Chrome Plating Facilities be advised! Phase II of the State Water Board’s PFAS Investigation Order were mailed out on October 25, 2019
By: David Renfrew, Vice President, Water Resources Director at Alta Environmental|NV5
On October 25, 2019, the State Water Resources Control Board (SWRCB) issued Investigative Order WQ 2019-0045-DWQ (Order). This was the second phase rollout of the SWRCB’s three phased investigation of per- and polyfluoroalkyl substances (PFAS) listed in SWRCB Resolution No. 92-49. The SWRCB already directed PFAS testing at 30 airports and 196 landfills, and intends to target other potential PFAS sources in the state to do the same. This second phase roll out listed chrome plating facilities in California that have stored and/or used fume suppressants or other substances that may contain PFAS and are required to submit information to the appropriate Regional Water Quality Control Board (RWQCB).
As listed in the Order “PFAS is a family of more than 3,000 man-made and mostly unregulated chemicals that have been produced since the mid-1900s. They are mobile, persistent, and bioaccumulative. They are resistant to degradation in the environment and when degradation occurs, it often results in the formation of other PFAS compounds…Currently the key classes of concern are perfluoroalkyl sulfonic acids such as the long-chain perfluorooctanesulfonate (PFOS) and perfluorooctanoic acid (PFOA)… Historically, fume suppressants used in chrome plating operations often contained PFOS as an active ingredient. Although PFOS based fume suppressants have not been used in California since September 2016, these newer non-PFOS fume suppressants may contain other PFAS.”
Facilities listed in the Order should be advised that Site Investigation Workplans are due to the State by January 31, 2020. Facilities listed in the Order that do not perform chrome plating, or if fume suppressants were not used, disposed, discharged, spilled, or released in any way to the land, drains, sewers, surface water, air, and/or groundwater, a questionnaire in lieu of performing the site investigation was due to be submitted to their local RWQCB by November 25, 2019. This date is past due, but there are many facilities that may not be aware of this Order.
The purpose of the order is to determine whether the stormwater, effluent wastewater, groundwater, and/or soil at a given location is impacted by PFAS and to obtain an understanding of PFAS concentrations in the soil, groundwater, stormwater runoff, and/or effluent wastewater at these facilities. The Order requires facilities to perform the following actions:
Facility managers should be advised that fully assessing your facility’s current or historical use of PFAS compounds may have particular implications on future management actions and planning. Also, developing a defensible work plan is critical and should consider specialized sampling and analytical techniques to ensure high quality and defensible results are obtained.
Alta Environmental’s experts provide consulting expertise, preparation of workplans, monitoring, and reporting in response to SWRCB Investigation Orders. For further assistance or to learn if your facility is subject to these regulations, or for just compliance concerns in general, give us a call at 562-495-5777 or email our Water Resources experts. David Renfrew can be reached via email at David.Renfrew@altaenviron.com.