April 2021 Update: Our original article (below) listed “products used to enhance oil recovery” as a source of PFAS in the oil & gas sector. Since publishing the article, it has come to our attention that enhanced oil recovery’s relationship to PFAS is currently under evaluation, and pending additional research.
Federal and state regulatory agencies are increasingly focused on evaluating past use and potential environmental impacts associated with per- and polyfluoroalkyl substance (PFAS)-containing products. Many industries are impacted by PFAS throughout the product lifecycle, whether from manufacturing, use in products/processes, consumer use, or disposal. Several industries, including the oil and gas sector, are preparing to respond to requirements to evaluate the effects of previously applying PFAS-containing products onsite. As the United States Environmental Protection Agency (EPA) and state agencies move forward with enacting PFAS-related regulations, oil and gas companies should be aware of the types of requirements being developed, including those surrounding groundwater sampling.
PFAS Sources in the Oil & Gas Sector
Since the United States military specification required use of PFAS in firefighting foams in the late 1960s, PFAS-containing foams have become an industry standard for extinguishing Class B (flammable liquid) fires. As such, a primary source of PFAS within the oil and gas sector comes from aqueous film-forming foam (AFFF). Historical use and handling of AFFF, for incident response or training purposes, has likely resulted in PFAS release into the subsurface, which could cause PFAS impacts to groundwater. Even modern foams, unless specified as being fluorine-free, are likely to contain PFAS. PFAS also occur in the oil and gas industry as constituents in gas pipe linings, products used to enhance oil recovery, and mechanical lubricants.
Upcoming PFAS Groundwater Sampling and Evaluation Requirements
In February 2019, EPA released a PFAS Action Plan. To date, at least 27 states have also passed PFAS-related legislation addressing PFAS regulation, remediation, and/or monitoring, and at least 10 states have conducted or plan to conduct PFAS source investigations.
California released a PFAS Phased Investigation Approach in March 2019, outlining plans to require groundwater investigations for PFAS at various potential source facilities and nearby drinking water wells. Investigative orders for each facility type have varied in terms of requirements for specific PFAS analytes, media, and spatial radius to be investigated. Refineries are anticipated to receive investigative orders in Phase II of the PFAS Phased Investigation Approach. Though originally scheduled for rollout in 2019, Phase II has been delayed. However, a May 2020 Water Boards memo has indicated investigative orders to refineries may be issued within the year. In anticipation of these orders, facilities may consider compiling available comprehensive baseline data through groundwater sampling.
PFAS Groundwater Sampling Considerations
PFAS exist in certain clothing, sampling equipment, food packaging materials, and other common products, and may adsorb to sampling materials. Recent research evaluated several types of materials associated with PFAS sampling and found that PFAS presence in many materials is not as widespread as was once feared. Nevertheless, because detection levels for PFAS are extremely low, with concentrations commonly reported in parts per trillion, strict sampling procedures are necessary to ensure water samples are not contaminated with foreign PFAS or stripped of existing PFAS prior to laboratory analysis. In the absence of federal guidelines, some states, including California, have developed sampling guidelines to ensure state-specific data quality objectives are met. Before starting any PFAS groundwater sampling, any available state sampling guidelines should be referenced and strictly followed. The guidelines vary, but typically address recommended and/or required sampling equipment, sampling containers, personal protective equipment, field clothing, sampling procedures, and other considerations. Key items for consideration in PFAS sampling include careful planning, use of PFAS-compatible equipment/materials, allocating adequate time to avoid rushing, and changing gloves frequently. With due planning, procedures can be found to accommodate PFAS protocol and site-specific health and safety requirements.
PFAS Management
PFAS management can apply above or below the ground surface. Above-ground considerations may include locations where AFFF is stored, transported, and handled. Although AFFF formulations have changed over time, and modern AFFF is unlikely to contain significant PFOA of PFOS, modern foams may contain other (“short-chain”) PFAS compounds. AFFF is likely to contain PFAS unless specifically labeled as fluorine-free. When AFFF is deployed for incident response or otherwise released, containment and/or recovery should be considered as soon as it is safe to do so. Of course, when an incident occurs, extinguishing a fire is the highest priority. Once incident response is complete, recovering foam before seepage into the ground or discharge off-site can reduce environmental impacts by PFAS associated with AFFF. Including AFFF management in incident response planning can reduce long-term liability and uncertainty when responding to an incident.
When considering subsurface soils and groundwater affected by historical PFAS releases, site assessment and characterization can help identify the extent and severity of the resulting impacts. If these practices confirm PFAS contamination exists at a level of concern, risk mitigation and/or remediation may be needed.
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