Looking Ahead to More PFAS Air Emissions Source Testing

PFAS (per- and polyfluoroalkyl substances) are a group of synthetic chemicals that are resistant to heat, water, and oil. They are used in a wide range of products, including aqueous film-forming foams used for firefighting, nonstick cookware, lubricants, food packaging, and stain-resistant fabrics. Because of their widespread use, PFAS can be released into the environment through a variety of sources, including industrial air emissions, industrial wastewater, and landfill leachate.

The concerns with PFAS releases to the environment are not just limited to their presence in water and consumer products, PFAS have also been identified in air emissions at certain types of facilities. Outside of site-specific testing at facilities that use PFAS in their manufacturing process, there is little air emissions data for PFAS, but we expect this may change as interest in PFAS evolves and the regulatory classifications of and reporting requirements for certain PFAS change.  U.S. EPA currently has a testing methodology to measure air emissions of PFAS.  However, it is challenging to apply the methodology in a manner that yields representative results.

Other Test Method 045 (OTM 045) is a fairly new method that has been developed for PFAS testing.  This sampling method was originally based on Method 0010 for semi-volatile organic compounds, except that the OTM 045 analysis is conducted using liquid chromatography and dual mass spectrometry (LC/MS/MS) with a qualitative analysis. OTM 045 can currently analyze 50 PFAS chemicals down to a 1.5 nanogram level (that’s super small!).

Because OTM 045 is a fairly new method, there are potential faults to be wary of when considering its use. PFAS compounds are everywhere and are very “sticky.” OTM 045 tries to accommodate the inherent omnipresence of the compounds by incorporating different types of blank samples: a proof blank, a field blank, and a reagent blank. A proof blank is used to determine if method analytes or other interferences are introduced into the sample from a clean, unused sample train (glassware with reagent, probe, and filter), while also accommodating the preparation and recovery of the sampling train in the field environment. A field blank is used with a sampling train that has previously been used in a sample run and will determine if method analytes or other interferences are introduced into the sample. Reagent blanks are used to determine if the reagents used in the sampling program are already contaminated with method analytes or other interferences. Blank samples are typically meant to be free of the substance for which they are being tested. However, when the substance is everywhere and laboratories are able to find PFAS substances in the nanogram levels, contamination is almost inevitable. As OTM 045 continues to be used in practice and is refined, regulatory agencies will be capable of collecting additional information that could be used to develop requirements or guidelines for emitters of PFAS.

Looking ahead, it is expected that the PFAS emitted to the air will be a target of data collection, health impact studies, and rule development.  Agencies are starting to ask questions about PFAS emissions and gather data that could result in requirements for additional types of sources to test their emissions and perform air dispersion modeling. Certain known PFAS air emissions sources are already subject to state air toxics programs or site-specific requirements to limit PFAS air emissions.  When considering whether you might have air emissions of PFAS at your facility, be sure to involve the right team of experts who understand your process, the sampling/analytical methodologies and their limitations, regulatory requirements around PFAS, and how the results of the PFAS air sampling program will be used.  Please contact us at info@all4inc.com for more information on test methods or for assistance developing a PFAS air emissions measurement program.