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EPA Considering Regulatory Action for PFAS in Air

September 7th, 2023 by Kathlynn Traub


Due to a diverse array of sources for air emissions, including but not limited to, chemical manufacturers, incineration processes, and various dynamic applications, the US EPA has been pressed to develop test methods for measuring PFAS source emissions. Of the already established methods for other source-emission categories like HAPs, TAPs, and VOCs, EPA has concentrated its efforts to further develop three (3) methods specific to PFAS.

The first method is called “(OTM)-45”. This method can detect up to 50 specific PFAS chemicals and quantify their emissions from stationary sources by taking a gaseous sample directly from the source and evaluating it via liquid chromatography coupled with tandem mass spectrometry.

The second method, “SW-846,” is a modified “Method 5” procedure revised specifically for PFAS assessment. This method was originally developed for semi/non-volatiles prior to the resurgence of PFAS in regulatory discussions.

Lastly, the EPA recommends method “TO-15”, which is a method created for volatiles. Since some longer chained PFAS chemicals are also considered VOCs, this method can work for identifying some PFAS chemicals. However, PFAS chemicals like GenX, will not be identified in this method.  

Source emissions from industry and commercial uses leads to concerns with ambient air quality and the development of standards for fugitive emissions, long term exposure calculations, and regulatory deposition. Methods for sampling or calculating ambient air figures for PFAS are still in developmental stages and are only loosely mentioned in EPA reference documents. However, the EPA recently issued a proposal for a change to air standards within the Federal Register. This proposal moves to identify PFAS compounds as Required Pollutants and include them in HAP related regulatory limitations. Prior to EPA developing threshold and exposure levels for air, drinking water, and various other environmental factors, EPA has alluded to the requirement under the proposed subpart that owners/operators of businesses would be required to use source measurements or, if measuring techniques have not yet been thoroughly developed, use estimation methods for reporting annual PFAS emissions. The proposed rule finishes with the reporting threshold for air emissions at 0.05 tons per year for any and all users/manufacturers of PFAS, PFAS-containing, and PFAS-related materials.  


Author:  Kathlynn Traub (Majors) 
Southeastern Sales Manager |Senior Consultant