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HomeMy WebLinkAboutDocumentation_Environmental Advisory Committee_Tab 04_3/11/2026 Agenda Item #3. Environmental Advisory Committee (EAC) STAFF MEMO R Meeting: Environmental Advisory Committee (EAC) - Mar 11 2026 Staff Contact: Brad Freese Department: Environmental Advisory Committee PFAS Contamination From Businesses SUMMARY: 9 do See attached memo and attachment from Chair Brad Freese regarding PFAS Contamination. This document and any attachments may be reproduced upon request in an alternative format by completing our Accessibility Feedback Form, sending an e-mail to the Village Clerk or calling 561- 768-0443. BUDGET AMOUNT NA AMOUNT AVAILABLE NA EXPENDITURE AMOUNT: NA FUNDING SOURCES: NA IS THIS A PIGGYBACK: ❑ Yes ❑ N/A DID YOU OBTAIN 3 QUOTES? ❑ Yes ❑ N/A QUOTE 1 - BUSINESS NAME Arial QUOTE 2 - BUSINESS NAME Arial QUOTE 3 - BUSINESS NAME Arial COMMENTS/EXPLANATION ON SELECTIONNA Chair Freese PFAS Memo Florida Statewide PFAS Pilot Study at Drvcleaning Sites Page 16 of 83 Agenda Item #3. V *111age of T 345 Tequesta Drive 561-768-0700 Tequesta, FL 33469 www.tequesta.org TO: Environmental Advisory Committee FROM: Brad Freese, Chair EAC DATE: 03/11/2026 SUBJECT: Potential PEAS Contamination From Tequesta Businesses This memo is in response to a message from Tom Bradford, Vice Chair EAC. Tom shared a news report on industries in NW Georgia using chemicals with PFAS. https://youtu.be/cPzEhGO02Yk?si=fr5EUve8ibNmR Unfortunately, sources and persistence of PFAS in the environment suggest contamination can originate from outside a community. However, I would like the help of committee and staff to identify local companies that may be using chemicals with PFAS. Two that I thought of are below. Keep in mind, PFAS regulations were passed federally last year to establish a maximum contaminant level (MCL) of 4 parts per trillion for several PFAS chemicals including PFOA and PFOS. Public water systems will be required to comply with this regulation by 2029. 1. Cement factories do use chemicals with PFAS, particularly in the form of cement additives. PFAS are known for their ability to enhance the durability and water- resistance of concrete, making them a popular choice in construction. 2. In dry cleaning, PFAS-based chemicals can be used as solvents or stain-repellent treatments to enhance fabric cleaning and protect textiles from future stains or water damage. In addition, traditional laundering of clothes treated with PFAS compounds may also result in the presence of PFAS in wastewater discharge. This document may be reproduced upon request in an alternative format by contacting the Village Clerk's Office at 561-768-0440 or by completing our accessibility form: https://bit.IV/3mnfeU4 Page 17 of 83 Agenda Item #3. FLORIDA STATEWIDE PFAS PILOT STUDY AT DRYCLEA-Nl-NG SITES Sponsored By: P. pEPART,y� O ~� O Z Z L 0 AZI O�MFN iAI p*0�` Florida Department of Environmental Protection Waste Site Cleanup Program 2600 Blair Stone Road, MS 4520, Tallahassee, FL 32399-2400 Prepared By: Nicholas Barnes, P.E., Fabio Fortes, P.E., Ziqi He, PhD, P.E., and Steven Folsom, P.E., BCEE 46 or MN I-aw 41 1 JA WH6% mi I..—" V w May 2021 PP Page 18 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites ABSTRACT The Florida Department of Environmental Protection Division of Waste Management recognizes the public health concerns related to the occurrence of Per and Polyfluoroalkyl Substances (PFAS) in the environment. As a means to evaluate the relationship of the occurrence of PFAS at drycleaning facilities within the state-administered Drycleaning Solvent Cleanup Program, a Pilot Study was commissioned to conduct background research, field investigations of environmental media, and analysis of waste stream components for PFAS related to drycleaning facilities. The findings of this Study, completed over the course of 18 months, resulted in the determination of historical releases of PFAS into the environment, the potential of future releases derived from drycleaning facilities, and the occurrence of urban anthropogenic background that may complicate definitive conclusions related to environmental investigations. This White Paper summarizes the scientific research, investigative techniques, interpretations of results, and lessons learned from the Study. (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com Innovative Solutions Within Your Reach... Page 19 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites INTRODUCTION PFAS Per-and Polyfluoroalkyl Substances (PFAS) are a group of more than 4,700 individual synthetic compounds that have been manufactured and used in a variety of consumer and industrial products since the 1940s (ITRC, 2020).The most common or notable uses for PFAS have been for fire-fighting foams, as protectants that improve water, grease, and soil repellency, paper/cardboard packaging products, nonstick coatings on cookware,textiles, waterproof clothing, leather products, electrical wire casing, fire-and chemical-resistant tubing, and plumbing thread seal tape. While no longer manufactured in the United States, perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS)were extensively manufactured and used for decades.The presence of PFAS in the environment only began to be studied in the early 2000s.These chemicals remain in the environment today due to their persistent chemical properties. In addition, PFOA and PFOS continue to be produced internationally and can be imported into the United States marketplace in consumer goods/products (ITRC, 2020). Studies have suggested that the exposure to some PFAS in the environment can be harmful for human health, with a greater focus on the longer-chain perfluoroalkyl acids (PFAAs), sometimes referred to as "terminal PFAS", including perfluoroalkyl carboxylic acids (PFCAs) such as PFOA and perfluoroalkane sulfonic acids (PFSAs) such as PFOS. Although there are thousands of other chemicals that fall into the PFAS group, most interest has been focused on PFOA and PFOS, given their ubiquitous presence in the environment and availability of extensive toxicity studies. In 2016,the US EPA issued a Lifetime Health Advisory Level (HAL) for the two most detected PFAS (PFOA and PFOS) at a threshold limit of 70 nanograms per liter (ng/L) for those two substances (individually as well as in combination). In 2018,the Florida Department of Environmental Protection (FDEP) developed provisional groundwater cleanup target levels (PGCTLs) of 70 ng/L for PFOA, PFOS, and the sum of PFOA and PFOS,that are protective of sensitive life stages. Based on the PGCTL of 70 ng/L for PFOA and PFOS, the FDEP also developed groundwater-based leachability provisional soil cleanup target levels (SCTLs) for these two compounds, along with Direct Exposure SCTLs for residential and commercial/industrial land uses. Information, sources, and threshold limits of PFAS continue to be studied by the US EPA (EPA 2020) and various other agencies (ITRC, 2020), due to the extent of their environmental impacts being still novel amongst the regulatory community. Study Objectives As part of the committed efforts to protect the groundwater resources of the state and the public health and safety of its residents,the Division of Waste Management (DWM) of the FDEP began investigations to assess potential sources and associated environmental impacts related to PFAS at known or suspected sites, including Department of Defense (DOD)facilities,fire training facilities, and state funded waste cleanup sites. Although PFAS are not typically known to be used by the drycleaning industry,the FDEP Drycleaning Solvent Cleanup Program (DSCP) initiated a pilot study to investigate the potential presence of PFAS at DSCP facilities.The objectives of this study were to: Determine whether PFAS impacts may be present at drycleaning sites, Evaluate whether PFAS impacts are attributable to drycleaning operations or to an offsite source, and Understand the environmental behavior of PFAS and its impacts at drycleaning facilities. (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 1 Innovative Solutions Within Your Reach... Page 20 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites INVESTIGATION APPROACHES AND METHODOLOGY Literature Review PFAS-based agents are commonly used, among other functions,for the surface treatment of clothing fabrics and other textiles to make the materials water and stain resistant. "Side-chain-fluorinated polymers" can be formed by impregnating a mixture of reactive PFAS to the surface of the fabrics (Holmquist, et al. 2016). Clothing and other textiles can also contain a variety of non-polymeric PFAS, consisting of trace residues of raw materials, intermediates or metabolites from the production of impregnating agents and impregnated clothes or through formation by the decomposition of the impregnating agents in the textiles. A variety of PFAS have been detected in textiles and clothing. PFAS could be released from PFAS- impregnated clothing through cleaning (wet/dry) of the textiles.Theoretically, drycleaning solvent is anticipated to enhance PFAS release rates from clothes, with limited studies having shown that PFAS were released in greywater or drycleaning site effluent(Clara, et al. 2008, Lassen, et al. 2015).Although PFAS have been incorporated in many surfactant/solvent production processes, no studies are available regarding their presence in chlorinated solvents. A study by the US EPA(EPA, 2009) revealed that PFCAs are present in 116 articles of commerce, including commercial carpet care products, household fabric- care liquids and foams, and impregnated apparel. In addition to PFAS use in fabrics, PFAS may be used as ingredients of cleaning agents.To date, no studies have been reported regarding PFAS presence and release mechanisms from drycleaning processing and facilities. It should be noted that potential release rates of PFAS from drycleaning operations would depend on the type and age of laundered clothes and the operational practices of the facility. PFAS releases to the environment would be expected to closely mimic that of chlorinated solvents in drycleaning practices (i.e., waste material spills, mop water discharges, separator water discharges, etc.). Upon release, PFAS may remain in the unsaturated zone where high organic carbon content in the matrix exists and subsequently migrates into the saturated zone from precipitation events. Because of their persistence and mobility PFOS/PFOA may travel as far as trichloroethene under the same conditions without degradation based upon reported organic carbon and mineral partitioning coefficient values), PFAS in the saturated zone may have relatively larger groundwater plumes than volatile organic halogens (VOHs) when considering much lower health based cleanup target levels. In addition, some PFAS may be precursors and slowly transition to "terminal PFAS" of PFCAs and PFCAs in the environment. For example, perfluoralkane sulfon-amides and fluorotelomer sulfonic acids in textiles released into the environment can be converted to PFOA and PFOS. Currently available information does not indicate that PFAS are a known constituent of raw drycleaning solvents, but instead could be attributable to other drycleaning facility functions such as spot treatment solutions, wet laundry, solvent releases following contact with PFAS-containing fabrics, or post- drycleaning fabric treatments. Description of Study Sites and Initial Screening In June 2019,the FDEP pilot project was initiated at a subset of eligible DSCP sites to determine whether PFAS are a constituent of concern that may be present.The initial screening included groundwater sample collection from two existing monitoring wells at fifteen pre-selected DSCP facilities throughout the state. The pilot facilities were selected by FDEP and represented sites with known VOH groundwater quality impacts (at varying concentrations) and located throughout the state of Florida (Figure 1). Accordingly, the sites exhibit a range of geology, hydrogeology, and surrounding land uses. Furthermore,the sites represented both active and non-active drycleaning facilities, with varying VOH (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com Innovative Solutions Within Your Reach... Page 21 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites remediation technologies employed.The two sampling locations at each site were determined based upon the known presence of VOHs and likely VOH release source areas. The initial screening results indicated the presence of PFAS in groundwater above laboratory practical quantitation limits (PQLs) at fourteen of the fifteen sites, and concentrations above the PGCTLs for PFOA, PFOS, or the sum of PFOA and PFOS in nine of the fifteen sites. The PFOA concentrations reported during the initial screening ranged from below detection limits up to 98 ng/L,while PFOS concentrations ranged from below detection limits up to 120 ng/L. A tenth site (Dryclean World) initially exhibited concentrations below the PGCTLs but greater than one half of the PGCTL.This site later exhibited exceedances of the applicable PGTLs during supplemental sampling.The initial screening sites are illustrated on Figure 1: r 11 12 �7 PEAS>PGCTL � 13* PFAS<PGCTL *8 1 10 5 kf 14 Site ID Site Name city 1 Celebrity Cleaners(Celebrity) Longwood 2 Cinderella Cleaners(Cinderella) Lake Park 3 Classic Cleaners(Classic) Stuart _ 9 4 Dolphin Fabricare(Dolphin) Fort Myers 3* 5 Dryclean World(DW) Winter Park 6 International Professional Dry Cleaners(IP) Miami 2* 7 Jasper Laundry&Drycleaners(Jasper) Jasper 4 8 Moses Cleaners(Moses) Lake City 9 North Trail Laundryland(NorthTrail) Sarasota 10 Touch of Quality Cleaners(TOQ) Dade City 11 Vick's Cleaners(Vick) Pensacola 6* 12 Randolph's Dry Cleaner(Randolph) Tallahassee 13 Former Sages Dry Cleaners(Sages) Jacksonville 14 Nanak Cleaners(Nanak) Winter Park 15 Touch of Class(TOC) Apollo Beach Figure 1.Site Location Map Site Review and Work Plan Based upon the results of the initial screening event of the Pilot Study, expanded PFAS investigation activities were conducted at ten (10) sites to further evaluate the extent of PFAS presence to determine whether PFAS are attributable to drycleaning operations, or from offsite sources.The expanded PFAS investigation activities included further evaluations of the site surroundings, site histories, and each site's representative geology and hydrogeology, to facilitate a sampling plan for further investigation activities.A summary of the operational histories of these ten sites is provided in Table 1. (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 3 Innovative Solutions Within Your Reach... Page 22 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites Table 1. Summary of Ten Pilot Study Sites SolventsYears of • . OperationsSite Name Active . Used PCE Release Mechanism History Celebrity Cleaners Prior to 1988 Drycleaning Machine SVE 1 (Celebrity) -2020 PCE Septic Drainfield ISCO Bioremediation Cinderella Cleaners 1963- SVE 2 PCE Drycleaning Machine (Cinderella) Current Bioremediation 3 Classic Cleaners 1992-2017 PCE& Drycleaning Machine SVE (Classic) Petro-based Dolphin Fabricare 1987- PCE& SVE 4 (Dolphin) Current Petro-based Drycleaning Machine Pump&Treat (Exxon F2000) Dryclean World 1986- PCE& Drycleaning Machine Excavation 5 (DW) Current Petro-Based Septic Drainfield SVE (HC BoostTM) ISCO International Ozone Sparging 6 Professional Dry Prior to 1979 PCE Drycleaning Machine SVE Cleaners(IP) -Current Rear door area Pump&Treat 7 Jasper Laundry& Prior to 1946 Stoddard Drycleaning Machine None Drycleaners(Jasper) -2013 Solvent& PCE Filter Powder Dumping Drycleaning Machine AS/SVE 8 Moses Cleaners 1968- PCE Rear door& Dumpster Pump&Treat (Moses) Current areas at nearby Sanitary Sewer Leaks petroleum site 1959—1994 North Trail (DC) Possible Drycleaning 9 Laundryland 1994— PCE Machine& Exterior None (NorthTrail) Current Dumping (Laundromat) Touch of Quality 1989- PCE& Drycleaning Machine Zero-Valent 10 Cleaners(TOQ) Current Petro-based Possible Sanitary Sewer Iron Injection & (SenseneTM) Leaks pH Adjustment Sample locations from soil and groundwater included locations near drycleaning machines, near sanitary sewer lines,former drainfield areas, and hydraulically upgradient monitoring wells in order to understand PFAS release mechanisms and subsurface impacts. A questionnaire was also developed to obtain information from current drycleaner operators about former and current operational practices. Samples from raw materials and/or waste stream processes were collected for evaluation of PFAS occurrence during current operations. Based on a typical drycleaning process layout (Figure 2),waste stream samples were collected from available locations at most study sites. (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 4 Innovative Solutions Within Your Reach... Page 23 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites Dry Cleaning Unit Washing Process O ne U nit Washes and D ries Drying Process f Process Used for 0 000 Wash&Dry Pre-Treatment Pressing Spotting - (Potential PFAS Source) U U' Dirty clothes Air to 4 (Potential HAS Source) Dirty Warm Vapor Atmosphere s Solvent from Dryer New Solvent& 00 Detergent Solvent ' '- - PFAS Source) Used, Liquid Filtered Finished Clothes Solvent HAZARDOUS Condensed WASTE a Liquid Solvent Clean Collected (Potential PFAS Solvent Used Solvent Wastewater Source) Discharge Figure 2. Diagram of the Typical Drycleaning Process and PFAS Sampling Locations Sample Collection and Analysis The field investigation activities were performed between June 2019 and November 2020. Quality assurance (QA) and Quality Control (QC) measures included the use of specific field sampling guidelines intended to minimize the potential for sample cross-contamination, along with the incorporation of field/laboratory blanks, and duplicates.All groundwater, soil, and waste stream samples were collected in accordance with the FDEP Field Sampling Standard Operating Procedures (SOPs), including the FDEP's PFAS sampling SOP (FDEP, 2019) and HSW's PFAS Sampling Guidelines (HSW, 2019). Specifically,to reduce the chance of inadvertent PFAS contamination of samples, HSW sampling personnel avoided using PFAS-containing items during the sampling process, such as items commonly used in sampling processes that may contain PFAS include polytetrafluoroethylene (PTFE, also known as Teflon). HSW field personnel avoided using other items which are commonly recognized as potentially containing PFAS such as aluminum foil, post-it notes,waterproof field books, chemical ice packs (e.g., blue ice), and certain decontamination soaps. In addition,field personnel avoided the use of PFAS-containing products such as cosmetics, moisturizers, insect repellant, sunscreen, and hand creams. Nitrile gloves were used during all sample collection activities, including equipment set-up, sample collection, and sealing of containers. Samples were transferred into laboratory-supplied containers, stored at appropriate temperatures, and submitted to selected laboratories for analysis of PFAS compounds by EPA Method 537 (modified) and laboratory specific SOPs.The PFAS compounds analyzed included eleven PFCAs (C4 through C14 carbon- chain), seven PFSAs (C4 through C10 carbon-chain),three perfluoralkane sulfon-amides(N-Me perfluorooctanesulfonamide acid (MeFOSAA), N-Et perfluorooctanesulfonamide acid (EtFOSAA), perfluorooctane sulfonamide (PFOSA)),three fluorotelomer sulfonic acids (4:2 Fluorotelomer sulfonate (4:2 FTS), 6:2 Fluorotelomer sulfonate (6:2 FTS), 8:2 Fluorotelomer sulfonate (8:2 FTS))and four replacement compounds in lieu of PFOS/PFOA(11C1-PF3OUdS (F-5313 Minor), 9CI-PF3ONS (F-5313 Major), ADONA, and HFPO-DA(GenX)).These PFAS are reportedly used as nonpolymer coatings or side-chain (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 5 Innovative Solutions Within Your Reach... Page 24 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites polymers in textiles to provide oil-and water- repellent and stain release finishes (ITRC, 2020). In order to evaluate the correlation between PFAS and drycleaning solvents, VOHs were analyzed for select samples by EPA Method 8260. In addition,field parameters and groundwater elevations were measured to evaluate PFAS fate and transport in groundwater. Some non-aqueous samples such as pure solvent samples and waste stream samples were prepared/processed by a laboratory-specific SOP prior to analysis. Specifically, a subsample of 15 mL for each solvent sample (like PCE) was concentrated to dryness through evaporation and reconstituted prior to analysis; and other cleaning products were diluted (e.g., 25 mL portion of sample diluted to 250 mL with PFAS-free water) prior to Liquid Chromatography and Tandem Mass Spectrometry (LC-MS/MS) analysis. Validation of the laboratory data was conducted upon receipt. RESULTSAND DISCUSSION Groundwater Results Results from the initial June 2019 statewide sampling event indicated the presence of PFAS above laboratory practical quantitation limits (PQLs) at fourteen (14) of the fifteen (15) sites sampled. At nine sites, concentrations of PFOA, PFOS, or the sum of PFOA and PFOS exceeded the PGCTL of 70 ng/L. Following review of the data from the limited sampling project, expanded PFAS investigations were initiated at the nine sites exhibiting data above the PGCTLs, and an additional site was added based on subsequent sampling exhibiting PFAS above PGCTLs. The expanded investigations included the sampling of additional existing monitoring wells both onsite and offsite,with installation of additional monitoring wells conducted at select sites to assist in the investigations. A summary of the PFOA and PFOS concentrations in groundwater reported during the pilot project are summarized in Table 2 below: Table 2. Maximum Detected PFOA and PFOS Concentrations in Groundwater Site Narne-. • • • • • Celebrity 716 113 Shallow/Former drainfield area onsite Cinderella 11520(879) 111(72.5) Intermediate/Sidegradient well offsite Classic 355 106 Shallow/downgradient well onsite Dolphin 130 890 Infiltration gallery sample DW 561(25.3) 82 (11) Shallow/Former drainfield area at rear of drycleaner(onsite) IP 31480(11980) 21640(11180) Shallow/Former drainfield area onsite Jasper 2,000 758 Shallow/downgradient well offsite near rear of former p drycleaner Moses 139 50.9 Shallow/upgradient well offsite NorthTrail 340 96 High PFOS in shallow upgradient well High PFOA in shallow downgradient well TOQ 1 40.1 1 58.6 1 Shallow onsite well *(#)Represents minimum temporal concentrations detected at the same well The maximum groundwater PFOA concentration from all samples collected was 2,640 ng/L and the maximum PFOS concentration was 3,480 ng/L, reported from the same sample from a monitoring well located at International Professional Dry Cleaners (IP) in Miami.This sample was located near a former drainfield that was historically used for disposal of effluent from an onsite wastewater treatment system for the tenants of a shopping center.Although no historical operational data is available,the aeration and oxidation process of the wastewater treatment system would be expected to remove VOHs if any releases occurred into the historical system, but have limited effectiveness on PFAS.The second highest (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com Innovative Solutions Within Your Reach... Page 25 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites PFOS concentration of 2,000 ng/L of PFOS was measured in a monitoring well located at the Jasper site, near a location where drycleaning filter powder is known to have been disposed of, resulting in substantial PCE impacts.The maximum concentrations of PFOA/PFOS at the remaining sites ranged from approximately 50 ng/L to 900 ng/L. Temporal fluctuations in PFAS concentrations were noted in some source wells, believed to be due to mass flux from the vadose zone source caused by rainfall infiltration and/or desorption when the groundwater table rose. For instance, at the Dryclean World (DW) site, PFOA and PFOS concentrations in groundwater in the source area with vadose zone soil impacts varied from below the PGCTL to several hundred ng/L, over the course of several quarterly sampling events. Evaluations of the PFAS data, as compared to applicable drycleaning-solvent related constituent (PCE and metabolic breakdown products) concentrations, generally did not exhibit strong positive correlations in concentrations,with some exceptions (i.e.,Jasper, Moses). This circumstance is believed to be due to differences in the fate and transport between PFAS and PCE. PCE may have undergone faster natural degradation through abiotic and biological processes in the subsurface,whereas PFOA/PFOS are not anticipated to undergo natural attenuation other than physical processes (e.g., sorption/desorption, and dilution). Another potential factor affecting the poor correlation between PFAS and PCE concentrations is previous remedial activities (i.e., in-situ chemical oxidation, soil vapor extraction, and enhanced anaerobic bioremediation)which are known to remove PCE but have limited effects upon PFAS compounds. Excluding chemical and biological degradation, due to relatively higher hydrophobic characteristics(i.e., higher retardation factors), PFAS molecules have a tendency to migrate slower than PCE and its breakdown products in saturated zones. PFOA/PFOS were rarely detected at intermediate or deep zones where PCE and its breakdown products were present, supporting the relatively slower migration for PFOA/PFOS than PCE. In addition, other sources of PFAS from upgradient or nearby locations may have contributed to PFAS in groundwater. Specifically, PFOA/PFOS were detected at elevated concentrations at hydraulically upgradient locations at the North Trail Laundryland,the Moses Cleaners, and the Celebrity Cleaners sites. Although upgradient or regional urban background PFAS may be present at some sites (e.g., Celebrity, Dolphin, Moses, North Trail), a PFOA/PFOS plume is generally co-present with chlorinated solvents in the vicinity of the subject drycleaning sites (Figure 3), supporting that elevated PFOA/PFOS are associated with the drycleaning sites.The lateral extent of PFOA/PFOS impacts above their PGCTL are mostly limited to the shallow groundwater in the vicinity of the drycleaning facilities. Radial diagrams of detected PFAS were used to illustrate spatial trends for individual PFAS constituents (inserts of six-PFAS radial diagrams are shown for key wells on each site plume map below). Different PFAS distribution patterns at hydraulically upgradient offsite monitoring wells from onsite or hydraulically downgradient wells provided evidence of upgradient offsite PFAS sources in addition to the drycleaning facilities, such as MW038 at Celebrity(Figure 3. a), PMW002 at Dolphin (Figure 3. d), MW041 at Moses (Figure 3. h), and MW021 at North Trail (Figure 3. i). In addition,the six-PFAS radial diagrams indicate variations in PFAS-distribution patterns between locations near drycleaning facility and locations hydraulically downgradient at most of the sites, indicating that distribution patterns change along the fate and transport based on retardation factors for the six PFAS compounds (relative migration rates PFHxA>PFHpA>PFOA>PFBS>PFHxS>PFOS based upon their reported Koc values (ITRC, 2020)). Theoretically, relatively more PFCAs than PFSAs are expected along a transport pathway,which were observed at most of the sites; however,there are exceptions such as the Cinderella site (Figure lb), where relatively dominant PFOS was noted at downgradient locations.The relatively more dominating PFOS at downgradient wells is likely due to offsite sources or earlier PFOS-dominating releases. (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 7 Innovative Solutions Within Your Reach... Page 26 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites PFHxA w+L ` 2 PFOS PFHpA -Ow. i Milk Ab 20 40 PFOA PFOS PF HxS _j,t• 1 1 _ MW037'�'� i • Y 7:F �t PFB`, ►i Shallow Groundwater Drycleaning Flow Direction !� IFacility PFH• location r �► MWO02 • A 1 f x MW001 ' �. T c • MW025 V 0�MW024 �MW03 MWO41.., Mwoao wo11 Mwozsl �I , MWo14, MW012 _ 036 W033 �,E Sanitary MW030R Sewer in , , Former Drainfield PFHxA � � ► k MW031 , MW035 PFHpA PF05 PFHpA PFOS PFHpA PFOA p, P=n,q PF85 0 8 Q PFAS>PGCTL 4 PFHxS VOH>GCTL 3a. Celebrity Cleaners Mwo13 PFHxA PFHxA t�+L PFOS PFHpA F'F05� PFHpA 0 4-0 40 F—! a PFOA PFBS MW PFHxA PFHxS PF Hx-s PF•kA PFOS PFHpA P PFOS PFH�A M W00 • �` PFOA PFBS MWO04 PFOA \ Z ,j Drycleaning Facility 011 Mw PFHxS PFHxS \ 1MW033 $hallowGroundwater k, Iillll�Fl Direction PFHxA MW003 „��.- PFOS PFH;;-- •, `• _a MW005 MW034 r — MW032 _ '. 'fir ` MW036 + PFOA PFBS n MW035 ` MW001R MW006 PFMxS _ ' t MW010 MW00 r MW007 MtiVUUF PFHpA PFHxA ' FAWU09 >FOS PFHpA PFOS PFHpA Sanitary•�f ' Sewer F PFBS PFOA PFBS Q PFAS>PGCTL , V011>GCTL \\\ PFHxS PFHxS e � , 3b. Cinderella Cleaners (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 8 Innovative Solutions Within Your Reach... Page 27 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites c ., 15 30 � �� '� =Hxn Feet + •� lb PFUS PFHpA r' J*� C �� 1. > PFOA I'Fn_ +^ Groundwat r Flow Dire i n 4i�i. MW008 t` PFHxA W006 PFOS PFHpA PMW001 !'I OA PI WS % �MWO02 MWO03 PFHxS -� 00MWO'O'l, I MW006 i Fig:.A • •e��` ' Mwoo� P PFHpA FUS PFOA PF65 MW004 %O1r , 1 PFrixS D y leanin rFacili PFAS>PGC1L rY 9 ty Approximate Sanitary Location�, Sewer Line VOH>GCTL I 3c. Classic Cleaners • •w ti ice' N - PFHxA ` Ot3 PFOS PFHpa 0 15 30 w� PFOA PFt15 i 1 - •�r r PFHxS 11 t Mwolac o1 12C" y "'� Mw •~ f •c. tip: . �,�. Shallow Groundwater Flow Direction MW006 .` PFHxA ..:. MW007 � PFOS PFHpA G � MW008 � ♦!* r �i'1 �. PFOA PFBS MWOU9 fit •r 1 _ Drycleaning I -- +14 Facility Location- PFHx' • i - - 1 '` MW005 'y:MW004 M1 .�t• • _ Infiltrati n G Ilery 1 10 PPMAW003 Sh lbw Groundwater > Flow DireciionT f. Approximate Sanity A&L err. ine PMWO02 1 Pr•IxA ' CIL r PFAS>PGCTL•+� VOH>GCTL Jk 3d. Dolphin Fabricare (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 9 Innovative Solutions Within Your Reach... Page 28 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites �t+L PFHxA 0 20 40 Feet _ PFOS PFHpA lAAV11009 • - 10 ^ I . PFHxA PFOA -)FE, E — � PFOS PFHp� F'F- se 1 1 e PFOA PFBS • PFP�S Sh Ilowroundwater Flow Direction MWO03 y RJ .r Former Se T l i I WO , MW021 MW00 : Mwooa Mwo0i - M Y Drycleaning PFHxA • Facility Location MWU05 1 * MW022 Pf0 PFHpA �_ - MW006 ��► _�" 'F C)A PFBS PFAS>PGCTL PFHxS r VOH>GCTL Orwrw 3e. Dryclean World L mot C PFHxA t5 30 PFOS PFHPA NW 105th St. -� Former Drainfield ----------------- Area PFOA PFB5 MIN ' ------ - PFHxS PMW00 r '' Former Infiltration —r Gallery r I • •� 46 • MW001 Shallow Groundwater Jki _ Flow Direction . tt♦. ryry i �'�,, • mMW012 i, � • Xt,W009 rot..MW01 -\�,MW019 Drycleaning Mw010 Facility MW018 ei Location Fc?rrnc�i VJ.i�.tk�watBr - MW014 PFHxA Treatment Plant • �Ir,a PFOS PFHoA MWooT , MWO06 - MW002 MWOOS �s l 'FOA PFBS W011 PFAS>PGCTL PFHxS Y r I1' I VOH>GCTL J f 1 I 3f. International Professional Dry Cleaners (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 10 Innovative Solutions Within Your Reach... Page 29 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites 6- K fr+f W 12S 7 Mom,;-rrpgr King Or.s� M W 11 S MW131 MW13 PFHxA0 i` r .4, PFOS PFripA MW9S MW10S ViUS.. - MW2S ti 15D MW7S PFOA PFBS 151 MWBS MW MW1S MW4S MW141 " PFHxS Mw14D 4 f• Former Drycleaning MW31 PFHxA it ty L at MWe3 MW5S PFBS PFHpA MVY81 `•jar PFOA PFBS S.hallowbrGroundwater Flow Direc' PFHxA PFHxS PFBS PFHpA PFOA PFBS MW1 MW16S MW171 MW1JS MW181 M1N191 PFHxS / MW eS MW18D MW19S MW19D PFAS>PGCTL F A VOH>GCTL 3g.Jasper Laundry and Dry Cleaners r L C 20 40 t. lrii{ +• PFAS>GCTL 4 MWOOB r w v F rH, jjMW003 )FOS FFHr ,5,1MW111 , Tf Drycleaning *- Facility WA j Loc ation MWO04 PFH., MWO01 1 MWO02 h r ` Shallow Groundwater Flow Direction \ PFH MW036 t'� MW038 _ PFOS PFMpA MW037 Mwo11 Approximat ita �,,,�� �I PFOA PFBS Sewene��� {Flow N'A t3'South) ' r MW058 PFHxS MW 010 MW02� M W 0421 _ ..T, # '.• �- PFAS>PGCTL �� �,�r 1 � , � ' M • VOH>GCTL 3h. Moses Cleaners (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 11 Innovative Solutions Within Your Reach... Page 30 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites A • i AL MW021'S, MW020i c - Approx r Line 1 MW015 / 1 MW016 Mow 8 fOrM West tO�East) PFHxA �� 1 PFOS PFHpA • .+ 3 MW002 PFHpA •' MW011 ' a • P PFOA PFBS 1 MW003 MW005,�y,A,,MW017 MW007 PFOS PFHpA MW001 M l MW005D PFOA PFBS Drycleaning I acility Location +••�• � Ir• PFHxS PFHxA dft MWO14„O MW018 i PFOS PfHPA MW012 - - MW009S' MW00 Si` •� MW006D a PFOA PFa• � h w r undwetar F w Dir coon PFHxS Mwo10 MW 19 MW013 PFAS>PGCTL VOH>GCTL 3i. North Trail Laundryland 11YYq >AI 1�1�� •%41t 0 20 40 Feet �, II / 4 • I +'��+'1 f PFHxA - - PFOS PFHpA MWO03 PFOA PFBS f • �� I Groundwater PFHxS 1 Flvw D r -� I'nus tal�sr Drycleanng Facility Location %DRT-010 IM1W004 • �/ MW001 MW001 R ' `-1 a PFHpA 4. .� MW005 <a A PFOS PFHpA ,1 PFOA PFP _ PFHxS O PFAS>PGCTL • 3j.Touch of Quality Dry Cleaners Figure 3. PFOA/PFOS versus VOH Groundwater Plume at 10 Sites (inserts represent PFAS distribution at key wells across each site) (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 12 Innovative Solutions Within Your Reach... Page 31 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites 3500 tw 3000 W 2500 7A 2000 r_ 0 1500 1000 V 500 Q a a a a Q a a Q a Q LL COLL � _ = o LL o m _ = o (A N o LL LL L OL a a` LL LL LL � LL a LL LL CL w -Celebrity(MW042) -Cinderella(MW010) Classic(MW001} Dolphin(I GOO 1.) DW(MW002) IP(MW020) Jasper(MW-65) NurthTraiI(MW002) Moses(Mwool) TOQ(MW001) Figure 4. PFAS Detected at Onsite Monitoring Wells In addition to prominently detected PFOA and PFOS, several other PFAS were detected in groundwater, primarily C4 through C10 carbon-chain PFCAs and C4 through C7 carbon-chain PFSAs (Figure 4). PFOS precursors McFOSAA, EtFOSAA and PFOSA were only detected in MW-6S at the Jasper site near the known filter powder disposal and PCE-release source area. PFHxA 1 0.8 0.6 PFOS ,o_ PFHpA PFOA PFBS PFHxS Celebrity(MW033) Cinderella(MW010) Classic(MW006) -Dolphin(MW001) DW(MW002) -IP(MW018) Jasper(MW006S) -North(MW002) -Moses(MW001) TOQ(MW001) Figure 5. Normalized PFAS Radial Diagram at Onsite Wells with Highest Concentrations Certain similar PFAS distribution patterns are not observed across the Pilot Study sites (Figure 5), due to lack of fabrics type/age and solvent release timeframe and locations, and other undistinguishable PFAS sources. However, a general similar pattern with relatively prominent PFOS was observed at most of the sites,with the exceptions of the Dolphin and TOQ sites, which had relatively higher abundance of PFOA, PFHxA, PFHpA and PFBS in comparison to PFOS. In addition, other PFAS compounds (PFHpA and PFOA) were detected at relatively higher concentration at the IP site.The relatively lower PFOS in Dolphin and TOQ are likely effects of previous VOH remedial activities. For example, groundwater remediation using (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 13 Innovative Solutions Within Your Reach... Page 32 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites pump and treat with granular activated carbon was conducted at the Dolphin site and the treated groundwater was discharged into an infiltration galley. PFOS may have been removed more efficiently than other compounds due to its highest Koc value among the six PFAS. It is known that zero valent iron (ZVI) is effective in reducing concentrations of PCE and its breakdown daughter products, whereas limited studies are available regarding ZVI effectiveness on PFAS removal.A study by Arvaniti et al. (2015) indicates that ZVI has a higher removal efficiency for PFOS than PFOA, likely due to more surface adsorption on ZVI material.Therefore,the previous injection of ZVI as a remedy for VOHs at the TOQ site may have affected the PFAS distribution pattern.The former wastewater treatment system and discharge into the former drainfield at the IP site may have contributed more PFAS to the site. Soil Results Soil samples were collected for analysis to evaluate the potential presence of PFAS in soil that may contribute to groundwater quality impacts. The soil samples were collected from various locations based on the site review and work plan,while taking into consideration individual site logistics and constraints. These locations included near drycleaning machines, near sanitary sewer lines, former drainfield areas, and near monitoring wells exhibiting elevated concentrations of PFAS in groundwater in specific cases. PFOA/PFOS concentrations in soil samples were reported at one to three orders of magnitude lower than the health based SCTLs for residential direct exposure (1,300 micrograms per kilogram (µg/kg)), however samples collected from several sites exhibited PFOA or PFOS concentrations near or above the Provisional Leachability based on Groundwater Criteria SCTLs (7 µg/kg for PFOS and 2 µg/kg for PFOA). Additional PFAS compounds, particularly C9 through C14 carbon-chain PFCAs,were detected above laboratory Method Detection Limits (MDLs) in some samples, however in most cases PFOS and/or PFOA were detected at higher concentrations or more frequently, with the exception of the Dolphin site, where FPDA, PFUnA, and PFDoA were detected at concentrations higher than PFOS, and the Jasper site, where McFOSSA and EtFOSSA were detected at concentrations higher than PFOS.The soil sample results for PFOA and PFOS are summarized in Table 3 below: Table 3. Detected PFOA and PFOS Concentrations in Soil Maximum Detected RIP Concentration • • L SampleDescription MM Celebrity 5.6 0.251 PFOS at former drainfield area PFOA inside former facility building Cinderella 1.2 0.25 U Inside facility building Classic 0.64 0.30 U Outside rear of facility Dolphin 2.3 1.5 Outside rear of facility DW 61.2 3.3 Former drainfield area at rear of facility PFOS at former drainfield area IP 14.9 8.7 PFOA at rear of drycleaner/former onsite wastewater treatment plant area Jasper 121 24.8 Rear of former drycleaner Moses 7 0.241 PFOS at offsite upgradient location PFOA inside facility building NorthTrail 1.6 0.141 PFOS onsite near sanitary sewer line PFOA onsite outside building TOQ 0.80 0.111 Onsite outside building The Synthetic Precipitation Leaching Procedure (SPLP)was completed on select soil samples exceeding the default Provisional SCTLs for Leachability based on Groundwater Criteria, with the analytical results (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 14 Innovative Solutions Within Your Reach... Page 33 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites confirming leachate levels above the PGCTLs for PFOS, PFOA, and/or the sum of PFOS and PFOA. It is known that the default Provisional SCTLs are based on specific geotechnical values (fraction of organic carbon [Foc], for instance) and PFAS compound specific physical properties (organic carbon-water partition co-efficient, Koc) and that leaching of PFAS from soil to groundwater may occur at concentrations below the default SCTLs depending on site-specific conditions.The SPLP data exhibited PFOA/PFOS in soil at concentrations around their leachability-based Provisional SCTLs had potential to cause groundwater impacts. As indicated in Table 3, the highest PFAS concentrations in soil were detected near former septic system drainfield areas at two sites (DW and IP) and outside the rear of the former drycleaner at the Jasper site (known historical filter powder dumping area).These elevated PFOA/PFOS concentrations in vadose zone soils are collocated with the highest PFAS groundwater impacts and generally with the historical VOH release areas at these sites (with exception of IP). Although PCE and its breakdown products are not present currently in these locations at DW and IP due to natural attenuation and/or active remediation activities, PFAS are still present in the vadose zone soil, resulting in continuing mass flux into groundwater dependent on infiltration and groundwater elevation changes. For example, PFOA and PFOS concentrations at the source well in the Dryclean World site varied by one order of magnitude, from 1 ng/L in June 2019 to 88 ng/L in October 2020 for PFOA and from 34 ng/L in June 2019 to 561 ng/L in October 2020 for PFOS,which was not surprising based upon the high SPLP results from the soil (highest concentrations reported at 113 ng/L for PFOA and 1,780 ng/L for PFOS). Waste Stream Results In addition to analysis of environmental media (soil and groundwater), samples of raw and waste materials from the drycleaning and wet laundry processes,where applicable and feasible based on the typical drycleaning process(Figure 2),were collected to further assist in the evaluation of the presence of PFAS associated with drycleaners.These types of samples were collected from active drycleaners, a recently abandoned drycleaner, and a former drycleaner now operating as a laundromat. Given the varying operational practices and layouts of the facilities,the types of samples collected varied, however where possible, samples were collected of or from: Solvents used in the drycleaning process; Sample(s)from the spotting agent(s) or detergent(s) used in the drycleaning or wet laundry process(es); Sample of potable water prior to the wet laundry process; Sample from spent solvent at the drain line of the drycleaning machine; Sample(s)from the hazardous waste storage containers (liquid, filtrate material,and unrecovered solvent); Sample from water collected after the condenser and separator process; Water and/or residue sample(s) from the discharge of the wet laundry process and/or at the sanitary sewer pipe, or nearby manhole; A majority of the active drycleaners in the pilot study do not store raw solvents onsite. Rather, most drycleaners have solvent delivered and placed directly into the drycleaning machines for immediate use. One active drycleaner in the pilot project stored raw PCE-based solvent onsite and one active drycleaner had an alternative solvent (SenseneTM) available for sample collection. For sites lacking available raw solvents, solvent distributors were contacted but would not provide solvents for purchase directly for this study. (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 15 Innovative Solutions Within Your Reach... Page 34 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites Table 4: PFOA/PFOS Concentrations in Drycleaning Process Samples Detected Concentrationsm �jj r • • • • 0 Site Name* 1k..PFOS PFOA L idol <15 <10 Raw Stain Remover <15 8.48 Raw Drycleaning Machine Cleaner Celebrity -- Raw PCE Solvent not available <80 <80 PCE Inside Machine(after filter) 21901.2 11621.1 PCE Waste(Machine Bottom) 18,549.4 20,559.3 PCE Waste from Waste Drum <80 <80 Raw Drycleaning Stain Remover -- -- Raw PCE Solvent not available Cinderella 11.34 31.56 Used PCE Inside Machine(after distiller) 66.58 99.61 Used PCE Inside Machine(before distiller) 13.87(ng/g) 43.29(ng/g) PCE Waste from Waste Drum <80 <80 Raw Drycleaning Machine Soap 21284.1 11046.8 Raw Petro-based Solvent mixed w/Soap(prior to Dolphin use) p 0.77 65.52 Drycleaning Machine Water Effluent 121.9(ng/g) 10.65 (ng/g) Waste Contents from Waste Drum (Solid) 16,597.6 21812.4 Waste Contents from Waste Drum (Liquid) <80 <80 Raw Stain Remover DW <80 <80 Raw Drycleaning Detergent -- -- Raw Solvent(HC BoostTM) not available <80 <80 Solvent Waste from Waste Drum <80 <80 Raw Stain Remover -- -- Raw PCE Solvent not available IP 100.2 <80 Drycleaning Machine Separator Water 97.7 <80 Spotting Machine Condensate Waste 421.9 380.9 Used PCE Inside Machine <16.67 <25 Raw PCE Solvent <16.67 <25 PCE Solvent at Separator 56.83 Moses 641.68 Water Sample at Separator 52.01 42.25 Spotting Machine Condensate Waste 31.77 106.46 Used PCE Inside Machine 9.52(ng/g) 36.92 (ng/g) PCE Waste from Waste Drum <80 <80 Raw Spotting Agent <80 <80 Raw Solvent(SenseneTM) TOQ 2.33(ng/g) 4.37(ng/g) Filter Contents 19,639.9 10,382.6 Spent SenseneTM Solvent from Waste Drum 211452.2 12,010.6 Spent SenseneTM Solvent from Waste Drum (Duplicate) *No waste stream samples collected from inactive Classic and Jasper sites **Certain samples analyzed as solid samples with analytical results provided in nanograms per gram(ng/g)(equal to micrograms per kilogram(µg/Kg)) Within the raw material and waste stream samples collected, elevated PFAS concentrations were detected primarily in the waste storage drums and from used solvent samples (both PCE and petroleum- based) collected from the discharge of the drycleaning machines, while influent water, raw solvents, detergents and soaps used during the drycleaning or wet laundry processes generally exhibited low or non-detect PFAS concentrations (Table 4 and Table 5). Compared to those in groundwater (Table 2), (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 1 Innovative Solutions Within Your Reach... Page 35 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites PFOA/PFOS concentrations in drycleaning waste streams were observed two to three orders of magnitude higher(Table 4). It should be noted that PFOA/PFOS were detected at low parts per trillion (ppt) levels in raw materials sampled, however,the solvent mixed with soap at the Dolphin site exhibited PFOA/PFOS concentrations (1,046.8 and 2,284.1 ng/L, respectively) above their PGCTL of 70 ng/L. In addition to PFOA/PFOS, several other PFAS were detected in the spent solvents at drycleaning facilities (Figure 6). PFHxA and PFOA precursors, 6:2 FTS and 8:2 FTS, were measured at similar or higher concentrations than PFHxA/PFOA(Celebrity and Dolphin sites), particularly 8:2 FTS at the Dolphin site. If this spent solvent is released to the subsurface,transformation of these precursors to PFOA over time may continue to contribute to PFOA concentrations in the groundwater.A very high concentration of C11 PFCA(PFUnA)was noted in the spent solvent at the Dolphin site, which represents an outlier to the other data sets. Low levels of McFOSAA, EtFOSAA, PFOSA and GenX were detected above the method detection limits in the spent solvents at the Moses site (data not shown). -- 40,000 J r_ 35,000 E 30,000 c� i }' 25,000 a� 20,000 I 15,000 Q 10,000 a 51000 0 1 _ 1 _ � _ ■ I m (U X 0- ap z o � o m v X Q_ p LL LL LLa- 2 LL LL CL LPL LL LL � LPL LL 0 LL LL LL (V fV 12L Celebrity(Spent PERC) C:inderella(Spent PERCJ Dolphin(Spent Solvent)(PFUnA/5,82 FTS/5) I (Spent Solvent) -Moses(P€RC from Separaior) TO (Spent PER Figure 6. PFAS Detected in Waste Streams. (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 17 Innovative Solutions Within Your Reach... Page 36 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites PFOA and PFOS were detected at low ppt levels in laundry influent waters,which represent the site tap water source. Slightly elevated PFOA/PFOS concentrations were observed in wet laundry effluent samples at the Dolphin site and the Moses site (Table 5). The concentrations at the Moses site were above the FDEP's PGCTL of 70 ng/L for PFOA/PFOS. The levels of PFAS in wet laundry effluent water are similar to the values reported by previous reports (Lassen, et al. 2015). Table 5: PFOA/PFOS Concentrations in Wet Laundry Samples retected Concentrations • Site Name JW PFCIS PFCIA Ir Sample Descript�ion AJ Celebrity 1.74 1.26 Influent Potable Water <80 <80 Laundry Detergent Cinderella 1.12 1.04 Influent potable water 2.8 2.1 Laundry discharge <80 <80 Laundry Detergent Dolphin 3.22 0.88 Influent potable water 14.88 8.4 Laundry discharge 128 <80 Laundry Detergent IP 21.2 6.2 Influent potable water 24.6 <10 Laundry discharge <2.06(ng/g) <2.06(ng/g) Laundry Detergent Moses 1.08 <1.21 Influent potable water 279 103.16 Laundry discharge DW 3.06 2.26 Influent Potable Water TOQ <80 <80 Influent potable water 2.36 57.58 Laundry discharge CONCLUSIONSAND IMPLICATIONS Conclusions Based on the findings from this pilot study, although urban background PFAS may provide some contribution to the PFAS concentrations reported in groundwater at several drycleaning sites, drycleaning and/or wet laundry activities are also contributing to elevated PFAS concentrations found in the vicinity of the pilot project facilities. The levels of PFAS exhibited in groundwater and soil at drycleaning facilities varied by one to two orders of magnitude,from low ppt levels to low parts per billion (ppb) levels.The median concentrations of PFAS detected at the pilot drycleaning facility sites are above typical urban anthropogenic background levels, which represent PFAS presence in environmental media at a site that are not the result or influenced by site activities or releases (Figure 6-3 and Table 17- 3. Observed PFAS concentrations in groundwater (ITRC, 2020)). Although strong positive correlations between PFAS and VOHs were not observed at the majority of the pilot sites, a PFOA/PFOS plume is generally co-present with chlorinated solvents in the vicinity of the facility, providing supporting evidence that elevated PFOA/PFOS are associated with the drycleaning sites.The highest PFOA/PFOS concentrations were often identified near drycleaning machines and site drainage locations,which were also identified as PCE sources areas, indicating that one potential release mechanism for PFAS is associated with drycleaning solvent waste releases. PFOA/PFOS were rarely detected at intermediate or deep zones where PCE and its breakdown products were present, supporting the relatively slower migration of PFOA/PFOS compared to PCE. Limited soil data also supports the presence of PFAS at known release areas. Concentrations of PFOA/PFOS detected in soil (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 18 Innovative Solutions Within Your Reach... Page 37 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites are below their Provisional Residential Direct Exposure SCTLs, but above their provisional leachability SCTL based on protection of groundwater quality at several sites. PFAS, particularly PFOA/PFOS, remain present today in some raw cleaning products; however, significantly higher concentrations are observed in wastes and discharges following drycleaning and wet laundry processes, indicating that PFAS are leaching from fabrics during the laundry or drycleaning processes. Waste materials from drycleaners generally contain high concentrations of PFAS, which along with their corresponding distribution in the environment, supports the hypothesis that the presence of PFAS at drycleaners is more likely attributed to releases following contact with PFAS- containing fabrics than a component of drycleaning solvents themselves. A general pattern of PFAS composition or a correlation with drycleaning solvents was not observed due to uncertainties in history of the facility operation and waste management practices, differences in fate and transport between solvents and PFAS, prior solvent remediation efforts, and offsite source contributions. Lessons learned Various lessons have been learned during the course of the pilot project, primarily including the following: The project findings reflect that the behavior and transport pathway of PFAS constituents in the environment are not necessarily the same as that of drycleaning solvent constituents. Sampling for PFAS at pre-determined high drycleaning solvent constituent locations may not be an appropriate approach to screen site PFAS impacts. As a matter of fact, only four wells out of the 30 initial screening wells exhibited the highest PFAS concentrations following the expanded PFAS investigations. Temporal variation in PFAS data is present, given the notable differences in concentrations across sampling events at some sites investigated over generally short intervals. It is not uncommon for PFAS concentrations in the same monitoring well to vary by several times over a different sampling period. Variations in hydrogeology and geochemistry can affect PFAS fate and transport in the subsurface. No consistent PFAS constituent composition and distribution patterns were observed across all sites, likely due to different PFAS release mechanisms and timeframes. Site-specific VOH remedial actions (SVE, ISCO, bioremediation, ZVI injection, etc.) may have played a role in altering the fate and transport of PFAS. The elevated long-carbon chain PFAS in waste streams are indicative that these compounds, particularly PFOA and PFOS, are still present in consumer products although manufacturing of these compounds has been phased out in the US since the last decade. PFAS may be present in laundry influent water at low ppt levels dependent on water sources and the effluent from conventional wet laundry can have elevated PFAS above the PGCTL of 70 ng/L for PFOA/PFOS leached from the laundry process. Cross-contamination during sample collection, transport, and laboratory analysis may occur considering the low regulatory levels for PFOA/PFOS and their ubiquitous presence in the environment. The field and laboratory QA/QC sample analytical results reported during the course of the pilot project were reviewed and the data was validated. Additionally, non-detects for 28 PFAS compounds were observed in groundwater plume boundary and deep monitoring wells at several (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 19 Innovative Solutions Within Your Reach... Page 38 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites sites. Thus,following the strict SOPs and sampling guidelines, cross-contamination was not noted during the pilot project. Uncertainties/Future Study Various uncertainties exist, including the precise timing and exact location(s) of PFAS release(s), current and historical types of PFAS used in fabrics,the degree of outside influences and/or additional sources upon the reported PFAS concentrations in environmental media, and how prior or current drycleaning- solvent constituent remediation efforts have or may affect the distribution or remediation of PFAS impacts. Although site histories and current/historical operational practices were studied through review of available historical documents and through questionnaires completed during waste stream sampling implementation,the precise practices of historical operators are difficult to determine. Several specific uncertainties and recommendations are provided below for consideration. Questionnaire survey results from current operators indicate that spent solvent volumes were typically less than raw solvent volumes used,though questionnaire results were relatively inconclusive. Example questions and responses from the questionnaires included: o In response to the question of how many gallons of solvent are used per month (or per quarter), the responses ranged from 1 to 5 gallons per month. However, in response to how many gallons of spent solvent are disposed of per month (or per quarter),the responses ranged from approximately 0.5 to 9 gallons per month. o Responses regarding how separator water was disposed of included containerizing for offsite disposal, onsite recycling, and evaporation. o All operators surveyed noted that stain resistance or water repellency treatment is not currently offered and has not previously been offered. o No facilities surveyed currently use septic tanks for disposal of wet laundry wash water, with sanitary sewer disposal utilized at all locations. Solvent loss through emission to the air is one environmental pathway at drycleaning facilities. PFAS mixed with the solvent may be deposited to the land surface after the solvent evaporates in the air. The air pathway was not evaluated in this pilot study due to the lack of validated sampling methods for PFAS in ambient air samples. Up to 28 PFAS compounds were analyzed in this study, but there are many additional PFAS compounds that are not detected as discrete compounds by existing commercially available analytical methods. For example, it is generally recognized that fluorotelomer alcohols (e.g., 8:2 FTOH) are found in the highest concentrations in impregnating agents for textiles (Lassen, et al. 2015), but this group of FTOHs are not analyzed by current commercially available analytical methods. FTOHs can be transformed to PFCAs such as PFOA in the environment. Total oxidizable precursor(TOP) assay analysis can be used to evaluate the potential of precursors for PFCAs and PFSAs. Relatively higher method detection limits reported for waste stream samples due to the matrix effects and non-detects in the raw materials do not necessarily indicate that PFAS are not present in the raw detergents or solvents used at the drycleaning sites. However,the presence of PFAS at these MDL levels would not be anticipated to contribute to elevated groundwater concentrations. Although groundwater was monitored at selected wells for two or more sampling events, duplicates or triplicates of samples or verifications by multi-laboratory analyses were not conducted in this (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 20 Innovative Solutions Within Your Reach... Page 39 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites study. Thus,the reported PFAS values may vary by certain degrees. Any anomalous outliers for one or more PFAS compound concentrations would have affected the PFAS distribution pattern analyses. Remedial activity effects on PFAS were qualitatively discussed as part of this pilot study; however, monitoring of PFAS changes in concentrations and distribution patterns during future remediation could provide information to further understand PFAS fate and transport. (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com 21 Innovative Solutions Within Your Reach... Page 40 of 83 Agenda#%n� #30 aper PFAS Pilot Study at Drycleaning Sites REFERENCE Arvaniti, O.S.,Y. Hwang, H.R. Andersen,A.S. Stasinakis, N.S.Thomaidis, and M.Aloupi. (2015). Reductive Degradation of Perfluorinated Compounds in Water using Mg-aminoclay coated Nanoscale Zero Valent Iron. Chemical Engineering Journal, 262:133-139. Clara, M.C., C. Scheffknecht, S. Scharf, S. Weiss and O. Gans. (2008). Emission of Perfluorinated Alkylated Substances (PFAS) from Point Sources—Identification of Relevant Branches. Water Science & Technology. 58 (1), 59-66. Florida Department of Environmental Protection (FDEP). (2019). DEP-SOP-Draft, PFAS Sampling. September. Holmquist, H., Schellenberger, S., van der Veen, I., G.M. Peters, P.E.G. Leonards, and I.T. Cousins (2016). Properties, performance and associated hazard of state-of-the-art durable water repellent (DWR) chemistry for textile finishing. Environmental International. 91, 251-264. HSW Engineering, Inc. (2019). PFAS Sampling Guidelines. Interstate Technology Regulatory Council—ITRC(2020). Per-and Polyfluoroalkyl Substances (PFAS). September 2020. https://pfas-1.itrcweb.org/ Lassen, C.,J. Kjoholt, S. H. Mikkelsen, M. Warming, A.A.Jensen, R. Bossi, and I. B. Nielsen. 2015. Polyfluoroalkyl Substances (PFASs) in Textiles for Children -Survey of Chemical Substances in Consumer Products. No. 136. Danish Environmental Protection Agency, Copenhagen, Denmark. United States Environmental Protection Agency— US EPA(2009). Perfluorocarboxylic Acid Content in 116 Articles of Commerce. EPA/600/R-09/033. March 2009. United States Environmental Protection Agency— US EPA(20209). EPA's Actions to Address PFAS. https://www.epa.gov/pfas/epa-actions-address-pfas (accessed in November 2020) (813)968-7722 ■ 15711 Mapledale Blvd.,Suite B■Tampa, FL 33624■www.hsweng.com Innovative Solutions within your reach... Page 41 of 83