North Carolina DEQ Action Strategy for PFAS

On June 7, 2022, the North Carolina Department of Environmental Quality (NC DEQ) announced their Action Strategy for Per- and Polyfluoroalkyl Substances (PFAS). NC DEQ plans to enact the Action Strategy in conjunction with the United States Environmental Protection Agency (U.S. EPA) PFAS Strategic Roadmap to address the impacts of PFAS in North Carolina. You can learn more from ALL4 about U.S. EPA PFAS Strategic Roadmap here.

Actions to Date

North Carolina has a history of taking action to address the impacts of PFAS, most notably when hexafluoropropylene oxide (HFPO) and its ammonium salt (together referred to as “GenX chemicals”) were discovered in the Cape Fear River in 2017. In response to this discovery, NC DEQ took actions to mitigate GenX chemicals in the area. The North Carolina Department of Health and Human Services (NC DHHS) also responded by establishing a state provisional drinking water health goal for GenX chemicals of 140 parts per trillion (ppt). This health goal has now been superseded by the U.S. EPA’s Drinking Water Health Advisories for PFAS for GenX chemicals of 10 ppt. You can learn more from ALL4 about U.S. EPA Drinking Water Health Advisories for PFAS here.

Additionally, NC DEQ has conducted several reviews and evaluations of PFAS. Other actions to date include, but are not limited to:

• Developing analytical methods and toxicology protocols;
• Establishing an air deposition monitoring network;
• Surveying PFAS foam occurrence;
• Monitoring surface water for PFAS; and
• Promulgating monitoring and disclosure requirements for National Pollutant Discharge Elimination System (NPDES) permits.

Future Priorities

The new Action Strategy prioritizes three key action areas:

Protecting Communities

The first action area is focused on increasing NC DEQ’s understanding on how people are exposed to PFAS. In addition to further research and testing, the Action Strategy includes:

• Promulgating reporting requirements for releases to air, surface water, and groundwater from priority locations (e.g., chemical plants, wastewater treatment plants, landfills, and facilities that use firefighting foam); and
• Developing a list of PFAS most frequently detected in North Carolina (referred to as the “PFAS Priority List”).

These goals are listed as “in progress” and “ongoing” in the Action Strategy.

Protecting Drinking Water

The second action area is focused on proposing regulatory standards. The Action Strategy includes:

• Proposing groundwater standards for perfluorooctanoic acid (PFOA), perfluorooctyl sulfonate (PFOS), Gen X, perfluorobutane sulfonic acid (PFBS), and perfluorobutanoic acid (PFBA) by Summer/Fall 2022;
• Proposing surface water standards for PFOA and other compounds by Fall/Winter 2022 or 2023; and
• Proposing maximum containment levels (MCLs) for priority PFAS in drinking water by Fall/Winter 2022 or 2023.

In addition to proposing regulatory standards, this action area also focuses on how the regulatory standards will be implemented. NC DEQ emphasizes that voluntary actions will be critical to reaching their goals and that it will directly support initiatives to lower the impacts of PFAS through technology and funding starting in Summer/Fall 2022.

Cleaning Up Existing Contamination

The third and final action area focuses on remediation of PFAS contaminated sites. The Action Strategy includes:

• Setting remediation goals for PFAS contaminated sites; and
• Promulgating requirements for responsible parties to clean up PFAS contaminated sites.

These goals are listed as “in progress” and “ongoing” in the Action Strategy.

Other Efforts

The Action Strategy acknowledges that other efforts to address the impacts of PFAS are being pursued by other entities, including the NC DHHS, the North Carolina Department of Justice, the North Carolina Collaboratory, and academic institutions.

Next Steps

ALL4 continues to track the regulatory movements of North Carolina and all other states, maintaining a database of current state PFAS activity. If you have any questions about the NC DEQ Action Strategy for PFAS or PFAS more broadly, contact Kayla Turney at 610-422-1143, or your ALL4 project manager for more information.