Yellowstone National Park is one of the most iconic and beloved natural areas in the world.

Spanning over 2.2 million acres, the park boasts an astonishing variety of geothermal features, wildlife, and landscapes, including Old Faithful, the Yellowstone River Canyon, and Lamar Valley.

Established on March 1, 1872, by President Ulysses S. Grant, Yellowstone was a landmark achievement in the history of conservation and public lands.

A Fresh Perspective

The idea of setting aside a large area of land for public enjoyment originated in the mid-19^th century, when several visionary leaders, including artist George Catlin and writer Henry David Thoreau, argued for the preservation of natural beauty and wilderness.

However, it wasn’t until the 1870s that the concept won support, thanks to the efforts of several key figures like geologist Ferdinand Hayden, railroad executive Nathaniel Langford, and journalist Thomas Moran.

Hayden’s surveys of the Yellowstone region in 1871 and 1872, which documented the unique geology, flora, and fauna of the area, convinced Congress to pass the Yellowstone National Park Protection Act in 1872, which designated Yellowstone as a public park and placed it under federal management.

This was a radical departure from the prevailing attitude of the time, which saw natural resources as commodities to be exploited for profit.

Setting the Precedent

The proposal would establish maximum contaminant levels for PFOA and PFOS, and a hazard index approach for four other PFAS compounds.

On March 14, 2023, the Environmental Protection Agency (EPA) proposed a federal action to address per- and polyfluoroalkyl substances (PFAS) in drinking water, the first in over a decade. If approved, these new National Primary Drinking Water Regulations (NPDWR) will add six contaminants to the list of over 90 existing chemical compounds that are federally regulated under the Safe Drinking Water Act (SDWA).

PFAS compounds were once widely used as water repellants, non-stick surface treatments, and firefighting foams. This EPA ruling would regulate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), which according to Science Reporter, Bella Isaacs-Thomas, are “two well-studied legacy chemicals that have largely been phased out of use in the United States but linger in the environment and are still used in manufacturing abroad.”

These regulations aim to cap PFOA and PFOS contamination at four parts per trillion (ppt), the lowest level at which they can be reliably measured. It’s worth noting that meeting this standard wasn’t possible in 2016, when the health advisory level was 70 ppt. However, as laboratory technology continues to evolve, water practitioners can detect, measure, and remove contaminants from drinking water better than ever.

The other four PFAS — perfluorononanoic acid (PFNA), perfluorohexane sulfonic acid (PFHxS), perfluorobutane sulfonic acid (PFBS), and hexafluoropropylene oxide dimer acid (GenX Chemicals) — would be regulated as a mixture, by testing for each one individually and assessing their risk in combination with one another.

Federal estimates place the number of public drinking water systems requiring treatment upgrades to meet new PFAS maximum contaminant levels (MCLs) between 3,300 and 6,600. That’s nearly 5-10% of the estimated 66,000 public drinking water systems that will need to treat their water to remove PFAS compounds to comply with new SDWA regulations for the six PFAS chemicals.

The EPA anticipates plans to be finalized by the end of 2023, but agencies will have additional time to adjust to these stringent changes. Officials will go through the usual proposal approval process, opening a public comment window after regulations are published to the Federal Register. Regulations won’t take full effect until year three.

As for public water systems in communities with limited resources, the EPA’s increasing involvement in PFAS regulation begs the question, how will they manage compliance costs?

Federal aid funding programs will help small and disadvantage communities redress contaminated drinking water. The Bipartisan Infrastructure Law allocates $9 billion towards underserved regions impacted by PFAS and other emerging contaminants. The EPA will direct that money toward water utilities and communities that are on the front lines and are resource-constrained the most.

And as the current administration advocates for EPA’s new budget this year, more resources will be required to combat this pervasive issue.

Local agencies can also access an approximate $12 billion in Drinking Water State Revolving Funds (DWSRF), dedicated to making drinking water safer, and billions more that the federal government has annually provided to fund DWSRF loans — all of which can help communities make important investments in solutions to remove PFAS from drinking water.

Treating the Cause, Not the Effect

The best available technologies to treat for PFAS are Granular Activated Carbon (GAC), Anion Exchange (AIX), Reverse Osmosis (RO), and Nano-filtration (NF). While all of these technologies have shown to be effective in achieving 99% removal and to specifically meet the four ppt proposed MCLs, they are removal technologies that result in contaminant transfer from one media to another rather than complete destruction.

This can be problematic as the EPA has also proposed regulating PFOA and PFOS as hazardous substances under CERCLA, which may ultimately affect the disposal costs associated with treatment residuals (i.e., spent carbon media, and concentrated waste streams). EPA estimates that disposing of spent treatment media would cost an additional 3-6%.

The EPA provided a cost-benefit evaluation, comparing the cost of treating the health effects associated with PFAS consumption in drinking water versus the treatment costs, and found that the costs were roughly the same, approximately $1 billion annually. Note that the treatment cost does not consider potential treatment residuals disposal cost increases associated with a change from non-hazardous to hazardous waste.

Although the cost of treating the PFAS in drinking water before it causes health effects is roughly comparable to the costs of treating the health effects themselves, EPA’s proposed regulation is effectively seeking to treat the cause rather than the effect to improve the overall health of the U.S. population served by public water systems.

Key Takeaways

1. The proposal sets numerical standards of four ppt for PFOA and PFOS, a hazard index of one for four GenX Chemicals, and non-enforceable Maximum Contaminant Level Goals (MCLGs) for all six PFAS.

*above table from

2. The new PFAS regulations will require additional testing at about 66,000 public water systems, and 5-10% of these systems are expected to require additional treatment to remove PFAS.

3. The Hazard Index considers the different toxicities of GenX Chemicals, PFBS, PFNA, and PFHxS. Water systems would use a hazard index calculation to determine if the combined levels of these PFAS in the drinking water at that system pose a potential risk.

*above table from

4. The MCLs were set at the levels that can “reliably be measured,” but the MCLG is zero, leaving potential for them to get even lower as analytical precision improves.

Authors:

Dawn E. Bockoras | National Director – Environmental Investigation & Remediation | ATLAS

Rik Lantz, P.G., LEED-AP | Senior Consultant, Federal Programs | ATLAS

Among the many hurdles to brownfields assessment, remediation, and redevelopment, funding is often the most significant. But thanks to a new federal law, the funding outlook for brownfields projects in the United States has never been better.

Enacted last November, the Bipartisan Infrastructure Law provided $1.5 billion over five years in federal funding for the Brownfields Program at the U.S. Environmental Protection Agency (EPA). This funding represents an approximately six-fold increase over typical annual spending levels for the program. Of the $1.5 billion, $600 million is allocated to assessment grants, which recipients may use to determine the extent of contamination and plan revitalization at brownfield sites. Another $160 million is for cleanup grants, and $150 million for multipurpose grants, which may be used for planning, assessing, and cleaning up sites.

In some cases, cost-share requirements are waived, making the money even more accessible to cash-strapped local governments. However, application deadlines are approaching, so communities looking to obtain their share of this grant funding need to have a plan.

Barriers to growth

A brownfield is a property that is difficult to develop because it is contaminated or believed to be contaminated. Unlike a superfund site, a brownfield may have any number of potential contaminants, including hazardous substances, petroleum, asbestos, lead-based paint, mold, meth-lab residue, or mine-scarred lands.

The EPA estimates that more than 450,000 brownfields exist in the United States. Unless addressed, such sites can hamper local development efforts and preclude economic growth.

To facilitate their development, some sites must undergo an extensive assessment process and, if necessary, cleanup. Although grant funding for these activities is available from the EPA and states, navigating the application processes can be confusing and time-consuming. For this reason, communities often opt to work with a trusted partner that can help them overcome the many hurdles in their way.

Help with grant funding

Working with rural and urban communities, state regulators, and the EPA’s Brownfields Program, �鶹TV��վ helps to revitalize communities by providing critical research needed for successful grant applications. We offer a wealth of expertise with  an experienced brownfields team that includes grant writers, licensed geologists and engineers, certified hazardous materials managers, certified industrial hygienists, certified safety professionals, and EPA-certified asbestos and lead-based paint building inspectors and risk assessors.

The company has a proven track record in helping communities procure much-needed funds for brownfields assessment, mitigation, and redevelopment. Some of the recent grants that �鶹TV��վ has helped to obtain include:          

• Gila County Brownfields Coalition, EPA Community-Wide Assessment Grant, awarded in 2021
• Vermillion County, Indiana, EPA Brownfields Community-Wide Assessment Grant, awarded in 2022
• City of Lebanon, Indiana, EPA Brownfields Community-Wide Assessment Grants, awarded in 2014, 2019, and 2022
• Town of Superior, Arizona, Community Development Block Grant for Assessment and Abatement, awarded in 2021
• City of Terre Haute, Indiana, EPA Brownfields Community-wide Assessment Grant, awarded in 2020
• Town of Chester, Connecticut, Connecticut Municipal Brownfields Grant for Assessment, awarded in 2022
• City of Indianapolis, Indiana, EPA Brownfields Multi-Purpose Grant, awarded in 2019
• Lawrenceburg, Aurora, Greendale and Dearborn County Coalition, Indiana, EPA Brownfields Coalition Assessment Grant, awarded in 2019

Obtaining an EPA grant for brownfields-related work can benefit communities in many ways, as shown by the example of the grant to Gila County. Serving as the grant administrator, the county represents a coalition of small communities in Arizona that share a prominent history of copper mining that continues today. Known as the “Copper Corridor,” the communities have worked with �鶹TV��վ to address blight issues and win the EPA grant. Armed with this funding, the communities can begin to assess and prioritize their needs, the first step in solving challenges pertaining to brownfields.

After an Award      

Winning a grant is only the first step. �鶹TV��վ collaborates with grant recipients to facilitate public outreach to affected communities. The outreach events are designed to provide information about the brownfield assessment and redevelopment process, benefits to the community, and additional funding opportunities and low-interest loan funding for eligible property-owners.

�鶹TV��վ also stands ready to help communities submit necessary post-award application materials, engage and inform stakeholders and community residents, develop or expand current brownfield inventories, as well as conduct the assessment and remediation of identified brownfield sites. We have extensive experience performing hundreds of brownfields projects with EPA oversight throughout the United States during the last 20 years.

For example, �鶹TV��վ has been working with the Salt River Pima-Maricopa Indian Community—a Native tribe located in the Phoenix metropolitan area—to implement a $750,000 EPA Brownfields grant that was awarded in 2021.  To this end, �鶹TV��վ is creating an all-encompassing Quality Assurance Project Plan (QAPP) and Sampling and Analysis Plan, both of which are required by the EPA to be completed and approved before initiating sampling or cleanup activities utilizing grant funds.

On the same project, �鶹TV��վ has also been tapped to complete Phase I Environmental Site Assessments and Phase II Environmental Site Assessments, following ASTM standards, and complete ground-penetrating radar investigations and surveys. �鶹TV��վ also will create an environmental records database, for future use, and conduct a brownfields survey of the community to assist with the creation of a community-wide inventory of blighted properties within the Salt River Pima-Maricopa Indian Community.

�鶹TV��վ provides professional testing, inspection, engineering, environmental, and consulting services from more than 150 locations nationwide, enabling us to provide our clients with a superior level of consistent support and resources no matter where their projects may be located. The company employs more than 3,500 professional staff, including professional engineers, geologists and environmental specialists who can be accessed as needed to provide additional project support.

From obtaining grant funding to conducting the necessary assessments and cleanup, �鶹TV��վ can help communities of all sizes address their needs regarding brownfields and unlock the economic and social potential of sites that currently are difficult or impossible to develop.

�鶹TV��վ, O’Neill Service Group and partners are driving Salmon recovery in the Pacific Northwest.

State and local habitat enhancement dollars are funding the rebuilding of critical infrastructure to better serve fish and human populations. Salmon are a critical part of the region’s ecology and culture; �鶹TV��վ is positioned to be a part of its recovery.

Washington State Department of Transportation’s program to replace more than 400 non-conforming culverts beneath state highways is one of these programs. �鶹TV��վ is developing National Environmental Policy Act documents, Section 404 and 401 permit applications, performing quality assurance and environmental/material testing for these projects to restore hundreds of miles of historic breeding and rearing habitat statewide. Fish have already returned to stream habitat above the repaired culvert replacements. �鶹TV��վ is under contract for 35 culvert replacement projects in Washington.

As construction manager for King County, �鶹TV��վ is also removing old levees and reestablishing critical floodplain habitat along the region’s major rivers. The levee setback program is a major win for both salmon and the local communities, improving flood protection function and reconnecting habitat. Historic runs of chum salmon are returning to newly created channels like the one at Lones Levee Setback and Floodplain Restoration Project.

�鶹TV��վ looks forward to many years of important restoration in the Pacific Northwest.

Published by Engineering News-Record (ENR) – Environmental Management
On August 1, 2022

As a leading environmental firm, �鶹TV��վ is committed to supporting our clients’ needs with sustainable PFAS solutions that are consistent with evolving regulatory changes and how those changes may affect their risk-based decisions.

PFAS are a group of synthetic chemicals that contain linked chains of carbon and fluorine. Often referred to as “forever chemicals,” the bond between carbon and fluorine atoms is one of the strongest in nature – making PFAS chemicals difficult to remediate and remove.

PFAS chemicals have been used in various industrial and commercial applications and consumer products since the 1940s, including non-stick cookware, waterproofing materials, and firefighting foam. While their unique stability and resistance to degradation ensure durable, long lasting consumer products, their pervasive nature also leads to significant environmental challenges. Because the chemicals have been used in products for decades, most people have been exposed to them through the food we eat, or from contaminated drinking water and can cause potential adverse health effects.

The ability of PFAS to bio-accumulate in the environment, coupled with its high mobility, have led to persistent contamination concerns. The introduction of PFAS into wastewater and solid waste has led to further distribution of PFAS into rivers and streams, surface water, and sludge applied to land.

While most advanced laboratories can identify up to 70 PFAS chemicals, thousands of PFAS chemicals are known to exist.  The PFAS class of chemicals continues to expand as manufacturers and laboratories identify and create replacement PFAS chemicals.

The absence of a comprehensive federal policy regarding PFAS chemicals creates challenges for many environmental lifecycle stages, including property transactions, investigation, treatment, waste handling and disposal, and litigation.

Although the use of certain PFAS chemicals has been discontinued, legacy uses, unregulated imported products, and a lack of commercially viable alternatives to certain public safety products (e.g., firefighting foams) will continue to present ongoing environmental issues and human health concerns.

Scientific research into human and environmental health concerns is considered a critical first step toward regulating PFAS chemicals.  This research can take years to complete and continues to lag behind the manufacturing and industrial waste that comes from their use. As a result, regulation has either been delayed, as is the case at the federal level, or has been pursued with intentional conservatism, which is the case in some states.

The EPA recently announced plans for new wastewater regulations, including first limits for PFAS, and updated limits for nutrients – from key industries. The new , identifies opportunities to better protect public health and the environment through regulation of wastewater pollution.

For the last five years, our team of scientists and geologists at �鶹TV��վ have specialized in providing site investigations and innovative treatment solutions for perfluoroalkyl and polyfluoroalkyl substances (PFAS). Our services include:

• Public Supply and Private Drinking Water Sampling
• Groundwater, Surface Water, Soil, & Sediment Sampling
• Stormwater Treatment Design
• Design of Poet Systems – Private and Public Supply
• Landfill Monitoring Services
• Forensic Analysis
• Standard Operating Procedures & Best Practices

For more information on how �鶹TV��վ addresses PFAS challenges, read more >>