxa-3FI-perfluorononanoic acid (DONA)
-Ammonium 4,8-dioxa-3FI-perfluorononanoate (ADONA)
- Sodium dodecafluoro-3FI-4, 8-dioxanonanoate (NaDONA)
- Perfluoromethoxypropyl carboxylic acid (PMPA)
- Perfluoro-2-methoxyacetic acid (PFMOAA)
- Perfluoro-3,6-dioxaheptanoic acid (NFDHA)
- Perfluoro-3,5-dioxahexanoic acid (PF02FixA)
- Perfluoro-3,5,7-trioxaoctanoic acid (PF030A)
- Perfluoro-3,5,7,9-tetraoxadecanoic acid (PF04DA)
- Perfluoro-3,5,7,9,ll-pentaoxadodecanoic acid (PF05DA)
- Perfluoro-4-isopropoxybutanoic acid (PFECA-G)
Per-and polyfluoroalkyl
ether sulfonic acids
(PFESAs)
Varies by Chemical
- 9-chlorohexadecafluoro-3-oxanone-l-sulfonic acid (9CI-PF30NS)
- Potassium 9-chlorohexadecafluoro-3-oxanonane-l-sulfonate (K-9CI-
PF30NS)
- ll-chloroeicosafluoro-3-oxaundecane-l-sulfonic acid (11CI-
PF30UdS)
- Potassium ll-chloroeicosafluoro-3-oxaundecane-l-sulfonate (K-
HCI-PF30UdS)
- Perfluoro-3,6-dioxa-4-methyl-7-octene-l-sulfonic acid (PFESA-BP1)
- Perfluoro-2-{[perfluoro-3-(perfluoroethoxy)-2-propanyl]oxy}ethane
sulfonic acid (PFESA-BP2)
Chemical Structure Abbreviations: C - carbon; H - hydrogen; N - nitrogen; 0 - oxygen; S - sulfur.
a - For purposes of this report, EPA presents all PFAS names and chemical structures as the neutral/acid form. Under typical environmental conditions, many PFAS are present in the anionic form,
b - PFCAs and PFSAs are denoted using the structural shorthand PFXY where: PF = perfluoro, X = length of the carbon chain (e.g., 0 for octane or 8 carbons), and Y = the functional group (e.g., A for
carboxylic acids and S for sulfonic acids) (ITRC, 2020). The number of carbons in the chain is presented in parentheses.
c -The table identifies short-chain PFCAs (<7 carbons) and short-chain PFSAs (<5 carbons) in blue text, while long-chain PFCAs (>8 carbons) and long-chain PFSAs (>6 carbons) are designated in red
text.
d - Potential PFCA and PFSA precursor,
e - Potential PFCA precursor.
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3—PFAS Overview
3.1.2 Polymer PFAS
Polymer PFAS are large molecules formed by combining many identical smaller molecules (monomers) in a
repeating pattern. Nonpolymer PFAS may be used in the manufacture of some polymer PFAS (either as raw
materials or processing aids), included in polymer products as impurities, or released during incineration or
degradation. This preliminary report discusses three subclasses of polymer PFAS: fluoropolymers,
perfluoropolyethers (PFPEs), and side-chain fluorinated polymers.
Fluoropolymers contain a carbon-only polymer backbone with fluorine directly attached to the backbone. They
are not typically made from nonpolymer PFAS raw materials; however, nonpolymer PFAS have been used as
processing aids in the polymerization of certain fluoropolymers. Certain high-molecular weight fluoropolymers,
including polytetrafluoroethylene (PTFE) and ethylene tetrafluoroethylene (ETFE), are chemically and thermally
stable, insoluble in water, and less bioavailable. Based on current information, the molecules of these
fluoropolymers are believed to be too large to cross cell membranes and are therefore believed to pose less risk
to human and ecological health relative to nonpolymer PFAS (Chemours, 2021; Henry et al., 2018).
Perfluoropolyethers (PFPEs) contain carbon and oxygen polymer backbones with fluorine directly attached to the
carbon. PFPEs are believed to have thermal and chemical stability and are not typically soluble in water. PFPEs are
not made from long-chain PFAAs or their potential precursors, nor are long chain PFAAs involved in their
manufacture.
Side-chain fluorinated polymers contain a nonfluorinated polymer backbone from which fluorinated side chains
branch. Some may degrade to PFAAs when the point of connection of a fluorinated side-chain to the polymer is
broken (OECD, 2013).
3.2 Phase Out and Replacement of Certain Long-Chain PFAS with Short-Chain PFAS
Until recently (early 2000s), industry primarily used long-chain PFAS, such as PFOS and PFOA, in the manufacture
of commercial products. Due to evidence of long-term persistence and adverse health outcomes associated with
long-chain PFAS, EPA's Office of Chemical Safety and Pollution Prevention, Office of Pollution Prevention and
Toxics (EPA OPPT) has taken a range of regulatory actions under the Toxic Substances Control Act (TSCA) to gather
health and exposure information on, require testing of, and control PFAS in manufacturing and consumer
products. EPA's efforts to address PFAS through TSCA include, but are not limited to, the following:
• In 2000, EPA worked with the 3M Company (3M) to support the company's voluntary phase out and
elimination of PFOA, PFOS, and other specific long-chain PFAAs from production and use. 3M reported that it
had completed most of the phase out by 2002, with full completion by 2008.
• In 2006, EPA launched the PFOA Stewardship Program which resulted in the voluntary phase out of long-
chain PFCAs and their precursors (i.e., PFOA, higher homologues of PFOA, and their precursors) by eight
major chemical manufacturers and processors by year-end 2015. Companies participating in the PFOA
Stewardship Program were Arkema, Asahi Glass Company (AGC), Ciba/BASF Corporation, Clariant
Corporation, Daikin Industries (Daikin), 3M/Dyneon, DuPont du Nemours (DuPont), and Solvay (formerly,
Solvay Solexis).
• Between 2002 and 2020, EPA issued Significant New Use Rules (SNURs) to require manufacturers (including
importers) and processors of certain long-chain PFAS to notify EPA at least 90 days before starting or
resuming significant new uses of these chemicals. These SNURs prohibit companies from manufacturing,
importing, or using certain long-chain PFAS in the United States without prior EPA review and approval.
• EPA's July 2020 SNUR closed an important loophole that previously allowed products containing certain PFAS
that have been phased out in the United States to be imported into the nation. The SNUR leveled the playing
field for companies that had already voluntarily phased-out the use of long-chain PFAS under EPA's PFOA
Stewardship Program by preventing new uses of these phased-out chemicals.
Although manufacture and import of certain long-chain PFAS and precursors effectively ceased as result of EPA's
actions under TSCA, products containing these chemicals that were manufactured or imported before 2020 may
still be in use. While manufacture of long-chain PFAS is restricted in the United States, Europe, and Japan, their
manufacture continues in China, India, Russia, and other countries.
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3—PFAS Overview
EPA's TSCA Chemical Substance Inventory lists over 1,000 PFAS, approximately half of which are known to be
commercially active within the United States in the last decade. As of February 2020, EPA reviewed more than
300 of the commercially active PFAS under the New Chemicals Program, and regulated about 200 PFAS with
consent orders and/or new chemical SNURs (EPA, 2020b).
The phase out and increasing concerns regarding persistence, bioaccumulation, and health effects of certain long-
chain PFAAs has led many manufacturers to develop replacement technologies. Manufacturers have developed
alternative processes and chemistries to substitute for these long-chain PFAS, including nonfluorinated chemicals,
short-chain PFCAs and PFSAs, and PFAS chemistries that do not degrade to long-chain PFAAs. The list below
presents several examples of alternative short-chain PFAS that manufacturers have developed and used to
replace long-chain PFAS:
• HFPO-DA (one chemical used in the DuPont/Chemours GenX technology) and ADONA (one chemical used in a
3M technology) are replacements for PFOA as a polymerization aid in the production of fluoropolymers and
PFPEs.5 Transition to the GenX- and ADONA-based processing aid technologies began in 2009 as part of
industry's commitment under the PFOA Stewardship Program to work toward the elimination of certain long-
chain PFAAs and precursors from emissions and products by 2015.
• Short-chain PFCAs (PFBA, PFPeA, PFHxA, PFHpA) and short-chain PFSAs (PFBS, PFPeS) are replacements for
PFOA and PFOS in chemical coatings, additives, and surface treatments. For example, PFBS (a four-carbon
homologue of the eight-carbon PFOS) replaced PFOS in 3M's Scotchgard™ stain repellent.
• Fluorotelomer-based substances with six or less fully fluorinated carbons (e.g., 6:2 FTSA, 6:2 FTOH) are
replacements for long-chain PFAAs and their precursors in aqueous film-forming foam (AFFF) and food
contact materials requiring water and oil resistance or nonstick properties.
• Fluorotelomer-based substances with six or less fully fluorinated carbons (e.g., 6:2 FTSA) and chlorinated
PFESAs (e.g., 9-chlorohexadecafluoro-3-oxanone-l-sulfonic acid and ll-chloroeicosafluoro-3-oxaundecane-l-
sulfonic acid) are replacements of PFOS used as metal plating mist and fume suppressants. The substances 9-
chlorohexadecafluoro-3-oxanone-l-sulfonic acid (9CI-PF30NS), ll-chloroeicosafluoro-3-oxaundecane-l-
sulfonic acid (HCI-PF30UdS), and their potassium salts are also known as "F-53B" chemicals.6
Many short-chain PFAS-based replacement chemicals are structurally similar to their predecessors and
manufactured by the same companies. Replacement short-chain PFAS may be used in higher quantities than long-
chain PFAS to achieve the same desired properties (Blepp et al., 2017; Blum et al., 2015).
Chemical property information is publicly available for only a few alternative PFAS chemistries; very few health,
toxicity, and hazard assessments have been performed for these chemicals (Blum et al., 2015). As part of this
study, EPA conducted a preliminary review of four short-chain PFAS adopted by industry to replace PFOA and
PFOS. Section 3.4 summarizes current information and data on advisory standards, toxicity, bioaccumulation and
persistence, and degradation of PFOA, PFOS, PFBS, 6:2 FTSA, 6:2 FTOH, and HFPO-DA.
3.3 Environmental Fate and Transport of PFAS
Short- and long-chain PFAS enter the environment through manufacturing and during use and disposal of
consumer items. According to ATSDR, PFAS have been found worldwide in surface water, groundwater, finished
drinking water, rainwater, soils, sediments, ice caps, outdoor and indoor air, plants, animal tissue, and human
blood serum. The highest environmental concentrations of long- and short-chain PFAS are found in surface water,
groundwater, soils, and sediments around facilities that have produced or used PFAS (ATSDR, 2021). According to
the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), fresh waters near
5 The Chemours Company (Chemours) is a July 2015 spinoff of the former DuPont performance chemicals business unit. GenX is the trade
name for a fluoropolymer processing aid technology that is associated with two chemicals, HFPO-DA and its ammonium salt, also referred
to as "GenX" chemicals.
6 The trade name "F-53B" refers specifically to a single chemical, 9CI-PF30NS, but the name is often used to encompass 9CI-PF30NS, minor
impurities such as the homologue HCI-PF30UdS, and their potassium salts. The major and minor components of F-53B are sometimes
referred to as "F-53B major" (9CI-PF30NS) and "F-53B minor" (HCI-PF30UdS).
3-8
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3—PFAS Overview
industrial sites have documented PFAS concentrations ranging up to 1,000 nanograms per liter (ng/L). Oceanic
concentrations of PFAS are several orders of magnitude lower, ranging from 0.01 to 0.1 ng/L (ASTSWMO, 2015).
EPA used the Unregulated Contaminants Monitoring Rule 3 (UCMR3) to collect data for contaminants suspected
to be present in drinking water, but that do not have health-based standards set under the Safe Drinking Water
Act. As part of UCMR3, EPA sampled drinking water for six PFAS (PFOS, PFOA, PFNA, PFHxS, PFHpA, and PFBS)
between 2013 and 2015 (EPA, 2017a). EPA's UCMR3 monitoring indicated that public water systems in 33 states
serving 16.5 million residents had detectable levels of long- and short-chain PFAS. Sixty-six public water systems
serving more than 6 million people were found to have at least one sample above 70 ng/L, EPA's lifetime health
advisory (LHA) value for the sum of PFOA and PFOS in drinking water (Hu et al., 2016). See Section 3.4 for more
information regarding EPA's LHA values for PFAS.
Owing to their chemical and thermal stability, some long- and short-chain PFAS can withstand heat, acids, bases,
reducing agents, and oxidants and, as a result, are not readily degradable by most natural processes. As discussed
in Section 3.2, manufacturers that have phased out certain long-chain PFAS have replaced them with alternative
PFAS chemistries, including short-chain PFCAs and PFSAs, and PFAS that do not degrade to long-chain PFAAs.
Some short-chain PFAS are as persistent in the environment as their long-chain homologues (Wang et al., 2013)
although other short-chains degrade much faster.
3.4 PFAS Exposure and Health Effects
This section summarizes information on exposure and adverse human health effects of certain PFAS. Research in
this field is ongoing and information presented in this section represents the current state of knowledge based on
EPA's review of technical literature, EPA toxicity assessments, ATSDR toxicological profiles, the United States
Department of Commerce National Oceanic and Atmospheric Administration (NOAA) Chemical Aquatic Fate and
Effects (CAFE) database (NOAA, 2019), and the United States Department of Health and Human Services National
Institutes of Health (NIH) Toxicology Data Network (TOXNET) (NIH, 2019).
There are a variety of ways that individuals may be exposed to PFAS. Known exposure routes for PFAS include
(ATSDR, 2021; EPA, 2016a, 2016b):
• Consumption of drinking water from contaminated public water systems or private wells.
• Consumption of contaminated fish.
• Consumption of crops grown in contaminated soils, particularly in agricultural areas that receive amendments
of biosolids from POTWs.
• In utero exposure.
• Consumption of contaminated breast milk by infants.
• Inhalation and ingestion of contaminated indoor dust.
• Direct contact with products treated with PFAS, such as food papers/packaging and treated carpets.
For the general population, contaminated drinking water and food are the most frequently documented routes of
exposure to long- and short-chain PFAS. There is evidence that exposure to certain PFAS can lead to adverse
health outcomes in animals and humans. If animals or humans ingest PFAS-contaminated food or water, the PFAS
are absorbed, and can accumulate in the body. Certain PFAS, such as PFOA and PFOS, may stay in the human
body for longer than 10 years. As individuals become exposed to PFAS from different sources over time, the level
of PFAS in their bodies may increase to the point where they suffer from adverse health effects (ATSDR, 2021).
In May 2016, EPA established an LHA value at 70 ng/L for the sum of PFOA and PFOS to protect the public from
these potential adverse health effects resulting from exposure to PFOA and PFOS in drinking water. EPA's LHA
values are based on the best available peer-reviewed studies of the effects of PFOA and PFOS on laboratory
animals (rats and mice) and were also informed by epidemiological studies of human populations that have been
exposed to PFAS (EPA, 2021d). EPA's LHA values are not legally enforceable; they provide technical information
on drinking water contaminants to federal, state, and local officials, and managers of public or community water
systems to assist them with protecting public health (EPA, 2018b). In 2021, EPA initiated a proposal to establish
3-9
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3—PFAS Overview
enforceable National Primary Drinking Water Regulations for PFOS and PFOA. This process will include evaluating
the need for enforceable maximum contaminant levels (MCLs) for PFOA and PFOS.
As discussed in Section 3.2, industry has effectively ceased manufacturing and using certain long-chain PFAS and
is substituting with short-chain PFAS. Less information about the toxicity and bioaccumulation of short-chain PFAS
is available compared to long-chain PFAS. EPA reviewed information on the toxicity, bioaccumulation, and
degradation potential for four short-chain PFAS (6:2 FTSA, 6:2 FTOH, PFBS, and HFPO-DA) adopted by industry to
replace long-chain PFAS. Table 3 summarizes available information for these four short-chain PFAS, as well as for
PFOA and PFOS for comparison. EPA notes that complete toxicity, bioaccumulation, and human half-life
information is not available for all substances; EPA presents draft values where final values are not yet available
(e.g., HFPO-DA toxicity values). See the Short-Chain PFAS Review: Fact Sheet for 6:2 FTSA, 6:2 FTOH, PFBS, and
HFPO-DA for additional information (ERG, 202Id).
The informational categories in the first column of Table 3 are defined below:
• Current Industrial Applications. Describes use of the PFAS by the five point source categories assessed.
• Chronic Reference Dose (RfD). An estimate of the daily oral exposure for a chronic duration to the human
population that is likely to be without an appreciable risk of deleterious effects during a lifetime. Generally
used in EPA's noncancer health assessments and expressed in weight of substance per unit weight of
organism per day (e.g., mg/kg-day). The lower the chronic RfD, the more toxic the substance.
• Oral Median Lethal Dose (LD50). A statistically derived single dose that can be expected to cause death in 50
percent of the test animals when administered by the route indicated (oral, dermal, inhalation). It is
expressed as a weight of substance per unit weight of animal (e.g., mg/kg). The lower the LD50, the more
acutely toxic the substance.
• Toxicity Effects. Describes types of adverse health effects observed in humans or test animals following
exposure to the substance.
• Bioaccumulation Factors (BAF). The ratio of the concentration of a contaminant in an organism to the
concentration in the ambient environment at steady state, where the organism can take in the contaminant
through ingestion with its food as well as through direct contact. EPA OPPT characterizes a chemical as
bioaccumulative if it has a bioconcentration factor (BCF) or BAF greater than or equal to 1,000. EPA OPPT
characterizes a chemical as very bioaccumulative if it has a BCF or BAF greater than or equal to 5,000 (EPA,
2017b).
• Human Half-Life. The time required for human biological processes to naturally eliminate half the amount of a
substance initially measured in blood serum.
• Degradation Products. Terminal products observed following degradation of the organic substance.
While information on human health effects of the four short-chain PFAS is limited, studies current when this
preliminary report was written suggest 6:2 FTSA, 6:2 FTOH, PFBS, and HFPO-DA demonstrate less risk to overall
human health and less potential for bioaccumulation, relative to PFOA and PFOS. However, EPA has documented
these short-chain PFAS are present in industrial discharges, are environmentally persistent, and do demonstrate
potential for adverse impacts to ecological and human health receptors. Additional findings from EPA's
preliminary review of these four short-chain PFAS, PFOA, and PFOS are listed below:
• PFBS, PFOA, and PFOS have lower reported minimum chronic RfD and oral LD50 values than 6:2 FTSA, 6:2
FTOH, and HFPO-DA. This suggests PFBS, PFOA, and PFOS may have higher chronic and acute toxicity.
• PFOA and PFOS meet EPA OPPT's criteria for designation as "very bioaccumulative" and "bioaccumulative,"
respectively. The four short-chain PFAS do not meet these criteria.
• Human half-life identified for PFBS is estimated as 43.8 days as compared to more than 2 years for PFOA and
PFOS, which suggests PFBS is less bioaccumulative.
• Fluorotelomers readily degrade and transform through multiple complex mechanisms. Terminal end products
for 6:2 FTSA and 6:2 FTOH include short-chain PFCAs and FTCAs (do not degrade to PFOA or PFOS); some of
these degradation products may be environmentally and biologically persistent (Kabadi et al., 2018, 2020).
• Available information suggests PFBS and HFPO-DA are stable under ambient environmental conditions.
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3—PFAS Overview
Table 3. Summary of Draft and Final Health Effects Information for Short-Chain PFAS, PFOA, and PFOS
6:2 FTSA
6:2 FTOH
PFBS
HFPO-DA
PFOA
PFOS
Current Industrial
Applications
Modern AFFF, food
contact substances,
and metal finishing
mist and fume
Modern AFFF, food
contact substances,
and intermediate in
chemical/resin
Chemical coatings,
additives and
surface treatments
(e.g., 3M
Polymerization aid
in production of
fluoropolymers and
PFPEs
Manufacture, use,
and import
restricted in the
United States
Manufacture, use,
and import
restricted in the
United States
suppressants
manufacturing
Scotchga rd™)
Chronic RfD
(mg/kg-day)
None identified
None identified
0.0003
0.00008 a
0.00002
0.00002
Oral LD50
(mg/kg)
300-2,000
1,750-2,000
430
1,730-1,750 b
430 - 680
251-579
Toxicity Effects
Skin irritation,
kidney and liver
effects
Kidney, liver,
immune system,
and developmental
effects
Thyroid, liver,
kidney,
developmental, and
reproductive
effects
Liver, kidney,
immune system,
hematological,
developmental, and
carcinogenic effects
Liver, kidney,
reproductive,
developmental, and
carcinogenic effects
Liver, kidney,
thyroid, immune
system,
developmental,
cardiovascular, and
carcinogenic effects
Bioaccumulation
Factors (BAF)
None identified
None identified
< 10
< 10 (tissue value)a
7,670
1,900
Human Half-Life
None identified
None identified
43.8 days
None identified
2.1 - 10.1 years
3.3 - 27 years
Degradation
Products
5:3 FTCA, PFPeA,
PFHxA
5:3 FTCA, PFPeA,
PFHxA
Environmentally
stable (no natural
degradation)
Environmentally
stable (no natural
degradation)
Environmentally
stable (no natural
degradation)
Environmentally
stable (no natural
degradation)
References
NASF, 2019a
EPA 2021v
Kabadi et al., 2018,
2020
Rice et al., 2020
EPA, 2021v
AECOM, 2019
ASTDR, 2021
Dupont, 2008
EPA, 2018c
ATSDR, 2021
EPA, 2016a, 2018a,
ATSDR, 2021
EPA, 2016b, 2018a,
EPA, 2021u, 2021v
2021v
2021v
a - Draft values from EPA's 2018 draft Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its Ammonium Salt (CASRN13252-13-6 and CASRN 62037-80-3)
(EPA, 2018c). Values subject to change; final GenX values anticipated in late 2021.
b -The oral median lethal doses (LD50s) were 1,730 mg/kg and 1,750 mg/kg in male rats and female rats, respectively. In these rat and mouse studies, animals received a single dose in the
dose range of 175-5,000 mg/kg HFPO-DA and were assessed for effects for 14 days (DuPont, 2008; EPA, 2018c).
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4—Data Collection Activities
4. Data Collection Activities
This section describes the data sources EPA collected and evaluated as part of the Multi-Industry PFAS Study,
provides information on data quality, and describes how EPA handles and safeguards confidential business
information (CBI).
4.1 Data Sources and Quality
EPA gathered available data and reached out to stakeholders to identify facilities producing or using PFAS,
determine wastewater characteristics, estimate PFAS in wastewater discharges, and identify effective PFAS
control practices and treatment technologies. Table 4 describes each data source EPA consulted as part of the
study and summarizes how each was used. EPA considered the accuracy, reliability, and representativeness of the
data sources listed in Table 4 to assess their usability for the Multi-Industry PFAS Study, as described below.
Accuracy. EPA assumed that data and information contained in supporting government publications or databases,
peer-reviewed journal articles, and other technical literature are sufficiently accurate to support the general
characterization of industries, sources, wastewater discharges, and treatment associated with PFAS, as well as
human health impacts and environmental fate, transport, and exposure pathways of PFAS. EPA considered the
data and information obtained from direct correspondence with individual companies, industry trade
associations, and state government representatives and regulators as sufficiently accurate to characterize and
quantify specific PFAS wastewater discharges or related process operations from individual facilities.
Reliability. EPA used the following criteria to evaluate the reliability of available data and other information
collected and used in its analyses:
• The work is clearly written, so that all assumptions and methodologies can be identified.
• The variability and uncertainty (quantitative and qualitative) of the information, or the procedures, measures,
methods, or models used to compile the information, are evaluated and characterized.
• The assumptions and methods are consistently applied throughout the analysis, as reported in the source.
• Wastestreams, analytes, units, and analytical limitations (when appropriate) are clearly characterized.
• The contact is reputable and has knowledge of the industry, facility, processes, and/or wastestreams of
interest.
EPA considered data sources that met these criteria sufficiently reliable to characterize and understand
industries, sources, and wastewater discharges associated with PFAS.
Representativeness. EPA evaluated whether data and information were characteristic of PFAS discharges and
impacts across industries or sources and were relevant to and representative of typical operations relevant to
PFAS.
EPA considered data sources that met these criteria of being sufficiently accurate, reliable, and representative to
characterize industries, sources, and wastewater discharges and treatment associated with PFAS, as well as
human health impacts and environmental fate, transport, and exposure pathways of PFAS.
4-1
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4—Data Collection Activities
Table 4. Multi-Industry PFAS Study Data Sources
Data Source
Description
Use in Study
EPA Data Sets and Coordination \
2016 Chemical Data
Reporting (CDR) Database
The CDR rule, under TSCA, requires manufacturers (including importers) to
provide EPA with information on the production and use of chemicals in
commerce. The information is collected every four years from
manufacturers and importers of certain chemicals when production volumes
exceed specified thresholds for a specific reporting year. EPA accessed CBI
CDR data reported in 2016 for chemicals listed in EPA's Cross-Agency PFAS
Research List, including facility names and locations and volumes of
chemicals for production, import, and use of PFAS. The CDR information
reported in 2016 reflects the most recent data set available and reflect
production volumes from 2012 through 2015 (EPA, 2021b).
Estimate PFAS production volumes,
identify companies and facilities
manufacturing or importing PFAS, and
identify industrial and commercial uses of
PFAS.
2019 and 2020 Discharge
Monitoring Reports (DMR)
EPA downloaded DMR data for PFAS from the Integrated Compliance
Information System National Pollutant Discharge Elimination System for
2019 and 2020 usinR the online Water Pollutant Loading Tool. The data
include pollutant discharge information (e.g., types and concentrations) and
discharge flow rate data for direct dischargers with PFAS effluent limitations
or monitoring requirements in their NPDES permits (EPA, 2020c, 2021c).
Evaluate wastewater characteristics,
estimate facility and industry PFAS
concentrations, and identify facilities with
NPDES permit requirements for PFAS.
industrial Wastewater
Treatment Technology
(IWTT) Database
EPA's IWTT database contains information on treatment technology
advances identified through EPA's Annual Reviews. As part of its screening of
industrial wastewater discharges, EPA reviews literature regarding the
performance of new and improved industrial wastewater treatment
technologies and enters the data into its IWTT database (EPA, 2021e).
Identify technologies used to remove PFAS
from wastewaters.
Drinking Water Treatability
Database (DWTD)
EPA's DWTD is a compilation of research articles on contaminants found in
drinking water sources and treatment technologies for drinking water
treatment plants. The DWTD includes PFAS removal performance data for an
assortment of treatment technologies and 37 PFAS (EPA, 2021f).
Identify PFAS treatment technologies and
assess PFAS removal performance.
EPA's Office of
Enforcement and
Compliance Assurance
EPA met with EPA's Office of Enforcement and Compliance Assurance and
received industry data submittals, reports, and sampling data for three
companies that manufacture or process PFAS (EPA, 2020d).
Identify unit operations, PFAS effluent
limitations or monitoring requirements,
and wastewater treatment in place. Used
to determine wastewater characteristics
and estimate PFAS in wastewater
discharges.
EPA's Office of Chemical
Safety and Pollution
Prevention, Office of
Pollution Prevention and
Toxics (EPAOPPT)
EPA met and coordinated with EPA's OPPT to discuss and collect PFAS data
available in the TSCA Chemical Substance Inventory and 2016 CDR database
(EPA, 2020f, 2021b).
Collect information on PFAS discussed in
this report. Identify commercially active
PFAS and companies and facilities
manufacturing or importing these PFAS, as
well as associated production volumes.
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4—Data Collection Activities
Table 4. Multi-Industry PFAS Study Data Sources
Data Source
Description
Use in Study
Previous Rulemaking
Materials and EPA
Publications
EPA obtained supporting documentation from previous EPA actions and
rulemakings associated with PFAS and the industrial categories included in
the Multi-Industry PFAS Study. These development documents contain
findings, conclusions, and data on industry profiles, PFAS use and
restrictions, and PFAS control and treatment technologies. Materials
collected included, but are not limited to, existing ELGs, National Emission
Standards for Flazardous Air Pollutants (NESFIAP), SNURs, PFOA Stewardship
Program status reports, EPA PFAS toxicology assessments, EPA's Interim
Guidance on PFAS Disposal and Destruction, and technology technical briefs
prepared by EPA's PFAS Innovative Treatment Team (PITT).
Background information on the population
and processes of the five industrial point
source categories and on the impacts of
current government programs and
regulations related to PFAS.
Information from Other Federal Agencies \
United States Department
of Transportation, Federal
Aviation Administration
(FAA)
EPA met with the FAA to discuss PFAS-containing AFFF use at airports. EPA
collected materials related to the military specifications for AFFF used at
commercial airports and FAA guidance for AFFF use and control (ERG,
2020a).
Background on PFAS use by commercial
airports and FAA activities to control PFAS.
United States Department
of Health and Fluman
Services, Food and Drug
Administration (FDA)
EPA collected and reviewed FDA-funded studies and food contact substance
notifications (FCNs) for PFAS approved for used in food contact materials
(FDA, 2020, 2021; Kabadi et al., 2018, 2020; Rice et al., 2020).
Background information on the use of
PFAS in food-contact materials.
Information from States and Regions \
National Pollutant
Discharge Elimination
System (NPDES) Permits,
Permit Applications, and
Fact Sheets
The CWA requires direct dischargers to control their discharges according to
limitations, monitoring, and requirements included in NPDES permits. EPA
obtained and reviewed copies of NPDES permits and, where available,
accompanying permit applications and fact sheets for facilities discharging
PFAS in the five industrial point source categories. Information contained in
permit materials includes onsite wastewater treatment processes, outfall
descriptions, and destinations of wastewater discharges.
Identify unit operations, PFAS effluent
limitations or monitoring requirements,
and wastewater treatment in place.
Michigan Department of
Environment, Great Lakes,
and Energy (Ml EGLE)
EPA met with Ml EGLE and local wastewater authorities on several occasions
between 2019 and 2021. EPA received or downloaded multiple documents
and data sets including PFAS survey materials, reports summarizing Ml
EGLE's efforts to identify sources of and address PFAS, and effluent
analytical data for direct and indirect discharges (ERG, 2019a, 2019b, 2019c;
Ml EGLE, 2020a, 2020b, 2020c, 2020d; Ml GLWA, 2019).
Identify unit operations, PFAS effluent
limitations or monitoring requirements,
and wastewater treatment in place. Used
to determine wastewater characteristics
and estimate PFAS in wastewater
discharges.
EPA Region 3
On February 26, 2020, EPA Region 3 submitted a field sampling investigation
report containing effluent data for a Sartomer (a division of Arkema) PFAS
production plant in West Chester, Pennsylvania. The sampling was
performed to confirm PFAS levels in a surface water and determine if the
Sartomer facility was the source of PFAS (EPA Region 3, 2019).
Determine wastewater characteristics and
estimate PFAS in wastewater discharges.
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4—Data Collection Activities
Table 4. Multi-Industry PFAS Study Data Sources
Data Source
Description
Use in Study
New Jersey Department of
Environmental Protection
(NJ DEP)
EPA met with NJ DEP and received effluent analytical data and/or the NPDES
permit materials for two facilities that manufacture or process PFAS (NJ DEP,
2015, 2018, 2020).
Identify unit operations, PFAS effluent
limitations or monitoring requirements,
and wastewater treatment in place. Used
to determine wastewater characteristics
and estimate PFAS in wastewater
discharges.
Wisconsin Department of
Natural Resources (Wi
DNR)
EPA met with the WI DNR to discuss sources of PFAS in the state of
Wisconsin (ERG, 2020b).
Identify companies and facilities
discharging PFAS in Wisconsin.
Information from Industry \
American Chemistry
Council (ACC) and ACC
FluoroCouncil
EPA met with the ACC and members of the ACC FluoroCouncil and collected
materials relevant to the production and use of PFAS in the United States as
well as assessments of certain PFAS (ERG, 2019d).
Background on PFAS manufacture and
processing in the United States, to identify
PFAS currently in the domestic market, and
to identify specific companies and facilities
that manufacture or process PFAS.
The Chemours Company
(Chemours)
EPA met with Chemours (a July 2015 spinoff of the former DuPont
performance chemicals business unit) and received materials from the
company including presentations, technical papers, materials associated
with a consent order for one Chemours PFAS manufacturing facility, and
effluent analytical data and the NPDES permit for another Chemours PFAS
manufacturing facility (ERG, 2019e; Chemours, 2020a; NJ DEP, 2018).
Identify unit operations, PFAS effluent
limitations or monitoring requirements,
and wastewater treatment in place. Used
to determine wastewater characteristics
and estimate PFAS in wastewater
discharges.
3M
EPA met with 3M and received materials from the company, including an
industry report on fluorochemical production, procedures for a direct
injection analytical method for PFAS, wastewater treatment diagrams,
NPDES permits, and effluent analytical data for three 3M facilities that
manufacture or process PFAS (ERG, 2019f; 3M, 2020a, 2020b).
Identify unit operations, PFAS effluent
limitations or monitoring requirements,
and wastewater treatment in place. Used
to determine wastewater characteristics
and estimate PFAS in wastewater
discharges.
Daikin
EPA met with Daikin America, a subsidiary of Daikin, to discuss manufacture,
formulation, and discharge of PFAS (ERG, 2019g).
Identify unit operations, PFAS effluent
limitations or monitoring requirements,
and wastewater treatment in place.
AGC
EPA met with AGC Chemicals Americas, a wholly owned subsidiary of AGC, to
discuss manufacture, formulation, and discharge of PFAS. AGC Chemicals
Americas stated that they do not operate any facilities domestically that
manufacture PFAS; however, they do have at least one facility that processes
PFAS (ERG, 2019h).
Identify companies and facilities
manufacturing or importing PFAS.
National Association for
Surface Finishing (NASF)
EPA met with NASF and collected materials related to the use and toxicity of
PFAS in metal finishing operations (ERG, 2020c; NASF, 2019a, 2019b, 2019c).
Background on PFAS use by the metal
finishing industry and to assess toxicity,
bioaccumulation, and persistence of PFAS.
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4—Data Collection Activities
Table 4. Multi-Industry PFAS Study Data Sources
Data Source
Description
Use in Study
American Forest and
Paper Association (AF&PA)
EPA met with the AF&PA and several member companies to discuss sources
and classifications of PFAS, including AF&PA member companies that use
PFAS and the potential to discharge PFAS into the environment. AF&PA
submitted information on the use and discharge of PFAS in four subsequent
data submissions and facilitated outreach with specific member companies
(ERG, 2020d; AF&PA, 2020a, 2020b, 2020c, 2020d).
Background on PFAS use by the pulp,
paper, and paperboard industry, to identify
unit operations and products associated
with PFAS, and determine wastewater
characteristics.
Ahlstrom-Munksjo USA
Inc. (Ahlstrom-Munksjo)
EPA met with Ahlstrom-Munksjo to discuss use and discharge of PFAS by the
company's pulp, paper, and paperboard facilities. Ahlstrom-Munksjo
currently uses PFAS in the manufacture of food contact paper and packaging
for five facilities in the United States. Ahlstrom-Munksjo is transitioning all
production to PFAS-free formulations in the next few years (EPA, 2021g).
Background on PFAS use by the pulp,
paper, and paperboard industry and to
identify facilities using PFAS.
Georgia Pacific, LLC
(Georgia-Pacific)
EPA met with Georgia-Pacific to discuss use and discharge of PFAS by the
company's pulp, paper, and paperboard facilities. Georgia-Pacific
discontinued application of PFAS to paper and packaging products more
than a decade ago. In 2021, Georgia-Pacific completely discontinued
purchase, conversion, and distribution of PFAS-treated paper and packaging
products (EPA, 2021h).
Background on PFAS use by the pulp,
paper, and paperboard industry and to
identify facilities using PFAS.
Graphic Packaging
International
EPA met with Graphic Packaging International to discuss use and discharge
of PFAS by the company's pulp, paper, and paperboard facilities. Graphic
Packaging International currently uses PFAS in the manufacture of food
contact paper and packaging at a single facility in the United States, but will
discontinue PFAS use at this facility by end of 2021 (EPA, 2021i).
Background on PFAS use by the pulp,
paper, and paperboard industry and to
identify facilities using PFAS.
WestRock Company
EPA met with WestRock Company to discuss use and discharge of PFAS by
the company's pulp, paper, and paperboard facilities. WestRock Company
discontinued application of PFAS to paper and packaging products across all
United States mills in 2020 (EPA, 2021j).
Background on PFAS use by the pulp,
paper, and paperboard industry and to
identify facilities using PFAS.
Sappi North America, Inc.
(Sappi)
EPA met with Sappi to discuss use and discharge of PFAS by the company's
pulp, paper, and paperboard facilities. Sappi currently uses PFAS in the
manufacture of food contact packaging at a single facility in the United
States, but will discontinue use at this facility by 2024 (EPA, 2021m).
Background on PFAS use in the pulp,
paper, and paperboard industry and to
identify facilities using PFAS.
Domtar Corporation
Domtar Corporation submitted a letter to EPA with information on the use
of PFAS by the company's pulp, paper, and paperboard facilities. Domtar
Corporation notified EPA that one mill was using PFAS in the manufacture of
food contact paper and packaging in 2021; however, this mill has closed and
none of the remaining United States facilities use PFAS (Domtar Corporation,
2021).
Identify companies and facilities
manufacturing or importing PFAS.
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4—Data Collection Activities
Table 4. Multi-Industry PFAS Study Data Sources
Data Source
Description
Use in Study
International Paper
Company
Domtar Corporation submitted a letter to EPA confirming the company does
not use PFAS in manufacturing products at United States mills and does not
sell or import into the United States products with PFAS intentionally added
(International Paper Company, 2021).
Identify companies and facilities
manufacturing or importing PFAS.
Airport Council
International - North
America
EPA met with the Airport Council International - North America to discuss
use and composition of PFAS-containing AFFF and efforts to reduce/control
releases (ERG, 2020e).
Background on AFFF use at commercial
airports and potential release of PFAS.
National Association of
Clean Water Agencies
(NACWA)
EPA met with the NACWA to discuss industrial producers and users of PFAS,
treatment technologies, and POTW concerns related to PFAS (ERG, 2019i).
Background on organizations or companies
collecting PFAS effluent and treatment
technology data.
Other Sources \
Scientific and Academic
Literature
As part of targeted literature reviews, EPA collected peer-reviewed and
technical literature relevant to PFAS manufacture, release,
sampling/analysis, treatment, toxicity, degradation, bioaccumulation,
persistence, and other topics.
Obtain information on the five industrial
point source categories, PFAS manufacture
and use, and PFAS characteristics.
Conferences/Webinars
EPA participated in and obtained information from multiple conferences and
virtual webinars relevant to PFAS manufacture, release, sampling/analysis,
treatment, toxicity, degradation, bioaccumulation, persistence, and other
topics.
Obtain information on the five industrial
point source categories, PFAS manufacture
and use, and PFAS characteristics.
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4—Data Collection Activities
4.2 Protection of Confidential Business Information
Certain data in the study record have been claimed as CBI or enforcement sensitive materials. As required by
federal regulations at 40 CFR Part 2, EPA has taken precautions to prevent the inadvertent disclosure of this CBI.
The agency has withheld CBI from the public docket in the Federal Docket Management System and available on
www,regulations.gov. In addition, EPA has found it necessary to withhold from disclosure some data not claimed
as CBI because the release of these data could indirectly reveal CBI. Where necessary, EPA has aggregated certain
data in the public docket, masked plant identities, or used other strategies to prevent the disclosure of CBI. The
agency's approach to protecting CBI ensures that the data in the public docket explain the basis for the study and
provide the opportunity for public comment without compromising data confidentiality.
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5—Review of the OCPSF Point Source Category
5. Review of the OCPSF Point Source Category
This section describes the OCPSF point source category, information and data EPA collected on its production and
use of PFAS, and EPA's estimates of types and concentrations of PFAS discharged by OCPSF facilities that
manufacture or formulate PFAS. EPA focused on PFAS manufacturers and PFAS formulators for its review of the
OCPSF point source category in this study. EPA collected and reviewed information on PFAS manufacture, use,
and discharge by this subset of OCPSF facilities from the sources below.
• Outreach with chemical manufacturers, industry trade associations, and state and local wastewater
authorities.
• The agency's Chemical Data Reporting (CDR) database.
• Discharge Monitoring Report (DMR) data available in EPA's Water Pollutant Loading Tool.
• Reports and data collected from industry and state and local wastewater authorities.
• Wastewater discharge permits.
• Industry submissions associated with PFAS consent orders and enforcement activities.
• Publicly available technical literature.
5.1 Industry Description, Manufacture, and Use of PFAS
The OCPSF point source category includes more than 1,000 facilities that manufacture certain organic chemicals,
plastics, and synthetic fibers and related products. The industry is diverse with many complex unit operations and
specialized manufacturing facilities that process raw materials into thousands of different products. OCPSF
facilities operate continuous processes as well as batch operations with a wide range of production volumes.
EPA promulgated the OCPSF Effluent Guidelines (40 CFR Part 414) in 1987, with technical amendments in 1989,
1990, 1992, and 1993. The OCPSF ELGs apply to process wastewater discharges resulting from the manufacture
of seven products or product groups (40 CFR Part 414 Subparts B to H) at facilities included within specified
United States Department of Commerce Bureau of the Census Standard Industrial Classification system (SIC)
groups. Table 5 summarizes the manufactured products and SIC groups applicable to each subpart. The OCPSF
ELGs apply to facilities that manufacture PFAS and may apply to facilities that use PFAS in production of applicable
products or product groups; however, these regulations do not establish effluent limitations or pretreatment
standards for any PFAS. See EPA's Product and Product Group Discharges Subject to Effluent Limitations and
Standards for the OCPSF Point Source Category - 40 CFR 414 report for additional information on applicability,
effluent limitations and pretreatment standards, and wastewaters subject to the OCPSF ELGs (EPA, 2005).
Table 5. Applicability of 40 CFR Part 414 Subparts to Manufacture of Products and Product Groups
40 CFR Part 414 Subpart
Manufactured Products and Applicable SIC Groups3
B - Rayon Fibers
Applies only to cellulosic manmade fiber (Rayon) manufactured by the Viscose®
process, generally classified and reported under SIC group 2823.
C - Other Fibers
Applies to all other synthetic fibers (except Rayon) generally classified and
reported under SIC groups 2823 or 2824.
D - Thermoplastic Resins
Applies to any plastic generally classified and reported under SIC group 28213.
E - Thermosetting Resins
Applies to any plastic generally classified and reported under SIC group 28214.
F - Commodity Organic
Chemicals
Applies to commodity organic chemicals and commodity organic chemical groups
generally classified and reported under SIC groups 2865, 2869, or 2899.
G - Bulk Organic
Chemicals
Applies to bulk organic chemicals and bulk organic chemical groups generally
classified and reported under SIC groups 2865, 2869, or 2899.
H - Specialty Organic
Chemicals
Applies to all other organic chemicals and groups not specifically listed in Subparts
F or G that are classified and reported under SIC groups 2865, 2869, or 2899.
SIC group key: 28213 (Thermoplastic Resins); 28214 (Thermosetting Resins); 2823 (Cellulosic Man-Made Fibers); 2824 (Synthetic Organic
Fibers, Except Cellulosic); 2865 (Cyclic Crudes and Intermediates, Dyes, and Organic Pigments); 2869 (Industrial Organic Chemicals, Not
Elsewhere Classified); 2899 (Miscellaneous Chemicals).
a -This SIC group listing is provided as a guide. See 40 CFR Part 414 for precise applicability and definitions of the OCPSF regulations.
5-1
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5—Review of the OCPSF Point Source Category
The OCPSF point source category includes a broad range of sectors, raw materials, and unit operations that may
manufacture or use PFAS. EPA identified that some OCPSF facilities manufacture PFAS through electrochemical
fluorination, fluorotelomerization, or other processes. EPA identified six facilities in the OCPSF point source
category that manufacture PFAS. For purposes of the Multi-Industry PFAS Study, EPA refers to these facilities as
"PFAS manufacturers." The PFAS feedstocks may be further processed on site or transferred to other facilities
where they are blended, converted, or integrated with other materials to produce new commercial or
intermediate products. EPA identified that some OCPSF facilities use PFAS feedstocks as polymerization
processing aids or in the production of plastic, rubber, resin, coatings, and commercial cleaning products. For the
purpose of this study, EPA refers to facilities that are the primary customers of PFAS manufacturers and that use
PFAS feedstocks to produce commercial goods or intermediary products as "PFAS formulators."
EPA focused on PFAS manufacturers and PFAS formulators for its review of the OCPSF point source category in
this study. Table 6 lists domestic OCPSF facilities that EPA identified as PFAS manufacturers or PFAS formulators
through outreach and information collected from chemical manufacturers, industry trade associations, and state
and local wastewater authorities (described in Section 5.2) and describes PFAS manufacturing operations for
each. These facilities produce products that have broad application in the industrial and consumer market. EPA
notes that Table 6 includes major PFAS manufacturing sites EPA has identified thus far and is not a comprehensive
list of all OCPSF facilities manufacturing or using PFAS in the United States.
EPA evaluated available information and data on the number, type, and volume of PFAS that are manufactured or
imported to the United States using data reported by industry to EPA under the TSCA and industry literature. As
of February 2020, EPA's TSCA Chemical Substance Inventory of active chemicals contains a total of 606 active
PFAS (EPA, 2020b, 2020g). However, the inventory reflects substances in commerce between 2006 and 2016 so it
includes long-chain PFAS now restricted in the United States and does not include any PFAS that have entered
commerce since. The CDR rule, under the TSCA, requires manufacturers (including importers) to provide EPA with
information on the production, import, and use of chemicals in commerce.7 EPA evaluated the 2016 CDR
database for PFAS in EPA's Cross-Agency PFAS Research List and determined that 118 of these PFAS were
reported between 2012 and 2015 (EPA, 2021a, 2021b). The six PFAS manufacturers presented in Table 6 reported
domestic manufacture or import of 76 individual PFAS. EPA notes that the 2016 CDR database does not reflect a
holistic view of the total United States volume of PFAS manufactured and used because these data are reported
as ranges in the database and facilities are exempt from reporting requirements if they have annual sales below
$4 million, do not meet the reporting threshold of 25,000 pounds, imported the chemical as part of an article, or
manufactured the chemical in a manner described in 40 CFR 720.30(g) or (h).
EPA also evaluated industry literature to assess the number of PFAS that are currently manufactured. A recent
study (Buck et al., 2021) conducted by representatives of three global fluorochemical producers - AGC,
Chemours, and Daikin - concluded that 256 PFAS were offered for sale as commercial products, ingredients, or
degradation products (including components and impurities) in December 2019. The study authors classified the
majority of PFAS reported as PFEAs or PFPEs (34 percent); short-chain fluorotelomers or fluorotelomer-based
side-chain fluorinated polymers (28 percent); or fluoropolymers (15 percent) (Buck et al., 2021). EPA determined
the study did not provide a comprehensive account of the number, type, and volume of PFAS manufactured in or
imported into the United States due to the following limitations:
• The results reflect only a subset of manufacturers which do not practice electrochemical fluorination (does
not account for PFAS produced by other companies or by electrochemical fluorination).
• The list of 256 PFAS reported were not identified in the study and may include PFAS only in commerce
outside of the United States.
• No production volume, commercial product names, use/functionality, or alternatives were assessed.
EPA contacted industry to seek more information on the list of 256 PFAS reported but did not receive additional
information. However, the industry did provide EPA with an economic assessment of the United States
7 Manufacturers and importers must report to the CDR database if they meet certain annual volume thresholds, typically 25,000 pounds,
but 2,500 pounds for chemicals subject to certain TSCA actions. The information is collected every four years. The CDR information
reported in 2016 (2016 CDR) reflects the most recent data set available and includes production volumes from 2012 to 2015.
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5—Review of the OCPSF Point Source Category
fluoropolymer industry, which estimated 85,000 tons of fluoropolymers are produced and 77,500 tons are sold in
the United States each year (Wood, 2020a).
Based on information and data derived from the data sets described above, EPA estimates that at least 118 PFAS
are active in the United States market and 85,000 tons of PFAS are produced domestically each year.
Table 6. OCPSF Facilities Identified as PFAS Manufacturers or PFAS Formulators
Facility Name
Location
Description of PFAS Manufacture
PFAS Manufacturers \
3M Cordova Plant
Cordova, Illinois
Manufactures specialty fluorochemicals used in electronics,
cleaning supplies, lubricant depositions, and antistatic
polymers.
3M Decatur Plant
Decatur, Alabama
Manufactures fluoropolymers, fluoroelastomers,
fluoroplastics, and flame-retardant polymers.
Chemours Chambers
Works
Deepwater, New
Jersey
Manufactures fluoropolymers, fluoroelastomers,
fluoromonomers, PFPEs, fluorotelomers, and PFAS
intermediates.
Chemours Fayetteville
Works
Fayetteville, North
Carolina
Manufactures PFPEs, fluoropolymers, fluoromonomers, and
polymerization aids used for the GenX technology.
Chemours Washington
Works
Parkersburg, West
Virginia
Manufactures fluoropolymers and fluorotelomers.
Daikin Decatur Plant
Decatur, Alabama
Manufactures fluoropolymers and fluorotelomer-based
substances.
PFAS Formulators \
3M Cottage Grove Plant
Cottage Grove,
Minnesota
Processes PFAS feedstocks from 3M's Decatur, Alabama and
Cordova, Illinois plants.
AGC Chemicals Americas
Thorndale,
Pennsylvania
Processes fluoropolymers and fluorinated solvents that are
manufactured internationally (no polymerization occurs in
the United States).
DuPont Circleville Plant
Circleville, Ohio
Converts PFAS intermediates into fluoropolymer resin and
film products.
DuPont Spruance Plant
Richmond, Virginia
Converts PFAS intermediates to produce PTFE fiber.
DuPont/Chemours
Montague Plant
Montague,
Michigan
Unknown.
Arkema/Sartomer
Production Plant
West Chester,
Pennsylvania
Processes fluoropolymers, such as PVDF.
Solvay Specialty Polymers
USA, LLC
West Deptford,
New Jersey
Processes fluoroelastomers and perfluoroelastomers.
5.2 Stakeholder Outreach
EPA met with industry stakeholders and state and local wastewater authorities, who voluntarily provided
information on the manufacture, use, and discharge of PFAS by OCPSF facilities. EPA used this information to
assess the volume and types of commercially produced PFAS and to understand better how to quantify and
control PFAS discharges.
Outreach to the OCPSF industry included meeting with the American Chemistry Council (ACC) FluoroCouncil, a
former subsidiary organization within the ACC that represented the world's leading manufacturers of fluorinated
chemistries, and member companies AGC, Chemours, Daikin, and Solvay (ERG, 2019d). ACC provided EPA with
technical literature concerning PFAS terminology and classification, a list of short-chain fluorotelomers studies, an
economic assessment of the United States fluoropolymer industry, and contacts at 3M, Chemours, and Daikin,
which they identified as the only PFAS manufacturing companies in the United States. The ACC FluoroCouncil
disbanded in April 2020 and was superseded by two new groups:
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5—Review of the OCPSF Point Source Category
• The Performance Fluoropolymer Partnership, which represents the world's leading companies that
manufacture, formulate, or process fluoropolymers, fluoroelastomers, and polymeric perfluoropolyethers.
Members include AGC, Chemours, Daikin, and Gujarat Fluorochemicals.
• The Alliance for Telomer Chemistry Stewardship, which represents leading manufacturers of six-carbon
fluorotelomer-based products in North America, Europe, and Japan. Members include AGC, Daikin, Dynax
Corporation, and Johnson Controls, Inc.
EPA met with representatives of 3M, AGC, Chemours, and Daikin and each company provided EPA with
information on PFAS manufacture as well as operations and wastewater treatment data for their United States
facilities (ERG, 2019e, 2019f, 2019g, 2019h). EPA also contacted other chemical manufacturers that voluntarily
participated in the phased elimination of specific long-chain PFAS through the PFOA Stewardship Program:
Arkema, BASF Corporation, Clariant Corporation, and Solvay. Clariant Corporation notified EPA that in 2013 it
divested its fluorotelomer business to an independent entity now known as Archroma and that Clariant
Corporation no longer manufactures PFAS (ERG, 2020f). EPA did not receive any additional information from
Archroma, Arkema, BASF Corporation, or Solvay.
EPA met with the wastewater permitting authorities from the Wisconsin Department of Natural Resources (Wl
DNR); New Jersey Department of Environmental Protection (NJ DEP); Michigan Department of Environment,
Great Lakes, and Energy (Ml EGLE); and two large wastewater authorities in Michigan with POTWs that are
investigating potential sources of PFAS wastewater. All provided EPA with wastewater permit materials and/or
PFAS sampling results from PFAS manufacturers and PFAS formulators operating in their jurisdictions (ERG,
2019a, 2019b, 2019c, 2020b; NJ DEP 2015, 2018, 2020).
5.3 PFAS Wastewater Regulatory Requirements and Controls
EPA collected and reviewed NPDES wastewater discharge permits for the PFAS manufacturers and PFAS
formulators listed in Table 6. EPA also collected publicly available materials associated with PFAS-related consent
orders for the Chemours Fayetteville Works and 3M Decatur facilities. EPA reviewed these materials to identify
effluent limitations or monitoring requirements for PFAS and assess current practices for managing PFAS-
containing wastewaters. Table 7 summarizes PFAS wastewater regulatory requirements and existing PFAS control
technologies and practices.
The National Defense Authorization Act for Fiscal Year 2020 established reporting requirements for 172 PFAS
under the Toxics Release Inventory (TRI) program. An additional three PFAS were added for reporting year 2021.
By July 1, 2021, facilities will have to report PFAS releases, including discharges to water, of any of 175 PFAS that
they manufacture, process, or use above a 100-pound reporting threshold. EPA will review 2020 TRI data
reported for PFAS once this information is publicly available.
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5—Review of the OCPSF Point Source Category
Table 7. PFAS Wastewater Regulatory Requirements and Controls for PFAS Manufacturers and PFAS Formulators
Facility Name
Location
PFAS Wastewater Regulatory Requirements
Existing PFAS Wastewater Controls3
PFAS Manufacturers \
3M Cordova Plant
Cordova, Illinois
- NPDES permit IL0003140 establishes quarterly
monitoring requirements for 14 PFAS.b
- No effluent limitations for PFAS.
- No known PFAS wastewater controls.
3M Decatur Plant
Decatur,
Alabama
" NPDES permit AL0000205 establishes quarterly
monitoring requirements for 11 PFAS.b
- 2020 consent order will require monitoring
requirements for 33 PFAS.
- No effluent limitations for PFAS.
- Granular activated carbon (GAC) treatment for
directly discharged process wastewater and
indirectly discharged fluoroelastomer washing
water, as required by 2020 consent order.
- Developing wastewater minimization plan and
evaluating PFAS control technologies to further
reduce PFAS discharged to wastewater
treatment plant, as required by 2020 consent
order.
Chemours Chambers Works
Deepwater,
New Jersey
- NPDES permit NJ0005100 establishes weekly
monitoring requirements for 16 PFAS.
- No effluent limitations for PFAS.
- Powdered activated carbon (PAC) systems are in
place, but not actively used to treat directly
discharged process wastewater.
Chemours Fayetteville
Works
Fayetteville,
North Carolina
- NPDES permit NC0003573 establishes
monitoring requirements for PFOA.
- 2019 consent order prohibits discharge of
Chemours' process wastewaters.
- NPDES permit NC0089915 establishes biweekly
monitoring requirements for HFPO-DA,
PFMOAA, PMPA, and 56 additional PFAS for
nonprocess wastewaters discharged via an old
process wastewater outfall.
- NPDES permit NC0089915 establishes effluent
limitations for HFPO-DA, PFMOAA, and PMPA
for nonprocess wastewaters discharged via an
old process wastewater outfall.
- Chemours' process wastewater is captured and
disposed off site via deep well injection or
incineration. The only process wastewater
discharged comes from Chemours' tenants
DuPont and Kuraray.
-As of November 2020, the facility was
conducting a pilot study to evaluate PFAS
removal from process wastewater using a
treatment train consisting of two-stage reverse
osmosis (RO), GAC, and ion exchange (IX)
(Chemours, 2020b).
- GAC treatment for contaminated nonprocess
wastewaters to achieve 99% reduction of
certain PFAS, as required by 2019 consent
order.
- Thermal oxidizer and thermolysis reactor to
control PFAS air emissions.
Chemours Washington
Works
Parkersburg,
West Virginia
- NPDES permit WV0001279 establishes effluent
limitations for APFO and HFPO-DA.
- NPDES permit WV0001279 establishes
monitoring requirements for 8 PFAS.
- Thermal oxidizer to control PFAS air emissions.
- GAC treatment for directly discharged process
wastewater.
- Plans to install additional treatment units to
meet future PFAS effluent limitations.
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5—Review of the OCPSF Point Source Category
Table 7. PFAS Wastewater Regulatory Requirements and Controls for PFAS Manufacturers and PFAS Formulators
Facility Name
Location
PFAS Wastewater Regulatory Requirements
Existing PFAS Wastewater Controls3
Daikin Decatur Plant
Decatur,
Alabama
- NPDES permit AL0064351 establishes quarterly
monitoring requirements for 7 PFAS.b
- No effluent limitations for PFAS.
- GAC treatment for directly discharged
fluoropolymer/polymerization process
wastewater.
- Fluorotelomerization process wastewater is
incinerated off site (no discharge).
PFAS Formulators \
3M Cottage Grove Plant
Cottage Grove,
Minnesota
- NPDES permit MN0001449 establishes monthly
monitoring requirements for 14 PFAS.
- No effluent limitations for PFAS.
- Hazardous waste incinerator.
- Regenerative thermal oxidizer and scrubber to
control PFAS air emissions.
- GAC treatment for process wastewaters.
AGC Chemicals Americas
Thorndale,
Pennsylvania
- Unknown.
- No known PFAS wastewater controls.
DuPont Circleville Plant
Circleville, Ohio
- NPDES permit OH0006327 establishes
monitoring requirements for PFOA.
- No effluent limitations for PFAS.
- No known PFAS wastewater controls.
DuPont Spruance Plant
Richmond,
Virginia
- NPDES permit VA0004669 establishes quarterly
monitoring requirements for PFOA.
- No effluent limitations for PFAS.
- No known PFAS wastewater controls.
DuPont/Chemours
Montague Plant
Montague,
Michigan
- NPDES permit MI0000884 establishes quarterly
monitoring requirements for 4 PFAS.
- No effluent limitations for PFAS.
- No known PFAS wastewater controls.
Arkema/Sartomer
Production Plant
West Chester,
Pennsylvania
- No monitoring requirements or effluent
limitations for PFAS.
- No known PFAS wastewater controls.
Solvay Specialty Polymers
USA, LLC
West Deptford,
New Jersey
- NPDES permit NJ0005185 establishes weekly
monitoring requirements for 12 PFAS.
- No effluent limitations for PFAS.
- No known PFAS wastewater controls.
a - Conventional wastewater treatment methods (e.g., primary settling, physical-chemical treatment, neutralization, biological treatment, clarification) are not demonstrated to be
effective controls for PFAS and are not presented in this table. See Section 10 for additional information on performance of wastewater treatment technologies,
b -The referenced NPDES permit has an expiration date that has passed but the permit is administratively extended.
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5—Review of the OCPSF Point Source Category
5.4 Wastewater Characteristics
EPA evaluated available data on types and concentrations of PFAS in wastewater discharged from PFAS
manufacturers and PFAS formulators. EPA summarized the limited information available and calculated average
PFAS concentrations in effluent from these facilities based on 2019 DMR, 2020 DMR, industry-submitted,
enforcement, and state and regional permitting authority data.
EPA identified analytical data that meet EPA's acceptance criteria for inclusion in analyses for characterizing PFAS
in industrial wastewater discharges. EPA's acceptance criteria are presented in the memorandum "Development
of the Multi-Industry PFAS Study Analytical Database" (ERG, 2021a). EPA identified seven sources of effluent
sampling and monitoring data from PFAS manufacturers and OCPSF PFAS formulators that meet EPA's acceptance
criteria:
• PFAS monitoring results reported in 2019 and 2020 DMRs (EPA, 2020c, 2021c).
• 2018 - 2019 PFAS monitoring results for three 3M facilities (3M, 2020a).
• 2020 PFAS monitoring results for Chemours Chambers Works (Chemours, 2020a).
• Ml ELGE 2020 PFAS monitoring results for direct discharge facilities (Ml EGLE, 2020b).
• NJ DEP PFAS monitoring data for Solvay Specialty Polymers USA, LLC in West Deptford, New Jersey (NJ DEP,
2020).
• An EPA Region 3 field sampling investigation report titled PFAS Screening of Goose Creek & Goose Creek
Industrial Users (EPA Region 3, 2019).
• PFAS effluent sampling results submitted by PFAS manufacturers to EPA's Office of Enforcement and
Compliance (EPA, 2020d).
EPA included 6,006 PFAS sample results representing all six PFAS manufacturers and 735 PFAS sample results
representing six of seven PFAS formulators in its analysis characterizing PFAS in effluent from PFAS manufacturers
and PFAS formulators. EPA calculated facility-level average, minimum, and maximum concentrations for each
PFAS with available data using the following assumptions and limitations:
• EPA assumed all nondetection results and results below the level of quantification (i.e., the reporting or
quantification limitation) were zero.8
• EPA did not have information on analytical method sensitivity and level of quantification for all data.
• EPA did not know the operations or treatment processes online at the facilities at the time of sampling.
• EPA does not have information on whether the observed PFAS concentrations are from legacy use of PFAS,
current use of PFAS, or formation from degradation of more complex PFAS.
EPA calculated an overall average, minimum, and maximum concentration for each PFAS based on the facility-
level results. EPA did not estimate average concentrations for any PFAS that were not detected at or above the
level of quantification across all facilities or did not have any data.
Table 8 presents the average, minimum, and maximum concentrations for each PFAS in PFAS manufacturer and
PFAS formulator effluent. As illustrated in the table, average PFAS concentrations in PFAS manufacturer effluent
were higher than in PFAS formulator effluent for all PFAS except PFNA and PFUnA. Average concentrations for
short-chain PFCAs and PFSAs were generally higher relative to long-chain PFCAs and PFSAs for both PFAS
manufacturers and formulators.
8 The lower level of quantification is the lowest concentration that the analytical method being used can measure accurately.
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5—Review of the OCPSF Point Source Category
Table 8. PFAS Manufacturer and PFAS Formulator PFAS Wastewater Concentrations
PFAS Manufacturers
PFAS Formulators
PFAS Subgroup
Analyteab
Quantified
Detections/
Total Sample
Results
Concentration
Range
(l-ig/L)
Average
Concentration
(l-ig/L)
Quantified
Detections/
Total Sample
Results
Concentration
Range
(l-ig/L)
Average
Concentration
(l-ig/L)c
PFCAs
PFBA
68/71
ND-2,390
153
24/25
ND - 177
41.7
PFPeA
78/95
ND-20
2.49
24/24
0.169-4.08
0.829
PFHxA
234/255
ND - 45
6.93
50/50
0.0022-0.519
0.111
PFHpA
220/246
ND - 26
1.50
34/62
ND - 0.112
0.0167
PFOA
1,235/1,367
ND - 430
3.77
60/73
ND - 1.6
0.116
APFO
709/747
ND - 450
3.27
1/2
ND-0.013
0.0065
PFNA
145/164
ND - 1.19
0.224
26/62
ND - 14
0.883
PFDA
120/125
ND - 1.5
0.271
25/50
ND-0.088
0.0112
PFUnA
32/74
ND - 0.09
0.0129
26/49
ND - 0.27
0.0401
PFDoA
96/125
ND - 0.14
0.0182
0/50
ND
ND
PFTrA
39/74
ND-0.039
0.00416
2/50
ND-0.0011
0.0000404
PFTeA
31/58
ND - 0.04
0.00315
0/26
ND
ND
PFHxDA
5/13
ND-0.012
0.00218
No Data
PFODA
4/13
ND-0.0044
0.000892
No Data
PFSAs
PFBS
188/194
ND - 777
6.49
26/62
ND - 17.6
2.77
PFPeS
4/14
ND-0.013
0.000901
No Data
PFHxS
214/245
ND - 28.6
0.510
26/62
ND-0.466
0.057
PFHpS
1/14
ND-0.0022
0.0000917
No Data
PFOS
58/76
ND - 21.2
3.37
49/63
ND - 0.153
0.034
PFNS
0/14
ND
ND
No Data
PFDS
0/14
ND
ND
No Data
FASAs
PFOSA
97/169
ND - 76.3
0.756
0/24
ND
ND
FTSAs
4:2 FTSA
0/14
ND
ND
No Data
6:2 FTSA
3/14
ND-0.022
0.00177
No Data
8:2 FTSA
0/14
ND
ND
No Data
N-Alkyl FASAs
NMePFOSA
0/13
ND
ND
No Data
NEtPFOSA
0/13
ND
ND
No Data
FASEs and
N-Alkyl FASEs
NMeFOSE
0/13
ND
ND
No Data
NEtFOSE
0/13
ND
ND
No Data
FAS A As and
N-Alkyl FASAAs
NMeFOSAA
70/107
ND - 112
2.92
No Data
NEtFOSAA
70/107
ND - 118
3.21
No Data
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5—Review of the OCPSF Point Source Category
Table 8. PFAS Manufacturer and PFAS Formulator PFAS Wastewater Concentrations
PFAS Manufacturers
PFAS Formulators
PFAS Subgroup
Analyteab
Quantified
Detections/
Total Sample
Results
Concentration
Range
(l-ig/L)
Average
Concentration
(l-ig/L)
Quantified
Detections/
Total Sample
Results
Concentration
Range
(l-ig/L)
Average
Concentration
(Hg/L)c
HFPO-DA
1,098/1,180
ND - 530
8.00
No Data
NaDONA
0/13
ND
ND
No Data
PMPA
0/3
ND
ND
No Data
PFMOAA
5/31
ND - 0.34
0.123
No Data
PFECAs
NFDHA
0/3
ND
ND
No Data
PF02HxA
0/31
ND
ND
No Data
PF030A
0/31
ND
ND
No Data
PF04DA
0/31
ND
ND
No Data
PF05DA
0/31
ND
ND
No Data
PFECA-G
0/31
ND
ND
No Data
K-9CI-PF30NS
0/13
ND
ND
No Data
PFESAs
K-llCI-PF30UdS
0/13
ND
ND
No Data
PFESA-BP1
0/31
ND
ND
No Data
PFESA-BP2
0/31
ND
ND
No Data
Sources: ERG, 2021b.
Abbreviations: ND-nondetection; |ig/L-micrograms per liter.
a -This table presents data for all PFAS listed in Table 2 for which sample results are available and meet EPA's acceptance criteria. See the PFAS Analytical Database for additional results
for the following 11 PFAS not discussed in this preliminary report: 10:2 FTSA, PFEESA, FBSA, PFDoS, Hydro-EVE Acid, EVE Acid, PEPA, NVHOS, PFESA Byproduct 4, PFESA Byproduct 5, PFESA
Byproduct 6.
b -The table identifies short-chain PFCAs (<7 carbons) and short-chain PFSAs (<5 carbons) in blue text, while long-chain PFCAs (>8 carbons) and long-chain PFSAs (>6 carbons) are
designated in red text.
c - In this analysis, EPA treated all nondetection results as zero for the purpose of estimating concentrations. All concentration values are rounded to three significant figures.
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5—Review of the OCPSF Point Source Category
5.5 OCPSF Point Source Category Summary
Based on information and data EPA collected for the Multi-Industry PFAS Study, EPA documented that PFAS have
been, and continue to be, manufactured and used by OCPSF facilities in the United States. The type and quantity
of PFAS manufactured and used vary by facility and have changed over time. Through outreach and data collected
from industry, EPA identified six OCPSF facilities that manufacture PFAS in the United States through
electrochemical fluorination, fluorotelomerization, or other processes. The PFAS feedstocks may be further
processed on site or transferred to other facilities where they are blended, converted, or integrated with other
materials to produce new commercial or intermediate products such as plastic, rubber, resins, coatings, and
cleaning products. EPA identified seven additional OCPSF facilities that use PFAS feedstocks to formulate other
products. EPA has not developed a comprehensive list of all PFAS manufacturers and formulators in the United
States and considers it probable that there are more OCPSF facilities using PFAS that EPA has not yet identified.
Based on limited information available, EPA estimates that the OCPSF facilities in the United States manufacture
or use at least 118 PFAS and produce 85,000 tons of fluoropolymers annually.
EPA documented that the manufacture or formulation of PFAS by OCPSF facilities may generate PFAS-containing
wastewaters. EPA verified that PFAS, including legacy long-chain PFAS and replacement PFAS, are present in
wastewater discharges from PFAS manufacturers and PFAS formulators to surface waters and POTWs. Using
available PFAS monitoring data, EPA estimated the average PFAS concentrations in PFAS manufacturer effluent
were higher than average PFAS concentrations in effluent from PFAS formulators. Average concentrations for
short-chain PFCAs and PFSAs were generally higher than the average concentrations of long-chain PFCAs and
PFSAs; this was true for both PFAS manufacturers and formulators.
PFAS manufacturers and formulators have few monitoring requirements, effluent limitations, or pretreatment
standards for PFAS in their wastewater discharge permits and may continue to discharge PFAS to POTWs or
surface waters unless effective controls are in place. EPA identified some PFAS manufacturers and formulators
successfully controlling PFAS in wastewater using granular activated carbon (GAC), ion exchange (IX), reverse
osmosis (RO), and thermal treatment systems. Based on EPA's Drinking Water Treatability Database (DWTD),
these technologies are able to remove more than 99 percent on some PFAS in industrial wastewater, or
completely eliminate the discharge of wastewater containing PFAS (EPA, 2021f). See Section 10 for more
information on PFAS discharge control technologies.
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6—Review of the Metal Finishing Point Source Category
6. Review of the Metal Finishing Point Source Category
This section describes the metal finishing point source category, information and data EPA collected on its PFAS
use and discharge, and EPA's estimates of types and concentrations of PFAS discharged by facilities within the
category. EPA collected and reviewed information on PFAS use and discharge by metal finishing facilities from the
following sources:
• Outreach with an industry trade association and state and local wastewater authorities.
• Reports and data collected from industry and state and local wastewater authorities.
• Publicly available technical literature.
6.1 Industry Description and Use of PFAS
Metal finishing refers to changing the surface of an object to improve its appearance and/or durability. EPA
promulgated the Metal Finishing Effluent Guidelines (40 CFR Part 433) in 1983, with technical amendments in
1984 and 1986. The regulations cover wastewater discharges from facilities that perform one or more of the
following six metal finishing operations on any basis material:
• Electroplating.9
• Electroless plating.
• Anodizing.
• Coating (phosphating, chromating, and coloring).
• Chemical etchings and milling.
• Printed circuit board manufacture.
If a facility performs any of these six core operations, then discharges from the 46 operations listed in 40 CFR Part
433.10(a) are covered by the Metal Finishing ELGs. EPA estimates about 44,000 facilities perform metal finishing
operations and discharge process wastewater directly to United States surface waters or indirectly to surface
waters through POTWs.
The metal finishing point source category includes a broad range of sectors, raw materials, and unit operations
that may use PFAS. EPA identified that some metal finishing facilities have used, and continue to use, nonpolymer
PFAS and related products as wetting agents, mist and fume suppressants (to prevent emissions of toxic metal
fumes to air), agents to reduce mechanical wear, and surface coatings to impart specific characteristics (e.g.,
reduced corrosion, enhanced aesthetic appearance). EPA also identified that some polymer PFAS, such as PTFE,
may be used in electroless nickel plating operations (NASF, 2019b; Ml EGLE, 2020d; ITRC, 2020; Gluge et al.,
2020). PFAS used by metal finishing facilities may be transferred to wastewater streams generated by the facility
and ultimately discharged to surface waters or POTWs.
Based on studies conducted by EPA and states since 2007, the agency identified chromium electroplating and
chromium anodizing operations (collectively referred to as "chromium electroplating facilities") as the most
significant source of PFAS, particularly PFOS, in the metal finishing point source category (MPCA, 2006; EPA
Region 5, 2009; Ml EGLE, 2020d). Thus, EPA focused on chromium electroplating facilities for its review of the
metal finishing point source category in this study.
Since the 1980s, mist and fume suppressants containing 5 to 10 percent PFOS by weight were frequently used by
United States chromium electroplating facilities to control hexavalent chromium emissions (a known human
carcinogen and inhalation hazard), as required under the Clean Air Act by the National Emission Standards for
9 Metal finishing is related to electroplating, which is the production of a thin surface coating of the metal upon another by
electrodeposition. Certain electroplating processes are covered by the ELGs for the Electroplating Category (40 CFR Part 413), rather than
the ELGs for the Metal Finishing Category. These include job shop electroplaters, independent printed circuit board manufacturers, indirect
discharge electroplating facilities, and electroplating facilities in operation before July 15, 1983.
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6—Review of the Metal Finishing Point Source Category
Hazardous Air Pollutants (NESHAP) for Chromium Emissions from Hard and Decorative Chromium Electroplating
and Chromium Anodizing (40 CFR Part 63, Subpart N). The surfactant properties of PFOS reduce the surface
tension of the electrolyte solution, which limits the release of hexavalent chromium vapors to the air and thereby
reduces worker exposure. Due to concerns about human health and environmental impacts of PFOS, in 2012 EPA
amended the NESHAP to phase out the use of mist and fume suppressants containing more than 1 percent PFOS
by weight in chromium electroplating by September 21, 2015 (ITRC, 2020; NASF, 2019b; EPA, 2012a). EPA
identified the following alternative technologies adopted by industry following the restriction on PFOS-based
agents:
• Replacing PFOS-based mist and fume suppressants with fluorotelomer-based substances (e.g., 6:2 FTSA) and
chlorinated PFESAs (e.g., F-53B).10
• Replacing PFOS-based mist and fume suppressants with nonfluorinated mist and fume suppressants.
• Using mechanical controls such as enclosed lines, air jet systems, air pollution scrubbers, and closed-loop
systems to manage hexavalent chromium emissions.
• Transitioning to trivalent chromium rather than hexavalent chromium for decorative chromium
electroplating. Trivalent chromium is considered less toxic and less bioavailable relative to hexavalent
chromium. However, trivalent chromium generally cannot be used for hard chromium electroplating because
of quality differences and cost (Ml ELGE, 2020a).
Once the electroplating bath liquid can no longer be used, it may be treated to remove chromium and other
metals, but PFAS may remain present and be discharged in effluent from chromium electroplating facilities still
using PFAS-based mist and fume suppressants. Most metal finishing facilities, including those that perform
chromium electroplating, discharge wastewater to their local sewer system rather than to surface waters.
In developing the 2012 NESHAP, EPA developed a profile of the 1,339 chromium electroplating facilities operating
in the United States (652 hard chromium electroplating, 517 decorative chromium electroplating, 170 chromium
anodizing) (EPA, 2012a). Approximately 50 percent of chromium electroplating facilities apply PFAS-based mist
and fume suppressants, based on information from the 2020 Ml EGLE report titled Identified Industrial Sources of
PFOS to Municipal Wastewater Treatment Plants (Ml EGLE, 2020d).
6.2 Stakeholder Outreach
EPA met with the National Association for Surface Finishing (NASF) and Michigan wastewater authorities, who
voluntarily provided information on the use and discharge of PFAS by metal finishing facilities. NASF is a trade
association that represents the United States surface coating industry and provided EPA with information to
categorize PFAS historically and currently used in the industry. NASF estimates that 30 to 40 percent of surface
finishing facilities have chromium electroplating processes, but not all facilities have used or currently use PFAS-
based mist and fume suppressants (NASF, 2019c). Representatives from Ml EGLE and two large Michigan
wastewater authorities investigating potential sources of PFAS wastewater provided EPA with information on
current efforts to regulate and control PFAS discharges and/or PFAS sample results for metal finishing facilities
operating in those jurisdictions. As part of ongoing investigations, Ml EGLE (2020d) determined that
approximately two-thirds of sampled chromium electroplating facilities discharged PFOS exceed the Michigan
water quality standard of 12 ng/L even though mist and fume suppressants containing more than 1 percent PFOS
are no longer in use. Ml EGLE also found no detectable amounts of PFOS precursors or PFOA precursors in mist
and fume suppressant samples from 11 chromium electroplating facilities. The presence of PFOS may be due to
legacy issues, trace levels (less than 1 percent) of PFOS in modern suppressants, or, to a lesser degree, due to
degradation of other more complex PFAS (Ml EGLE, 2020a, 2020d).
6.3 PFAS Wastewater Regulatory Requirements and Controls
EPA did not identify any chromium electroplating facilities with PFAS effluent limitations or pretreatment
standards in their wastewater discharge permits. As part of Michigan's Industrial Pretreatment Program PFAS
Initiative, Ml EGLE required 95 POTWs to evaluate their industrial users as potential sources of PFOS and PFOA.
These local POTWs implemented requirements for industrial users discharging to their system to monitor for
10 EPA and Ml EGLE analysis of modern mist and fume suppressants used by 11 chromium electroplaters in Michigan showed that 6:2 FTSA
was the only detectable PFAS; PFOS and PFOS precursors were not detected in any suppressant samples evaluated (Ml EGLE, 2020a).
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6—Review of the Metal Finishing Point Source Category
PFOA and PFOS and, if effluent PFOS concentrations exceeded Michigan's screening value of 12 ng/L, implement
PFOS reduction programs. Ml EGLE reports that numerous POTWs identified chromium electroplating facilities as
sources of PFOS discharges and have required these sources to install PFAS pretreatment, such as GAC. Ml EGLE
identified six Michigan chromium electroplating facilities have lowered effluent concentrations of PFAS using GAC
(Ml EGLE, 2020d).
6.4 Wastewater Characteristics
EPA evaluated available data on types and concentrations of PFAS in wastewater discharged from chromium
electroplating facilities. EPA has not identified any facilities with PFAS monitoring requirements or effluent
limitations; therefore, no DMR data are available for PFAS. EPA summarized the limited information available and
calculated average PFAS concentrations in effluent from chromium electroplating facilities based on Michigan
permitting authority data.
EPA identified analytical data that meet EPA's acceptance criteria for inclusion in analyses for characterizing PFAS
discharges in industrial wastewater discharges. EPA's acceptance criteria are presented in the memorandum
"Development of the Multi-Industry PFAS Study Analytical Database" (ERG, 2021a). EPA identified two sources of
analytical data for chromium electroplating, both of which meet EPA's acceptance criteria: Targeted and
Nontargeted Analysis of PFAS in Fume Suppressant Products at Chrome Plating Facilities (2020 chromium
electroplating report) (Ml EGLE, 2020a) and Ml EGLE PFAS monitoring results for indirect discharge facilities (Ml
EGLE, 2020c). EPA included 1,137 PFAS sample results representing 47 chromium electroplating facilities in its
analysis characterizing PFAS in chromium electroplating wastewater.
Some wastewater sample data from the 2020 chromium electroplating report (Ml EGLE, 2020a) were collected
before adsorption treatment processes that target PFAS. EPA included these data in this preliminary analysis
because most chromium electroplating facilities do not have dedicated treatment for PFAS in place and, thus, the
samples are representative of effluent from most facilities. During discussions with EPA, NASF representatives
stated that the Ml EGLE (2020a) data are a fair representation of the industry as a whole (ERG, 2020c).
EPA calculated facility-level average, minimum, and maximum concentrations for each PFAS with available data
using the following assumptions and limitations:
• EPA assumed all nondetection results and results below the level of quantification (i.e., the reporting or
quantification limitation) were zero.11
• EPA did not have information on analytical method sensitivity and level of quantification for all data.
• EPA did not know the operations or treatment processes online at the facilities at the time of sampling.
• EPA does not have information on whether the observed PFAS concentrations are from legacy use of PFAS,
current use of PFAS, or form from degradation of more complex PFAS.
EPA calculated an overall average, minimum, and maximum concentration for each PFAS based on the facility-
level results. EPA did not estimate average concentrations for any PFAS that were not detected at or above the
level of quantification across all facilities or did not have any data.
Table 9 presents the average, minimum, and maximum concentrations for each PFAS observed in chromium
electroplating facility effluent. As illustrated in the table, EPA estimated the average wastewater concentration of
6:2 FTSA was more than 100 times greater than any other PFAS detected in chromium electroplating wastewater.
Despite the phase out of PFOS-based mist and fume suppressants, some chromium electroplating facilities still
report detectable levels of PFOS in their wastewater.
11 The lower level of quantification is the lowest concentration that the analytical method being used can measure accurately.
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6—Review of the Metal Finishing Point Source Category
Table 9. Chromium Electroplating Wastewater PFAS Concentrations
PFAS Subgroup
Analyteab
Facilities with
Data
Quantified
Detections/Total
Sample Results
Concentration
Range
(Hg/L)c
Average
Concentration
(Hg/L)c
PFCAs
PFBA
11
5/12
ND - 4.71
0.492
PFPeA
11
5/12
ND - 0.93
0.108
PFHxA
11
8/12
ND - 0.34
0.0703
PFHpA
11
8/12
ND - 0.49
0.0687
PFOA
47
51/406
ND - 0.74
0.00770
PFNA
11
0/12
ND
ND
PFDA
11
0/12
ND
ND
PFUnA
11
0/12
ND
ND
PFDoA
11
0/12
ND
ND
PFTrA
11
0/12
ND
ND
PFTeA
11
0/12
ND
ND
PFSAs
PFBS
10
7/11
ND - 19.8
2.09
PFPeS
11
2/12
ND-0.088
0.015
PFHxS
11
8/12
ND - 1.22
0.147
PFHpS
11
7/12
ND-0.323
0.0595
PFOS
47
412/456
ND - 240
4.86
PFNS
11
3/12
ND-0.043
0.00636
PFDS
11
1/12
ND-0.014
0.00127
FASAs
PFOSA
11
0/12
ND
ND
FTSAs
4:2 FTSA
11
8/12
ND - 1.39
0.229
6:2 FTSA
11
11/12
ND-3,140
532
8:2 FTSA
11
7/12
ND-0.237
0.0633
FAS A As and
N-Alkyl FASAAs
NMeFOSAA
11
0/12
ND
ND
NEtFOSAA
11
0/12
ND
ND
PFECAs
HFPO-DA
11
5/12
ND-0.065
0.0124
Sources: ERG, 2021b.
Abbreviations: ND-nondetection; |ig/L-micrograms per liter.
a -This table presents data for all PFAS listed in Table 2 for which sample results are available and meet EPA's acceptance criteria. EPA
does not have any sample results PFAS note listed.
b -The table identifies short-chain PFCAs (<7 carbons) and short-chain PFSAs (<5 carbons) in blue text, while long-chain PFCAs (>8
carbons) and long-chain PFSAs (>6 carbons) are designated in red text.
c- In this analysis, EPA treated all nondetection results as zero for the purpose of estimating concentrations. All concentration values are
rounded to three significant figures.
6.5 Metal Finishing Point Source Category Summary
Based on information and data EPA collected for the Multi-Industry PFAS Study, EPA documented that PFAS have
been, and continue to be, used by metal finishing facilities in the United States. EPA identified chromium
electroplating facilities as the most significant source of PFAS in the metal finishing point source category.
Chromium electroplating facilities use PFAS-based mist and fume suppressants to control toxic hexavalent
chromium emissions. PFOS-based mist and fume suppressants were frequently used until 2015, when EPA's
revisions to the chromium electroplating NESFIAP required chromium electroplating facilities to phase out mist
and fume suppressants containing more than 1 percent PFOS by weight. Chromium electroplating facilities have
adopted alternative technologies, including mist and fume suppressants containing fluorotelomer-based
substances (e.g., 6:2 FTSA) and chlorinated PFESAs (e.g., F-53B), to replace use of PFOS-based products. EPA
estimates that approximately half of the 1,339 chromium electroplating facilities in the United States still apply
some type of PFAS-based mist and fume suppressant.
EPA documented that the use of PFAS-based mist and fume suppressants may generate wastewaters containing
PFAS. EPA verified that PFAS, including legacy long-chain PFAS and replacement PFAS, are present in wastewater
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6—Review of the Metal Finishing Point Source Category
discharges from chromium electroplating facilities to surface waters and POTWs. Using available sampling data,
EPA estimated the average wastewater concentration of 6:2 FTSA was more than 100 times greater than any
other PFAS evaluated. 6:2 FTSA was the only PFAS detected in a 2020 Ml EGLE targeted analysis of PFAS in mist
and fume suppressants used by several facilities included in this analysis. Despite the phase out of PFOS-based
mist and fume suppressants, some chromium electroplating facilities still report detectable levels of PFOS in their
wastewater. Ml EGLE (2020d) determined that approximately two-thirds of the evaluated chromium
electroplating facilities discharged PFOS exceed the Michigan water quality standard of 12 ng/L even though mist
and fume suppressants containing more than 1 percent PFOS are no longer in use. As part of a separate study,
EPA and Ml EGLE found no detectable amounts of PFOS precursors or PFOA precursors in mist and fume
suppressant samples from 11 facilities. The presence of PFOS may be due to legacy issues, trace levels (less than 1
percent) of PFOS in modern suppressants, or, to a lesser degree, due to degradation of other more complex PFAS
(Ml EGLE, 2020a, 2020d).
EPA did not identify any chromium electroplating facilities with PFAS effluent limitations or pretreatment
standards in their wastewater discharge permit and estimates that less than 5 percent of chromium electroplating
facilities monitor for PFAS. Most chromium electroplating facilities are not monitoring for PFAS and are likely to
continue to discharge PFAS to POTWs or surface waters unless effective controls are in place. EPA identified that
at least six Michigan chromium electroplating facilities have lowered effluent concentrations of PFAS using GAC.
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7—Review of the Pulp, Paper, and Paperboard Point Source Category
7. Review of the Pulp, Paper, and Paperboard Point Source
Category
This section describes the pulp, paper, and paperboard point source category; information and data EPA collected
on the category's PFAS use and discharge; and EPA's estimates of types and concentrations of PFAS discharged by
the category. EPA collected and reviewed information on PFAS use and discharge by pulp, paper, and paperboard
facilities from the following sources:
• Outreach with pulp and paper companies, an industry trade association, and state and local wastewater
authorities.
• Reports and data collected from industry and state and local wastewater authorities.
• Publicly available technical literature.
7.1 Industry Description and Use of PFAS
The pulp, paper, and paperboard point source category includes companies and facilities that convert wood into
pulp, paper, paperboard, and other cellulose-based products. Facilities that convert wood to pulp, paper, or
paperboard are generally classified as integrated mills or nonintegrated mills. Integrated mills have the onsite
capability to convert wood into pulp, and then into paper, while nonintegrated mills only manufacture paper or
paperboard from purchased pulp. There are additional types of mills that manufacture only pulp or recycled fiber
for manufacture of various good elsewhere (e.g., market pulp mills, dissolving pulp mills, fluff pulp mills, recycled
fiber mills). There are also converting facilities which cut, fold, or otherwise convert manufactured paper into
commercial products.
EPA promulgated the Pulp, Paper, and Paperboard Effluent Guidelines (40 CFR Part 430) in 1974 and 1977, with
numerous technical amendments and revisions between 1982 and 2007. EPA estimated approximately 565 pulp,
paper, and paperboard mills operated in the United States in 1997, the time of the most recent major ELGs
rulemaking. The ELGs cover wastewater discharges from facilities which perform specified pulping processes or
manufacture specified paper products and are typically classified under four SIC groups: 2621, 2631, 2641, and
2661. The existing ELGs do not establish effluent limitations or pretreatment standards for PFAS.
PFAS have been used by pulp, paper, and paperboard facilities as an additive or coating to impart certain
surfactant qualities to finished paper products. Some facilities have manufactured high-performance paper
products, such as those requiring oil, grease, and/or moisture resistance, using additives mixed with the pulp
before it is formed into paper. Other facilities have applied coatings containing PFAS to the finished paper. PFAS
are primarily used by facilities that manufacture food contact papers and packaging (e.g., fast food wrappers,
take-out containers, bakery bags, popcorn bags, pizza boxes), but also have limited applications for specialty
paper products (e.g., carbonless forms, masking paper) (AF&PA, 2020a; WA DEC, 2021).
Chemicals used in food contact paper and packaging are regulated by the United States Department of Health
and Human Services, Food and Drug Administration (FDA) because of their potential to migrate to food. All food
contact substances (FCSs) must be approved through the food contact substance notification (FCN) program,
under which the FDA will review available migration, exposure, and human health risk data to ensure an FCS is
safe for its intended use prior to approving it for use in market. Manufacturers of chemicals approved to be used
as an FCS are permitted to market and sell these chemicals to food contact paper and packaging producers who
will use them in their products (FDA, 2020).
Since the 1960s, the FDA has authorized several broad classes of PFAS for use as FCSs, including long-chain PFAS
such as PFOS and PFOA, and more recently short-chain, fluorotelomer, and side-chain polymer PFAS. As of
December 2020, there are 17 distinct PFAS approved by the FDA for use to provide oil and grease resistance in
food contact applications. All approved PFAS are for polyfluorinated polymers, with the majority being six-carbon
side-chain fluorinated polymers and the rest being perfluoropolyethers (FDA, 2021; WA DEC, 2021).
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7—Review of the Pulp, Paper, and Paperboard Point Source Category
When the FDA identifies potential safety concerns with an FCS, the agency may work with industry to reach
voluntary market phase out agreements or revoke food contact authorizations. In 2011, the FDA worked with
three manufacturers (DuPont, Clariant Corporation, and BASF Corporation) to voluntarily end sale of several long-
chain PFAS for food contact applications. In 2016, the FDA revoked authorization for the remaining uses of long-
chain PFAS and these chemicals are no longer approved for use in food contact applications in the United States.
In July 2020, the FDA announced that four manufacturers will voluntarily phase out the use of PFAS containing or
degrading to 6:2 FTOH. The market phase out is a response to FDA research that raised questions about human
health risks for 6:2 FTOH. The four manufacturers (AGC, Chemours, Daikin, and Archroma) hold FCNs for
approximately 11 PFAS containing or degrading to 6:2 FTOH. AGC, Daikin, and Archroma agreed to a complete
market phase out of PFAS containing 6:2 FTOH by December 31, 2023; Chemours has already stopped sales of 6:2
FTOH-containing products in the United States (FDA, 2020; WA DEC, 2021).
In recent years, an increasing number of major food distributers and retailers (e.g., Sweetgreen, Chipotle,
McDonald's, Taco Bell, Whole Foods Market, Trader Joes, Kroger, Panera Bread) have announced plans to phase
out all PFAS in food contact papers and packaging in response to consumer and regulatory pressures. Several
states, including California, Maine, New York, Vermont, and Washington, are also acting to restrict use of PFAS in
these materials and identify alternative substances that provide comparable performance without use of PFAS.
Washington Department of Ecology identified the following FDA-approved alternatives to PFAS coated food
contact paper (WA DEC, 2021):
• Uncoated paper.
• Wax coated paper.
• Clay coated paper.
• Siloxane coated paper.
• Polyvinyl alcohol (PVOH) or ethylene vinyl alcohol (EVOH) copolymer coated paper.
• Polylactic acid (PLA) and PLA coated paper.
• Polyethylene (PE) or polyethylene terephthalate (PET) coated paper.
7.2 Stakeholder Outreach
EPA met with industry stakeholders and state and local wastewater authorities, who voluntarily provided
information on the use and discharge of PFAS by pulp, paper, and paperboard facilities. EPA used this information
to categorize PFAS being used in the industry, quantify PFAS in discharges, and to learn how the industry controls
PFAS discharges.
Outreach to the industry included contact with the American Forest and Paper Association (AF&PA) and
companies that historically or currently manufacture food contact paper/packing or specialty paper products.
AF&PA is a national trade association for the forest, pulp, and paper industry; its 38 member companies represent
approximately 85 percent of the pulp, paper, tissue, and paper-based packaging products manufactured in the
United States. EPA met with the AF&PA and 10 member companies in March 2020 (ERG, 2020d). AF&PA provided
four letters to EPA containing information on the use and discharge of PFAS in the pulp and paper industry
(AF&PA, 2020a, 2020b, 2020c, 2020d).
AF&PA reported that the pulp, paper, and paperboard industry phased out the use of PFOA and PFOS
approximately 10 years ago, but continues to use FDA-approved short-chain PFAS in the manufacture of food
contact packaging and specialty paper products to enhance resistance to water, oil, and grease. According to
AF&PA, PFAS is not integral to or used in the pulping process (including pulp brightening or bleaching), recycling
of paper and packaging, or manufacture of products requiring absorbency, publishing papers, newsprint, and
conventional packaging (e.g., standard corrugated boxes). AF&PA states certain PFAS may be present in process
equipment components (e.g., PTFE piping or valves), cleaners, and firefighting foam used at pulp, paper, and
paperboard facilities; however, these substances are used infrequently and in small volumes compared to raw
materials used in pulp and paper manufacturing. Additionally, AF&PA reported that some PFAS may enter the
facility through intake water or from recycled paper products that are used to create recovered pulp and fiber.
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7—Review of the Pulp, Paper, and Paperboard Point Source Category
Whether PFAS are in an additive mixed with the pulp prior to forming it into paper, or in a coating applied to the
surface of the paper after the paper is formed, AF&PA reports the majority of PFAS would remain in the final
product and not be transferred to a wastewater stream. AF&PA stated that the PFAS chemistries may be
expensive, so there is economic incentive for facilities to minimize PFAS use, minimize loss to process wastewater,
and retain as much PFAS as possible in the final product.
In 2020, AF&PA conducted a survey of their member companies regarding their use of PFAS. Nineteen AF&PA
member companies responded to the survey, representing 146 of the 171 mills operated by members. Five of the
146 mills covered by the respondents reported they intentionally use PFAS in the manufacture of pulp and paper
products as of July 2020. The five mills are operated by different companies and all reported that PFAS would be
phased out of production processes in the next three to four years. Table 10 summarizes the PFAS-containing
products produced by these mills and company plans to reduce or alter PFAS use.
Table 10. Summary of AF&PA Member Company Mills Using PFAS
Mill ID
Products and Processes Using PFAS
PFAS Phase Out Steps
A
Uses FDA-approved PFAS in products with
food service applications.
Products to be phased out in 2021, so no alternatives
to PFAS under consideration.
B
Uses FDA-approved PFAS in food packaging.
Commercial alternatives under evaluation. Other
coatings in development.
C
Uses FDA-approved PFAS in paper for food
packaging and other specialty packaging.
Production-scale trials expected for two PFAS-free
product designs.
D
Uses FDA-approved PFAS in coatings on
bleached kraft paper for specialty business
forms.
Alternative materials have been evaluated in lab,
with plans to move forward on pilot testing and
manufacturing trials.
E
Uses FDA-approved PFAS in food packaging.
Facility closed in 2021 with no plans to move
manufacture to another site in the United States.
Source: AF&PA, 2020a, 2020b, 2020c, 2020d.
The total production of paper containing PFAS for the five mills (85,000 tons) accounts for 4.3 percent of these
five mills' total paper production and roughly 0.14 percent of the mill production of all AF&PA members. AF&PA
stated that one mill, Mill E, closed in 2021 and the company no longer uses PFAS at any United States mills.
AF&PA also confirmed that no PFOA, PFOS, or GenX chemicals (including HFPO-DA) are intentionally added to the
products at the four mills that remain active. The four active mills indicated that they are either actively seeking
nonPFAS alternatives for their coatings or ending production of PFAS-containing product lines, a decision driven
by public opinion, market pressure, and regulatory measures.
AF&PA identified major producers of food contact paper and packaging or specialty paper products and provided
EPA with contact information for representatives of these companies. EPA met separately with representatives of
Ahlstrom-Munksjo USA, Inc. (Ahlstrom-Munksjo); Georgia-Pacific, LLC (Georgia-Pacific); Graphic Packaging
International, Inc. (Graphic Packaging); WestRock Company; and Sappi North America, Inc. (Sappi). Each company
provided EPA with information on their historical and current PFAS use, as well as operations and wastewater
treatment data for their United States facilities.
EPA and representatives from Ahlstrom-Munksjo discussed the company's operations at two pulp and paper mills
and two specialty paper manufacturing facilities in Wisconsin. Ahlstrom-Munksjo became a member of AF&PA
after the trade association's PFAS survey was conducted and their facilities are not included the survey results. As
of July 2021, the four Ahlstrom-Munksjo Wisconsin facilities are applying coatings containing PFAS to impart oil
and grease resistance to food service products. Two copolymer coatings, supplied by Daikin and Solvay, contain
FDA-approved PFAS and are applied to finished sheets in a closed-loop, recirculating system (excess coating is
captured and reused). To Ahlstrom-Munksjo's knowledge, no wastewaters are generated during the coating
process. Ahlstrom-Munksjo estimated that approximately 10 percent of production at the four Wisconsin plants is
manufactured using PFAS; however, Ahlstrom-Munksjo is transitioning all Wisconsin facilities to FluoroFree®
technology and 100 percent PFAS-free products, with a goal to eliminate PFAS use by end of 2023. Ahlstrom-
Munksjo stated the company also operates five additional pulp, paper, or paperboard manufacturing facilities in
other states. Of these five facilities, only one site, in Windsor Locks, Connecticut is using significant volumes of
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7—Review of the Pulp, Paper, and Paperboard Point Source Category
FDA-approved PFAS. Ahlstrom-Munksjo did not provide additional information on PFAS use at the Windsor Locks,
Connecticut facility or other facilities in the United States (Ahlstrom-Munksjo, 2021; EPA, 2021g).
Georgia-Pacific has not directly purchased or applied PFAS to paper products since 3M phased out production of
PFOA, PFOS, and other long-chain PFAS in the 2000s. Until April 2021, Georgia-Pacific continued to purchase, cut,
fold, and otherwise convert paper treated with FDA-approved PFAS into food contact products, including
sandwich wraps, take-out containers, and food trays. In April 2021, Georgia-Pacific discontinued purchasing PFAS-
treated paper, and switched to paper treated with a nonPFAS polymer blend. Based on the company's estimate at
the time, the inventory of PFAS-treated paper in the supply chain would be distributed by July 2021. Georgia-
Pacific indicated that the transition to nonPFAS alternatives was influenced by customer interest in PFAS-free
products and the company's forecast of market demand for such products. Georgia-Pacific confirmed that the
company does not own or operate any of the five mills presented in Table 10; however, the company reported
that their Packerland Plant in Green Bay, Wisconsin, purchased and converted PFAS-treated paper in 2020.
Georgia-Pacific provided EPA with PFAS monitoring data, representing effluent from two pulp, paper, and
paperboard mills in Green Bay, Wisconsin (not the Packerland Plant) and also confirmed that the company
operated two facilities represented in a sampling data set previously provided by AF&PA (EPA, 2021h).
As of June 2021, Graphic Packaging was intentionally applying PFAS-based coatings in the manufacture of food
contact paper and packaging at one facility, the Texarkana Mill in Queen City, Texas. Graphic Packaging estimates
15,000 tons of PFAS-treated product is manufactured at the Texarkana Mill annually, accounting for less than 2
percent of the mill's total annual production and less than 1 percent of the total annual production across all
Graphic Packaging facilities. Wastewater generated during the papermaking process and washing equipment is
treated at an onsite wastewater treatment plant before it is discharged to the Sulphur River. Graphic Packaging
reported that the Battle Creek Mill in Battle Creek, Michigan also intentionally applied PFAS until 2018 (zero PFAS
use since 2018). Graphic Packaging further reported that all PFAS use will be discontinued by January 1, 2022 (this
inventory will be exhausted by end of March 2022) and PFAS-based coatings will be substituted with alternative
technologies such as polymer resins and proprietary nonfluorinated coatings (EPA, 2021i).
WestRock Company historically used FDA-approved PFAS in production of food contact papers and packaging. As
of 2021, WestRock Company no longer intentionally uses PFAS in pulp, paper, and paperboard production at any
of the company's 28 mills and more than 200 converting facilities in the United States. WestRock Company
completed transition of the last facility using PFAS to nonfluorinated technologies in 2020 (EPA, 202lj).
As of July 2021, Sappi was intentionally using PFAS-based additives in food packaging applications at their
Somerset Mill, one of the company's three United States mills. The Somerset Mill is an integrated pulping and
papermaking mill in Skowhegan, Maine that uses FDA-approved PFAS to enhance grease-resistance of specialty
food packaging products. The company reported that less than 2 percent of the Somerset Mill's annual
production is manufactured using PFAS-based additives and that they account for less than 1 percent of the
weight of the food packaging products in which they are used. The PFAS additives are applied at the wet-end of
the papermaking process in one product line of grease-proof food packaging products. Wastewater generated
during the process is captured and treated at the Somerset Mill's onsite wastewater treatment plant prior to
being discharged to the Kennebec River. This treatment includes primary settling, activated sludge, and a
polishing pond prior to discharge, and does not include any treatment for PFAS chemicals specifically. Sappi
reports that the company is developing nonfluorinated additive alternatives and will eliminate PFAS use across all
product lines by 2024 (EPA, 2021m).
EPA also contacted Kimberly-Clark Corporation, Domtar Corporation, and International Paper Company to discuss
potential use of PFAS at pulp, paper, and paperboard facilities. Kimberly-Clark Corporation notified EPA that PFAS
would inhibit the high absorbency of their products and that the specialty paper business unit was spun off as a
separate entity known as Neenah Paper in 2004 (EPA, 20211). EPA attempted to contact Neenah Paper to discuss
potential use of PFAS and received no response (EPA, 2021n). Neither Kimberly-Clark Corporation or Neenah
Paper are members of AF&PA. In a June 2021 letter, Domtar Corporation notified EPA that the company's Port
Huron Mill, in Port Huron, Michigan, used FDA-approved short-chain PFAS to manufacture food contact paper
and packaging until the facility closed in March 2021. None of Domtar Corporation's remaining nine pulp, paper,
and paperboard manufacturing facilities use PFAS in production of paper-based products (Domtar Corporation,
2021). In a July 2021 letter, International Paper Company confirmed the company does not use PFAS in
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7—Review of the Pulp, Paper, and Paperboard Point Source Category
manufacturing products at United States mills and does not sell into the United States products with PFAS
intentionally added (International Paper Company, 2021).
7.3 PFAS Wastewater Regulatory Requirements and Controls
As part of the Multi-Industry PFAS Study, EPA did not identify any pulp, paper, and paperboard facilities with PFAS
effluent limitations or pretreatment standards in their wastewater discharge permits. As part of Michigan's
Industrial Pretreatment Program PFAS Initiative, Ml EGLE required 95 POTWs to evaluate their industrial users as
potential sources of PFOS and PFOA. These local POTWs implemented requirements for industrial users
discharging to their system to monitor for PFOA and PFOS and, if effluent PFOS concentrations exceeded
Michigan's screening value of 12 ng/L, implement PFOS reduction programs. Ml EGLE reports that POTWs
identified approximately ten pulp, paper, or paperboard manufacturing facilities as sources of PFOS discharges
and are collaborating with these sources to further investigate and reduce PFOS concentrations (Ml EGLE, 2020d).
7.4 Wastewater Characterization
EPA evaluated the available data on types and concentrations of PFAS in wastewater discharged from pulp, paper,
and paperboard facilities. EPA has not identified any facilities with PFAS monitoring requirements or effluent
limitations; therefore, no DMR data are available for PFAS. EPA summarized the information available and
calculated average PFAS concentrations in effluent from pulp, paper, and paperboard facilities based on industry
and state permitting authority data.
EPA identified analytical data that meet EPA's acceptance criteria for inclusion in analyses for characterizing PFAS
discharges in industrial wastewater discharges. EPA's acceptance criteria are presented in the memorandum
"Development of the Multi-Industry PFAS Study Analytical Database" (ERG, 2021a). EPA identified four sources of
PFAS analytical data for pulp, paper, and paperboard effluent:
• Ml ELGE 2020 PFAS monitoring results for direct and indirect discharge facilities (Ml EGLE, 2020b, 2020c).
• 2019 study of PFAS in industrial, municipal, and landfill leachate discharges commissioned by the Vermont
Department of Environmental Conservation (VT DEC, 2020).12
• PFOA and PFOS sampling results for Georgia-Pacific facilities located in Green Bay, Wisconsin (EPA, 2021h).
• AF&PA summary of PFAS concentrations in effluent from six unidentified pulp and paper mills, originally
collected by the National Council for Air and Stream Improvement (AF&PA, 2020c).
EPA determined that the AF&PA submission did not meet all of EPA's acceptance criteria for inclusion in analyses
for characterizing PFAS in pulp, paper, and paperboard facility discharges because results were not reported as
individual or average concentration results. EPA determined that all individual sample results in the other three
data sources did meet EPA's acceptance criteria. EPA included 358 PFAS sample results representing 23 facilities
from these sources in its analysis characterizing PFAS in pulp, paper, and paperboard effluent.
EPA calculated facility-level average, minimum, and maximum concentrations for each PFAS with available data
using the following assumptions and limitations:
• EPA assumed all nondetection results and results below the level of quantification (i.e., the reporting or
quantification limitation) were zero.13
• EPA did not have information on analytical method sensitivity and level of quantification for all data.
• EPA did not know the operations or treatment processes online at the facilities at the time of sampling.
12 AF&PA excluded the PFAS sample results from this 2019 study from its data submittal to EPA. AF&PA and the National Council for Air and
Stream Improvement asserted the data in the report "may be imprecise as evidenced by the high degree of variability" and "split samples
collected by one of the facilities and analyzed at a separate laboratory showed much lower concentrations" (AF&PA, 2020c). Based on
discussions with WestRock Company and the Vermont Department of Environmental Conservation, EPA determined the effluent data for
the two pulp, paper, and paperboard facilities in the report met EPA's acceptance criteria and were of sufficient quality for a preliminary
review of PFAS concentrations in industry discharges (EPA, 202lj; VT" DEC, 2021).
13 The lower level of quantification is the lowest concentration that the analytical method being used can measure accurately.
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7—Review of the Pulp, Paper, and Paperboard Point Source Category
• EPA does not have information on whether the observed PFAS concentrations are from legacy use of PFAS,
current use of PFAS, or form from degradation of more complex PFAS.
EPA calculated an overall average, minimum, and maximum concentration for each PFAS based on facility-level
results. EPA did not estimate average concentrations for any PFAS that were not detected at or above the level of
quantification across all facilities or did not have any data.
Table 11 presents the average, minimum, and maximum concentrations for each PFAS observed in effluent from
the 23 pulp, paper, and paperboard facilities. As illustrated in the table, EPA estimated the average
concentrations for 6:2 FTSA and short-chain PFCAs (both degradation products of FDA-approved PFAS used in
food packaging) were generally higher relative to PFSAs and long-chain PFCAs. Despite the phase out of long-
chain PFAAs, some pulp, paper, and paperboard facilities still report detectable levels of PFOA and PFOS in their
wastewater.
Table 11. Pulp, Paper, and Paperboard Wastewater PFAS Concentrations
PFAS Subgroup
Analyteab
Facilities with
Data
Quantified
Detections/Total
Sample Results
Concentration
Range
(Hg/L)c
Average
Concentration
(|ag/L)
PFBA
2
8/8
0.149-0.638
0.377
PFPeA
2
8/8
0.0308-0.246
0.145
PFHxA
2
8/8
0.0841-0.64
0.250
PFHpA
2
8/8
0.0235-0.206
0.118
PFOA
23
55/79
ND - 0.68
0.0377
PFCAs
PFNA
2
8/8
0.00592-0.0526
0.0235
PFDA
2
4/8
ND-0.0197
0.00501
PFUnA
2
4/8
ND-0.0153
0.00441
PFDoA
2
4/8
ND-0.0203
0.00496
PFTrA
2
4/8
ND-0.0249
0.00579
PFTeA
2
4/8
ND-0.023
0.00493
PFBS
2
4/8
ND-0.254
0.0343
PFPeS
2
0/8
ND
ND
PFHxS
2
0/8
ND
ND
PFSAs
PFHpS
2
0/8
ND
ND
PFOS
23
56/80
ND - 0.41
0.0318
PFNS
2
1/8
ND-0.00217
0.000271
PFDS
2
1/8
ND-0.00517
0.000646
FASAs
PFOSA
2
0/8
ND
ND
4:2 FTSA
2
0/8
ND
ND
FTSAs
6:2 FTSA
2
7/8
ND-0.284
0.0691
8:2 FTSA
2
0/8
ND
ND
FAS A As and
NMeFOSAA
2
0/8
ND
ND
N-Alkyl FASAAs
NEtFOSAA
2
0/8
ND
ND
Sources: ERG, 2021b.
Abbreviations: ND-nondetection; |ig/L-micrograms per liter.
a -This table presents data for all PFAS listed in Table 2 for which sample results are available and meet EPA's acceptance
criteria. EPA does not have any sample results for PFAS not listed.
b -The table identifies short-chain PFCAs (<7 carbons) and short-chain PFSAs (<5 carbons) in blue text, while long-chain PFCAs
(>8 carbons) and long-chain PFSAs (>6 carbons) are designated in red text.
c- In this analysis, EPA treated all nondetection results as zero for the purpose of estimating concentrations. All concentration
values are rounded to three significant figures.
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7—Review of the Pulp, Paper, and Paperboard Point Source Category
7.5 Pulp, Paper, and Paperboard Point Source Category Summary
Based on information and data EPA collected for the Multi-Industry PFAS Study, EPA documented that PFAS have
been, and continue to be, used by pulp, paper, and paperboard facilities in the United States; however, only a
small subset of facilities are actively applying PFAS and it appears the production of paper products containing
PFAS at these facilities is a small percentage of the overall production. Additionally, the industry has indicated
they plan to eliminate PFAS use by 2024. Information collected from one trade association and eight major
companies indicates the industry phased out the use of PFOA and PFOS approximately 10 years ago, but
continues to use FDA-approved short-chain PFAS in limited quantities in the manufacture of food contact
packaging and specialty paper products. PFAS may be in additives mixed with the pulp prior to forming it into
paper or in coatings applied to the surface of the paper after the paper is formed to enhance resistance to water,
oil, and grease. Based on outreach and a trade association survey of companies representing 85 percent of United
States production, EPA identified 10 pulp, paper, and paperboard facilities operated by six companies that have
applied PFAS since 2020. The PFAS-based production volume of these 10 mills represents less than 10 percent of
their total production and less than 1 percent of the total produced by this industry in the United States. The
companies operating all 10 facilities reported to EPA that they will transition to PFAS-free technologies and
eliminate all application of PFAS in their United States pulp and papermaking operations by 2024. This schedule
coincides with an FDA agreement with chemical manufacturers to voluntarily phase out use of PFAS that contain
or may degrade to 6:2 FTOH in food contact applications by 2024.
EPA did not identify any pulp, paper, and paperboard facilities with PFAS effluent limitations or pretreatment
standards in their wastewater discharge permit and estimates that only a small fraction of pulp, paper and
paperboard facilities monitor for PFAS. EPA did not identify any pulp, paper, and paperboard facilities employing
wastewater treatment systems known to effectively reduce PFAS in industrial wastewater. Although industry
reports the application of PFAS to pulp, paper, and paperboard products is typically a dry or closed-loop process
and may not generate a wastewater stream, EPA documented PFAS, including legacy long-chain PFAS and
replacement PFAS, are present in wastewater discharges from pulp, paper, and paperboard facilities to surface
waters and POTWs. Using available sampling data, EPA estimated average concentrations for 6:2 fluorotelomers
and short-chain PFCAs (both degradation products of FDA-approved PFAS used in food packaging) were generally
higher relative to PFSAs and long-chain PFCAs. The presence of PFOA, PFOS, and other long-chain PFAAs may be
due to legacy issues or degradation of other more complex PFAS.
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8—Review of the Textile Mills Point Source Category
8. Review of the Textile Mills Point Source Category
This section describes the textile mills point source category and information and data that EPA collected on its
PFAS use and discharge. EPA collected and reviewed information on PFAS use and discharge by textile mills from
the following sources:
• Outreach to textile manufacturing companies, carpet manufacturing companies (a subset of the category),
industry trade associations, and state and local wastewater authorities.
• Publicly available technical literature.
8.1 Industry Description and Use of PFAS
Textile mills receive and prepare fibers; transform fibers into yarn, thread, or webbing; convert yarn and webbing
into fabric or related products; or finish these materials. Many facilities produce a final consumer product such as
thread, yarn, fabric, hosiery, towels, sheets, and carpet while the rest produce an intermediate product for use by
other establishments in the industry. As part of EPA's 1996 Preliminary Study of the Textile Mills Category, EPA
estimated that approximately 6,000 establishments in the United States manufactured textile products. The
majority of United States textile mills, including carpet manufacturers, are concentrated in the southeastern
United States (EPA, 1996). The city of Dalton, Georgia contains over 150 carpet manufacturing plants, and more
than 90 percent of the world's carpeting is produced within a 65-mile radius of the city (Town of Centre AL v.
Dalton GA Manufacturers, 2017).
EPA promulgated the Textile Mills Effluent Guidelines (40 CFR Part 410) in 1974, with technical amendments in
1977 and 1982. The regulations cover wastewater discharges generated from textile mills using the following
processes:
• Wool scouring, topmaking, and general cleaning of raw wool.
• Wool finishing, including carbonizing, fulling, dyeing, bleaching, rinsing, and fireproofing.
• Yarn manufacture, unfinished fabric manufacture, fabric coating, fabric laminating, tire cord and fabric
dipping, carpet tufting, and carpet backing.
• Woven fabric finishing, including desizing, bleaching, mercerizing, dyeing, printing, resin treatment,
waterproofing, flameproofing, application of soil repellent, and other special finishes.
• Knit fabric finishing, including bleaching, mercerizing, dyeing, printing, resin treatment, waterproofing,
flameproofing, application of soil repellent, and other special finishes.
• Carpet finishing, including bleaching, scouring, carbonizing, fulling, dyeing, printing, resin treatment,
waterproofing, flameproofing, application of soil repellent, looping, and backing with latex and jute.
• Stock and yarn finishing, including cleaning, scouring, bleaching, mercerizing, dyeing, and finishing.
• Manufacturing of nonwoven textile products of wool, cotton, synthetics, or blends of such fabrics.
The current ELGs do not establish effluent limitations or pretreatment standards for PFAS.
Textile mills use PFAS to impart outdoor gear, clothing, household fabrics, carpets, and other textile products with
water, oil, soil, and heat resistance; improve cleanability of oil- and water-based stains; as a wetting or
antifoaming agent when dyeing and bleaching, and as a breathable moisture barrier to wind and rain (NCTO,
2016; Wood, 2020b; Gluge et al., 2020). Some textile products that may contain PFAS include consumer apparel
and accessories, professional apparel (including medical and firefighter uniforms and personal protection
equipment), sportswear, outdoor gear, heat-resistant gloves, footwear, carpeting and rugs, backpacks, swimwear,
and upholstery (NRDC, 2021; SAICM, 2021). Fluoropolymer PFAS are most commonly used as breathable
membranes, while side-chain fluorinated polymers are used as long-lasting durable water repellent finishes
(Wood, 2020b; Gluge et al., 2020). During fabric and carpet manufacturing, PFAS can either be incorporated as an
additive mixed into the individual fibers or sprayed as a coating onto finished fabrics, either during manufacturing
or after sale (GSPI, 2021).
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8—Review of the Textile Mills Point Source Category
A National Resources Defense Council (NRDC) analysis of a 2016 fluorotelomer market study concluded the global
textile industry was the largest user of fluorotelomers (relative to the volumes used in firefighting foams, food
packaging, stain resistance chemicals, and other products), making up approximately 36 percent of the total
market (NRDC, 2021; Ahuja and Mamtani, 2016).
Some retailers and textile companies have committed to eliminating the sale or manufacture of PFAS-containing
textile products in the coming years, including Interface, Tarkett, IKEA, Herman Miller, Crate and Barrel, Room
and Board, Engineered Floors, Lowes, and Home Depot. Fashion, apparel, and home textile brands are currently
the most common adopters of PFAS-free commitments. Sports and outdoor brands face more challenges to
phase out PFAS while keeping the current level of product performance and functionality because there are no
technologies which can repel oil-based materials to the same levels that PFAS achieve, and which are acceptable
to the industry. (NRDC, 2021; NCTO, 2018; GSPI, 2021). At least one state, California, is in the process of
regulating PFAS in carpets, rugs, and after-market treatments. The major categories of nonfluorinated water-
repellant alternatives available on the market include hydrocarbons, silicones, dendrimers, polyurethanes, and
nanomaterials (Wood, 2020b).
8.2 Stakeholder Outreach
EPA attempted to meet with industry stakeholders and state and local wastewater authorities to collect, on a
voluntary basis, information on the use and discharge of PFAS for textile and carpet mills.
EPA reached out to two trade associations and three textile or carpet manufacturing companies that the agency
considered possible users of PFAS. The trade associations and companies that EPA contacted are listed below:
• National Council of Textile Organizations (NCTO). A national trade association representing more than 150
companies across the entire spectrum of the United States textile industry and comprising four councils: the
fiber council, the yarn council, fabric and home furnishing council, and the industry support council.
• Carpet and Rug Institute (CRI). A trade association for the North American carpet industry, providing
carpeting-related informational tools, programs, and research resources. CRI represents manufacturers
producing 94 percent of carpet in the United States, suppliers of raw materials, and services to the industry.
• Milliken and Company (Milliken). Global manufacturer and supplier of household textiles (including carpets),
performance and protective textiles, specialty chemicals, and other industrial textiles.
• Shaw Industries Group, Inc. (Shaw). Global manufacturer of carpets, rugs, and household textiles.
• W.L. Gore and Associates (Gore). Global manufacturer of industrial and commercial fluoropolymer-based
products, including waterproof, breathable fabrics (e.g., GORE-TEX) used in apparel, footwear,
workwear/technical wear, and outdoor textiles.
NCTO, CRI, and their member companies declined to meet with EPA and did not provide any information on PFAS
use in the industry (EPA, 2021o, 2021p). Milliken informed EPA that they are not in a position to discuss PFAS due
to ongoing litigation involving claims against multiple defendants related to alleged discharge of PFAS from carpet
manufacturing facilities in and around Dalton, Georgia.14 Milliken explained that the Milliken facility at issue in
that litigation was operated by Milliken for only a short time, from October 2009 to November 2012. Milliken also
stated that none of the current NPDES permits held by the company's textile mills have any monitoring
requirements for PFAS (EPA, 2021q). EPA did not receive responses or any additional information from Shaw or
Gore (EPA, 2021r, 2021s).
8.3 PFAS Wastewater Regulatory Requirements and Controls
As part of the Multi-Industry PFAS Study, EPA did not identify any textile mills with PFAS effluent limitations,
pretreatment standards, or monitoring requirements in their wastewater discharge permits. EPA identified a draft
14 The plaintiff of this litigation, the Water Works and Sewer Board of the City of Centre, brought a complaint against owners, operators,
and/or chemical suppliers to manufacturing facilities (including textile and carpet manufacturers) located in and around Dalton, Georgia,
The plaintiff claims that they have and continue to be damaged due to the past and present release of toxic chemicals, including PFOA,
PFOS, precursors to PFOA and PFOS and related chemicals released during manufacturing operations (Town of Centre AL v. Dalton GA
Manufacturers, 2017).
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8—Review of the Textile Mills Point Source Category
NPDES permit for one textile mill in Georgia which, if finalized, would require the company to determine if the
facility has potential to release PFAS to the environment through discharge of wastewater effluent or industrial
sludge disposal (GA DNR, 2020).
8.4 Wastewater Characteristics
EPA evaluated the available data on types and concentrations of PFAS in wastewater discharged from textile mills.
As of July 2021, EPA has not identified any textile mills with PFAS monitoring requirements or effluent limitations;
therefore, no DMR data is available for PFAS. EPA summarized the information available and calculated average
PFAS concentrations in effluent from textile mills based on Michigan permitting authority data.
EPA identified analytical data that meet EPA's acceptance criteria for inclusion in analyses for characterizing PFAS
discharges in industrial wastewater discharges. EPA's acceptance criteria are presented in the memorandum
"Development of the Multi-Industry PFAS Study Analytical Database" (ERG, 2021a). EPA identified one source of
analytical data of textile mill effluent and determined that all individual sample results in the source met EPA's
acceptance criteria, Ml EGLE PFAS monitoring results for indirect discharge facilities (Ml EGLE, 2020c). EPA
included 16 PFAS sample results representing three indirect discharge mills in its analysis characterizing PFAS in
textile mill effluent.
EPA calculated facility-level average, minimum, and maximum concentrations for each PFAS with available data
using the following assumptions and limitations:
• EPA assumed all nondetection results and results below the level of quantification (i.e., the reporting or
quantification limitation) were zero.15
• EPA did not have information on analytical method sensitivity and level of quantification for all data.
• EPA did not know the operations or treatment processes online at the facilities at the time of sampling.
• EPA does not have information on whether the observed PFAS concentrations are from legacy use of PFAS,
current use of PFAS, or formation from degradation of more complex PFAS.
EPA calculated an overall average, minimum, and maximum concentration for each PFAS based on the facility-
level results. Table 12 presents the average, minimum, and maximum concentrations for each PFAS observed in
effluent the three indirect discharge textile mills.
Table 12. Textile Mill Wastewater PFAS Concentrations
PFAS
Subgroup
Analyteab
Facilities with
Data
Quantified
Detections/Total
Sample Results
Concentration
Range
(Hg/L)c
Average
Concentration
(kig/L)c
PFCAs
PFOA
3
4/8
ND - 0.114
0.00807
PFSAs
PFOS
3
4/8
ND-0.0361
0.00249
Source: ERG, 2021b.
Abbreviations: ND-nondetection; |ig/L-micrograms per liter.
a -This table presents data for all PFAS listed in Table 2 for which sample results are available and meet EPA's acceptance criteria. EPA
does not have any sample results for PFAS not listed.
b -The table identifies long-chain PFCAs (>8 carbons) and long-chain PFSAs (>6 carbons) in red text.
c- In this analysis, EPA treated all nondetection results as zero for the purpose of estimating concentrations. All concentration values are
rounded to three significant figures.
8.5 Textile Mills Point Source Category Summary
Based on information and data EPA collected for the Multi-Industry PFAS Study, EPA documented that PFAS have
been, and continue to be, used by textile mills in the United States. Textile mills use PFAS to enhance resistance to
water, oil, soil, and heat; improve cleanability of oil- and water-based stains; as a wetting and antifoaming agency;
and in the breathable moisture barrier to wind and rain. PFAS have been applied in a wide range of textiles
15 The lower level of quantification is the lowest concentration that the analytical method being used can measure accurately.
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8—Review of the Textile Mills Point Source Category
including but not limited to clothing, footwear, carpets and rugs, household fabrics, upholstery, medical
garments, firefighting gear, luggage, and outdoor gear (e.g., jackets, hats, gloves, tents). During fabric and carpet
manufacturing, PFAS can either be incorporated as an additive mixed into the individual fibers or sprayed as a
coating onto finished fabrics during manufacturing or after sale.
EPA's review of PFAS use and discharge by the textile mills point source category is largely based on publicly
available information and literature. EPA attempted to meet with representatives of industry trade associations
and companies to collect, on a voluntary basis, information on the use and discharge of PFAS at textile and carpet
mills. Ultimately, EPA did not meet or receive additional information from these entities.
EPA did not identify any textile mills with PFAS effluent limitations or pretreatment standards in their wastewater
discharge permit and estimates that only a small fraction of textile mills monitor for PFAS. EPA did not identify any
textile mills employing wastewater treatment systems known to effectively reduce PFAS in industrial wastewater.
Based on a small number of sample results, EPA has observed that PFAS, including legacy long-chain PFAS, are
present in wastewater discharges from textile mills to POTWs. Most textile mills are not monitoring for PFAS and
may continue to discharge PFAS to POTWs or surface waters unless effective controls are in place.
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9—Review of the Commercial Airport Point Source Category
9. Review of the Commercial Airport Point Source Category
This section describes the commercial airport point source category, the use of PFAS-containing firefighting foam
(i.e., AFFF) for firefighting activities and certification exercises, and mechanisms for PFAS release to the
environment. EPA collected and reviewed information on PFAS use and discharge by commercial airports from
outreach with the United States Department of Transportation, Federal Aviation Administration (FAA) and an
industry trade association; government reports and databases; a survey and report published by the Airport
Cooperative Research Program (ACRP); and publicly available technical literature.
9.1 Industry Description and Use of PFAS
The FAA and Airport and Airway Improvement Act (AAIA) (49 U.S.C. Chapter 471) classify commercial airports by
size based on volume of commercial traffic. Commercial airports are defined by the FAA and AAIA as publicly
owned airports that have at least 2,500 passenger boardings (number of passengers boarding a plane for
departure) each calendar year and receive scheduled passenger service (EPA, 2012b). As of April 2021, the FAA
has certified 519 commercial airports (FAA, 2021a). Military installations and other facilities operated by the
United States Department of Defense (DOD) are not considered commercial airports; therefore, PFAS use and
discharge by DOD facilities are outside the scope of this study.
14 CFR Part 139 contains the regulations pertaining to certification of airports and requires commercial airports
to conduct periodic testing of certain equipment and train personnel to perform aircraft rescue and firefighting
(ARFF) operations. In 2006, the FAA required that commercial airports certified under 14 CFR Part 139 purchase
only firefighting foams that conform to military specification (Mil-Spec) MIL-PRF-24385 for performance and
procurement, which required that AFFF liquid concentrates contain fluorocarbon (i.e., PFAS) surfactants (FAA,
2006). In May 2019, the DOD amended Mil-Spec MIL-PRF-24385 to remove the Mil-Spec's requirement that AFFF
contain fluorocarbon surfactants (DOD, 2019). However, as of June 2021, all firefighting foam formulations that
meet MIL-PRF-24385 contain PFAS in concentrations less than 800 parts-per-billion (ACRP, 2017; ERG, 2020a).
AFFF is produced by mixing PFAS-containing concentrate with water at the specified proportion, typically 3 or 6
percent ratio to water. AFFF has been, and continues to be, stored and used at military installations, industrial
facilities, petroleum refineries, and airports to prevent, extinguish, or control Class B flammable fuel fires and for
firefighter training. When mixed with water, AFFF concentrate generates an aqueous film and foam solution that
spreads across the surface of a hydrocarbon (e.g., grease, oil, gasoline, solvent) fire to extinguish the flames and
form a vapor barrier separating fuel and atmospheric oxygen to prevent reignition. Military and commercial
airport AFFF applications subject to the Mil-Spec MIL-PRF-24385 account for more than 75 percent of AFFF used
in the United States (ACRP, 2017).
The FAA requires periodic testing of foam proportioning system performance in ARFF vehicles, as prescribed in 14
CFR Parts 139.315 to 139.319. The number of ARFF vehicles and amount of AFFF present at each airport is based
on the length of aircraft and average number of daily departures from the airport. Until recently, foam
proportioning system testing required airports to perform output-based testing, in which AFFF is sprayed from
the ARFF vehicle for at least 30 seconds to demonstrate that the firefighting equipment operates correctly. During
output-based testing, safeguards, such as capture containers, containment basins, absorbent pads, and use
separator/scrubbing systems may be used to prevent the release of PFAS to the environment (ACRP, 2017; FAA,
2021b). 14 CFR Part 139 also permits input-based testing, a method that requires additional equipment but
allows for a substitute (typically water) to be sprayed instead of AFFF. Input-based testing requires the
establishment of a baseline by spraying foam from the ARFF vehicles. Once a baseline is established, the test can
be run using water rather than foam. As of June 2021, the FAA has approved and encourages use of four different
types of AFFF testing equipment that do not require dispensing AFFF. The FAA and some states are providing
funding for the purchase of input-based testing equipment that does not require foam to be dispensed onto the
ground (FAA, 2019a, 2019b, 2021b). Commercial airports that use input-based testing equipment will eliminate
potential discharges of wastewater containing PFAS during periodic testing of foam proportioning system
performance in ARFF vehicles.
The FAA also requires all airport firefighting personnel to complete an annual live-fire fighting training as dictated
in 14 CFR Parts 139.315 to 139.319. Live firefighting training involves extinguishing a pit fire with an aircraft mock-
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9—Review of the Commercial Airport Point Source Category
up using enough fuel to simulate the type of conditions that could be encountered during a rescue situation. If
training of airport firefighting personnel does not occur within a 12-month period, an airport will be considered
out of compliance with 14 CFR Part 139. Commercial airports are not required to use AFFF during live firefighting
testing (water solutions or alternative methods may be used). Some airports have a designated firefighting
training area to perform training, while others do not (ACRP, 2017).
Until application, AFFF is managed as a concentrated product containing less than 2 percent PFAS by weight. PFAS
account for less than 1 percent of AFFF after the concentrate is mixed with water to create the firefighting
solution. AFFF formulations are generally categorized into three groups, based on the PFAS type included:
• Legacy PFOS-based AFFF. First-generation AFFF formulations where PFOS is an active ingredient.
Manufactured by 3M via electrochemical fluorination and sold under the brand name Light Water™ in the
United States from 1970s to 2002.
• Legacy fluorotelomer-based AFFF. Second-generation AFFF formulations containing precursors to long-chain
PFCAs (e.g., PFOA) and manufactured via fluorotelomerization in the United States from 1970s to 2016.
• Modern fluorotelomer-based AFFF. Modern AFFF formulations containing four- and six-carbon fluorotelomer
chemistries (e.g., 6:2 FTSA) and developed in response to the PFOA Stewardship Program. These AFFF
formulations are currently being commercially sold in the United States market.
While modern fluorotelomer-based AFFF formulations have the potential to be less harmful to human health and
the environment than legacy formulations, much remains unknown about the short-chain PFAS used. Four- and
six-carbon chain fluorotelomers degrade into short-chain PFCAs and other short-chain PFAS, as discussed in
Section 3.4. Since certain short-chain PFAS are less effective surfactants than their long-chain counterparts,
greater quantities of short-chain PFAS may be required to provide equivalent performance (ACRP, 2017).
PFAS contamination has been observed in surface water, groundwater and drinking water in proximity to airports
that use AFFF (Hu et al., 2016; Gewurtz et al., 2014; ITRC, 2020). Due to growing concerns related to PFAS use and
release at airports, the FAA Reauthorization Act of 2018 (enacted October 5, 2018) mandates that the FAA can no
longer require the use of AFFF by 14 Part 139 airports no later than three years from the date of enactment
(October 4, 2021). As a result, the FAA has approved, encourages use of, and, in some cases, funds technologies
that do not require dispensing AFFF when airports conduct periodic equipment testing and training. While the
FAA Reauthorization Act of 2018 will end the requirement for use of AFFF, it does not prohibit its use by
commercial airports (FAA, 2018, 2019c, 2021b).
The National Defense Authorization Act of fiscal year 2020 (enacted December 20, 2019) requires the DOD to
phase out its use of AFFF at all military installations by October 2024, with limited exceptions, and immediately
stop military training exercises with AFFF. The Secretary of the Navy must publish specifications for PFAS-free
firefighting foam at all military installations and ensure that the foam is available for use by October 2023 (ITRC,
2020). These mandates do not apply to commercial airports and the FAA has not yet announced plans to require
exclusive use of PFAS-free formulations at commercial airports.
Despite discontinued manufacture of legacy AFFF formulations with long-chain PFAS chemistries, many airports
have AFFF in service or in stockpiles and are not prohibited from using legacy or modern AFFF. AFFF has a long
shelf life; some manufacturers claim PFAS-containing AFFF can remain viable up to 25 years if stored properly
(ACRP, 2017). This means that PFAS-containing AFFF, including legacy PFOS-based products, still exist in United
States inventories and ongoing permitted use of AFFF at commercial airports can still result in PFAS releases. The
current volume of AFFF in commercial airport stockpiles or used annually is not known.
The DOD, states, and other organizations recommend the complete replacement of legacy AFFF and have
launched proper disposal and take-back programs. As of January 2020, EPA has identified eleven states with AFFF
procurement, use, storage, and/or disposal regulations: Arizona, Colorado, Georgia, Kentucky, Michigan,
Minnesota, New Hampshire, New York, Virginia, Washington, and Wisconsin (ACRP, 2017; ERG, 2020a; Bloomberg
Law, 2020).
Many firefighting foam manufacturers now offer Class B fluorine-free foam products. A 2020 literature review
and market study found that fluorine-free alternative foams, including hydrocarbon- and detergent-based foams,
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9—Review of the Commercial Airport Point Source Category
are generally available and technically feasible, and have been successfully implemented in many industrial
sectors in Europe (Wood, 2020c).
As of June 2021, the FAA has not identified any fluorine-free foams on the market that provide the same level of
fire suppression, flexibility, and scope of usage as MIL-PRF-24385 AFFF and therefore they are not used at DOD-
and FAA-regulated facilities. To aid in the transition to nonfluorinated AFFF, the FAA, the DOD, Airports Council
International - North America, firefighting foam manufacturers/developers, and other organizations are
researching and testing at least 15 commercially available fluorine-free AFFF alternatives to identify formulations
that are environmentally friendly and provide the same level of safety currently offered by the Mil-Spec MIL-PRF-
24385. The FAA has built a research testing facility and conducted over 400 tests in an effort to find a new
fluorine-free alternative firefighting extinguishing agent (ERG, 2020a; FAA, 2019a, 2021b; SERDP, 2020).
9.2 Stakeholder Outreach
EPA met with the FAA and the Airports Council International - North America to collect, on a voluntary basis,
information on the use and release of PFAS-containing AFFF by commercial airports. FAA representatives
provided EPA with an overview of firefighting requirements for commercial airports to maintain 14 CFR Part 139
certification. EPA collected information on the Mil-Spec MIL-PRF-24385, FAA development and approval of input-
based testing systems, and the FAA's guidance to commercial airports to control release of AFFF. EPA continues
to coordinate with the FAA to understand the status of research on fluorine-free formulations and actions taken
to address AFFF. The Airports Council International - North America is a trade association for the North American
airport industry and provided EPA with information on its members' practices for using and capturing AFFF.
9.3 PFAS Wastewater Regulatory Requirements and Controls
As part of the Multi-Industry PFAS Study, EPA did not identify any commercial airports with PFAS effluent
limitations, pretreatment standards, or monitoring requirements in their wastewater discharge permits.16
9.4 PFAS Releases Associated with AFFF Use
Commercial airports have historically generated PFAS-containing wastewater during periodic testing of ARFF
equipment, live-fire firefighting training, emergency response activities, rinsing ARFF equipment, and accidental
leaks. The volume of PFAS released to the environment can vary depending on the activity and types of controls
employed by the airport. A 2016 survey of 167 airports across the United States and Canada indicated that nearly
80 percent of respondents sprayed AFFF directly on the ground rather than an engineered containment system.
Most airports which reported directly spraying AFFF onto the ground also reported that AFFF was left to
evaporate, dissipate, dilute, or infiltrate into the ground. Most airports that reported capturing AFFF in a
containment system or cleaning up AFFF sprayed onto the ground ultimately discharged the solution to POTW via
a sewer or to a surface water (ACRP, 2017). Most on-site airport wastewater treatment systems and POTWs are
not capable of effectively removing PFAS. Once released, AFFF foam can contaminate soil, surface water, and
groundwater.
To minimize AFFF releases, the FAA and Airports Council International - North America are working with airports
to enhance education of AFFF issues; reduce AFFF release during periodic testing and training activities; and
promote practices and technologies used for the capture of AFFF, and subsequent treatment at municipal
wastewater treatment plants (ERG, 2020a; FAA, 2021b). Since 2019, the implementation of input-based testing
and PFAS control processes and technologies have reduced AFFF releases by commercial airports. Releases to the
environment will be further reduced based on federal actions to review and revise mandates to use PFAS-
containing AFFF and proliferation of fluorine-free firefighting foams alternatives. The FAA states that approval of
input-based testing and updated guidance has eliminated the need for commercial airports to discharge
16 The FAA requires commercial airports and air carriers to conduct deicing and anti-icing of aircraft and airfield pavement to ensure safety
of flights. In 2012, EPA promulgated the Airport Deicing ELGs (40 CFR Part 449), which address control of wastewater generated by deicing.
The ELGs do not apply to wastewater generated by AFFF use at commercial airports, nor do they establish PFAS requirements or effluent
limitations (EPA, 2012b).
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9—Review of the Commercial Airport Point Source Category
wastewater contaminated with AFFF except during actual emergency response situations (i.e., AFFF should not be
released during periodic testing of ARFF equipment.
9.5 Commercial Airports Point Source Category Summary
The FAA Reauthorization Act of 2018 (enacted October 5, 2018) mandates that the FAA can no longer require the
use of PFAS-based AFFF by 14 CFR Part 139 airports no later than three years from the date of enactment
(October 4, 2021). As a result, the FAA has approved, encourages use of, and in some cases funds four different
types of AFFF testing equipment that do not require dispensing AFFF when airports conduct periodic equipment
testing and training (FAA, 2021b). The FAA has also built a research testing facility and has conducted over 400
tests in an effort to find a new fluorine-free alternative firefighting extinguishing agent (FAA, 2019b).
Historically, the FAA required that commercial airports certified under 14 CFR Part 139 purchase only firefighting
foams that conform to Mil-Spec MIL-PRF-24385 for performance and procurement (FAA, 2006). In May 2019, the
DOD amended Mil-Spec MIL-PRF-24385 to remove the requirement that AFFF must contain PFAS. As of July 2021,
all firefighting foam formulations that meet MIL-PRF-24385 contain less than 800 parts-per-billion of PFAS. The
FAA and the DOD are continuing to collaborate on research and to test fluorine-free alternatives that provide the
same level of safety currently offered by Mil-Spec MIL-PRF-24385.
Based on this information, EPA determined that commercial airports may generate PFAS-containing wastewater
from live-fire firefighting training, emergency response activities, and accidental leaks from stockpiles of AFFF.
The volume of PFAS released to the environment can vary depending on the activity, types of controls employed
by the airport, and type and volume of AFFF released.
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10—Review of PFAS Treatment Technologies
10. Review of PFAS Treatment Technologies
This section summarizes information and performance data EPA collected on treatment technologies capable of
removing or destroying PFAS in water streams. For the purposes of this preliminary report, PFAS destruction
(sometimes referred to as mineralization) is the complete chemical degradation of PFAS molecules into base
elements or compounds such as carbon dioxide (C02), water (H20), and fluorine ions (F"). Incomplete destruction
leaves behind partially degraded PFAS, resulting in increased concentrations of PFAAs or precursors. Removal is
the physical separation of PFAS from an influent wastestream, but does not imply chemical transformation.
Removal technologies result in PFAS being concentrated into another wastewater stream or solid waste.
EPA reviewed technical literature, Industrial Wastewater Treatment Technology (IWTT) database (EPA, 2021e),
and EPA's Drinking Water Treatability Database (DWTD) (EPA, 202If) to identify technologies capable of removing
or destroying PFAS in industrial wastewater, drinking water, and municipal wastewater. The following treatment
types are presented in this preliminary report:
• Conventional Water Treatment. Physical, biological, and chemical processes which are commonly applied in
drinking water treatment plants (DWTPs) or POTWs to remove organic pollutants, solids, nutrients, and
provide disinfection (see Section 10.1).
• Adsorption. Removal by transfer of contaminants from a liquid phase onto the surface of a solid adsorbent
through hydrophobic partitioning or electrostatic interactions with active sites (see Section 10.2).
• Membrane Filtration. Removal of contaminants from a solution into a concentrated liquid wastestream using
a selective barrier (see Section 10.3).
• Incineration/Thermal Treatment. Destruction by application of heat to break down the chemical structure of
contaminants (i.e., breaking chemical bonds of PFAS molecules using extremely high temperatures) (see
Section 10.4).
• Advanced Oxidation and Reduction Processes. Destruction using oxidizing or reducing agents and processes
to break down the chemical structure of contaminants (i.e., breaking chemical bonds of PFAS molecules
through a series of oxidation-reduction reactions) (see Section 10.5).
• Emerging Technologies for PFAS Treatment. Additional technologies being studied for PFAS removal or
destruction but not yet widely implemented or demonstrated (see Section 10.6).
Table 13 summarizes demonstrated PFAS technologies identified through EPA's review. Where available,
treatment capabilities reported in literature or EPA's DWTD are provided for six PFAS representing a range of
chain length, functional group, and level of fluorination (PFOA, PFOS, PFBA, PFBS, 6:2 FTSA, HFPO-DA). See EPA's
2021 Evaluation of Industrial Wastewater Treatment Technologies report for additional information and data on
these and additional PFAS treatment technologies (ERG, 2021c).
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10—Review of PFAS Treatment Technologies
Table 13. Summary of Available PFAS Treatment Technologies
Treatment
Technology
Treatment Description
Observed PFAS Removal Level3
Considerations for Use
Conventional Drinking
Water and Wastewater
Treatment
Water treatment processes
commonly used by DWTPs or
POTWs including filtration,
coagulation, sedimentation,
biological treatment,
clarification, and disinfection.
Marginal reduction (< 25%) in
concentration for most PFAS.
• PFAS removal limited to compounds adsorbed onto solids (i.e., dissolved
PFAS are not removed).
• May increase effluent concentrations of PFCAs and PFSAs through
transformation of precursors.
Activated Carbon
Transfers PFAS from a liquid
wastestream onto a solid
powdered or granulated
carbon-based adsorbent.
Includes granular activated
carbon (GAC) and powdered
activated carbon (PAC).
PFOA: Up to 99% a
PFOS: Up to 99% a
PFBA: Up to 99% a
PFBS: Up to 99% a
HFPO-DA: Up to 93% a
6:2 FTSA: Up to 88% a
• Short-chain PFAS have lower removal rates than long-chain PFAS.
• PFCAs have lower removal rates than PFSAs.
• Sorption rates sensitive to water solution chemistry (e.g., greater pH or
higher organic content of wastewater is linked to lower sorption rates).
• Requires thermal regeneration or disposal of spent adsorbent media.
• GAC is commercially available and has been implemented at OCPSF and
chromium plating facilities to capture PFAS.
Ion Exchange Resin
Synthetic resins used to
remove charged PFAS. Can be
used in batch or flow-through
reactors.
PFOA: Up to 99% a
PFOS: 90-99% a
PFBA: Up to 99% a
PFBS: Up to 99% a
HFPO-DA: Up to 99% a
6:2 FTSA: Up to 99% a
• Can be tailored to target electrostatically charged PFAS.
• PFAS selective resins are more expensive but demonstrate higher removal
capacities than activated carbon treatment for certain PFAS.
• Rate of exchange depends on PFAS type, influent PFAS concentration,
resin properties, and solution ionic strength.
• Requires chemical generation or disposal of spent resin. Single-use resins
create a solid waste stream onto which PFAS is absorbed. Regeneration of
a reusable resin with a chemical solution generates a concentrated PFAS
liquid wastestream. Regenerable resin cannot be infinitely regenerated
and will create a solid wastestream onto which PFAS is adsorbed.
• Commercially available for wastewater treatment.
Membrane
Separation
Separation treatment that
pushes water molecules
through a semi-permeable
membrane while rejecting
larger PFAS molecules.
Includes nanofiltration (NF)
and reverse osmosis (RO).
PFOA: Up to 99% a
PFOS: Up to 99% a
PFBA: Up to 99% a
PFBS: Up to 99% a
HFPO-DA: Up to 99% a
6:2 FTSA: Up to 99% a
• Higher capital cost and energy demand than conventional treatments or
adsorption.
• Effective in removing most PFAS from water solutions.
• Susceptible to fouling without pretreatment.
• Generates a concentrated PFAS wastestream that must be treated or
disposed.
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10—Review of PFAS Treatment Technologies
Table 13. Summary of Available PFAS Treatment Technologies
Treatment
Technology
Treatment Description
Observed PFAS Removal Level3
Considerations for Use
icineration/
mal Treatment
Process of applying high
temperatures to chemically
breakdown PFAS molecules.
Complete PFAS destruction at
temperatures ranging 200 -
1,400°C (varies from one PFAS
to another).
• Can be used to regenerate solid adsorbents, such as GAC, while also
destroying PFAS. Fiowever, high heat required to break carbon-fluorine
bond can destroy adsorbent as well.
• Incomplete destruction of PFAS may result in increased PFAA and
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precursor concentrations.
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• Requires high energy or chemical catalyst input to initiate reactions.
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H o
x Jr
O °-
"S o
c
nj ^
Use of chemical or
electrochemical catalyst to
breakdown PFAS molecules.
Up to 99% PFAS destruction.
• Pretreatment to create a concentrated PFAS influent will reduce energy
demand.
• Incomplete destruction of PFAS may result in increased PFAA and
precursor concentrations.
> -a
-a cu
< cc
• Advanced reduction requires strong alkaline systems.
a - Potential removal rates are based on reported data from EPA's DWTD for PFAS. See the DWTD for removal rates for additional PFAS (EPA, 2021f).
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10—Review of PFAS Treatment Technologies
10.1 Conventional Treatment Technologies
Treatment methods commonly found in DWTPs include coagulation, sand or multimedia filtration, and
disinfection involving ultraviolet light or chemicals. POTWs typically treat wastewater using primary screening,
sedimentation, secondary biological treatment (e.g., suspended growth or fixed-film biological processes),
clarification, filtration, and/or disinfection. These conventional treatment processes used in POTWs and DWTPs
do not degrade the carbon-fluorine bond and are ineffective at removing PFAS. No or inconsistent removal of
PFAS has been observed, with most studies reporting less than 25 percent removal of total PFAS. PFAS removal
for these treatments is limited to physical removal of PFAS bound to filtered solids, leaving behind dissolved PFAS
(Appleman et al., 2014; Rahman et al., 2014; EPA, 2021f). Nonpolymer polyfluorinated PFAS and polymer PFAS
may be partially degraded in drinking water or wastewater treatment processes, leading to increased PFAA
detections in effluent and sludge (Pan et al., 2016; Hamid and Li, 2016).
10.2 Adsorption
Adsorption is a demonstrated process for contaminant removal in water and wastewater and is the most
common treatment method for PFAS. Adsorption is both a physical and chemical process that removes a
compound in an aqueous solution (adsorbate) through association to a solid phase (adsorbent). Adsorption does
not chemically alter or destroy PFAS; rather, compounds are transferred from the liquid phase to a solid when
they adhere to the solid's active sites.
PFAS adsorption rates may be affected by pH, organic co-contaminant nature and concentration, and the ionic
strength of the solution. Because adsorption processes can remove a wide spectrum of organic contaminants, the
presence of nontargeted contaminants can increase competition for sorption sites, thus reducing removal of PFAS
(Gagliano et al., 2020). Pretreatment steps may be necessary to optimize the performance of media, including
coagulation, precipitation, filtration, pH adjustment, or oxidant removal.
Adsorption technologies require further treatment or disposal of the spent adsorbent media. Once adsorptive
media is exhausted and breakthrough (i.e., PFAS is observed at a specific concentration in the effluent) occurs,
the adsorbent media is considered spent and must be replaced or reactivated using high temperatures or
chemical regenerants to renew adsorptive capabilities. Reactivation can create concentrated PFAS separate
wastestreams from regenerant concentrate or through incineration gas emissions. Once an adsorbent can no
longer be reactivated, it must be disposed of as a solid waste.
The following sections outline different adsorbents that rely on physical adsorption of PFAS.
10.2.1 A ctiva ted Carbon
Activated carbon is a widely used adsorbent for contaminant treatment. Granular activated carbon (GAC) and
powdered activated carbon (PAC) are carbonaceous media that can be used to adsorb natural and synthetic
organic compounds. Activated carbon treatment is available, relatively inexpensive, and can be scaled to suit
treatment requirements.
GAC and PAC differ in the diameters of the activated carbon particles (1.2 to 1.6 millimeters for GAC,
approximately 0.1 millimeter for PAC). Because of the small particle size, PAC cannot be used in a flow through
bed, but can be added directly to the water and then removed in the clarification stage (conventional water
treatment or low-pressure membranes such as microfiltration or ultrafiltration). Used in this way, PAC is not as
efficient or economical as GAC at removing PFAS.
The application of GAC as a treatment technology for PFAS removal has been practiced for more than a decade at
industrial sites, military installations, and DWTPs. GAC media regeneration requires heating the spent material to
temperatures greater than 1,000 °C and regenerated GAC may be less effective than virgin GAC (Watanabe et al.,
2016).
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10—Review of PFAS Treatment Technologies
GAC and PAC performance for PFAS treatment has been documented with bench, pilot, and full-scale studies
reporting up to 99 percent removal of PFAS depending on the compound being treated (Zhao et al., 2011; Ross et
al., 2018). Studies have shown that PFSAs are more readily adsorbed than PFCAs, and long-chain PFAS are more
readily adsorbed than short-chain PFAS (Appleman et al., 2014; Ross et al., 2018; EPA, 2021f). Increased pH and
organic matter content in the adsorbate can decrease PFAS adsorption rates.
10.2.2 Ion Exchange Resins
Ion exchange (IX) technology removes charged contaminant ions using exchange sites on synthetic, highly porous
resins in batch or continuous flow reactors. The charged resin sites attract and bind to oppositely charged
contaminant ions.
Most PFAAs are present in environmental matrices in their anionic form and may be removed from water by
anion exchange resins. Sorption rates will vary based on the resin and porosity. Unlike activated carbon, IX resins
can be specialized to selectively target specific PFAS, require less contact time, and remove higher PFAS loads
than GAC or PAC.
While IX technology has been used for decades, the development and use of selective resins for PFAS removal is
relatively new. IX resin options for removal of PFAS include single-use and regenerable resins. Single-use resins
are used until breakthrough occurs at a preestablished threshed and are then removed from the treatment unit.
Regenerable IX resins may be regenerated on site using regenerant solution once active sites have been occupied
but may not offer the same removal efficiency as single-use resins and cannot be infinitely regenerated. Resin
regeneration creates a concentrated PFAS liquid wastestream that must be further treated or disposed.
Continuous flow studies of IX resins for PFAS removal report that breakthrough occurs for PFCAs before PFSAs
and short-chain PFAS before long-chain PFAS (Boyer et al., 2021). Bench- and pilot-scale studies captured in EPA's
DWTD report PFAS removals from 30 to 99 percent (EPA, 2021f).
10.2.3 Other Adsorbents for PFAS Removal
EPA identified several other adsorbents that have demonstrated an ability to remove PFAS, listed below. As with
activated carbon and IX resins, the properties of the adsorbent and the wastestream impact the amount of PFAS
that can be removed.
• Polymer adsorbents. Synthetic materials that can be designed with specific traits suitable for the targeted
removal of specific PFAS. Polymer adsorbents may have high hydrophobicity or an electrostatically charged
surface to increase PFAS removal. Some polymer adsorbents may be regenerated and studies show
regeneration can occur under much lower temperatures compared to GAC, allowing for less damage to the
adsorbent. Some polymer adsorbents, such as crosslinked cyclodextrin polymers and cationic hydrogels,
demonstrate more than 90 percent removal of long-chain PFAS and more than 80 percent removal of short-
chain PFAS (greater sorption of short-chain PFAS than GAC) (Xiao et al., 2019; Ateia et al., 2019; EPA, 2021f).
• Modified mineral adsorbents. Mineral sorbents that have been modified using organic additives to increase
PFAS sorption, such as organically modified silica and organoclays (Stebel et al., 2019). Bench-scale studies
have observed more than 90 percent removal of total PFAS, with higher PFSAs removal rates than PFCAs.
• Biochar. Carbonaceous material derived from biomass. Biochar requires less energy to generate than
activated carbon but has slower adsorption kinetics and lower observed PFAS removal relative to GAC. Short-
chain PFAS are not readily removed using biochar (Xiao et al., 2017; ITRC, 2020).
10.3 Membrane Filtration
Membrane filtration is a physical separation process used for removal of both organic and inorganic compounds
in water. A driving force is applied to the influent stream to push pressurized water through a semi-permeable
membrane while rejecting larger, undesirable contaminants. Treated water (permeate) passes through the
membrane and the rejected water (concentrate) is collected for treatment or disposal. All membrane processes
generate a concentrated PFAS liquid wastestream that must be further treated or disposed. Membranes may also
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10—Review of PFAS Treatment Technologies
need to be replaced or disposed, generating a solid waste product. The following types of membranes are well-
studied for PFAS removal:
• Reverse Osmosis (RO). RO is a form of membrane filtration in which pressure is applied to transport liquid
through a membrane with a pore size of less than 1 nanometer. RO can be run as a continuous flow or batch
process. EPA's DWTD reports that RO typically achieves at least 98 percent removal of PFAS regardless of
chain length or functional group (EPA, 202If). One full-scale treatment study has reported between 67 and 97
percent removal of total PFAS using RO (Glover et al., 2018).
• Nanofiltration (NF). NF is a membrane process that is lower in pressure than RO in which the membrane has
pore sizes between 1 and 10 nanometers. Nanometer-sized membrane pores are used to remove compounds
in a process similar to RO, but NF allows smaller PFAAs and salt ions to pass through which would otherwise
be captured by the smaller pore sized used in an RO system. Lab-scale studies have shown nanofiltration
removal of PFAS up to 90 percent (Boo et al., 2018).
• Low Pressure Membrane Filters. Ultrafiltration and microfiltration, two additional types of membrane filters
with pore sizes larger than 10 nanometers, are less effective at capturing nonpolymer PFAS and are typically
used for particulate removal. Sampling at full scale DWTPs using microfiltration or ultrafiltration has shown no
or inconsistent removal (typically less than 50 percent) of PFCAs and PFSAs (EPA, 2021f), unless a powdered
adsorbent is used within the system.
Wastestreams may need to go through a pretreatment step to reduce the risk of membrane damage or fouling
(loss of production capacity) due to accumulation of material on the membrane surface.
10.4 Incineration/Thermal Treatment
Thermal treatment or incineration is using high temperatures to chemically break down PFAS. Incineration has
been used to destroy other halogenated organic chemicals such as polychlorinated biphenyls (PCBs) and ozone-
depleting substances, where sufficiently long exposures to sufficiently high temperatures break the carbon-
halogen bond, after which the halogen can be scrubbed from the flue gas, typically as an alkali-halogen (EPA,
2019c). These treatments can be used for AFFF and solid wastes onto which PFAS has adsorbed, such as spent
GAC or sludge, but may also be applied to PFAS-containing wastewater. However, PFAS are more difficult to break
down than other halogenated organic chemicals due to fluorine's electronegativity and the chemical stability of
fluorinated compounds.
Incinerators or combustors that are already in place for hazardous or municipal waste destruction may be used to
destroy PFAS (Watanabe et al., 2016; EPA, 2020e). Incomplete destruction of PFAS during combustion can result
in the formation of smaller PFAS or mixed halogenated organic byproducts, referred to as products of incomplete
combustion (PICs) (EPA, 2019c, 2020f).
The effectiveness of incineration to destroy PFAS and the tendency for formation of PICs is not currently well
understood. Few experiments have been conducted under oxidative and temperature conditions representative
of field-scale incineration. Limited studies on the thermal destructibility of fluorotelomer-based polymers found
no detectable levels of perfluorooctanoic acid after 2 second residence time at 1,000°C (Yamada et al., 2005;
Taylor et al., 2014). Emission studies, particularly for PICs, have been incomplete due to lack of necessary
measurement methods suitable for the comprehensive characterization of fluorinated and mixed halogenated
organic compounds. EPA is actively researching the effective destruction temperatures and treatment times for
PFAS, the potential to generate PICs, and the release and potential land deposition of PFAS-containing stack
gases.
10.5 Advanced Oxidation and Reduction Processes
Advanced oxidation and reduction as methods for destruction of PFAS have been studied more in recent years.
Through a series of oxidation and reduction reactions, PFAS molecules are defluorinated, decreasing the
fluorinated carbon chain length until the PFAS molecules are degraded into base components such as C02, H20,
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10—Review of PFAS Treatment Technologies
and F". Full destruction is achieved when only the base components remain. Because PFAS are destroyed through
these processes, PFAS are eliminated from wastewater rather than being captured via adsorption or membrane
filtration. If PFAS molecules are not fully destroyed through these reactions, effluent concentrations of PFAAs and
precursors can increase.
Most advanced oxidation and reduction processes do not generate a liquid or solid waste that would need to be
managed.
10.5.1 A dvanced Oxida tion Processes
Advanced oxidation processes (AOPs) treat water by activating an oxidizing agent to react with and degrade
contaminants. Chemical oxidation uses chemical catalysts to initiate degradation reactions. Chemical catalysts
that have been studied for PFAS destruction include ozone, zero valent iron, and persulfate (Mitchell et al., 2013;
Dai et al., 2019; Lee et al., 2020). Electrochemical oxidation uses electrical currents generated by specialty
electrodes to catalyze oxidation reactions. Boron doped diamond electrodes, metal-oxide electrodes, and porous
electrode membranes have been studied for PFAS destruction and studies report PFAS mass reductions ranging
from 71 to 99 percent (Gomez-Ruiz et al., 2017; Le et al., 2019; AECOM, 2020; EPA, 2021w).
EPA's PFAS Innovative Treatment Team (PITT) identified electrochemical oxidation and supercritical water
oxidation (SWCO) as two noncombustion PFAS destruction treatments for further research and consideration
(EPA, 2021w, 2021x). SWCO catalyzes rapid oxidation reactions by applying heat greater than 705 °C and pressure
greater than 221.1 bar to an aqueous solution or solid. In the presence of an oxidizing agent, supercritical water
dissolves and oxidizes PFAS. SWCO has demonstrated up to 99 percent destruction of targeted PFAS in diluted
AFFF, membrane concentrate, and landfill leachate by three vendors (EPA, 2021x). PITT further reports that
SWCO is a potential solution for treatment of spent GAC and IX resin.
AOPs are nonselective, oxidizing all available contaminants. Therefore, the presence of nonPFAS oxidizable
compounds in the influent may increase competition and reduce PFAS removal efficiency (particularly with
chemical oxidation). Removing nonPFAS oxidizable compounds prior to AOP reduces treatment time and the
amount of oxidant needed to destroy PFAS, increasing treatment performance (Ross et al., 2018).
10.5.2 A dvanced Reduction Processes
Advanced reduction processes (ARPs) use the same reaction mechanisms as AOPs but use positively charged
radicals to initiate reduction reactions to degrade PFAS rather than oxidation reactions. Strong alkaline systems
are required to initiate reduction reactions. Lab-scale studies have shown between 70 percent and 99.9 percent
destruction of PFAS at pH9 to pH 12 using ARPs (Qu et al., 2014; Bentel et al., 2020).
10.6 Emerging PFAS Treatment Technologies
Table 14 presents PFAS treatment technologies that are in earlier stages of research and development. Some of
these technologies build on treatment mechanisms outlined in the previous sections. There are limited data
available on applicability and scalability of these treatments.
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10—Review of PFAS Treatment Technologies
Table 14. Emerging PFAS Destruction Technologies
Treatment
Treatment Description
State of Research
Reference
Aqueous Electrostatic
Concentrator
Combined use of IX membrane and electrodes to
separate PFAS from solution and initiate oxidation
reactions.
Lab-scale study of the patented technology reports
99% removal of both PFOA and PFOS.
Jackson, 2019
Bismuth
Oxyhydroxyphosphate
(BOHP)
Photocatalytic process in which BOHP (Bi30(OH)(P04)2) is
activated by ultraviolet light to degrade PFAS through
oxidation or reduction reactions.
A pilot-scale study from the DOD's Strategic
Environmental Research and Development Program
(SERDP) reports up to 95% destruction of PFCAs and
90% degradation of fluorotelomers.
Sahu et al., 2018
Cates, 2020
Boron Nitride Oxidation
Use of activated boron nitride and ultraviolet light to
degrade compounds.
One lab-scale study reports 99% removal of PFOA and
20% removal of FIFPO-DA.
Duan et al., 2020
Electron Beam
(E-beam)
Use of an accelerator to generate a stream of highly
energetic electrons that are bombarded onto
contaminated water, initiating both reduction and
oxidation reactions.
Reports from SERDP state E-beam technology reduced
PFOA and PFOS concentrations by up to 99.99% in soil
samples and up to 87.91% in groundwater samples.
Pillai, 2020
Enhanced Contact
Plasma Reactors (ECPR)
Plasma-based water treatment uses electricity to convert
water into a mixture of highly reactive species (i.e.,
plasma) that rapidly and nonselectively degrade PFAS.
Lab-scale studies report up to 99% removal of PFAS for
lab-prepared solutions and landfill leachate samples.
Singh et al.,
2019, 2021
Mechanochemical
Degradation
Destruction method using a high-energy ball-milling
device and co-milling reagents to produce localized high
temperatures and radicals that break down
contaminants.
One lab-scale study reports 99% destruction of target
PFAS in AFFF-impacted soil. Identified by EPA's PITT as
a potential noncombustion destruction method for
PFAS that would not require high temperatures or
solvents.
EPA, 2021y
Pyrolysis and
Gasification
Thermal treatment that decomposes materials at
moderately elevated temperatures in oxygen free or very
low oxygen environments. Used to transform biosolids
into biochar and hydrogen-rich synthetic gas.
Limited data available on PFAS destruction. Identified
by EPA's PITT as a potential noncombustion
destruction method for PFAS in biosolids.
EPA, 2021z
Sonochemical
Oxidation/ Ultrasound
Use of sound waves to facilitate cavitation in water which
in turn releases large amounts of thermal energy and
hydroxyl radicals to initiate PFAS degradation reactions.
One lab-scale study reports 90% destruction of PFOS.
Identified by EPA's PITT as a potential noncombustion
destruction method for PFAS in biosolids.
Wood et al.,
2020
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11—References
11. References
1. 3M, 2020a. 3M Company. 2018 - 2019 PFAS Characterization Data for 3M Manufacturing Facilities. (01
May 2020).
2. 3M, 2020b. 3M Company. NPDES Permit Materials and Wastewater Treatment Diagrams for Cottage
Grove (MN), Decatur (AL), and Cordova (IL) Facilities. (2020).
3. ACRP, 2017. Airport Cooperative Research Program, National Academies of Sciences, Engineering, and
Medicine 2017. Use and Potential Impacts ofAFFF Containing PFASs at Airports. ACRP Research Report
173. (2017). Washington, DC: The National Academies Press. Available online at
https://doi.orR/10.17226/24800.
4. AECOM, 2019. Perfluorobutane Sulfonic Acid (PFBS) Chemistry, Production, Uses, and Environmental
Fate in Michigan. Prepared for Michigan Department of Environment, Great Lakes, and Energy. (23
September 2019). Available online at
https://www.michiRan.Rov/documents/pfasresponse/Perfluorobutane Sulfonic Acid PFBS Chemistry
Production Uses and Environmental Fate 704238 7.pdf
5. AECOM, 2020. DE-FLUORO™ Demonstration Program Results. (2020). Available online at
https://www.aecom.com/au/wp-content/uploads/2019/ll/DE-FLUORO-Demonstration-ProRram-
Report Industry Reduced-for-web.pdf
6. AF&PA, 2020a. American Forest and Paper Association. Letter to EPA Office of Water, Engineering and
Analysis Division: AF&PA Information Related to EPA's Study of Potential PFAS Effluent Limitations
Guidelines. (15 July 2020).
7. AF&PA, 2020b. American Forest and Paper Association. Letter to EPA Office of Water, Engineering and
Analysis Division: American Forest and Paper Association's Follow Up Information Related to EPA's
Study of Potential PFAS Effluent Limitations Guidelines. (3 September 2020).
8. AF&PA, 2020c. American Forest and Paper Association. Letter to EPA Office of Water, Engineering and
Analysis Division: Updated Tables Summarizing PFAS Concentrations in Pulp and Paper Mill Treated
Effluents, Intake Waters, and Pulp Fiber. (19 October 2020).
9. AF&PA, 2020d. American Forest and Paper Association. Letter to EPA Office of Water, Engineering and
Analysis Division: Additional Information Related to EPA's Study of Potential PFAS Effluent Limitations
Guidelines. (18 November 2020).
10. Ahlstrom-Munksjo, 2021. Fluorofree papers and sustainable packaging solutions: FluoroFree®
Greaseproof Technology. (Accessed 19 July 2021). Available online at https://www.ahlstrom-
munksio.com/Media/articles/fluorofree-papers-and-sustainable-packaRinR-solutions/ and
https://www.ahlstrom-munksio.com/products/technoloRies/ff-Rreaseproof-technoloRies/.
11. Ahuja, K., and Mamtani, K. 2016. Fluorotelomers Market Size by Product (Fluorotelomer Iodide,
Fluorotelomer Acrylate, Fluorotelomer Alcohols), by Application (Textiles, Stain Resistant, Food
Packaging, Fire Fighting Foams), Industry Analysis Report, Regional Outlook, Application Potential, Price
Trends, Competitive Market Share & Forecast, 2016-2023. (April 2016). Available online at
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12. Appleman et al., 2014. Appleman, T.D., Higgins, C., Quinones, 0., Vanderford, B., Kolstad, C., Zeigler-
Holady, J., Dickenson, E. Treatment of poly- and perfluoroalkyl substances in U.S. full-scale water
treatment systems. (15 March 2014). Water Research, 51, 246-255. Available online at
https://doi.orR/10.1016/i.watres.2013.10.067.
13. ASTSWMO, 2015. Association of State and Territorial Solid Waste Management Officials, Remediation
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