Over the last several months, the California Department of Toxic Substances Control (DTSC) has issued letters to a number of industrial parties, including treatment, storage and disposal facilities (TSDFs), requesting information relating to hazardous substances, hazardous waste, and hazardous materials regarding the occurrence of per- and poly-fluoroalkyl substances (PFAS). DTSC is primarily interested in information related to PFOA and PFOS due to the US EPA Drinking Water Health Advisory of 70 ppt for the sum of PFOA and PFOS.
The information requested is as follows:
1. Any generator supplied data or information that you possess concerning the presence of PFOA or PFOS in off-site generated hazardous waste managed at your facility.
2. Any data or information produced by your facility concerning the presence of PFOA or PFOS in off-site generated hazardous waste managed at your facility.
3. Any data or information produced by your facility concerning the presence of PFOA or PFOS in waste generated at your facility (e.g., wastewater, landfill leachate, etc.).
4. Any data or information produced by your facility concerning the presence of PFOA or PFOS in environmental media (i.e., ambient air, soil, soil gas, storm water, and/or groundwater).
The letter goes on to require a certifying signature (under penalty of law), confirming whether the recipients have PFAS information to provide (and provide it), or do not have PFAS information to provide.
While this request is limited to information available and there is no current expectation that recipients perform any sampling or analysis in response to the letter, it is prudent for the regulated community to expect that the DTSC will likely require sampling and analysis of groundwater at some point, similar to New York state.
Rock J. Vitale, CEAC
Technical Director of Chemistry/Principal
This article is brought to you by Rock J. Vitale. For more information you can reach him at rvitale@www.envstd.com
