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PFAS & Air: What Do We Know?

May 23rd, 2023

If you’re reading this, it’s safe to assume that you’re at least familiar with PFAS (If you’re not, run, don’t walk, to subscribe to HRP’s PFAS Pulse).  You’ve heard about PFAS in wastewater, and drinking water, and groundwater – really all the waters, but what about AIR?! Don’t worry – your friendly neighborhood airhead is here to tell you everything we know about PFAS regulations as it relates to air. 

The Short of It

There’s not too much to worry about yet.  As those of us who deal in air know, EPA typically saves the best for last.  But that doesn’t mean we get a get out of jail free card.  It’s coming eventually and it’s always best to be prepared.

The Long of It

Although EPA hasn’t done much yet, states are stepping up to fill in the gap.  New York, Michigan, Minnesota, Texas, and others are starting to regulate PFAS under their respective air toxics programs.   This could mean facilities would be required to identify and quantify emissions and maybe even conduct dispersion modeling depending on the individual state requirements.

Preliminary modeling analyses conducted by EPA and other private entities have shown that AERMOD is fairly accurate at predicting where maximum impacts occur, but not necessarily the correct concentrations.  As you know, PFAS is a family of compounds, each of which can behave differently in the environment.  More research is being done on this (spoiler alert- this is a theme).

In addition to modeling research, EPA and private entities are developing test methods to measure PFAS via stack testing.  Different compounds can behave as volatiles or particulates, so again, more research is being done on this. 

To get more information on PFAS usage, EPA started collecting data via Toxics Release Inventory (TRI or Form R) reporting.  Starting in 2020 facilities were required to report their PFAS usage, however it turned out, likely due to the de minimis exemption, only about 40 facilities nationwide reported PFAS usage.  As a result, EPA has proposed to remove the de minimis exemption to get a better picture of PFAS emissions.

The Future of It

While I know we’re all hoping for PFAS detecting hoverboards, the future of PFAS in air is not quite as exciting. In the near term, we expect EPA to continue to collect information from facilities through increased TRI reporting and formal Information Collection Requests (ICRs).  States will continue to step up and incorporate PFAS regulation into their state regulatory programs.  In the end, EPA will likely use the NESHAP program to regulate PFAS from source categories, though that is probably 5-10 years out. 

Although the future is uncertain, HRP has your back.  We’re continuously monitoring PFAS regulatory actions, and our capable airheads are here to help!